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 the answer is yes.
4. What do I have to lose or gain by filing an ex
