Re: [WISPA] 11Ghz Licensing Warning Question
-BEGIN PGP SIGNED MESSAGE- Hash: SHA1 On 01/19/2011 03:11 PM, Tom DeReggi wrote: No one is suggesting that we dont challenge big companies with vested interests. I'm suggesting the opposite. I'm suggesting that we challenge big company spectrum hogs to give back spectrum, if they can use innovative techniques to free it. So this is like ipv4. Ask for huge swaths of space back. That doesn't scale. It just delays the problem. Asking for spectrum back will help for a while, but it won't be sufficient. We need to do the innovative research/development and work with the FCC to get rules changed. People don't give things back, it's a fact of life. The innovation that results from scarcity, will ultimately flow back into the large spectrum holders. Then hopefully they won't need more spectrum, because they will be able to use what they have at a great density. - -- Charles N Wyble (char...@knownelement.com) Systems craftsman for the stars http://www.knownelement.com Mobile: 626 539 4344 Office: 310 929 8793 -BEGIN PGP SIGNATURE- Version: GnuPG v1.4.10 (GNU/Linux) Comment: Using GnuPG with Mozilla - http://enigmail.mozdev.org/ iQIcBAEBAgAGBQJNOHWtAAoJEMvvG/TyLEAtQkgQAIJeY3+flLzAEfenL/3AlAon QcOKoOYg8kN6zh9AQ6Dw8vU3nKPP8/dgJttqVCFyRXAuaQsXUA4c6IMDiJtVn9Tw 0tBFDT585L/R8zLMnzcRKQ+bMGvlTj46tP2Wuwp9jBnyNEeH3LZS6nG59vJ1c5Nh 7ysHCLIRAZKqbNxybSkKMQBJwsxL9ObZlDszb2PV5YQatEG3qXfQCGhBFjnlN3at iyCvFluHfBxucpuZAPkbDnoX2tQkPwc+29wOtWBERnGPRxNErKKTC5pzDU0hiQim R6ZNGLRZhAowW8C1UdCtHODjk8OKqvYibT//O0y48Iq4XMgZvIy/hgpmFSwZenWd 9Pb/tbCwITdlaMZngLsKeKEHVEbnvcbEdvSADO9pnqdCARqvI+m0mTnyEb2Rod5/ Pi8mYqXrHXaIDadjIJxtkc858ULtIG4Lk0Y562VoDg51JfmW7QpCoA5yJFvP5gyC apCED1j1dd6ZxdsBGE0N9S8OwSvOv9ufDPDodhXl0HhgAqSq+48fbT/vSX+lW1rw 2E1+m9crVZbzfX1n/MK+DwodTZVyqCzBb1tr7r4IdAFYO/gLTBOdFe/uX5KCMNYe wB0+PVJgBODZm0RAVeKH2+ZC8IuWNa7J+gTNOwbQqM+peLFrRUg9GJuisMM2PNWt doW27++KiZC2Obs0WZB3 =t1gJ -END PGP SIGNATURE- WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
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 RO 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
Re: [WISPA] 11Ghz Licensing Warning Question
Fred, Thanks for the data. Point proven. How many WISP in that list? None! From license quantity 300-7000, no WISPs. So who will Aux stations in PArt101 benefit? Only exception might be RADIO DYNAMICS CORPORATION or Comcsearch, that do licenses for third parties. But even then, a minority on the list. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: Fred Goldstein To: WISPA General List Sent: Friday, January 14, 2011 11:13 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question Tom asked, A relevent question is... What percent of Pre-existing PArt-101 licenses are owned by who? For example, what percentage of PArt101 licenses are owned by Sprint or Fiber tower? Surely without those numbers disclosed, we really cant understand who these auxilary stations really would be helping. If our competitors own most of the PArt101 licenses, Icant agree that helping our competitors be more successful will make WISPs more sucessful. I'd want to see that private independant WISPs and WISP industry own a significantly large enough portion of the PArt101 band already. Can we get these specs? FCC microwave license data is public; you can download the whole database. I've done this a couple of times, most recently a bit more than a year ago. (Warning: It's pretty tricky to work with. It's relational, with a ton of little files, and they just distribute the text files, not the SQL that may generate the most interesting answers. But if you like hacking in Access, it can be fun to try.) From that data, not today's, here is the count of the top 100 licensee names. (L=licensee; CL=licensee contact) entity_name entity_type CountOfcall_sign Verizon Wireless CL 6956 FIBERTOWER CORPORATION CL 3930 New Cingular Wireless PCS, LLC L 3450 HOLLAND KNIGHT LLPCL 3389 FiberTower Network Services Corp. L 3265 RADIO DYNAMICS CORPORATION CL 2988 Cingular Wireless LLC CL 2484 METROPOLITAN AREA NETWORKS, INC L 2460 ATT Mobility LLC CL 2270 Keller and Heckman LLP CL 1977 UNION PACIFIC RAILROAD L 1480 ComsearchCL 1471 UNION PACIFIC RAILROAD CL 1461 CLEARWIRE SPECTRUM HOLDINGS III, LLCCL 1416 ATT CORP. CL 1355 Clearwire Spectrum Holdings III, LLCL 1185 CELLCO PARTNERSHIP L 1174 Teligent, Inc. CL 1108 Sensus CL 1090 T-Mobile License LLCL 1064 Consolidated Spectrum Services CL 1003 LOS ANGELES SMSA LIMITED PARTNERSHIPL 968 ATT CORP. L 895 Clearwire Corporation CL 798 TELECOM TRANSPORT MANAGEMENT, INC. L 797 McDERMOTT WILL EMERY LLP CL 789 Verizon Wireless (VAW) LLC L 786 CLEARWIRE SPECTRUM HOLDINGS II LLC L 775 KATLINK LLC (debtor-in-possession) L 770 KATLINK LLC (debtor-in-possession) O 770 Telecom Transport Management, Inc. CL 752 Covington Burling LLP CL 745 CLEARWIRE SPECTRUM HOLDINGS II LLC CL 737 BNSF Railway Co.L 726 Dow, Lohnes Albertson, PLLC CL 723 BNSF Railway Co. CL 718 Conterra Ultra Broadband, LLC L 679 Conterra Ultra Broadband, LLC CL 677 McDERMOTT, WILL EMERY CL 648 ATT CORP L 615 T-Mobile License LLCCL 608 W. Stephen Cannon, Management Trustee L 599 W. Stephen Cannon, Management Trustee O 599 Dow Lohnes PLLC CL 599 Qwest Corporation L 586 Qwest CorporationCL 576 BACKLINK V, LLC CL 575 BACKLINK V, LLC L 575 ART Licensing Corp. L 571 Constantine Cannon CL 571 Alltel Communications, LLC L 552 WILKINSON BARKER KNAUER, LLPCL 550 TRILLION PARTNERS, INC. CL 538 Trillion Partners, Inc. L 529 BACKLINK IV, LLCL 511 BACKLINK IV, LLC CL 511 BACKLINK III, LLC L 508 BACKLINK III, LLC CL 508 BACKLINK II, LLCL 506 BACKLINK II, LLC CL 506 BACKLINK I, LLC L 505 BACKLINK I, LLC CL 505 CHEVRON USA INC L 495 CBS BROADCASTING INC. L 492 NBC TELEMUNDO LICENSE CO. L 490 Clearwire Spectrum Holdings II, LLC L 484 Northrop Grumman Information Technology, Inc. L 467 Northrop Grumman Information Technology, Inc. CL 462 Sprint Nextel CorporationCL 453 GTECH CORPORATION L 452 Stratos Offshore Services Company CL 447 ALLTEL COMMUNICATIONS, INC. CL 447 Alltel Communications, LLC CL 438 CAPSTAR TX LIMITED PARTNERSHIP L 428 Wiley Rein LLP CL 426 MCI WORLDCOM NETWORK SERVICES INC
Re: [WISPA] 11Ghz Licensing Warning Question
So, why are you proposing that we do not challenge the big companies who have vested interests in maintaining the status quo? No one is suggesting that we dont challenge big companies with vested interests. I'm suggesting the opposite. I'm suggesting that we challenge big company spectrum hogs to give back spectrum, if they can use innovative techniques to free it. Nothing in WSI's proposal suggests measures that would result in Pre-existing Spectrum Holders (BIG COMPANIES) to free up spectrum for the industry. Incentives are needed allong with innovation, so big companies will choose innovation not only to help themselves, but to help the industry. Making efficient use of NEW sectrum allocation is only part of the battle. Part of the problem is also how to gain more efficient use of the spectrum already used to free up spectrum for new purposes and applicants. What dynamic would encourage a pre-existing license holder to re-use their own spectrum with Aux stations than apply for a new primary path. Some WISPs heavilly desire a way to obtain licensed last mile spectrum, without auction. But I think they are also being a bit short sighted. I think they may not realize that having licensed spectrum might not benefit them as much as they think, when they run out of high capacity PTP spectrum, and dont have enough PTP spectrum to backhaul their Auxilary stations and cell sites. Then they will be stuck buying transport and transit from the local Tier1 ISPs and Telcos which will charge inflated prices and control the WISP's profit margin anyways. And PTMP becomes less realisitic when we are competing with fiber speed trends. The fact is... WISPs need both adequate PTP and PTMP spectrum. One without the other is a flawed model. I'm not necessarilly against Auxilary stations, I'm just saying its might not be appropriate for all bands. And I'm also suggesting that maybe the dynamics of different geograpghic areas might be different on whether PTP or PTMP spectrum is most needed. We need to find more spectrum to complete 400mbps-800mbps links 10-20 miles long. How do we gain that? Aux station rules would likely incourage the use of smaller antennas on pre-existing backhauls, not keeping larger more directional antennas. Because those that already have PTP spectrum need more PTMP spectrum. And being less efficient (wider beam antennas) with their primary license backhauls will allow the Keyhole to be larger for PTMP Aux stations. At this point I recognize I'm getting a bit repetitive. So I'm gonna try to defer from posting. But the primary purpose of my posts was to point out that some looked at Aux stations as a all good - no disadvantage concept, but there are two valid sides to this topic, and its not all good. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: michael mulcay To: 'WISPA General List' Sent: Friday, January 14, 2011 1:31 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question 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
Re: [WISPA] 11Ghz Licensing Warning Question
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
Re: [WISPA] 11Ghz Licensing Warning Question
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
Re: [WISPA] 11Ghz Licensing Warning Question
Matt, As you can see, I strongly believe that the FCC proposed rulemaking to allow the use of auxiliary stations would be good for the wireless industry and especially for WISPs. Thanks, Mike From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Matt Larsen - Lists Sent: Thursday, January 13, 2011 11:43 PM To: WISPA General List Subject: Re: [WISPA] 11Ghz Licensing Warning Question Wow Michael, That was an outstanding post. Thank you for taking the time to put it together. Matt Larsen vistabeam.com On 1/13/2011 11:31 PM, michael mulcay wrote: 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
Re: [WISPA] 11Ghz Licensing Warning Question
I believe the license database is now available in the more friendly CSV format. See: http://data.fcc.gov/download/license-view/ and http://data.fcc.gov/download/license-view/fcc-license-view-data-csv-format.zip I'd make a page that shows what percentage is owned by who but I already have a weekend project :-) On Fri, Jan 14, 2011 at 10:13 AM, Fred Goldstein fgoldst...@ionary.com wrote: Tom asked, A relevent question is... What percent of Pre-existing PArt-101 licenses are owned by who? For example, what percentage of PArt101 licenses are owned by Sprint or Fiber tower? Surely without those numbers disclosed, we really cant understand who these auxilary stations really would be helping. If our competitors own most of the PArt101 licenses, Icant agree that helping our competitors be more successful will make WISPs more sucessful. I'd want to see that private independant WISPs and WISP industry own a significantly large enough portion of the PArt101 band already. Can we get these specs? FCC microwave license data is public; you can download the whole database. I've done this a couple of times, most recently a bit more than a year ago. (Warning: It's pretty tricky to work with. It's relational, with a ton of little files, and they just distribute the text files, not the SQL that may generate the most interesting answers. But if you like hacking in Access, it can be fun to try.) From that data, not today's, here is the count of the top 100 licensee names. (L=licensee; CL=licensee contact) entity_name entity_type CountOfcall_sign Verizon Wireless CL 6956 FIBERTOWER CORPORATION CL 3930 New Cingular Wireless PCS, LLC L 3450 HOLLAND KNIGHT LLPCL 3389 FiberTower Network Services Corp. L 3265 RADIO DYNAMICS CORPORATION CL 2988 Cingular Wireless LLC CL 2484 METROPOLITAN AREA NETWORKS, INC L 2460 ATT Mobility LLC CL 2270 Keller and Heckman LLP CL 1977 UNION PACIFIC RAILROAD L 1480 Comsearch CL 1471 UNION PACIFIC RAILROAD CL 1461 CLEARWIRE SPECTRUM HOLDINGS III, LLCCL 1416 ATT CORP. CL 1355 Clearwire Spectrum Holdings III, LLCL 1185 CELLCO PARTNERSHIP L 1174 Teligent, Inc. CL 1108 Sensus CL 1090 T-Mobile License LLCL 1064 Consolidated Spectrum Services CL 1003 LOS ANGELES SMSA LIMITED PARTNERSHIPL 968 ATT CORP. L 895 Clearwire Corporation CL 798 TELECOM TRANSPORT MANAGEMENT, INC. L 797 McDERMOTT WILL EMERY LLP CL 789 Verizon Wireless (VAW) LLC L 786 CLEARWIRE SPECTRUM HOLDINGS II LLC L 775 KATLINK LLC (debtor-in-possession) L 770 KATLINK LLC (debtor-in-possession) O 770 Telecom Transport Management, Inc. CL 752 Covington Burling LLP CL 745 CLEARWIRE SPECTRUM HOLDINGS II LLC CL 737 BNSF Railway Co.L 726 Dow, Lohnes Albertson, PLLC CL 723 BNSF Railway Co. CL 718 Conterra Ultra Broadband, LLC L 679 Conterra Ultra Broadband, LLC CL 677 McDERMOTT, WILL EMERY CL 648 ATT CORP L 615 T-Mobile License LLCCL 608 W. Stephen Cannon, Management Trustee L 599 W. Stephen Cannon, Management Trustee O 599 Dow Lohnes PLLC CL 599 Qwest Corporation L 586 Qwest Corporation CL 576 BACKLINK V, LLC CL 575 BACKLINK V, LLC L 575 ART Licensing Corp. L 571 Constantine Cannon CL 571 Alltel Communications, LLC L 552 WILKINSON BARKER KNAUER, LLPCL 550 TRILLION PARTNERS, INC. CL 538 Trillion Partners, Inc. L 529 BACKLINK IV, LLCL 511 BACKLINK IV, LLC CL 511 BACKLINK III, LLC L 508 BACKLINK III, LLC CL 508 BACKLINK II, LLCL 506 BACKLINK II, LLC CL 506 BACKLINK I, LLC L 505 BACKLINK I, LLC CL 505 CHEVRON USA INC L 495 CBS BROADCASTING INC. L 492 NBC TELEMUNDO LICENSE CO. L 490 Clearwire Spectrum Holdings II, LLC L 484 Northrop Grumman Information Technology, Inc. L 467 Northrop Grumman Information Technology, Inc. CL 462 Sprint Nextel Corporation CL 453 GTECH CORPORATION L 452 Stratos Offshore Services Company CL 447 ALLTEL COMMUNICATIONS, INC. CL 447 Alltel Communications, LLC CL 438 CAPSTAR TX LIMITED PARTNERSHIP L 428 Wiley Rein LLP CL 426 MCI WORLDCOM NETWORK SERVICES INC L 425 American Electric Power Service Corporation CL 410 CALIFORNIA, STATE OFL 406 Covington Burling CL 406 Brooks, Pierce, et al. CL 403 Pacific Gas and Electric CompanyL 398 Winstar
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
Re: [WISPA] 11Ghz Licensing Warning Question
Tom asked, A relevent question is... What percent of Pre-existing PArt-101 licenses are owned by who? For example, what percentage of PArt101 licenses are owned by Sprint or Fiber tower? Surely without those numbers disclosed, we really cant understand who these auxilary stations really would be helping. If our competitors own most of the PArt101 licenses, Icant agree that helping our competitors be more successful will make WISPs more sucessful. I'd want to see that private independant WISPs and WISP industry own a significantly large enough portion of the PArt101 band already. Can we get these specs? FCC microwave license data is public; you can download the whole database. I've done this a couple of times, most recently a bit more than a year ago. (Warning: It's pretty tricky to work with. It's relational, with a ton of little files, and they just distribute the text files, not the SQL that may generate the most interesting answers. But if you like hacking in Access, it can be fun to try.) From that data, not today's, here is the count of the top 100 licensee names. (L=licensee; CL=licensee contact) entity_name entity_type CountOfcall_sign Verizon WirelessCL 6956 FIBERTOWER CORPORATION CL 3930 New Cingular Wireless PCS, LLC L 3450 HOLLAND KNIGHT LLPCL 3389 FiberTower Network Services Corp. L 3265 RADIO DYNAMICS CORPORATION CL 2988 Cingular Wireless LLC CL 2484 METROPOLITAN AREA NETWORKS, INC L 2460 ATT Mobility LLC CL 2270 Keller and Heckman LLP CL 1977 UNION PACIFIC RAILROAD L 1480 Comsearch CL 1471 UNION PACIFIC RAILROAD CL 1461 CLEARWIRE SPECTRUM HOLDINGS III, LLCCL 1416 ATT CORP. CL 1355 Clearwire Spectrum Holdings III, LLCL 1185 CELLCO PARTNERSHIP L 1174 Teligent, Inc. CL 1108 Sensus CL 1090 T-Mobile License LLCL 1064 Consolidated Spectrum Services CL 1003 LOS ANGELES SMSA LIMITED PARTNERSHIPL 968 ATT CORP. L 895 Clearwire Corporation CL 798 TELECOM TRANSPORT MANAGEMENT, INC. L 797 McDERMOTT WILL EMERY LLP CL 789 Verizon Wireless (VAW) LLC L 786 CLEARWIRE SPECTRUM HOLDINGS II LLC L 775 KATLINK LLC (debtor-in-possession) L 770 KATLINK LLC (debtor-in-possession) O 770 Telecom Transport Management, Inc. CL 752 Covington Burling LLP CL 745 CLEARWIRE SPECTRUM HOLDINGS II LLC CL 737 BNSF Railway Co.L 726 Dow, Lohnes Albertson, PLLC CL 723 BNSF Railway Co.CL 718 Conterra Ultra Broadband, LLC L 679 Conterra Ultra Broadband, LLC CL 677 McDERMOTT, WILL EMERY CL 648 ATT CORP L 615 T-Mobile License LLCCL 608 W. Stephen Cannon, Management Trustee L 599 W. Stephen Cannon, Management Trustee O 599 Dow Lohnes PLLC CL 599 Qwest Corporation L 586 Qwest Corporation CL 576 BACKLINK V, LLC CL 575 BACKLINK V, LLC L 575 ART Licensing Corp. L 571 Constantine Cannon CL 571 Alltel Communications, LLC L 552 WILKINSON BARKER KNAUER, LLPCL 550 TRILLION PARTNERS, INC. CL 538 Trillion Partners, Inc. L 529 BACKLINK IV, LLCL 511 BACKLINK IV, LLCCL 511 BACKLINK III, LLC L 508 BACKLINK III, LLC CL 508 BACKLINK II, LLCL 506 BACKLINK II, LLCCL 506 BACKLINK I, LLC L 505 BACKLINK I, LLC CL 505 CHEVRON USA INC L 495 CBS BROADCASTING INC. L 492 NBC TELEMUNDO LICENSE CO. L 490 Clearwire Spectrum Holdings II, LLC L 484 Northrop Grumman Information Technology, Inc. L 467 Northrop Grumman Information Technology, Inc. CL 462 Sprint Nextel Corporation CL 453 GTECH CORPORATION L 452 Stratos Offshore Services Company CL 447 ALLTEL COMMUNICATIONS, INC. CL 447 Alltel Communications, LLC CL 438 CAPSTAR TX LIMITED PARTNERSHIP L 428 Wiley Rein LLP CL 426 MCI WORLDCOM NETWORK SERVICES INC L 425 American Electric Power Service Corporation CL 410 CALIFORNIA, STATE OFL 406 Covington Burling CL 406 Brooks, Pierce, et al. CL 403 Pacific Gas and Electric CompanyL 398 Winstar Wireless Fiber Corp. (Chapter 7 Debtor) L 395 Winstar Wireless Fiber Corp. (Chapter 7 Debtor) O 395 UTC SPECTRUM SERVICES CL 391 SprintCom, Inc. L 386 Teligent License Company II, L.L.C. (debtor-in-possession) L 385 Teligent License Company II, L.L.C. (debtor-in-possession) O 385 Graham Brock, Inc. CL 384 MICHIGAN, STATE OF L 380 MOTOROLA INCL 380 Pacific Gas and Electric CompanyCL 374 PACIFICORP L 369 Gannett Co.,
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 Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
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 Goldsteink1io fgoldstein at ionary.com ionary Consultinghttp://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
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 Goldsteink1io fgoldstein at ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
, because the Auxilarystation financial benefit is limited, and a primary license purchase would need to be justified on the PArt101 primary license need alone. It would also make Part101 licenses more affordable for small companies, because they could spread the cost of a Part101 primary license over 3-4 customer orders. My point here is that There is a huge need for PTP backbone spectrum, that is NOT shared with multiple points. It is a substantion need that every ISP or WISP needs to get high capacity to its remote cell sites. It requires 300-400mbps backbones in today's INternet Broadband world. This PTP spectrum is in shortage. The last thing we want is to repurpose PTP spectrum to PtMP at the expense of it no longer being available for PTP. The last thing we want to do is give the first in LArge Telco an advantage to gain cheap spectrum with out small operators able to do the same, because someone else already owns the license. Instead, I'd argue whether the existing license holder really needs the fulll width license channel they are using. The beauty of Part101 spectrum is most people wont buy it until they think they need it, so its available for those that may need it in the future.. Giving Auxillary station use may change that mentality. In my opiinon, in order to support Auxilary stations, we must assess a fair cost to each Auxilary station license, or give every party the right to deploy equipment in the area that would not cause interference to the primary holder. For example, that area unserved by the primary beam, could be allocated for unlicensed secondary use at low power, at a power level not possible to interfere with the primary. That would allow all providers to gain access to that vacant area. What I think is that owners of PTP licenses dont have enough free capacity to share it with PTMP. Instead, they are likely to just buy two links. One that can be used in PTMP, and one that can be used for dedicated backbone. Thus buyign twice as many licenses than they previously needed. The second thing I see happening is that pre-existing license holders will build fiber to their towers for backhaul, so they no longer need their PArt101 licenses for backhaul. But instead of returning the PArt101 licenses back to the FCC pool of available channels, they will unjustly keep them for auxilary stations a different purpose than the part101 license was originally granted for. This would give pre-existing part101 license holders unfair access to hord spectum meant for another purpose. If these tower gain fiber, the Spectrum should be given back so those that dont have fiber can use the spectrum for PTP. I recogize that Auxilary station may have different models of use. For example, 1 might be to sahre a single radio on a tower between multiple end points. Another example might be to use seperate radios, but have the auxilary station use radios at lower power that would not interfere with the primary link. I'm concerned that license applicants will select wider beam dish antennas at their shared tower side, calculating that they'll gain better coverage for Auxilary stations, thus once against reducing the number of possible PTP links in an area. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: michael mulcay To: 'WISPA General List' Sent: Sunday, January 09, 2011 9:03 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question In comments and reply comments to the FCC's NPRM WT Docket 10-153; ATT, Verizon and Comsearch et al are proposing that the FCC impose unnecessary regulation on the operation of radios with adaptive modulation and they oppose the FCC's proposal to allow the use of auxiliary stations in licensed frequency bands below 13GHz. The FCC's auxiliary station proposal would permit the use of small antennas and make it feasible to operate PTP and PTMP. This would make it possible for equipment manufacturers to re-band their unlicensed band equipment to operate in licensed bands with small antennas, thereby lowering licensed microwave CAPEX and OPEX (Exalt has already re-banded their TDD equipment to operate in the 5.9 - 6.4GHz and 10.7 - 11.7GHz licensed bands). With a ruling by the FCC to not impose unnecessary regulation on adaptive modulation and to allow the use of auxiliary stations, WISPs would have the tools to compete in all markets, including the rapidly growing licensed microwave markets for backhaul and access. Power Point slides used by WSI at its December 8th 2010 ex parte meeting with the FCC, opposing additional regulation on adaptive modulation and supporting the use of auxiliary stations, are attached. Mike Wireless Strategies Inc. 831-601-0086 From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Tom DeReggi Sent: Friday, January 07, 2011 11:22 AM To: WISPA
Re: [WISPA] 11Ghz Licensing Warning Question
Like who, because I have to tell you Comsearch was the lowest price license I've ever done and the best experience. How about providing some info on who you recommend. I've only done a few links so I don't have a lot to go on. Thanks Scott Carullo Technical Operations 855-FLSPEED x102 From: Bob Moldashel lakel...@gbcx.net Sent: Friday, January 07, 2011 3:16 PM To: wireless@wispa.org Subject: Re: [WISPA] 11Ghz Licensing Warning Question FYI There are a lot cheaper coordinators out there than Comsearch. This is like buying a Escalade and then buying replacement tires from the dealer. Just a comment... -B- On 1/7/2011 7:54 AM, michael mulcay wrote: Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Scott Carullo Sent: Thursday, January 06, 2011 2:46 PM To: wireless@wispa.org Subject: [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
CTI does coordination pretty cheaply. Regards, Chuck On Sat, Jan 8, 2011 at 6:53 AM, Scott Carullo sc...@brevardwireless.comwrote: Like who, because I have to tell you Comsearch was the lowest price license I've ever done and the best experience. How about providing some info on who you recommend. I've only done a few links so I don't have a lot to go on. Thanks Scott Carullo Technical Operations 855-FLSPEED x102 -- *From*: Bob Moldashel lakel...@gbcx.net *Sent*: Friday, January 07, 2011 3:16 PM *To*: wireless@wispa.org *Subject*: Re: [WISPA] 11Ghz Licensing Warning Question FYI There are a lot cheaper coordinators out there than Comsearch. This is like buying a Escalade and then buying replacement tires from the dealer. Just a comment... -B- On 1/7/2011 7:54 AM, michael mulcay wrote: Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 *From:* wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.orgwireless-boun...@wispa.org] *On Behalf Of *Scott Carullo *Sent:* Thursday, January 06, 2011 2:46 PM *To:* wireless@wispa.org *Subject:* [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document *FCC Rule Part(s)* Description *Result / Action* N/A *site1* Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A *site2* Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) *site1* - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A *site1* Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 WISPA Wants You! Join today!http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe:http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Scott Carullo Sent: Thursday, January 06, 2011 2:46 PM To: wireless@wispa.org Subject: [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 http://www.flhsi.com/files/emaillogo.jpg WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
On a License application, one must state the modulation that they will use or state that they will use adaptive modulation. Legally one is supposed to configure their equipment for what was approved. And there are reasons for that, regarding the freq Coordination. For example If in QAM 256, one must have a lower noise floor and a higher signal to acheive reliabilty. For example... a link might state to operate at -35 and as low as -64 in rain fade, and maintain a SNR of 30db, so no one else can generate over a -94 noise floor, or they would interfere. If in QPSK, one might say they can operate at a sensitivity as low as -90. and only need 10db of SNR. That would mean either that Others could deploy if they did not generate more than -100 noise floor, or that if the Primary link operated at -35, as low as -64 in rain fade and maintain SNR of 10db, that the someone else could deploy without causing interference if theey did not generate a noise floor over -75. Either way, there is a big difference between -75 and -100 and -94. What level can a new license holder broadcast at, if the specs of other license holders are not consistent? If a licensee was able to put there gear on any modulations, it would require others new licensees to plan for worst case, and not generate noise higher than -100, limiting them. Thus it would only be fair if the provider actually used Adaptive modulation. The question them come ups, if one states adaptive modulation, but then does not use it, what harm is there and who would know ? After all it could allow the provider to also lower there transmit in non-rain cases. If someone states 256QAM, and does Adaptive modulation anyway, isn't it just giving risk to the one that stated incorrectly? So yes, I support allowing flexibilty in setting adaptive modulation or not, after the fact. The original license holder should be able to maintain flexibilty. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: michael mulcay To: sc...@brevardwireless.com ; 'WISPA General List' Sent: Friday, January 07, 2011 7:54 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Scott Carullo Sent: Thursday, January 06, 2011 2:46 PM To: wireless@wispa.org Subject: [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 -- WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
FYI There are a lot cheaper coordinators out there than Comsearch. This is like buying a Escalade and then buying replacement tires from the dealer. Just a comment... -B- On 1/7/2011 7:54 AM, michael mulcay wrote: Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 *From:*wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] *On Behalf Of *Scott Carullo *Sent:* Thursday, January 06, 2011 2:46 PM *To:* wireless@wispa.org *Subject:* [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) _Path Warnings Document_ *FCC Rule Part(s)* Description *Result / Action* N/A *site1*Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A *site2*Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) *site1*- ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A *site1*Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] 11Ghz Licensing Warning Question
Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] 11Ghz Licensing Warning Question
The last two entries are relative to the FAA height restrictions for that location based on a possible encroachment to an instrument approach of one kind or another. If this link is going on an existing tower or structure, make sure you have the proper mounting height and that it does not exceed the existing structure height. If you took a guess at the mounting height, this may be your problem and you requested a height taller than the existing approved structure. If it is a new tower you are building, you will need to go through the whole FAA study process and will likely have to light this structure if you can even get the requested height approved. If this is going on an existing structure that has lights, find out the current FAA approval number for the study that was originally conducted and put that on the application. Thank You, Brian Webster http://www.wirelessmapping.com www.wirelessmapping.com www.Broadband-Mapping.com From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Scott Carullo Sent: Thursday, January 06, 2011 5:46 PM To: wireless@wispa.org Subject: [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 http://www.flhsi.com/files/emaillogo.jpg WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
