Fred,
Useful discussion, let's continue. I am guessing that in those cases, you didn't begin a presentation by putting a pointed set of insults (the whole obstructionism bit) into the Record. Your slide set might have been entertaining at a WISPA conference, or as a political broadside aimed at outsiders whose views of the FCC you wish to lower. But as a presentation to be mainly read by the professional staffers at the FCC, who are for the most part dedicated, competent people whose work is fettered by politics from above, it struck me as counterproductive. They do not want to be insulted. WSI's comments and reply comments to the NPRM were very formal and factual. My ex parte meetings at the Commission on December 8th 2010 were oral presentations with the slides in question being used as visual aids, which stated the facts as WSI saw them. Most of my regulatory work is in the Part 51 area (mainly CLECs), which is predominantly political. What technical questions arise there are usually resolved on a political, not fact-based, basis, mainly as cover for an industry position. I still harbor some illusions that Part 101 and Part 15, to give two examples, are handled on a somewhat more honest basis, with technical rather than political judgement being most important. The current version of the old joke is that the FCC staff is 1500 lawyers and Stagg Newman, but I know there are really a few other engineers left to help keep Stagg sane. To be sure, WTB is rather politicized, and my own experiences with them are not so good, but a lot of that has to do with internal politics and silos. I think the auctioned spectrum is subject to a lot more political pressure. I believe that the way people act depends a lot on their past experiences and your experience at the Commission have been: "Most of my regulatory work is in the Part 51 area (mainly CLECs), which is predominantly political. What technical questions arise there are usually resolved on a political, not fact-based, basis, mainly as cover for an industry position." On the other hand, my thirty years of experience at the Commission has been in Part 15 and Part 101 where I have found the OET and WTB to have based their rulings mainly on the technical facts. When I see others make comments that are not factually based and are made " ... mainly as cover for an industry position" I contend their actions define them as "obstructionists," one who attempts to stifle new technologies. I have no problem with innovation. As you might have noted, I think there's good reason to have more PtMP services, like a new updated DTS. And indeed I do think that some of the current requirements of Part 101 Fixed Services lead to excessive cost. Especially outside of the most congested areas, for instance, smaller antennas, with less wind loading, would be most useful. My comment on narrowband is that they require very high spectrum efficiency (hence the whole issue over adaptive modulation) using narrowband means, which rules out OFDM-type approaches which might (I'm only guessing) in practice work as well (using lower interference margins and more FEC, for instance). I generally agree but note that all equipment for use in all licensed bandwidths should strive for the maximum through-put capability and today most have 256QAM capability with adaptive modulation. Also, I see the whole issue over adaptive modulation to be manufactured by obstructionists who base their "fear of abuse" argument on a false premise. Whoa. The coordination requires that the path be *checked*. It does not mean that a frequency is *blocked* for 125 miles for the full circle. HUGE difference. If I use a given frequency from say Indy (say, Henry St., which is probably Ground Zero for congestion) to McCordsville, somebody looking for a path from, say, Crow's Nest to Carmel will need to protect that path. But the paths don't mutually interfere. So they same frequency can probably be used for both. And a path from Kokomo to Gas City won't interfere. If the coordinators do give grief on these, then we have a problem with the coordination rules. Your exaggerated presentation makes these look "wasted". But actually most of the wasted paths are unwanted, since there's probably no demand for many fixed paths from Gas City to Wheeling, or from Wheeling to Leisure, etc. *And the WTB guys know this.* Mobile of course is very different... When a potentially blocked path becomes wanted by a new applicant and he is blocked, the path blockage becomes very real. Under Part 101 Fixed rules, each path, when requested, gets coordinated and given primary status. Or rejected. I'm noting Tom's concern that auxiliary, by turning PtP into PtMP, may increase demand for PtP primary licenses, and thus worsen, not reduce, congestion. And the little guys always lose. There is an increasing demand for higher and higher capacity microwave paths. What we want is to create rules that make better use of spectrum (100 auxiliary paths instead of 100 primary paths), increase the value of that spectrum and leave more spectrum available for all new applicants. In this way everybody wins. I will again quote FCC Chairman Genachowski: "We can't create more spectrum, so we have to make sure it's used efficiently." Nobody disagrees with that platitude. The question is "how?" You support one view, but your arguments were not well made. And from the PoV of the WISP community, there is risk as well as opportunity. What risk? I see the risk as being opportunity lost. . Last but not least, auxiliary stations will give WISPs a significant business growth opportunity. I have a suspicion that much larger companies would be more likely to be the ones to win any battles here. I don't think so, as the FCC's rules on spectrum acquisition levels the playing field and also WISPs are better placed to be first to market in their service area with the same licensed service performance and, with their traditionally low overhead, they have an opportunity to beat the competition on price. 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? You are suggesting a best-case outcome for a proposal that you have not argued for very well. I am suggesting that there may be better approaches, and that Tom has a point that your proposal could possibly backfire on the WISP community. There are those who fear change and those who embrace change. I believe there is a major opportunity for those WISPs who are willing to take it. The fear is that those who fail to be proactive will be left on the outside looking in. Mike From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Fred Goldstein Sent: Friday, January 14, 2011 7:41 AM To: WISPA General List Subject: Re: [WISPA] 11Ghz Licensing Warning Question At 1/14/2011 01:31 AM, Michael Mulcay wrote: Content-Type: multipart/alternative; boundary="----=_NextPart_000_0013_01CBB371.AEA7F3F0" Content-Language: en-us 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. You do not know my position. What I was pointing out was twofold. One, your technique was bad; two, there are valid reasons (which Tom has spelled out well) to see the WSI position as not being a certain win for the WISP community. BTW I am not necessarily opposing all auxiliary-station use. But your presentation to the FCC doesn't make the case. 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 am guessing that in those cases, you didn't begin a presentation by putting a pointed set of insults (the whole obstructionism bit) into the Record. Your slide set might have been entertaining at a WISPA conference, or as a political broadside aimed at outsiders whose views of the FCC you wish to lower. But as a presentation to be mainly read by the professional staffers at the FCC, who are for the most part dedicated, competent people whose work is fettered by politics from above, it struck me as counterproductive. They do not want to be insulted. Most of my regulatory work is in the Part 51 area (mainly CLECs), which is predominantly political. What technical questions arise there are usually resolved on a political, not fact-based, basis, mainly as cover for an industry position. I still harbor some illusions that Part 101 and Part 15, to give two examples, are handled on a somewhat more honest basis, with technical rather than political judgement being most important. The current version of the old joke is that the FCC staff is 1500 lawyers and Stagg Newman, but I know there are really a few other engineers left to help keep Stagg sane. To be sure, WTB is rather politicized, and my own experiences with them are not so good, but a lot of that has to do with internal politics and silos. I think the auctioned spectrum is subject to a lot more political pressure. 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. I have no problem with innovation. As you might have noted, I think there's good reason to have more PtMP services, like a new updated DTS. And indeed I do think that some of the current requirements of Part 101 Fixed Services lead to excessive cost. Especially outside of the most congested areas, for instance, smaller antennas, with less wind loading, would be most useful. My comment on narrowband is that they require very high spectrum efficiency (hence the whole issue over adaptive modulation) using narrowband means, which rules out OFDM-type approaches which might (I'm only guessing) in practice work as well (using lower interference margins and more FEC, for instance). .(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. I agree. What I'd like to avoid at all costs are auctions, whether explicit or implicit ("sorry, no more licenses available", so then a company who has them will be bought by a Wall Street firm for the sake of resale, essentially a private auction). 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. I'm not sure it's working poorly. Those areas are crowded. There's not much spectrum available. And the FCC's wireline policy, essentially created by the ILECs to milk their monopolies without regulation, creates unnecessary demand for terrestrial spectrum in urban areas. Why do the CMRSs *need* wireless backhaul? In most countries they'd get fiber from the ILEC (e.g., Carrier Ethernet or leased E3) at a reasonable price, but US (FCC) policy is totally messed up. So the non-ILEC CMRS has to pay the ILEC $3k+/month to hook up one measly cell site (an urban rooftop, a church steeple, whatever) to a local node. Microwave looks pretty good compared to that. 20 years ago, when optical fiber was first being pulled big time, we simply assumed that microwave was on its way out, consigned to niche markets, like rural. Boy were we wrong. 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. Whoa. The coordination requires that the path be *checked*. It does not mean that a frequency is *blocked* for 125 miles for the full circle. HUGE difference. If I use a given frequency from say Indy (say, Henry St., which is probably Ground Zero for congestion) to McCordsville, somebody looking for a path from, say, Crow's Nest to Carmel will need to protect that path. But the paths don't mutually interfere. So they same frequency can probably be used for both. And a path from Kokomo to Gas City won't interfere. If the coordinators do give grief on these, then we have a problem with the coordination rules. Your exaggerated presentation makes these look "wasted". But actually most of the wasted paths are unwanted, since there's probably no demand for many fixed paths from Gas City to Wheeling, or from Wheeling to Leisure, etc. *And the WTB guys know this.* Mobile of course is very different... Under Part 101 Fixed rules, each path, when requested, gets coordinated and given primary status. Or rejected. I'm noting Tom's concern that auxiliary, by turning PtP into PtMP, may increase demand for PtP primary licenses, and thus worsen, not reduce, congestion. And the little guys always lose. ...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." Nobody disagrees with that platitude. The question is "how?" You support one view, but your arguments were not well made. And from the PoV of the WISP community, there is risk as well as opportunity. So, why are you proposing that we do not challenge the big companies who have vested interests in maintaining the status quo? I'm not suggesting that we do not challenge the status quo. I'm questioning how to go about it. Turning PtP into PtMP licenses may be clever, but it could backfire too. Remember, before there were FCC auctions, there were non-FCC auctions, as license-holding shell companies were bought and sold. Do you think any of the last FCC license lottery winners (remember when MMDS lottery tickets were being hawked via radio ads for about $10k apiece?) actually wanted to build networks? Part 101 today is relatively clean in that regard. The facts are these: . Spectrum is a finite precious national resource. Duh. . Every month thousands of new licenses are issued for primary stations when many of the services could have been provided by auxiliary stations. Maybe, maybe not. . For every license issued spectrum is wasted and millions of future paths are blocked, adding to already congested airwaves. No. Paths, desired or not, are subject to coordination. Interfering paths are blocked. I do not oppose reopening the standards of determining interference, if they are no longer realistic. (I claim no special knowledge here. I know they are extremely conservative.) As the NPRM states, "An FS licensee is entitled to prevent another licensee's signal from traversing its signal pattern pattern if, but only if, that trespass interferes with the original licensee's ability to receive its signal at its downlink location. Thus, for example. another licensee might transit a signal at right angles to the original licensee's signal, crossing its midpoint, without creating unacceptable interference. In such a case, our rules and the frequency oordination process would normally allow the second link to be deployed." I have no problem with innovation. And as you might have noted, I think there's good reason to have more PtMP services, like a new updated DTS. And indeed I do think that some of the current requirements of Part 101 Fixed Services lead to excessive cost. Especially outside of the most congested areas, for instance, smaller antennas, with less wind loading, would be most useful. My comment on narrowband is that they require very high spectrum efficiency (hence the whole issue over adaptive modulation) using narrowband means, which rules out OFDM-type approaches which might (I'm only guessing) in practice work as well (using lower interference margins and more FEC, for instance). . 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. Maybe. Maybe not. . Last but not least, auxiliary stations will give WISPs a significant business growth opportunity. I have a suspicion that much larger companies would be more likely to be the ones to win any battles here. 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? You are suggesting a best-case outcome for a proposal that you have not argued for very well. I am suggesting that there may be better approaches, and that Tom has a point that your proposal could possibly backfire on the WISP community. -- Fred Goldstein k1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701
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