Fred,
Tom DeReggi's comments were business-case based and constructive; basically exploring whether the Commission's NPRM on auxiliary stations would benefit the large operators or WISPs or both. In WSI's opinion the answer is both, but with WISPs getting the higher business growth percentage. Frankly, I do not see anything in your position that would benefit the WISP community. Further, I have nearly thirty years of experience working with the FCC, initially with the Xerox XTEN filing, and later, at Western Multiplex as VP of Business Development I wrote the request for a Rule Making and an Immediate Waiver of the Rules pending a Rule Making to allow unlimited EIRP in the 2.4GHz and 5.8GHz ISM bands. Both were granted (with the 1 for 3 rule at 2.4GHz) and we were able to take Western Multiplex from the "Living Dead" (profitable with no growth) to a "Star Performer" (rapid profitable growth), growing the company by 25%, 50% and 100% in three consecutive years. I believe that auxiliary stations can give WISPs the same type of growth opportunity. I believe your last paragraph summarizes your view, so I will address this paragraph. "But Part 101 is all about using conventional means. Wrong -- Part 101Fixed Service rules are about the use of spectrum for Fixed Services, fortunately not about "conventional" means as this would preclude innovation. .(narrow beams, narrow bands) to squeeze in as many PtP users as possible via coordination, not auctions. There are two problems with the conventional approach: 1. Narrower and narrower beams mean larger and larger antennas with the related dramatic increases in CAPEX and OPEX, and even then they are still not perfect. 2. The FS market requirement is for higher and higher speeds requiring higher and higher bandwidths, not narrower and narrower bandwidths. It works pretty well. Actually it works very poorly as demonstrated by the difficulty of Prior Coordinating new 6GHz and 11GHz paths in cities such as New York and Los Angeles. The reason for the congestion is that every licensed station is given protection from harmful interference and all antennas radiate and receive signals in all directions, hence the reason for Rule 101.103 and the large antennas are a major contributor to the high cost of conventional licensed microwave links. As some of the Reply Comments noted, the alleged "keyhole" for auxiliary stations doesn't really exist very often. The "keyhole" has nothing to do with auxiliary stations as it is a contour around any station for a given interferer. Prior coordination requires that a new applicant check the EIRP at all angles around the proposed stations for all distances up to 125 miles at angles between five and three hundred and fifty five degrees, and at all distances up to 250 miles for all angles within five degrees of the antenna azimuth. This means that there are a very large number of locations around existing paths where a new applicant path cannot be deployed because the new path would cause harmful interference, and as the distance from the new applicant to an existing path or paths decreases, the number of choices for the new applicant path also decreases to the point where a new path at any angle will not prior coordinate. With a "conventional" approach these locations are unused, they are wasted. But with auxiliary stations the existing licensee can put the unused locations to productive use. But TDD and FDD also risk compatibility problems, and most of Part 101 is FDD, while your proposal is TDD. Wrong -- there are no compatibility problems using TDD in areas where FDD is operating, since a TDD path must prior coordinate before a license will be issued. Also, there is nothing preventing an auxiliary path from operating FDD, TDD, FDD-TDMA or TDD-TDMA. So it might make more sense to push for more spectrum elsewhere, rather than use self-defeating hyperbole to fight Part 101 interests head-on." I will again quote FCC Chairman Genachowski: "We can't create more spectrum, so we have to make sure it's used efficiently." So, why are you proposing that we do not challenge the big companies who have vested interests in maintaining the status quo? The facts are these: . Spectrum is a finite precious national resource. . Every month thousands of new licenses are issued for primary stations when many of the services could have been provided by auxiliary stations. . For every license issued spectrum is wasted and millions of future paths are blocked, adding to already congested airwaves. . Auxiliary stations, with their small antennas and low cost, will for the first time be able to solve the "last mile" cost barrier, bringing economically viable licensed broadband to un-served and underserved communities. . Last but not least, auxiliary stations will give WISPs a significant business growth opportunity. What you are proposing is maintain the legacy approach, with all of its drawbacks. How will that conserve spectrum, dramatically lower the cost of licensed microwave backhaul and access, and benefit WISPs? Mike Wireless Strategies Inc. From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Fred Goldstein Sent: Thursday, January 13, 2011 12:34 PM To: WISPA General List Subject: Re: [WISPA] 11Ghz Licensing Warning Question At 1/13/2011 02:40 PM, Michael Mulcay wrote: ... The FCC committee was correct as spectrum is the life blood of all WISPs and conservation of spectrum is absolutely essential. Of course. I read your presentation, and some of the Reply Comments and other parties' views. So please take my criticism as constructive. You shot yourself in the foot with your opening pages. The whole routine about obstructionism, and the stories about cars being disassembled near animals, serves to alienate you from the skilled technical people at the FCC who have to make these decisions. Part 101 is not as politically charged as, say, Part 51. Your story could easily be construed as an insult. In fact it is hard to construe it otherwise. This doesn't win cases. (Do you see this as being how it's taken? "Aw, he called me a name. I guess I'll have to adopt his position, so he doesn't call me a name again.") FCC submissions, including WISPAs, are normally very diplomatic. Second, your repeated references to millions of paths being lost are clearly hyperbole. Yes, technically, there could be a zillion paths, but the demand for any one of those paths is miniscule. The only ones that matter are the ones that people will use. There are essentially three types of path. Fixed point-to-point paths, fixed point-to-multipoint, and mobile. Part 101 is about the first category. WISPs usually deal in the second. CMRS is about the third. "Auxiliary stations" are essentially a way to turn Part 101 into what it isn't, fixed point-to-multipoint. Now I *do* agree that the FCC has set aside too little spectrum below 28 GHz for that purpose. IIRC there was once a 10 GHz allocation, based on the 1980ish Petition of Xerox for what they were planning to call XTEN but abandoned. This was called Digital Termination Systems and I don't know if any such licensing still exists, but it was narrowband. I have a slide set here from 1982 from a company (LDD) that was building a 10 GHz DTS PtMP system called RAPAC, which shared technology with their other product, the CAPAC -- probably the first cable modem! But they tanked. I think the MMDS->BRS band is authorized for PtMP, but licensed/auctioned, making it inaccessible. So I do see the need. But Part 101 is all about using conventional means (narrow beams, narrow bands) to squeeze in as many PtP users as possible via coordination, not auctions. It works pretty well. As some of the Reply Comments noted, the alleged "keyhole" for auxiliary stations doesn't really exist very often; with high-performance (good F/B ratio) antennas and modest transmitter power (<70 dBm EIRP, <1 W TPO), back-to-back stations can coexist. But TDD and FDD also risk compatibility problems, and most of Part 101 is FDD, while your proposal is TDD. So it might make more sense to push for more spectrum elsewhere, rather than use self-defeating hyperbole to fight Part 101 interests head-on. -- Fred Goldstein k1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701
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