Comments inline.

jack


On 2/8/2011 2:09 PM, Blair Davis wrote:
> Copied to both lists to stimulate comments on this...
>
> done.
>
> Some serious enforcement is in order.  Major fines for repeated
> offense...  $100K or more for 2nd offense...
Last month we recommended to the FCC OET that they publicize actions against 
offenders who they locate. This would help get the message out that this is a 
serious problem and that enforcement is in fact taking place.
> I'd rather see the TDWR band notched out than any kind of required GPS
> and database...
Notching may be the ultimate outcome for all new equipment. The disadvantage is 
that notching deprives everyone from using the spectrum, even the 90% of 
operators who are nowhere near a TDWR system.
> Maybe then we can get the rest of the band back to non-DFS rules.  And
> they can stop lumping 5180-5320 into these rules as well.
It's unlikely DFS will ever go away because there are military radars 
throughout 
the 5250 - 5600 range and DFS will always be needed to avoid interfering with 
them.
> And since we are talking about new rules...
>
> What is going on with the 3.65 stuff?  I still think we need some kind
> of license enforcement there...
WISPA recently had it's first 3650 Steering Committee meeting and it was agreed 
that major work (education, best practices, possible rules changes, etc.) is 
needed because the interference situation is getting way out of hand. There are 
also more and more illegal (unlicensed) "bootleggers" using the band. One 
solution (among many) is to use a regional email list to coordinate between 
different operators. This is in use now in Phoenix.

jack

> On 2/8/2011 4:47 PM, Jack Unger wrote:
>> In spite of the noteworthy efforts on the part of many WISP operators and in
>> spite of a temporary decrease in the levels of TDWR interference reported to 
>> us
>> by the FCC, the TDWR interference situation has unfortunately deteriorated. 
>> The
>> FCC now reports that some locations (New York, Chicago, Denver and Dallas) 
>> that
>> were recently “cleared” of interference are once again experiencing 
>> significant
>> interference problems. The TDWR interference in San Juan Puerto Rico is so 
>> bad
>> that the TDWR system had to be shut off by the FAA. This is not good news
>> because the FAA is pushing the FCC to solve these interference problems once 
>> and
>> for all.
>>
>> Voluntary database registration has unfortunately not proven to be effective
>> enough. There are still some operators who apparently have not heard about 
>> the
>> TDWR interference problem and some who have simply failed to bring and keep
>> their systems in compliance. On the supply-chain side, there are several
>> manufacturers and distributors who did take positive, affirmative and
>> responsible action to help address the problem however they were they in the
>> minority. Most manufacturers and distributors did not “step up to the plate”
>> with customer education or software upgrades. Because airline safety is a 
>> very
>> important issue, it only takes a few “bad actors” to cause significant 
>> problems
>> for everyone else.
>>
>> The FCC is under strong pressure to take steps to solve the interference 
>> problem
>> for good. The FCC Office of Engineering and Technology has started drafting a
>> Notice of Proposed Rulemaking (NPRM). We don’t know yet what new rules the 
>> FCC
>> will propose. They could require that the 5570 to 5680 frequency range be
>> “notched out” for all new equipment. This would mean that we would lose the 
>> use
>> of 110 MHz of spectrum. Another possibility is that TDWR database 
>> registration
>> will be required of all WISPs instead the current voluntary registration for
>> WISPs located near TDWRs. A third possibility is that all new equipment might
>> have to automatically log into a geo-location database (similar to the TV 
>> White
>> Space database) and receive a list of allowable frequencies. Nearby TDWR
>> frequencies and a guard band around the TDWR frequency range would be 
>> prohibited.
>>
>> The FCC OET has agreed to meet with us to listen to and discuss our 
>> suggestions
>> about ways to address the problem and what new rules should be proposed in 
>> the
>> NPRM. I’ve prepared a short online survey for WISPA Members to see what new
>> rules they prefer and what suggestions they have. Please take a few minutes
>> today to review this survey and give me your feedback before I publish this
>> survey to our Members. I expect that there will be a variety of opinions and
>> possibly additional solutions. WISPA’s policy will be guided by whatever the
>> majority of WISPA Members say they want.
>>
>> Here’s the link to the survey<   http://www.surveymonkey.com/s/HPCC7BL>
>>
>> Most of us do not want new rules and regulations however the bottom line is 
>> that
>> we need to save this spectrum. 110 MHz of 5 GHz spectrum is too valuable to 
>> just
>> give up. We have to fight too hard to acquire spectrum; it wouldn’t be right 
>> for
>> all of us to lose 110 MHz of spectrum because of the actions of a few
>> noncompliant operators.
>>
>> As always, thank-you for your help.
>>
>> Jack Unger
>> Chair - WISPA FCC Committee
>> 818-227-4220
>>
> _______________________________________________
>
> WISPA Membership Mailing List
>
> -----------------------------------------------
>
>

-- 
Jack Unger - President, Ask-Wi.Com, Inc.
Author (2003) - "Deploying License-Free Wireless Wide-Area Networks"
Serving the WISP, Networking and Telecom Communities since 1993
www.ask-wi.com  818-227-4220  jun...@ask-wi.com





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