Re: [WISPA] FCC NPRM WT Docket 10-153
Rick, Pleased to give you WSI's opinion and comments re WISPA's Reply Comments WT Docket 10-153. Section I. Reject FiberTower's Proposal Well stated and WSI is in full agreement. Section II. Shared Spectrum WSI agrees. Section III. Adaptive Modulation By agreeing with Verizon and Comsearch et al, who are proposing unnecessary regulation based on a false premise and an incorrect reading the rules, you are supporting regulation that would unnecessarily deny service or increase the cost of service. See slides 20 and 34 of the attached Power Point slides from WSI's December 8, 2010 ex parte meetings with the FCC. Section IV. Auxiliary Stations WSI agrees but we would have added the key items of smaller antenna size and lower costs. Section V. Smaller Antennas Agree on the need for smaller antennas but small (less than 4ft at 11GHz and 6ft at 6GHz) antennas for frequencies at and below 13GHz can only be used on short paths for good availability numbers. Also, if patterned after the 11GHz rules every path would block very large numbers of future paths. Therefore, WSI believes these short paths should be auxiliary paths where even at 6GHz the antennas can be any size that works (1ft, 2ft) and no future paths will be blocked by the auxiliary stations. WSI's Comments to the NPRM/NOI, Page 8, and Review of Part 101 Antenna Standards are given below: "In Section 101.115 of the Rules the Commission wisely specifies the electrical requirements that must be met but not how the electrical requirements are to be met, thereby promoting innovation. As noted in this NOI, smaller antennas have several advantages for carriers and consumers; however, the advantages from the use of smaller antennas should not come at the expense of wasting spectrum, but should come from innovation. For example, this NPRM is proposing to allow the use of very small antennas on auxiliary stations (for example 1ft. antennas at 6GHz) without causing any interference to existing licensees or future applicants. Therefore, WSI strongly recommends that any revision to the antenna rules facilitate innovation as the means to promote more efficient and cost effective use of spectrum." Thank you for asking for our comments, I hope they are useful. Best, Mike From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Rick Harnish Sent: Monday, January 17, 2011 12:00 PM To: 'WISPA General List' Subject: Re: [WISPA] FCC NPRM WT Docket 10-153 Mike, Where to you fall in with WISPA's Reply Comments.http://fjallfoss.fcc.gov/ecfs/document/view?id=7020921272. I would love to hear your honest opinions, criticisms or supportive statements. Respectfully, Rick Harnish Executive Director WISPA 260-307-4000 cell 866-317-2851 WISPA Office Skype: rick.harnish. rharn...@wispa.org From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of michael mulcay Sent: Monday, January 17, 2011 2:11 PM To: 'WISPA General List' Subject: [WISPA] FCC NPRM WT Docket 10-153 In my experience, significant growth opportunities occur in wireless when there is a regulatory change, a technology change, or both. The last major opportunity in backhaul and access occurred in the 1990's when, as stated in a previous post, Western Multiplex Corporation petitioned the FCC 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. When both were granted (with the 3 for 1 rule at 2.4GHz), Western Multiplex introduced the Lynx spread spectrum radio, a technology change in conventional backhaul and access. Western Multiplex grew rapidly and the regulatory and technology changes created the opportunities for entrepreneurs to start wireless internet service companies and the WISP industry was born. With the FCC's Notice of Proposed Rule Making, WT Docket 10-153, to allow auxiliary stations and make it feasible for technologies used in Part 15 frequency bands to be used in Part 101 frequency bands below 13GHz, the scene is set for a dramatic decrease in the cost of provisioning Part 101 fixed service licensed backhaul and access, thereby presenting WISPs large and small with significant growth opportunities. I believe the questions for a WISP are: 1. Can I grow my business with the added ability to provide +100Mb licensed services at or near the cost of provisioning unlicensed service? I believe the answer is yes, as applications are requiring faster and faster speeds. 2. Are Part 101 frequencies below 13GHz available in my service area? I believe the answer is yes for most if not all WISPs. 3. Do I want to take control of my own destiny, that is, own exclusive-use spectrum so as not to be at the mercy of interference from others, as is the case when using unlicensed bands? I believe
Re: [WISPA] FCC NPRM WT Docket 10-153
Mike, Where to you fall in with WISPA's Reply Comments.http://fjallfoss.fcc.gov/ecfs/document/view?id=7020921272. I would love to hear your honest opinions, criticisms or supportive statements. Respectfully, Rick Harnish Executive Director WISPA 260-307-4000 cell 866-317-2851 WISPA Office Skype: rick.harnish. rharn...@wispa.org From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of michael mulcay Sent: Monday, January 17, 2011 2:11 PM To: 'WISPA General List' Subject: [WISPA] FCC NPRM WT Docket 10-153 In my experience, significant growth opportunities occur in wireless when there is a regulatory change, a technology change, or both. The last major opportunity in backhaul and access occurred in the 1990's when, as stated in a previous post, Western Multiplex Corporation petitioned the FCC 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. When both were granted (with the 3 for 1 rule at 2.4GHz), Western Multiplex introduced the Lynx spread spectrum radio, a technology change in conventional backhaul and access. Western Multiplex grew rapidly and the regulatory and technology changes created the opportunities for entrepreneurs to start wireless internet service companies and the WISP industry was born. With the FCC's Notice of Proposed Rule Making, WT Docket 10-153, to allow auxiliary stations and make it feasible for technologies used in Part 15 frequency bands to be used in Part 101 frequency bands below 13GHz, the scene is set for a dramatic decrease in the cost of provisioning Part 101 fixed service licensed backhaul and access, thereby presenting WISPs large and small with significant growth opportunities. I believe the questions for a WISP are: 1. Can I grow my business with the added ability to provide +100Mb licensed services at or near the cost of provisioning unlicensed service? I believe the answer is yes, as applications are requiring faster and faster speeds. 2. Are Part 101 frequencies below 13GHz available in my service area? I believe the answer is yes for most if not all WISPs. 3. Do I want to take control of my own destiny, that is, own exclusive-use spectrum so as not to be at the mercy of interference from others, as is the case when using unlicensed bands? I believe the answer is yes. 4. What do I have to lose or gain by filing an ex parte letter in support of the FCC's NPRM to allow auxiliary stations? I believe that there is nothing to lose and everything to gain. I suggest that if you agree with the above that you file an ex parte letter in support of the FCC's proposal to allow the use of auxiliary stations. If any of you would like help composing and filing an ex parte letter please contact me off list and I will customize one for you and help with an electronic filing (it takes less than two minutes). I believe that the FCC's NPRM re auxiliary stations represents a golden growth opportunity. Thanks, Mike Wireless Strategies Inc. m...@wirelessstrategies.net Direct: 831-659-5618 Mobile: 831-601-0086 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] FCC NPRM WT Docket 10-153
In my experience, significant growth opportunities occur in wireless when there is a regulatory change, a technology change, or both. The last major opportunity in backhaul and access occurred in the 1990's when, as stated in a previous post, Western Multiplex Corporation petitioned the FCC 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. When both were granted (with the 3 for 1 rule at 2.4GHz), Western Multiplex introduced the Lynx spread spectrum radio, a technology change in conventional backhaul and access. Western Multiplex grew rapidly and the regulatory and technology changes created the opportunities for entrepreneurs to start wireless internet service companies and the WISP industry was born. With the FCC's Notice of Proposed Rule Making, WT Docket 10-153, to allow auxiliary stations and make it feasible for technologies used in Part 15 frequency bands to be used in Part 101 frequency bands below 13GHz, the scene is set for a dramatic decrease in the cost of provisioning Part 101 fixed service licensed backhaul and access, thereby presenting WISPs large and small with significant growth opportunities. I believe the questions for a WISP are: 1. Can I grow my business with the added ability to provide +100Mb licensed services at or near the cost of provisioning unlicensed service? I believe the answer is yes, as applications are requiring faster and faster speeds. 2. Are Part 101 frequencies below 13GHz available in my service area? I believe the answer is yes for most if not all WISPs. 3. Do I want to take control of my own destiny, that is, own exclusive-use spectrum so as not to be at the mercy of interference from others, as is the case when using unlicensed bands? I believe the answer is yes. 4. What do I have to lose or gain by filing an ex parte letter in support of the FCC's NPRM to allow auxiliary stations? I believe that there is nothing to lose and everything to gain. I suggest that if you agree with the above that you file an ex parte letter in support of the FCC's proposal to allow the use of auxiliary stations. If any of you would like help composing and filing an ex parte letter please contact me off list and I will customize one for you and help with an electronic filing (it takes less than two minutes). I believe that the FCC's NPRM re auxiliary stations represents a golden growth opportunity. Thanks, Mike Wireless Strategies Inc. m...@wirelessstrategies.net Direct: 831-659-5618 Mobile: 831-601-0086 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/