It would be amazing if one time our government could get spectrum policy right. Up until now they have not got it right even once regarding access to spectrum in my opinion. Unlicensed is closer to right than licensed because it at least allows other entrants into the space other than just the ultra-rich. It gives back some of the power to the people. Unlicensed is wrong because it has no possibility of protections at all for those who use this to build their business. That completely stinks.. License auctions create a "land grab" mentality with little to no thought given to how people will be served in the long run. We have seen this fail time and time again.

The right way is for us to finally have a band dedicated to broadband use with some right to run a little power...please!... for God's sake!...give us some power one time! It would start as unlicensed with registration required. As the band could be proven to be substantially used (serving real customers with actual services) by an operator then licenses would be issued. A license would be for only one base station though. If an operator shows he has customers served on a base station then he can apply for a license. No more blanket region licenses. The substantial use provision means nobody gets squatters rights. You either prove you are using the band to serve actual customers on a base station or you run unlicensed until you can prove substantial use.

Then the incentive is for operators to build out a network and serve customers as quickly as possible to attain licenses as opposed to buying large regions and squatting on licenses leaving them unused for years or even decades as we see now. If they price it too high then people do not buy service from the operator and the operator cannot get the protection of a license. Note the operator has the right to serve immediately as an unlicensed operator and has an incentive to serve customers as quickly as possible to gain license protections. I think that the licenses should be contingent upon public good for perpetuity. If public good is lost in the future (by an operator who over-prices or sells to a mega-corp who does not care) then the license could become open again if people request this. Charge too much, lose your license. Sell to megasuck.net, lose your license. Provide crap service, lose your license. Note that this does not mean you cannot operate there if you lose your license. It just means you lose your exclusive license and right to impose interference protection. It means competition can move in on you and work toward gaining the license if you do not do your job. This puts the power right where it should be, in the hands of the people.

In a 50 MHz band (like 3650) with 10 MHz channels imposed you could conceivably have up to 5 licenses available for 5 base station in any one location. If you are an operator who is building good business relationships you might get all 5 licenses in an area. Maybe not. Maybe you get 2 or 3 and someone else gets some. The point is that you have SOME rights if you do a good job and do not screw the customer.

It is time to stop the lack of rights for those building networks on unlicensed bands and stop the squatting on licenses for those with the fattest wallets. It is time for the people to be in control of their spectrum assets. The public good provisions do that. Why should one federal agency get to tell all the people what they can and cannot do with one of our country's most valuable assets?

I have a name for this new way of looking at spectrum policy.. I call this "Middle Class Spectrum Policy" and I would really like to see us all start moving toward this as a group strategy in the future. If we attain some control of spectrum under these terms I am reasonably certain all future spectrum policy would reflect at least the spirit of the policy as outlined above. Do we want to continue to allow policy to happen around us or do we want to start building policy that is forward thinking enough to empower us all?
John Scrivner

PS. If you are reading this and you have not paid your WISPA dues then go to http://signup.wispa.org/ right now and stop letting others pay to take care of you in D.C. We need your support!



Matt Liotta wrote:

Splitting up the band will just make it useless and interference free.

-Matt

Patrick Leary wrote:

You make the mistake of assuming that I am talking about an unlicensed 3.65 product Charles. We would not likely build a UL version of all that. I am in complete agreement with you on 3.650 in terms of the end reality and utility
of the band in a licensed versus unlicensed allocation. That is why I
support essentially splitting the band.

Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243

-----Original Message-----
From: Charles Wu [mailto:[EMAIL PROTECTED] Sent: Friday, May 26, 2006 10:46 AM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment

Hi Patrick,

But all the "fancy schmancy" technology you implement won't do @#$@ unless
3650 is licensed b/c interference from 20 other systems in the area
(including several from our GPS-synced FM-based FSK friends) eats you for
breakfast, lunch & dinner =(

-Charles

-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Patrick Leary
Sent: Thursday, May 25, 2006 4:41 PM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment


A. More power Tom. B. Much more sophistication in the equipment yielding
much higher spectral efficiency and system gain.

Frequency plays a major role, but you need to understand that other factors are of almost similar levels of importance. For example, our 802.16e version of WiMAX uses SOFDMA with beam forming and 4th order diversity at the base station and MIMO with 6 antennae embedded in the self-install CPE with a SIM card. Couple that with higher power available in a licensed allocation and
you get zero truck roll self-install CPE with no external antenna.

Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
-----Original Message-----
From: Tom DeReggi [mailto:[EMAIL PROTECTED] Sent: Thursday, May 25, 2006 9:23 AM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

3.5Ghz does,


I find that hard to believe. 2.4Ghz couldn't do it, which is why we rely on

900Mhz.

What makes 3.5Ghz appropriate for the task?

With 3650 from what I understood, is only supposed to be allowed for PtP or mobile service only (not indoor) based on the high power levels allowed.

Not sure whats at the other 3.5G ranges in US.

Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband


----- Original Message ----- From: "jeffrey thomas" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Thursday, May 25, 2006 4:02 AM
Subject: Re: [WISPA] 3650 equipment


The benchmark is the ability to provide NLOS, portable or fixed service to at least a 2 mile radius per cell, indoors.

5.8 doesnt really give true NLOS to that distance indoors

5.4 doesnt really give true NLOS to that distance indoors

4.9 doesnt really give true NLOS to that disance indoors

3.5Ghz does, to "portable" devices similar to the equipment used by clearwire. Airspan for example claims their wimax solution works indoors to about 3 miles out, which is pretty good IMHO.

When you can deliver a zero truck roll model with 90% or above availablity, is when operators by the truckload will deploy equipment. At that point, you will see deployments in the thousands, like the ones in mexico of 750,000 homes serviced.

-

Jeff



On Thu, 25 May 2006 02:20:23 -0400, "Tom DeReggi" <[EMAIL PROTECTED]> said:
How do you figure?
You don't think 5.4 is going to solve part of that?

Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband


----- Original Message -----
From: "Jeffrey Thomas" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Wednesday, May 24, 2006 10:55 PM
Subject: Re: [WISPA] 3650 equipment


Frankly,

The FCC should really hurry up and finish the rules to allow the
industry
to
really take off. The common view with most manufacturers I have found is that until there is 3.5ghz or near spectrum available, there will be small and limited deployments of wisp size and not many large scale deployments
outside of 2.5ghz or 700 mhz operators.

-

Jeff





On 5/24/06 6:14 AM, "Charles Wu" <[EMAIL PROTECTED]> wrote:

All the same time, the industry doesn't bother to fill out their Form 477s also

The sad thing is is that there are long term consequences towards "flaunting the rules" -- namely the fact that you are just reinforcing the ILEC argument that unlicensed spectrum just creates a bunch of "cowboys" that
can't be taken seriously

Heck, even Marlon knows better than to wear his skin-tight pink
flamingo
suit when he represents the industry in DC

-Charles

-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com



-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On
Behalf Of jeffrey thomas
Sent: Tuesday, May 23, 2006 11:37 PM
To: WISPA General List
Subject: RE: [WISPA] 3650 equipment


In the larger scale of things- when you compare this to a carrier deployment which would deliver thousands of CPE's service, this is a test. I know


of
one company that has recieved 28 STA's for 14 markets, for over 2000
CPE.




-

Jeff

On Tue, 23 May 2006 21:33:33 -0400, "Gino A. Villarini" <[EMAIL PROTECTED]>
said:
Do you really think towerstream need 150 field units or cpes to
"test"
a single base station?

Gino A. Villarini
[EMAIL PROTECTED]
Aeronet Wireless Broadband Corp.
tel  787.273.4143   fax   787.273.4145

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On Behalf Of Jack Unger
Sent: Tuesday, May 23, 2006 9:07 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

Gino,

Is Towerstream doing this - using 3650 to deliver commercial service?

jack


Gino A. Villarini wrote:

Towerstream anyone ?

Gino A. Villarini
[EMAIL PROTECTED]
Aeronet Wireless Broadband Corp.
tel  787.273.4143   fax   787.273.4145
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On Behalf Of Jack Unger
Sent: Tuesday, May 23, 2006 6:56 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

Jeffrey,

I have to question the "judgement ability" (or the lack of it) of anyone who abuses the FCC rules to the extent of taking a licensed "experimental" system and using it for a commercial,
revenue-generating
purpose. Someone who would do this is (IMHO):

1. Someone with no business sense
2. Someone with no appreciation of (or experience with) the enforcement powers of the FCC
3. Someone who will likely turn out to be their own worst enemy
4. NOT someone who I could rely upon to provide me reliable, long-term
WISP service.
              jack



jeffrey thomas wrote:


Patrick,

It doesnt change the fact that many have launched "limited" deployments as a "test" but still charged for the access service, banking on the fact that the FCC has set the band aside for unlicensed anyways, and that the chance of the FCC cracking down on them is very low.

Im not saying this is right, but reality is such that they will be evenutally amending the rules and the gear according to my sources that is available today will be compliant. *shrug*

-

Jeff

On Tue, 23 May 2006 12:37:11 -0700, "Patrick Leary" <[EMAIL PROTECTED]> said:


Exactly, it clearly shows that an operator today CANNOT launch any commercial services using 3650MHz.

- Patrick

-----Original Message-----
From: Charles Wu [mailto:[EMAIL PROTECTED]
Sent: Tuesday, May 23, 2006 8:40 AM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment

Read below and you can decide on whether or not you will be "breaking the law" w/ a 3650 deployment


---------------------------
To: "'WISPA General List'" <wireless@wispa.org>
Cc: <isp-wireless@isp-wireless.com>; <[EMAIL PROTECTED]>
Sent: Wednesday, February 08, 2006 6:32 AM
Subject: [equipment-l] Experimental Licensing in the 3650 MHz
Band -
Clarifications


Recently, there have been some misleading advertisements promising turn-key 3.65 GHz licensing services as a means of avoiding interference in congested license-exempt ISM/UNII bands. Although the FCC issued adopted rules
back
in March 2005 to open access to new spectrum for wireless broadband
in
the
3.65 GHz band, a "minor" contention-based requirement has delayed the deployment of wireless broadband services in this band as equipment
manufacturers currently work behind the scenes to iron out the
details.
As
things currently stand, deploying a 3.65 GHz system today falls
under
Subpart 5: Experimental Radio Service of the FCC Rules.

Infrastructure Investment & Experimentation under Part 5 needs to be done strictly from a "curiosity" perspective rather than one of "commercial network expansion." Part 5 permits experimentation in scientific or technical operations directly related to the use of radio waves. The rules provide the opportunity to experiment with new techniques or new services prior to submitting proposals to the FCC to change its rules.

Some useful excerpts regarding Experimental Licensing

47CFR5.3: Scope of Service

Stations operating in the Experimental Radio Service will be permitted to conduct the following type of operations: (a) Experimentations in scientific or technical radio research (b) Experimentations under contractual agreement with the United

States
Government, or for export purposes.
(c)    Communications essential to a research project.
(d)   Technical demonstrations of equipment or techniques.
(e)    Field strength surveys by persons not eligible for
authorization
in
any other service.
(f)     Demonstration of equipment to prospective purchasers by
persons
engaged in the business of selling radio equipment.
(g)    Testing of equipment in connection with production or
regulatory
approval of such equipment.
(h) Development of radio technique, equipment or engineering data

not
related to an existing or proposed service, including field or factory testing or calibration of equipment. (i) Development of radio technique, equipment, operational data
or
engineering data related to an existing or proposed radio service.
(j)     Limited market studies.
(k) Types of experiments that are not specifically covered under paragraphs (a) through (j) of this section will be considered upon demonstration of need

47CFR5.51: Eligibility of License

(a) Authorizations for stations in the Experimental Radio Service

will
be
issued only to persons qualified to conduct experimentation utilizing radio waves for scientific or technical operation data directly related to a use of radio not provided by existing rules; or for communications in connection with research projects when existing communications facilities are
inadequate.

47CFR5.63: Supplementary Statements

(a) Each applicant for an authorization in the Experimental Radio
Service
must enclose with the application a narrative statement describing in detail the program of research and experimentation proposed, the specific objectives sought to be accomplished; and how the program of experimentation
has a reasonable promise of contribution to the development,
extension,
or
expansion, or utilization of the radio art, or is along lines not

already
investigated.

For further information regarding experimental licensing, the FCC has a nice online FAQ that gives a step-by-step how-to on experimental licensing: http://www.fcc.gov/oet/faqs/elbfaqs.html


-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com


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