Scriv, You were one of the few who immediately saw the potential benefits. Thanks for the help over the years.
To answer your questions: 1. Wireless Strategies mission is to engineer, provision, lease and/or sell concurrently coordinated licensed microwave networks. 2. Concurrently coordinated spectrum will support FDD, TDD, FDD-TDMA or TDD-TDMA depending on the application. Therefore, all existing products and technologies that can support PTP, MPTP and PTMP applications can be used and WSI has no intellectual property interest in these products. In the 6GHz and 11GHz licensed bands there are many manufacturers that have FCC certified FDD equipment but only Exalt has FCC certified FDD and TDD equipment. For PTMP operation there are many product manufacturers with product in the unlicensed bands (Motorola, Proxim etc.) that I believe could simply be re-banded from the 5.8GHz band to the 5.9GHz to 6.4GHz band. So, the question that WISPs should ask their microwave equipment suppliers is: "How soon after a ruling by the FCC to allow the use of auxiliary stations are they able to deliver equipment and what would be the price?" 3. Regarding smart adaptive antennas, WSI deployed and operated a custom designed 6GHz smart adaptive antenna in Baltimore. OEM Comm., who recently joined WISPA, has a custom designed 11GHz adaptive antenna. However, we expect adaptive antennas to soon be available from several manufactures (with costs competitive with legacy CAT A antennas). Best, Mike -----Original Message----- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of John Scrivner Sent: Monday, January 17, 2011 2:57 PM To: WISPA General List Subject: Re: [WISPA] 11Ghz Licensing Warning Question I want to thank you gentlemen for taking the time here to debate these issues. I have been a proponent for concurrent coordination as proposed by Michael Mulcay for a few years now. Michael did an eloquent job of proposing these ideas before the WCAI around 2005 maybe? I was in the audience. The licensed players there did not really see anything novel about the opportunity. They blinked. Michael and I spent a great deal of time discussing many of the same concerns I have seen discussed here. I brought the concurrent coordination proposal before the WISPA FCC Committee at that time but saw much of the same lack of interest as was witnessed at the WCAI show where I had first heard about it directly from Michael. We blinked too. Now we see that we are finally starting to see some traction for concurrent coordination within WISPA. I feel that Jack Unger has done a good job of bringing this proposal before the committee and making sure the opportunity was clearly described and explained in a way that made sense to our members. Thank you for that Jack. You work hard for us and it is appreciated. I too see this as an "all ships rise in higher waters" type of proposal. WISPs are buying more and more licensed backhaul. Clearwire has stopped making their crazy 300 PCN requests in a day. The true opportunity here is for WISPs to take advantage of. It is one of the only ways we can sell a real metro-Ethernet style service with an SLA. We can be our own first customers too. No longer needing a dedicated backhaul to each individual rural tower would be a windfall in cost and logistics for WISPs who want to replace all their backhaul with something that is truly carrier-class. The only question I have left is who will be building gear that is legal to operate as a concurrently coordinated link radio once you get your R&O in your favor? Will you, Michael Mulcay, be the sole beneficiary of licensing this technology? If yes then what are the terms by which existing manufacturers of licensed radios can buy a license of your intellectual property to include concurrently coordination into base stations and CPEs? If this detail has not been established then our support for you could easily turn into an incredible windfall for you and your company but may not really yield us anything of real value in the end. So Michael, I ask you, what is the status of the intellectual property license opportunity for concurrent coordination? Have any manufactuers bought a license or have agreed to buy a l;icense to use your IP for this purpose? How much of a percentage of the total price of the product would we expect to pay for your IP as part of a base station? For a customer CPE? John Scrivner On Mon, Jan 17, 2011 at 1:02 PM, michael mulcay <m...@wirelessstrategies.net> wrote: > Fred, > > > > Useful discussion, lets 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 cant create more spectrum, so we have to make sure its 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 cant create more spectrum, so we have to make sure its 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 > > > ---------------------------------------------------------------------------- ---- > WISPA Wants You! 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