[WISPA] whitespaces, take two

2008-11-18 Thread Marlon K. Schafer
We need to be ready to be involved with this process if there is a way to do 
so (from the nprm)

We anticipate that the capabilities of products for operating in this 
spectrum will develop

and evolve over time and that much will be learned about the potential for 
unlicensed TVBDs to cause

interference to licensed services and how to avoid that interference. We may 
therefore need to revisit

these rules to make adjustments both to provide more flexibility for 
unlicensed devices and to refine the

protections for licensed services. Consistent with our objective to allow 
unlicensed TVBDs to operate

with the most flexibility and capabilities possible consistent with 
protection of licensed services, we are

directing our staff to conduct a review and report to the Commission in two 
years from the date of this

Second Report and Order on the state of these devices, including the types 
of devices on the market, the

extent of their implementation, technical developments, any interference 
problems that may have arisen,

and aspects of the rules that should be altered to increase features and 
opportunities for use or to address

conflicts.



marlon






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[WISPA] Whitespaces take two

2008-10-26 Thread Marlon K. Schafer
Here's version number 2:

Odessa Office Equipment is one of the nations first WISP operators.  We 
started our ISP in the spring of 1997 and installed our first wireless 
system in the winter of 1999/2000.  We now cover parts of 4 counties in 
eastern Washington state.  The bulk of our coverage is in western Lincoln 
and eastern Grant counties.  Lincoln county has approximately 10,000 
citizens with Grant county coming in at about 40,000.  These are also some 
of the geographically largest counties in the state.  We have roughly 6000 
square miles of coverage serviced by about 30 transmit sites, most with 
multiple access points.



Due to the low power restrictions in the 5.3 and 5.4 GHz bands we are not 
able to use those bands to service customers in any meaningful fashion. 
Almost all of our network has been built using WiFi based devices at 2.4 
GHz.  This has been mainly due to cost and range considerations.  However, 
as you know the tragedy of the commons has created a huge problem in the 2.4 
GHz band.  When I first started operations there were a large number of cell 
phone and public safety backhaul systems in place.  Mainly using Western 
Multiplex (or the older Glenair (sp?) gear) always on systems that typically 
used all or most of the band per link.  Naturally most of those systems were 
also located on the higher ground that we also needed to use.



Over the years we have gotten quite good at using coverage zone, antenna 
polarity, and power level tuning to allow us to operate in that environment. 
But now, most of those systems have been replaced with licensed point to 
point links.  In their place we see a HUGE number of unlicensed devices.  In 
my home town of Odessa a brief scan (about 60 seconds) for WiFI access 
points done by only one of my AP's shows that it detects around 80 other 
AP's.  This may not seem like many, but please remember that Odessa is in a 
bowl, nothing is being detected from out of town and there are less than 
1000 people living here!  In Ephrata, that same test, done from a distance 
of about one mile and with a 45* sector netted 99 AP's in a one minute scan!



We are also seeing a significant problem with system to system interference. 
Or, self inflicted interference.  Due to practical client per AP limitations 
and interference rejection we often have more than one AP per site.  For 
more info on this problem and how we try to deal with it please see:

http://www.wi-fiplanet.com/tutorials/article.php/3756431



As you can see, a better standard in an outdoor friendly band is desperately 
needed if we are to meet the next decade's needs in the broadband industry. 
As the only viable 3rd rail of broadband the FCC should insure that WISPs 
can continue to service rural un or under served markets as well as force 
competition in more dense markets.



By and large I agree with WISPA's stance on Whitespaces.  A licensed lite 
approach brings several self evident advantages to the table.  I fully 
support the concept.  Knowing that almost all WISPs are self funded and 
often self staffed it's important that care be taken to insure that any 
licensing mechanism is inexpensive in both dollars and time.



This may also be a good time to tie the right to use spectrum to the 
existing reporting requirements.  I disagree that the government has any 
business requiring compliance with the form 477.  It's more important that 
coverage zones be tracked than customer bases.  And if the government wishes 
to know such information they should spend the time and money to gather the 
data, not pass those expenses onto us.  However, I can see a case being made 
that only those that follow the rules and file their 477's should have 
access to any possible new bands.  I'm not advocating for or against this 
stance, just tossing out the idea for consideration.



I also agree with WISPA, fiber tower and others,  that much higher power 
levels are needed today in much of the country.  If there are trees in the 
area it takes power to penetrate them at meaningful distances.  In open 
ground long distances are needed (30 to 40 mile cell sizes should be a 
viable option).  In my area we have rolling hills, tree lines as windbreaks 
and line of site in the 50 to 60 mile range.  30 to 40 mile line of site is 
commonplace.  We have to reach out a LONG way and be able to plow through 
the windbreaks (sometimes several).  We also have to have sufficient 
capacity on those long range networks to use them as feeds to repeaters as 
we shoot down the canyons in our area.



Personally, I'd like to see extremely rural areas allowed to use even more 
than 20 watts of transmit power at the radio.  I'd like to see a scale, 
something like 200 miles from a top 50 MSO, 40 watts.  Less than 200 miles 
20 watts.  Maybe 10 or 20 miles would be 10 watts or less.



I'd also like to see a geolocation and/or sensing mechanism put in place 
under the rules.  Set reasonably high standards of protection