Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
Regarding GPS I'm not against GPS in radios. The fact is It is NOT expensive to design GPSs into a radio. GPS chips are less than $5 now, and have been for quite some time. But, I am against mandatory disclosure or registration of a radio's GPS info. The identiy and location of a Radio should be able to be kept in confidence by database operator, at operator's request. (its a privacy issue). However, its worth the $5 just to have the GPS as a tool to remind the ISP where the radio is located, if they forget :-) Or as an anti-theft mechanism, to alert when it has moved. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "Jeromie Reeves" To: "WISPA General List" Sent: Wednesday, February 09, 2011 1:14 AM Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed > That would be great. What options do you see? DFS2 looks to have not > got the job done. No one knows how the GPS+DB stuff will really look, > or the costs it will add. The simplest way to do GPS would be to make > a serial receive port. The DB part would be a pretty simple script. > > On Tue, Feb 8, 2011 at 9:50 PM, Tom DeReggi > wrote: >> I do not see why we must suggest or FCC mandate a static one shoe fits >> all >> approach. >> >> The fact is, there are multiple ways to address the problem, each of >> which >> could be equally effective. As long as any one of those several options >> are >> chosen by an operator or manuacturer, problem solved. Why not support and >> enable "choice"? >> >> >> Tom DeReggi >> RapidDSL & Wireless, Inc >> IntAirNet- Fixed Wireless Broadband >> >> >> ----- Original Message - >> From: "Jeromie Reeves" >> To: "WISPA General List" >> Sent: Wednesday, February 09, 2011 12:10 AM >> Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes >> needed >> >> >> On Tue, Feb 8, 2011 at 8:48 PM, Blair Davis wrote: >>> Inline reply's >>> >>> On 2/8/2011 11:31 PM, Jeromie Reeves wrote: >>> >>> On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble >>> wrote: >>> >>> -BEGIN PGP SIGNED MESSAGE- >>> Hash: SHA1 >>> >>> On 02/08/2011 02:23 PM, Jack Unger wrote: >>> >>> Comments inline. >>> >>> jack >>> >>> >>> On 2/8/2011 2:09 PM, Blair Davis wrote: >>> >>> Some serious enforcement is in order. Major fines for repeated >>> offense... $100K or more for 2nd offense... >>> >>> Serious fines and maybe total revocation of $Individual/$corp to >>> transmit RF at all. >>> I am all for the steel boot the first warning. Sometimes >>> slipups happen. >>> Repeated slipups is clear intent. >>> >>> I agree with this totally. >>> >>> Last month we recommended to the FCC OET that they publicize actions >>> against >>> offenders who they locate. This would help get the message out that this >>> is >>> a >>> serious problem and that enforcement is in fact taking place. >>> >>> That would be nice to see for many reasons. >>> >>> Is that covered at http://fcc.gov/eb/Orders/Welcome.html or >>> http://fcc.gov/eb/FieldNotices/ ? >>> >>> I'd rather see the TDWR band notched out than any kind of required GPS >>> and database... >>> >>> Why? I think we operators need to work out a policing deal with the >>> FCC. If there was a easy way for the FAA/FCC >>> to let us know that interference is happening at site ABC. Maybe a >>> simple email list that we sign up to. This would >>> be more akin to hams self policing. I do /not/ want to lose the band. >>> Maybe we need a database that we can report >>> links that we see and their locations/suspected locations. I know I >>> have seen many illegal links and reports to the >>> FCC fall on deaf ears so long ago I stopped trying to report it. >>> >>> Why? Because it will likely raise the cost of the equipment quite a bit >>> to >>> include the GPS hardware and the database access system... >> >> I am hoping for a system that forestalls the GPS needs. Namely, >> Disallow use in any radar areas if people >> can not pull their heads out of .. what ever dark places it is at. Or, >> at the very least a place WISPs can >> report what we see, and a place that the FCC can report what they see. &g
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
The problem is all of the equipment that is already out in the supply channels. Thank You, Brian Webster -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Fred Goldstein Sent: Wednesday, February 09, 2011 2:22 PM To: WISPA General List Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed I notice that the FCC issued a $10,000 fine to Ayustar in San Juan about a year ago. I hope they got the message. It just might be that the FCC and NTIA were a little fast in making 5600-5650 part of the Part 15 bands. Sure, licensed equipment can be used without a license (vis. 3650) but that's a pretty straightforward violation. On the other hand, it would be better to have access to that band, including the 30 MHz guard bands that the NTIA presentation shows as being needed, at least near the TDWRs. And that's the rub: There are 45 TDWRs, and a lot of places nowhere near them. Sensing has not proven reliable. But a GPS/database approach is costly. Maybe the best compromise is to take 5570-5680 and take it out of Part 15, or limit Part 15 use to indoor low power only (like 5150-5250). Then the 110 MHz at risk can be made available under Part 90, as nonexclusive light licensing. The license would have to specify its frqeuencies area of operation, and follow rules that avoid TDWR interference. So if it's within say 10 miles of a TDWR, it would need the 30 MHz spacing, and if within some larger radius, it would need less spacing, and if way far from one of them, it could operate within the TDWR band. In exchange for this, we should ask for higher power limits, perhaps the same as on 5725-5850 ISM, for places where it wouldn't interfere with TDWR (say if it's both >30 MHz and > 20 km away, or >100 km away). This could be done with a map of both TDWR and any other protected radars. At 2/9/2011 01:59 PM, Jack Unger wrote: >On 2/9/2011 9:49 AM, Marlon K. Schafer wrote: > > The proper fix for this problem is a visit from the enforcement guys, and a > > nasty fine for repeat offenders. > Joint FAA/FCC Enforcement teams have been out for a long time >but this is >a VERY costly solution and likely not sustainable in this era of shrinking >budgets. That's why it's better to solve this problem before >enforcement becomes >the option of (costly) last resort. WISPA has suggested to the FCC that they >better PUBLICIZE enforcement actions and they are considering that. > > After that, what would be so hard about using sensing and DFS (done right > > this time) to cause systems near the radars to notch out the 110mhz of > > spectrum while not bothering anyone else? > This is much more difficult that it sounds. The wireless >industry has been >working for over a year (manufacturers, chip makers, etc.) to do >this and has so >far been unable to come up with an acceptable technical solution. >The effort is >on hold at the moment. > > The radar systems are well known, should be an easy signal to detect. > They are not so easy to detect. New radar waveforms come into >use. Radars >go on and off-line. Wireless systems can't sit around all day just listening; >they have real world traffic to handle. Again, the best minds in the industry >have so far failed to figure out an acceptable solution. > > The radios already tend to send a LOT of data back and forth, radio name, > > signal levels, speed, language, channel used etc. etc. etc. Certainly any > > radio that turns on could sense for 30 seconds, if it detects a TDWR signal > > at a certain threshold, then report than back to the AP and the AP could > > then lock out the needed channels for that particular location. > You are more than welcome to volunteer to join the wireless "Industry >Group" engineering team that has been addressing this issue for the >last year. >I'll be happy to introduce you to the team leader so you can sign up to >contribute your engineering advice. > > This should be able to be done via a firmware upgrade to any legacy or new > > hardware out there. > Well, the manufacturers are not stepping up to develop new >firmware. This >is one of the frustrations that the FCC feels. > > Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of > > newly acquired spectrum from the rest of the country. >I would welcome your help to reach out to and motivate the >manufacturers to >do this. Let me know when you are ready to start your outreach program. > > A quick note on PR. The operator(s) there has run foot loose and > fancy free > > with the rules for as long as I can remember. Perhaps it's time to fine > > them at a
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
One suggestion to get the word out about this problem would be to get press releases and journalists from the IT magazine industries involved. IT types who just throw up a link or two probably don't even know how to spell WISPA or TDWR. Thank You, Brian Webster www.wirelessmapping.com www.Broadband-Mapping.com -Original Message- From: members-boun...@wispa.org [mailto:members-boun...@wispa.org] On Behalf Of Jack Unger Sent: Wednesday, February 09, 2011 1:59 PM To: WISPA General List; memb...@wispa.org Subject: Re: [WISPA Members] [WISPA] Your input on 5 GHz rules changes needed On 2/9/2011 9:49 AM, Marlon K. Schafer wrote: > The proper fix for this problem is a visit from the enforcement guys, and a > nasty fine for repeat offenders. Joint FAA/FCC Enforcement teams have been out for a long time but this is a VERY costly solution and likely not sustainable in this era of shrinking budgets. That's why it's better to solve this problem before enforcement becomes the option of (costly) last resort. WISPA has suggested to the FCC that they better PUBLICIZE enforcement actions and they are considering that. > After that, what would be so hard about using sensing and DFS (done right > this time) to cause systems near the radars to notch out the 110mhz of > spectrum while not bothering anyone else? This is much more difficult that it sounds. The wireless industry has been working for over a year (manufacturers, chip makers, etc.) to do this and has so far been unable to come up with an acceptable technical solution. The effort is on hold at the moment. > The radar systems are well known, should be an easy signal to detect. They are not so easy to detect. New radar waveforms come into use. Radars go on and off-line. Wireless systems can't sit around all day just listening; they have real world traffic to handle. Again, the best minds in the industry have so far failed to figure out an acceptable solution. > The radios already tend to send a LOT of data back and forth, radio name, > signal levels, speed, language, channel used etc. etc. etc. Certainly any > radio that turns on could sense for 30 seconds, if it detects a TDWR signal > at a certain threshold, then report than back to the AP and the AP could > then lock out the needed channels for that particular location. You are more than welcome to volunteer to join the wireless "Industry Group" engineering team that has been addressing this issue for the last year. I'll be happy to introduce you to the team leader so you can sign up to contribute your engineering advice. > This should be able to be done via a firmware upgrade to any legacy or new > hardware out there. Well, the manufacturers are not stepping up to develop new firmware. This is one of the frustrations that the FCC feels. > Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of > newly acquired spectrum from the rest of the country. I would welcome your help to reach out to and motivate the manufacturers to do this. Let me know when you are ready to start your outreach program. > A quick note on PR. The operator(s) there has run foot loose and fancy free > with the rules for as long as I can remember. Perhaps it's time to fine > them at a high enough level that it puts them out of business? Kind of a 3 > strikes your out thing. Yep. Sounds right. jack > marlon > > - Original Message - > From: "Jack Unger" > To:; "WISPA General List" > Sent: Tuesday, February 08, 2011 1:47 PM > Subject: [WISPA Members] Your input on 5 GHz rules changes needed > > > > In spite of the noteworthy efforts on the part of many WISP operators and in > spite of a temporary decrease in the levels of TDWR interference reported to > us > by the FCC, the TDWR interference situation has unfortunately deteriorated. > The > FCC now reports that some locations (New York, Chicago, Denver and Dallas) > that > were recently "cleared" of interference are once again experiencing > significant > interference problems. The TDWR interference in San Juan Puerto Rico is so > bad > that the TDWR system had to be shut off by the FAA. This is not good news > because the FAA is pushing the FCC to solve these interference problems once > and > for all. > > Voluntary database registration has unfortunately not proven to be effective > enough. There are still some operators who apparently have not heard about > the > TDWR interference problem and some who have simply failed to bring and keep > their systems in compliance. On the supply-chain side, there are several > manufacturers and distributors who did take positive, affirmative and > responsible action to help address the problem however they were they in the > minority. Most manufacturers and distributors did not "step up to the plate" > with customer education or software upgrades. Because airline safety is a > very > important issue, it only takes a few "bad actors" to cause significant > problems > for everyone else. > > The
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
I like this idea. Combine it with a requirement for manufacturers to disable access to the TDWR frequencies until an unlocking code is entered. The unlocking code will be generated once a license is issued for the link as part of the licensing process. I'm assuming that the main problem here is uneducated users deploying links without knowing the effects they are having on the TDWR systems. This isn't going to help the rogue operators who know what they're doing and don't care. I seem to remember one violator in PR who was using Canopy 5700BH boards inside a 5400BH case, and had changed the channel down into 5.4 using the engineering page, bypassing DFS requirements and power limits. -- Patrick Shoemaker Vector Data Systems LLC shoemak...@vectordatasystems.com office: (301) 358-1690 x36 http://www.vectordatasystems.com On 2/9/2011 2:22 PM, Fred Goldstein wrote: > I notice that the FCC issued a $10,000 fine to Ayustar in San Juan > about a year ago. I hope they got the message. > > It just might be that the FCC and NTIA were a little fast in making > 5600-5650 part of the Part 15 bands. Sure, licensed equipment can be > used without a license (vis. 3650) but that's a pretty > straightforward violation. On the other hand, it would be better to > have access to that band, including the 30 MHz guard bands that the > NTIA presentation shows as being needed, at least near the TDWRs. > > And that's the rub: There are 45 TDWRs, and a lot of places nowhere > near them. Sensing has not proven reliable. But a GPS/database > approach is costly. Maybe the best compromise is to take 5570-5680 > and take it out of Part 15, or limit Part 15 use to indoor low power > only (like 5150-5250). Then the 110 MHz at risk can be made > available under Part 90, as nonexclusive light licensing. The > license would have to specify its frqeuencies area of operation, and > follow rules that avoid TDWR interference. So if it's within say 10 > miles of a TDWR, it would need the 30 MHz spacing, and if within some > larger radius, it would need less spacing, and if way far from one of > them, it could operate within the TDWR band. In exchange for this, > we should ask for higher power limits, perhaps the same as on > 5725-5850 ISM, for places where it wouldn't interfere with TDWR (say > if it's both>30 MHz and> 20 km away, or>100 km away). This could > be done with a map of both TDWR and any other protected radars. > > At 2/9/2011 01:59 PM, Jack Unger wrote: >> On 2/9/2011 9:49 AM, Marlon K. Schafer wrote: >>> The proper fix for this problem is a visit from the enforcement guys, and a >>> nasty fine for repeat offenders. >> Joint FAA/FCC Enforcement teams have been out for a long time >> but this is >> a VERY costly solution and likely not sustainable in this era of shrinking >> budgets. That's why it's better to solve this problem before >> enforcement becomes >> the option of (costly) last resort. WISPA has suggested to the FCC that they >> better PUBLICIZE enforcement actions and they are considering that. >>> After that, what would be so hard about using sensing and DFS (done right >>> this time) to cause systems near the radars to notch out the 110mhz of >>> spectrum while not bothering anyone else? >> This is much more difficult that it sounds. The wireless >> industry has been >> working for over a year (manufacturers, chip makers, etc.) to do >> this and has so >> far been unable to come up with an acceptable technical solution. >> The effort is >> on hold at the moment. >>> The radar systems are well known, should be an easy signal to detect. >> They are not so easy to detect. New radar waveforms come into >> use. Radars >> go on and off-line. Wireless systems can't sit around all day just listening; >> they have real world traffic to handle. Again, the best minds in the industry >> have so far failed to figure out an acceptable solution. >>> The radios already tend to send a LOT of data back and forth, radio name, >>> signal levels, speed, language, channel used etc. etc. etc. Certainly any >>> radio that turns on could sense for 30 seconds, if it detects a TDWR signal >>> at a certain threshold, then report than back to the AP and the AP could >>> then lock out the needed channels for that particular location. >> You are more than welcome to volunteer to join the wireless "Industry >> Group" engineering team that has been addressing this issue for the >> last year. >> I'll be happy to introduce you to the team leader so you can sign up to >> contribute your engineering advice. >>> This should be able to be done via a firmware upgrade to any legacy or new >>> hardware out there. >> Well, the manufacturers are not stepping up to develop new >> firmware. This >> is one of the frustrations that the FCC feels. >>> Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of >>> newly acquired spectrum from the rest of the country. >> I would welcome your help to reach out to and mot
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
I notice that the FCC issued a $10,000 fine to Ayustar in San Juan about a year ago. I hope they got the message. It just might be that the FCC and NTIA were a little fast in making 5600-5650 part of the Part 15 bands. Sure, licensed equipment can be used without a license (vis. 3650) but that's a pretty straightforward violation. On the other hand, it would be better to have access to that band, including the 30 MHz guard bands that the NTIA presentation shows as being needed, at least near the TDWRs. And that's the rub: There are 45 TDWRs, and a lot of places nowhere near them. Sensing has not proven reliable. But a GPS/database approach is costly. Maybe the best compromise is to take 5570-5680 and take it out of Part 15, or limit Part 15 use to indoor low power only (like 5150-5250). Then the 110 MHz at risk can be made available under Part 90, as nonexclusive light licensing. The license would have to specify its frqeuencies area of operation, and follow rules that avoid TDWR interference. So if it's within say 10 miles of a TDWR, it would need the 30 MHz spacing, and if within some larger radius, it would need less spacing, and if way far from one of them, it could operate within the TDWR band. In exchange for this, we should ask for higher power limits, perhaps the same as on 5725-5850 ISM, for places where it wouldn't interfere with TDWR (say if it's both >30 MHz and > 20 km away, or >100 km away). This could be done with a map of both TDWR and any other protected radars. At 2/9/2011 01:59 PM, Jack Unger wrote: >On 2/9/2011 9:49 AM, Marlon K. Schafer wrote: > > The proper fix for this problem is a visit from the enforcement guys, and a > > nasty fine for repeat offenders. > Joint FAA/FCC Enforcement teams have been out for a long time >but this is >a VERY costly solution and likely not sustainable in this era of shrinking >budgets. That's why it's better to solve this problem before >enforcement becomes >the option of (costly) last resort. WISPA has suggested to the FCC that they >better PUBLICIZE enforcement actions and they are considering that. > > After that, what would be so hard about using sensing and DFS (done right > > this time) to cause systems near the radars to notch out the 110mhz of > > spectrum while not bothering anyone else? > This is much more difficult that it sounds. The wireless >industry has been >working for over a year (manufacturers, chip makers, etc.) to do >this and has so >far been unable to come up with an acceptable technical solution. >The effort is >on hold at the moment. > > The radar systems are well known, should be an easy signal to detect. > They are not so easy to detect. New radar waveforms come into >use. Radars >go on and off-line. Wireless systems can't sit around all day just listening; >they have real world traffic to handle. Again, the best minds in the industry >have so far failed to figure out an acceptable solution. > > The radios already tend to send a LOT of data back and forth, radio name, > > signal levels, speed, language, channel used etc. etc. etc. Certainly any > > radio that turns on could sense for 30 seconds, if it detects a TDWR signal > > at a certain threshold, then report than back to the AP and the AP could > > then lock out the needed channels for that particular location. > You are more than welcome to volunteer to join the wireless "Industry >Group" engineering team that has been addressing this issue for the >last year. >I'll be happy to introduce you to the team leader so you can sign up to >contribute your engineering advice. > > This should be able to be done via a firmware upgrade to any legacy or new > > hardware out there. > Well, the manufacturers are not stepping up to develop new >firmware. This >is one of the frustrations that the FCC feels. > > Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of > > newly acquired spectrum from the rest of the country. >I would welcome your help to reach out to and motivate the >manufacturers to >do this. Let me know when you are ready to start your outreach program. > > A quick note on PR. The operator(s) there has run foot loose and > fancy free > > with the rules for as long as I can remember. Perhaps it's time to fine > > them at a high enough level that it puts them out of business? Kind of a 3 > > strikes your out thing. > Yep. Sounds right. > >jack > > > marlon > > -- 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] [WISPA Members] Your input on 5 GHz rules changes needed
On 2/9/2011 9:49 AM, Marlon K. Schafer wrote: > The proper fix for this problem is a visit from the enforcement guys, and a > nasty fine for repeat offenders. Joint FAA/FCC Enforcement teams have been out for a long time but this is a VERY costly solution and likely not sustainable in this era of shrinking budgets. That's why it's better to solve this problem before enforcement becomes the option of (costly) last resort. WISPA has suggested to the FCC that they better PUBLICIZE enforcement actions and they are considering that. > After that, what would be so hard about using sensing and DFS (done right > this time) to cause systems near the radars to notch out the 110mhz of > spectrum while not bothering anyone else? This is much more difficult that it sounds. The wireless industry has been working for over a year (manufacturers, chip makers, etc.) to do this and has so far been unable to come up with an acceptable technical solution. The effort is on hold at the moment. > The radar systems are well known, should be an easy signal to detect. They are not so easy to detect. New radar waveforms come into use. Radars go on and off-line. Wireless systems can't sit around all day just listening; they have real world traffic to handle. Again, the best minds in the industry have so far failed to figure out an acceptable solution. > The radios already tend to send a LOT of data back and forth, radio name, > signal levels, speed, language, channel used etc. etc. etc. Certainly any > radio that turns on could sense for 30 seconds, if it detects a TDWR signal > at a certain threshold, then report than back to the AP and the AP could > then lock out the needed channels for that particular location. You are more than welcome to volunteer to join the wireless "Industry Group" engineering team that has been addressing this issue for the last year. I'll be happy to introduce you to the team leader so you can sign up to contribute your engineering advice. > This should be able to be done via a firmware upgrade to any legacy or new > hardware out there. Well, the manufacturers are not stepping up to develop new firmware. This is one of the frustrations that the FCC feels. > Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of > newly acquired spectrum from the rest of the country. I would welcome your help to reach out to and motivate the manufacturers to do this. Let me know when you are ready to start your outreach program. > A quick note on PR. The operator(s) there has run foot loose and fancy free > with the rules for as long as I can remember. Perhaps it's time to fine > them at a high enough level that it puts them out of business? Kind of a 3 > strikes your out thing. Yep. Sounds right. jack > marlon > > - Original Message - > From: "Jack Unger" > To:; "WISPA General List" > Sent: Tuesday, February 08, 2011 1:47 PM > Subject: [WISPA Members] Your input on 5 GHz rules changes needed > > > > In spite of the noteworthy efforts on the part of many WISP operators and in > spite of a temporary decrease in the levels of TDWR interference reported to > us > by the FCC, the TDWR interference situation has unfortunately deteriorated. > The > FCC now reports that some locations (New York, Chicago, Denver and Dallas) > that > were recently “cleared” of interference are once again experiencing > significant > interference problems. The TDWR interference in San Juan Puerto Rico is so > bad > that the TDWR system had to be shut off by the FAA. This is not good news > because the FAA is pushing the FCC to solve these interference problems once > and > for all. > > Voluntary database registration has unfortunately not proven to be effective > enough. There are still some operators who apparently have not heard about > the > TDWR interference problem and some who have simply failed to bring and keep > their systems in compliance. On the supply-chain side, there are several > manufacturers and distributors who did take positive, affirmative and > responsible action to help address the problem however they were they in the > minority. Most manufacturers and distributors did not “step up to the plate” > with customer education or software upgrades. Because airline safety is a > very > important issue, it only takes a few “bad actors” to cause significant > problems > for everyone else. > > The FCC is under strong pressure to take steps to solve the interference > problem > for good. The FCC Office of Engineering and Technology has started drafting > a > Notice of Proposed Rulemaking (NPRM). We don’t know yet what new rules the > FCC > will propose. They could require that the 5570 to 5680 frequency range be > “notched out” for all new equipment. This would mean that we would lose the > use > of 110 MHz of spectrum. Another possibility is that TDWR database > registration > will be required of all WISPs instead the current voluntary registration for > WISPs located near TDWRs.
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
A quick note on PR. The operator(s) there has run foot loose and fancy free with the rules for as long as I can remember. Perhaps it's time to fine them at a high enough level that it puts them out of business? Kind of a 3 strikes your out thing Probably cause down there everyone is running 4 watt Hyperlink Amps on 2.4ghz, 5.8ghz sounds like its prob trashed too and so only thing left is 5.4 that's why they are getting so many probs on it. Kurt Fankhauser Wavelinc Communications http://www.wavelinc.com P.O. Box 126 Bucyrus, OH 44820 419-562-6405 Sent from Microsoft Outlook -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Marlon K. Schafer Sent: Wednesday, February 09, 2011 12:50 PM To: memb...@wispa.org; WISPA General List Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed The proper fix for this problem is a visit from the enforcement guys, and a nasty fine for repeat offenders. After that, what would be so hard about using sensing and DFS (done right this time) to cause systems near the radars to notch out the 110mhz of spectrum while not bothering anyone else? The radar systems are well known, should be an easy signal to detect. The radios already tend to send a LOT of data back and forth, radio name, signal levels, speed, language, channel used etc. etc. etc. Certainly any radio that turns on could sense for 30 seconds, if it detects a TDWR signal at a certain threshold, then report than back to the AP and the AP could then lock out the needed channels for that particular location. This should be able to be done via a firmware upgrade to any legacy or new hardware out there. Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of newly acquired spectrum from the rest of the country. A quick note on PR. The operator(s) there has run foot loose and fancy free with the rules for as long as I can remember. Perhaps it's time to fine them at a high enough level that it puts them out of business? Kind of a 3 strikes your out thing. marlon - Original Message - From: "Jack Unger" To: ; "WISPA General List" Sent: Tuesday, February 08, 2011 1:47 PM Subject: [WISPA Members] Your input on 5 GHz rules changes needed In spite of the noteworthy efforts on the part of many WISP operators and in spite of a temporary decrease in the levels of TDWR interference reported to us by the FCC, the TDWR interference situation has unfortunately deteriorated. The FCC now reports that some locations (New York, Chicago, Denver and Dallas) that were recently "cleared" of interference are once again experiencing significant interference problems. The TDWR interference in San Juan Puerto Rico is so bad that the TDWR system had to be shut off by the FAA. This is not good news because the FAA is pushing the FCC to solve these interference problems once and for all. Voluntary database registration has unfortunately not proven to be effective enough. There are still some operators who apparently have not heard about the TDWR interference problem and some who have simply failed to bring and keep their systems in compliance. On the supply-chain side, there are several manufacturers and distributors who did take positive, affirmative and responsible action to help address the problem however they were they in the minority. Most manufacturers and distributors did not "step up to the plate" with customer education or software upgrades. Because airline safety is a very important issue, it only takes a few "bad actors" to cause significant problems for everyone else. The FCC is under strong pressure to take steps to solve the interference problem for good. The FCC Office of Engineering and Technology has started drafting a Notice of Proposed Rulemaking (NPRM). We don't know yet what new rules the FCC will propose. They could require that the 5570 to 5680 frequency range be "notched out" for all new equipment. This would mean that we would lose the use of 110 MHz of spectrum. Another possibility is that TDWR database registration will be required of all WISPs instead the current voluntary registration for WISPs located near TDWRs. A third possibility is that all new equipment might have to automatically log into a geo-location database (similar to the TV White Space database) and receive a list of allowable frequencies. Nearby TDWR frequencies and a guard band around the TDWR frequency range would be prohibited. The FCC OET has agreed to meet with us to listen to and discuss our suggestions about ways to address the problem and what new rules should be proposed in the NPRM. I've prepared a short online survey for WISPA Members to see what new rules they prefer and what suggestions they have. Please take a few minutes today to review this survey and give me your feedback
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
The proper fix for this problem is a visit from the enforcement guys, and a nasty fine for repeat offenders. After that, what would be so hard about using sensing and DFS (done right this time) to cause systems near the radars to notch out the 110mhz of spectrum while not bothering anyone else? The radar systems are well known, should be an easy signal to detect. The radios already tend to send a LOT of data back and forth, radio name, signal levels, speed, language, channel used etc. etc. etc. Certainly any radio that turns on could sense for 30 seconds, if it detects a TDWR signal at a certain threshold, then report than back to the AP and the AP could then lock out the needed channels for that particular location. This should be able to be done via a firmware upgrade to any legacy or new hardware out there. Cheap, relatively easy, fixes the problem and does NOT take away 110mhz of newly acquired spectrum from the rest of the country. A quick note on PR. The operator(s) there has run foot loose and fancy free with the rules for as long as I can remember. Perhaps it's time to fine them at a high enough level that it puts them out of business? Kind of a 3 strikes your out thing. marlon - Original Message - From: "Jack Unger" To: ; "WISPA General List" Sent: Tuesday, February 08, 2011 1:47 PM Subject: [WISPA Members] Your input on 5 GHz rules changes needed In spite of the noteworthy efforts on the part of many WISP operators and in spite of a temporary decrease in the levels of TDWR interference reported to us by the FCC, the TDWR interference situation has unfortunately deteriorated. The FCC now reports that some locations (New York, Chicago, Denver and Dallas) that were recently “cleared” of interference are once again experiencing significant interference problems. The TDWR interference in San Juan Puerto Rico is so bad that the TDWR system had to be shut off by the FAA. This is not good news because the FAA is pushing the FCC to solve these interference problems once and for all. Voluntary database registration has unfortunately not proven to be effective enough. There are still some operators who apparently have not heard about the TDWR interference problem and some who have simply failed to bring and keep their systems in compliance. On the supply-chain side, there are several manufacturers and distributors who did take positive, affirmative and responsible action to help address the problem however they were they in the minority. Most manufacturers and distributors did not “step up to the plate” with customer education or software upgrades. Because airline safety is a very important issue, it only takes a few “bad actors” to cause significant problems for everyone else. The FCC is under strong pressure to take steps to solve the interference problem for good. The FCC Office of Engineering and Technology has started drafting a Notice of Proposed Rulemaking (NPRM). We don’t know yet what new rules the FCC will propose. They could require that the 5570 to 5680 frequency range be “notched out” for all new equipment. This would mean that we would lose the use of 110 MHz of spectrum. Another possibility is that TDWR database registration will be required of all WISPs instead the current voluntary registration for WISPs located near TDWRs. A third possibility is that all new equipment might have to automatically log into a geo-location database (similar to the TV White Space database) and receive a list of allowable frequencies. Nearby TDWR frequencies and a guard band around the TDWR frequency range would be prohibited. The FCC OET has agreed to meet with us to listen to and discuss our suggestions about ways to address the problem and what new rules should be proposed in the NPRM. I’ve prepared a short online survey for WISPA Members to see what new rules they prefer and what suggestions they have. Please take a few minutes today to review this survey and give me your feedback before I publish this survey to our Members. I expect that there will be a variety of opinions and possibly additional solutions. WISPA’s policy will be guided by whatever the majority of WISPA Members say they want. Here’s the link to the survey < http://www.surveymonkey.com/s/HPCC7BL> Most of us do not want new rules and regulations however the bottom line is that we need to save this spectrum. 110 MHz of 5 GHz spectrum is too valuable to just give up. We have to fight too hard to acquire spectrum; it wouldn’t be right for all of us to lose 110 MHz of spectrum because of the actions of a few noncompliant operators. As always, thank-you for your help. Jack Unger Chair - WISPA FCC Committee 818-227-4220 -- Jack Unger - President, Ask-Wi.Com, Inc. Author (2003) - "Deploying License-Free Wireless Wide-Area Networks" Serving the WISP, Networking and Telecom Communities since 1993 www.ask-wi.com 818-227-4220 jun...@ask-wi.com _
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
That would be great. What options do you see? DFS2 looks to have not got the job done. No one knows how the GPS+DB stuff will really look, or the costs it will add. The simplest way to do GPS would be to make a serial receive port. The DB part would be a pretty simple script. On Tue, Feb 8, 2011 at 9:50 PM, Tom DeReggi wrote: > I do not see why we must suggest or FCC mandate a static one shoe fits all > approach. > > The fact is, there are multiple ways to address the problem, each of which > could be equally effective. As long as any one of those several options are > chosen by an operator or manuacturer, problem solved. Why not support and > enable "choice"? > > > Tom DeReggi > RapidDSL & Wireless, Inc > IntAirNet- Fixed Wireless Broadband > > > - Original Message - > From: "Jeromie Reeves" > To: "WISPA General List" > Sent: Wednesday, February 09, 2011 12:10 AM > Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes > needed > > > On Tue, Feb 8, 2011 at 8:48 PM, Blair Davis wrote: >> Inline reply's >> >> On 2/8/2011 11:31 PM, Jeromie Reeves wrote: >> >> On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble >> wrote: >> >> -BEGIN PGP SIGNED MESSAGE- >> Hash: SHA1 >> >> On 02/08/2011 02:23 PM, Jack Unger wrote: >> >> Comments inline. >> >> jack >> >> >> On 2/8/2011 2:09 PM, Blair Davis wrote: >> >> Some serious enforcement is in order. Major fines for repeated >> offense... $100K or more for 2nd offense... >> >> Serious fines and maybe total revocation of $Individual/$corp to >> transmit RF at all. >> I am all for the steel boot the first warning. Sometimes >> slipups happen. >> Repeated slipups is clear intent. >> >> I agree with this totally. >> >> Last month we recommended to the FCC OET that they publicize actions >> against >> offenders who they locate. This would help get the message out that this >> is >> a >> serious problem and that enforcement is in fact taking place. >> >> That would be nice to see for many reasons. >> >> Is that covered at http://fcc.gov/eb/Orders/Welcome.html or >> http://fcc.gov/eb/FieldNotices/ ? >> >> I'd rather see the TDWR band notched out than any kind of required GPS >> and database... >> >> Why? I think we operators need to work out a policing deal with the >> FCC. If there was a easy way for the FAA/FCC >> to let us know that interference is happening at site ABC. Maybe a >> simple email list that we sign up to. This would >> be more akin to hams self policing. I do /not/ want to lose the band. >> Maybe we need a database that we can report >> links that we see and their locations/suspected locations. I know I >> have seen many illegal links and reports to the >> FCC fall on deaf ears so long ago I stopped trying to report it. >> >> Why? Because it will likely raise the cost of the equipment quite a bit to >> include the GPS hardware and the database access system... > > I am hoping for a system that forestalls the GPS needs. Namely, > Disallow use in any radar areas if people > can not pull their heads out of .. what ever dark places it is at. Or, > at the very least a place WISPs can > report what we see, and a place that the FCC can report what they see. > > If the band is totally not allowed, then the added cost of GPS would > not matter would it? > >> >> Notching may be the ultimate outcome for all new equipment. The >> disadvantage >> is >> that notching deprives everyone from using the spectrum, even the 90% of >> operators who are nowhere near a TDWR system. >> >> Maybe the FCC needs to 'notch' the TDWR areas, like the 3.650 >> exclusion zones. I would hate for such large areas >> to lose access but /I/ do not want to lose access because others are >> being /%$#@/ >> >> I could go for a 'licensed lite' system for the 5.4 band... but, if there >> is >> no better enforcement on 5.4 than there is on 3.65, what is the point? >> >> Very true. >> >> What is going on with the 3.65 stuff? I still think we need some kind >> of license enforcement there... >> >> Why? >> >> WISPA recently had it's first 3650 Steering Committee meeting and it was >> agreed >> that major work (education, best practices, possible rules changes, etc.) >> is >> needed because the interference situation is getting way out of hand. >> >> Hmmm. Interesting. That's news to
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
I do not see why we must suggest or FCC mandate a static one shoe fits all approach. The fact is, there are multiple ways to address the problem, each of which could be equally effective. As long as any one of those several options are chosen by an operator or manuacturer, problem solved. Why not support and enable "choice"? Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: "Jeromie Reeves" To: "WISPA General List" Sent: Wednesday, February 09, 2011 12:10 AM Subject: Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed On Tue, Feb 8, 2011 at 8:48 PM, Blair Davis wrote: > Inline reply's > > On 2/8/2011 11:31 PM, Jeromie Reeves wrote: > > On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble > wrote: > > -BEGIN PGP SIGNED MESSAGE- > Hash: SHA1 > > On 02/08/2011 02:23 PM, Jack Unger wrote: > > Comments inline. > > jack > > > On 2/8/2011 2:09 PM, Blair Davis wrote: > > Some serious enforcement is in order. Major fines for repeated > offense... $100K or more for 2nd offense... > > Serious fines and maybe total revocation of $Individual/$corp to > transmit RF at all. > I am all for the steel boot the first warning. Sometimes > slipups happen. > Repeated slipups is clear intent. > > I agree with this totally. > > Last month we recommended to the FCC OET that they publicize actions > against > offenders who they locate. This would help get the message out that this > is > a > serious problem and that enforcement is in fact taking place. > > That would be nice to see for many reasons. > > Is that covered at http://fcc.gov/eb/Orders/Welcome.html or > http://fcc.gov/eb/FieldNotices/ ? > > I'd rather see the TDWR band notched out than any kind of required GPS > and database... > > Why? I think we operators need to work out a policing deal with the > FCC. If there was a easy way for the FAA/FCC > to let us know that interference is happening at site ABC. Maybe a > simple email list that we sign up to. This would > be more akin to hams self policing. I do /not/ want to lose the band. > Maybe we need a database that we can report > links that we see and their locations/suspected locations. I know I > have seen many illegal links and reports to the > FCC fall on deaf ears so long ago I stopped trying to report it. > > Why? Because it will likely raise the cost of the equipment quite a bit to > include the GPS hardware and the database access system... I am hoping for a system that forestalls the GPS needs. Namely, Disallow use in any radar areas if people can not pull their heads out of .. what ever dark places it is at. Or, at the very least a place WISPs can report what we see, and a place that the FCC can report what they see. If the band is totally not allowed, then the added cost of GPS would not matter would it? > > Notching may be the ultimate outcome for all new equipment. The > disadvantage > is > that notching deprives everyone from using the spectrum, even the 90% of > operators who are nowhere near a TDWR system. > > Maybe the FCC needs to 'notch' the TDWR areas, like the 3.650 > exclusion zones. I would hate for such large areas > to lose access but /I/ do not want to lose access because others are > being /%$#@/ > > I could go for a 'licensed lite' system for the 5.4 band... but, if there > is > no better enforcement on 5.4 than there is on 3.65, what is the point? > > Very true. > > What is going on with the 3.65 stuff? I still think we need some kind > of license enforcement there... > > Why? > > WISPA recently had it's first 3650 Steering Committee meeting and it was > agreed > that major work (education, best practices, possible rules changes, etc.) > is > needed because the interference situation is getting way out of hand. > > Hmmm. Interesting. That's news to me. Where does one see info about the > violations? Is it happening on private lists or something? I don't > recall any complaints on the WISPA general list about it. > > There are > > also more and more illegal (unlicensed) "bootleggers" using the band. One > solution (among many) is to use a regional email list to coordinate > between > different operators. This is in use now in Phoenix. > > H. Well illegal/unlicensed use is a clear enforcement action and > should be referred to the FCC EB. Coordination among entities... as I > recall that was very vague in the R&O. > > Is the FCC feeling pressure to do the enforcement side of its job and > not wanting to, or is it unable, or ? > I am all for helping them clean things up. How can we as w
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
On Tue, Feb 8, 2011 at 8:48 PM, Blair Davis wrote: > Inline reply's > > On 2/8/2011 11:31 PM, Jeromie Reeves wrote: > > On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble > wrote: > > -BEGIN PGP SIGNED MESSAGE- > Hash: SHA1 > > On 02/08/2011 02:23 PM, Jack Unger wrote: > > Comments inline. > > jack > > > On 2/8/2011 2:09 PM, Blair Davis wrote: > > Some serious enforcement is in order. Major fines for repeated > offense... $100K or more for 2nd offense... > > Serious fines and maybe total revocation of $Individual/$corp to > transmit RF at all. > I am all for the steel boot the first warning. Sometimes > slipups happen. > Repeated slipups is clear intent. > > I agree with this totally. > > Last month we recommended to the FCC OET that they publicize actions against > offenders who they locate. This would help get the message out that this is > a > serious problem and that enforcement is in fact taking place. > > That would be nice to see for many reasons. > > Is that covered at http://fcc.gov/eb/Orders/Welcome.html or > http://fcc.gov/eb/FieldNotices/ ? > > I'd rather see the TDWR band notched out than any kind of required GPS > and database... > > Why? I think we operators need to work out a policing deal with the > FCC. If there was a easy way for the FAA/FCC > to let us know that interference is happening at site ABC. Maybe a > simple email list that we sign up to. This would > be more akin to hams self policing. I do /not/ want to lose the band. > Maybe we need a database that we can report > links that we see and their locations/suspected locations. I know I > have seen many illegal links and reports to the > FCC fall on deaf ears so long ago I stopped trying to report it. > > Why? Because it will likely raise the cost of the equipment quite a bit to > include the GPS hardware and the database access system... I am hoping for a system that forestalls the GPS needs. Namely, Disallow use in any radar areas if people can not pull their heads out of .. what ever dark places it is at. Or, at the very least a place WISPs can report what we see, and a place that the FCC can report what they see. If the band is totally not allowed, then the added cost of GPS would not matter would it? > > Notching may be the ultimate outcome for all new equipment. The disadvantage > is > that notching deprives everyone from using the spectrum, even the 90% of > operators who are nowhere near a TDWR system. > > Maybe the FCC needs to 'notch' the TDWR areas, like the 3.650 > exclusion zones. I would hate for such large areas > to lose access but /I/ do not want to lose access because others are > being /%$#@/ > > I could go for a 'licensed lite' system for the 5.4 band... but, if there is > no better enforcement on 5.4 than there is on 3.65, what is the point? > > Very true. > > What is going on with the 3.65 stuff? I still think we need some kind > of license enforcement there... > > Why? > > WISPA recently had it's first 3650 Steering Committee meeting and it was > agreed > that major work (education, best practices, possible rules changes, etc.) is > needed because the interference situation is getting way out of hand. > > Hmmm. Interesting. That's news to me. Where does one see info about the > violations? Is it happening on private lists or something? I don't > recall any complaints on the WISPA general list about it. > > There are > > also more and more illegal (unlicensed) "bootleggers" using the band. One > solution (among many) is to use a regional email list to coordinate between > different operators. This is in use now in Phoenix. > > H. Well illegal/unlicensed use is a clear enforcement action and > should be referred to the FCC EB. Coordination among entities... as I > recall that was very vague in the R&O. > > Is the FCC feeling pressure to do the enforcement side of its job and > not wanting to, or is it unable, or ? > I am all for helping them clean things up. How can we as wisps do this > and how can wispa help us and > the FCC? > > A) WISPS need a open place to report things we see > B) The FCC needs a place to report to us when it see's/receives a > report of interference. > > Thoughts? > > I mentioned this a month or two back... > > In an area with NO other registered 3.65 locations, I have already found > 3.65 gear in use. That is not good. We need a way to shut them down. How many man hours does it take to do this? I wonder if there is a boiler plate cease and desist that could be worked up. If a (qualified, certified, licensed, approved, etc) wisp could report information to the FCC, and then have a letter delivered to the /site owner/ about /hardware X is generating interference Y/ and hold the site owner to the coals, would that be a acceptable solution? > > Especially, UBNT NSM365 gear used as PtP to link up house to barn and so > on... > > I have proposed that equipment sellers be required to check for an FCC > license before selling 3.65 gear. That should be required. It should
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
Inline reply's On 2/8/2011 11:31 PM, Jeromie Reeves wrote: On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble wrote: -BEGIN PGP SIGNED MESSAGE- Hash: SHA1 On 02/08/2011 02:23 PM, Jack Unger wrote: Comments inline. jack On 2/8/2011 2:09 PM, Blair Davis wrote: Some serious enforcement is in order. Major fines for repeated offense... $100K or more for 2nd offense... Serious fines and maybe total revocation of $Individual/$corp to transmit RF at all. I am all for the steel boot the first warning. Sometimes slipups happen. Repeated slipups is clear intent. I agree with this totally. Last month we recommended to the FCC OET that they publicize actions against offenders who they locate. This would help get the message out that this is a serious problem and that enforcement is in fact taking place. That would be nice to see for many reasons. Is that covered at http://fcc.gov/eb/Orders/Welcome.html or http://fcc.gov/eb/FieldNotices/ ? I'd rather see the TDWR band notched out than any kind of required GPS and database... Why? I think we operators need to work out a policing deal with the FCC. If there was a easy way for the FAA/FCC to let us know that interference is happening at site ABC. Maybe a simple email list that we sign up to. This would be more akin to hams self policing. I do /not/ want to lose the band. Maybe we need a database that we can report links that we see and their locations/suspected locations. I know I have seen many illegal links and reports to the FCC fall on deaf ears so long ago I stopped trying to report it. Why? Because it will likely raise the cost of the equipment quite a bit to include the GPS hardware and the database access system... Notching may be the ultimate outcome for all new equipment. The disadvantage is that notching deprives everyone from using the spectrum, even the 90% of operators who are nowhere near a TDWR system. Maybe the FCC needs to 'notch' the TDWR areas, like the 3.650 exclusion zones. I would hate for such large areas to lose access but /I/ do not want to lose access because others are being /%$#@/ I could go for a 'licensed lite' system for the 5.4 band... but, if there is no better enforcement on 5.4 than there is on 3.65, what is the point? Very true. What is going on with the 3.65 stuff? I still think we need some kind of license enforcement there... Why? WISPA recently had it's first 3650 Steering Committee meeting and it was agreed that major work (education, best practices, possible rules changes, etc.) is needed because the interference situation is getting way out of hand. Hmmm. Interesting. That's news to me. Where does one see info about the violations? Is it happening on private lists or something? I don't recall any complaints on the WISPA general list about it. There are also more and more illegal (unlicensed) "bootleggers" using the band. One solution (among many) is to use a regional email list to coordinate between different operators. This is in use now in Phoenix. H. Well illegal/unlicensed use is a clear enforcement action and should be referred to the FCC EB. Coordination among entities... as I recall that was very vague in the R&O. Is the FCC feeling pressure to do the enforcement side of its job and not wanting to, or is it unable, or ? I am all for helping them clean things up. How can we as wisps do this and how can wispa help us and the FCC? A) WISPS need a open place to report things we see B) The FCC needs a place to report to us when it see's/receives a report of interference. Thoughts? I mentioned this a month or two back... In an area with NO other registered 3.65 locations, I have already found 3.65 gear in use. Especially, UBNT NSM365 gear used as PtP to link up house to barn and so on... I have proposed that equipment sellers be required to check for an FCC license before selling 3.65 gear. I also KNOW of a WISP that was planning on deploying 3.65 gear without a license at all. - -- 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/ iQIcBAEBAgAGBQJNUgaFAAoJEMvvG/TyLEAteVwP/iZ/0b6im8NQhJXXIJxR+0V9 3vhg+UegyqimJJkMPnwKBdSr
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
On Tue, Feb 8, 2011 at 7:14 PM, Charles N Wyble wrote: > -BEGIN PGP SIGNED MESSAGE- > Hash: SHA1 > > On 02/08/2011 02:23 PM, Jack Unger wrote: >> Comments inline. >> >> jack >> >> >> On 2/8/2011 2:09 PM, Blair Davis wrote: >>> >>> Some serious enforcement is in order. Major fines for repeated >>> offense... $100K or more for 2nd offense... Serious fines and maybe total revocation of $Individual/$corp to transmit RF at all. I am all for the steel boot the first warning. Sometimes slipups happen. Repeated slipups is clear intent. >> Last month we recommended to the FCC OET that they publicize actions against >> offenders who they locate. This would help get the message out that this is a >> serious problem and that enforcement is in fact taking place. That would be nice to see for many reasons. > > Is that covered at http://fcc.gov/eb/Orders/Welcome.html or > http://fcc.gov/eb/FieldNotices/ ? > >>> I'd rather see the TDWR band notched out than any kind of required GPS >>> and database... Why? I think we operators need to work out a policing deal with the FCC. If there was a easy way for the FAA/FCC to let us know that interference is happening at site ABC. Maybe a simple email list that we sign up to. This would be more akin to hams self policing. I do /not/ want to lose the band. Maybe we need a database that we can report links that we see and their locations/suspected locations. I know I have seen many illegal links and reports to the FCC fall on deaf ears so long ago I stopped trying to report it. >> Notching may be the ultimate outcome for all new equipment. The disadvantage >> is >> that notching deprives everyone from using the spectrum, even the 90% of >> operators who are nowhere near a TDWR system. Maybe the FCC needs to 'notch' the TDWR areas, like the 3.650 exclusion zones. I would hate for such large areas to lose access but /I/ do not want to lose access because others are being /%$#@/ > > Very true. > >>> What is going on with the 3.65 stuff? I still think we need some kind >>> of license enforcement there... > > Why? > >> WISPA recently had it's first 3650 Steering Committee meeting and it was >> agreed >> that major work (education, best practices, possible rules changes, etc.) is >> needed because the interference situation is getting way out of hand. > > Hmmm. Interesting. That's news to me. Where does one see info about the > violations? Is it happening on private lists or something? I don't > recall any complaints on the WISPA general list about it. > > There are >> also more and more illegal (unlicensed) "bootleggers" using the band. One >> solution (among many) is to use a regional email list to coordinate between >> different operators. This is in use now in Phoenix. > > H. Well illegal/unlicensed use is a clear enforcement action and > should be referred to the FCC EB. Coordination among entities... as I > recall that was very vague in the R&O. Is the FCC feeling pressure to do the enforcement side of its job and not wanting to, or is it unable, or ? I am all for helping them clean things up. How can we as wisps do this and how can wispa help us and the FCC? A) WISPS need a open place to report things we see B) The FCC needs a place to report to us when it see's/receives a report of interference. Thoughts? > > > - -- > 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/ > > iQIcBAEBAgAGBQJNUgaFAAoJEMvvG/TyLEAteVwP/iZ/0b6im8NQhJXXIJxR+0V9 > 3vhg+UegyqimJJkMPnwKBdSrW/i2FBVDc1LHftkn1aEOjj5GamoeiAnV6umG3VbF > r23XC5vvUCr3drosgprLr3FHXi2wQE+D+ToYCB+YdU3bklvHD/AJ4hTZKfM6ZDJK > Vo4cNflKC28o+D9qlwvjheFflhkxf1dBl7eAJe+wvxtHXqgE/tfOig+20wRXBQea > ruyD40BWNLPOCqcjafHCto3zzgTMX03hqwKqT8a+bvdqOrAoAHsZUIv7RFhOY6Xv > oVMJZMDgzrZUUCq+LHBgZZ33+Xr94uABqKz+1JMjwdCPUNe8POBOU7st6RkHPjkj > l+J55/xlV7KMq3eS+pvGEVFY7Vt26oPo1AHhIvdutkrkYVtWmAvcmPQAReTmUfZQ > QsdGv/U/mqms2Kd0ujSaGFvQk8kwC5Nl5Hi7nnObc5nbRao53z/KiB4PGycfIiw9 > N5IcL8Cay+nl+OqYYX4VdIU2laWFQh7Vst5ZH+MXk3wXvGFb0TIKexLimAdXO66Z > 3kHWXYZhEUAQ+QQQ6mJLKWAly1tlmyL3FqLrUQKNpISEWpysqOuxxpBw8jlwrdaj > Xq9F36fRZvj8CqyImQdPQaFQq5NKdANMHTXS5b3G8cBNF1/NJQUJb/8ecwuK2iw6 > FtnI80BWXzQwIe/bfPci > =3Dzr > -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/ > WISPA Wants You! Join today! http://signup.wispa.org/ --
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
Charles, My new comments are preceded by . jack On 2/8/2011 7:14 PM, Charles N Wyble wrote: > -BEGIN PGP SIGNED MESSAGE- > Hash: SHA1 > > On 02/08/2011 02:23 PM, Jack Unger wrote: >> Comments inline. >> >> jack >> >> >> On 2/8/2011 2:09 PM, Blair Davis wrote: >>> Some serious enforcement is in order. Major fines for repeated >>> offense... $100K or more for 2nd offense... >> Last month we recommended to the FCC OET that they publicize actions against >> offenders who they locate. This would help get the message out that this is a >> serious problem and that enforcement is in fact taking place. > Is that covered at http://fcc.gov/eb/Orders/Welcome.html or > http://fcc.gov/eb/FieldNotices/ ? I don't know how or if the FCC has acted on our recommendations but I'll ask them for more information when we meet with them this Friday. >>> I'd rather see the TDWR band notched out than any kind of required GPS >>> and database... >> Notching may be the ultimate outcome for all new equipment. The disadvantage >> is >> that notching deprives everyone from using the spectrum, even the 90% of >> operators who are nowhere near a TDWR system. > Very true. > >>> What is going on with the 3.65 stuff? I still think we need some kind >>> of license enforcement there... > Why? That was not my comment - best to ask Blair about that. >> WISPA recently had it's first 3650 Steering Committee meeting and it was >> agreed >> that major work (education, best practices, possible rules changes, etc.) is >> needed because the interference situation is getting way out of hand. > Hmmm. Interesting. That's news to me. Well, that's what one very large and responsible operator reported. > Where does one see info about the > violations? As I stated above, I don't know where the current info is published but I will ask the FCC. > Is it happening on private lists or something? Some is on the private "Phoenix" email list. I think I've also seen interference posts on WISPA's lists but I don't recall the details. You can always just ask if anyone is experiencing 365 interference and see what responses people give. > I don't > recall any complaints on the WISPA general list about it. > > There are >> also more and more illegal (unlicensed) "bootleggers" using the band. One >> solution (among many) is to use a regional email list to coordinate between >> different operators. This is in use now in Phoenix. > H. Well illegal/unlicensed use is a clear enforcement action and > should be referred to the FCC EB. We can't expect much enforcement action from the FCC on 3.65. 1) They have a very limited enforcement budget that is reserved for interference that is caused to (fully) licensed services, 2) They expect us to police ourselves, not turn to them. > Coordination among entities... as I > recall that was very vague in the R&O. Yes it is vague although we supported a filing by the Fixed Wireless Communications Coalition last year to make it less vague. Because it is vague, it's really up to us, not the FCC. If we don't demonstrate that we can make 3.65 litely-licensed spectrum work then we should not hold out of getting any more in the future. > > - -- > 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/ > > iQIcBAEBAgAGBQJNUgaFAAoJEMvvG/TyLEAteVwP/iZ/0b6im8NQhJXXIJxR+0V9 > 3vhg+UegyqimJJkMPnwKBdSrW/i2FBVDc1LHftkn1aEOjj5GamoeiAnV6umG3VbF > r23XC5vvUCr3drosgprLr3FHXi2wQE+D+ToYCB+YdU3bklvHD/AJ4hTZKfM6ZDJK > Vo4cNflKC28o+D9qlwvjheFflhkxf1dBl7eAJe+wvxtHXqgE/tfOig+20wRXBQea > ruyD40BWNLPOCqcjafHCto3zzgTMX03hqwKqT8a+bvdqOrAoAHsZUIv7RFhOY6Xv > oVMJZMDgzrZUUCq+LHBgZZ33+Xr94uABqKz+1JMjwdCPUNe8POBOU7st6RkHPjkj > l+J55/xlV7KMq3eS+pvGEVFY7Vt26oPo1AHhIvdutkrkYVtWmAvcmPQAReTmUfZQ > QsdGv/U/mqms2Kd0ujSaGFvQk8kwC5Nl5Hi7nnObc5nbRao53z/KiB4PGycfIiw9 > N5IcL8Cay+nl+OqYYX4VdIU2laWFQh7Vst5ZH+MXk3wXvGFb0TIKexLimAdXO66Z > 3kHWXYZhEUAQ+QQQ6mJLKWAly1tlmyL3FqLrUQKNpISEWpysqOuxxpBw8jlwrdaj > Xq9F36fRZvj8CqyImQdPQaFQq5NKdANMHTXS5b3G8cBNF1/NJQUJb/8ecwuK2iw6 > FtnI80BWXzQwIe/bfPci > =3Dzr > -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/ > > -- Jack Unger - President, Ask-Wi.Com, Inc. Author (2003) - "Deploying License-Free Wireless Wide-Area Networks" Serving the WISP, Networking and Telecom Communities since 1993 www.ask-wi.com 818-227-4220 jun...@ask-wi.com --
Re: [WISPA] [WISPA Members] Your input on 5 GHz rules changes needed
-BEGIN PGP SIGNED MESSAGE- Hash: SHA1 On 02/08/2011 02:23 PM, Jack Unger wrote: > Comments inline. > > jack > > > On 2/8/2011 2:09 PM, Blair Davis wrote: >> >> Some serious enforcement is in order. Major fines for repeated >> offense... $100K or more for 2nd offense... > Last month we recommended to the FCC OET that they publicize actions against > offenders who they locate. This would help get the message out that this is a > serious problem and that enforcement is in fact taking place. Is that covered at http://fcc.gov/eb/Orders/Welcome.html or http://fcc.gov/eb/FieldNotices/ ? >> I'd rather see the TDWR band notched out than any kind of required GPS >> and database... > Notching may be the ultimate outcome for all new equipment. The disadvantage > is > that notching deprives everyone from using the spectrum, even the 90% of > operators who are nowhere near a TDWR system. Very true. >> What is going on with the 3.65 stuff? I still think we need some kind >> of license enforcement there... Why? > WISPA recently had it's first 3650 Steering Committee meeting and it was > agreed > that major work (education, best practices, possible rules changes, etc.) is > needed because the interference situation is getting way out of hand. Hmmm. Interesting. That's news to me. Where does one see info about the violations? Is it happening on private lists or something? I don't recall any complaints on the WISPA general list about it. There are > also more and more illegal (unlicensed) "bootleggers" using the band. One > solution (among many) is to use a regional email list to coordinate between > different operators. This is in use now in Phoenix. H. Well illegal/unlicensed use is a clear enforcement action and should be referred to the FCC EB. Coordination among entities... as I recall that was very vague in the R&O. - -- 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/ iQIcBAEBAgAGBQJNUgaFAAoJEMvvG/TyLEAteVwP/iZ/0b6im8NQhJXXIJxR+0V9 3vhg+UegyqimJJkMPnwKBdSrW/i2FBVDc1LHftkn1aEOjj5GamoeiAnV6umG3VbF r23XC5vvUCr3drosgprLr3FHXi2wQE+D+ToYCB+YdU3bklvHD/AJ4hTZKfM6ZDJK Vo4cNflKC28o+D9qlwvjheFflhkxf1dBl7eAJe+wvxtHXqgE/tfOig+20wRXBQea ruyD40BWNLPOCqcjafHCto3zzgTMX03hqwKqT8a+bvdqOrAoAHsZUIv7RFhOY6Xv oVMJZMDgzrZUUCq+LHBgZZ33+Xr94uABqKz+1JMjwdCPUNe8POBOU7st6RkHPjkj l+J55/xlV7KMq3eS+pvGEVFY7Vt26oPo1AHhIvdutkrkYVtWmAvcmPQAReTmUfZQ QsdGv/U/mqms2Kd0ujSaGFvQk8kwC5Nl5Hi7nnObc5nbRao53z/KiB4PGycfIiw9 N5IcL8Cay+nl+OqYYX4VdIU2laWFQh7Vst5ZH+MXk3wXvGFb0TIKexLimAdXO66Z 3kHWXYZhEUAQ+QQQ6mJLKWAly1tlmyL3FqLrUQKNpISEWpysqOuxxpBw8jlwrdaj Xq9F36fRZvj8CqyImQdPQaFQq5NKdANMHTXS5b3G8cBNF1/NJQUJb/8ecwuK2iw6 FtnI80BWXzQwIe/bfPci =3Dzr -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] [WISPA Members] Your input on 5 GHz rules changes needed
Comments inline. jack On 2/8/2011 2:09 PM, Blair Davis wrote: > Copied to both lists to stimulate comments on this... > > done. > > Some serious enforcement is in order. Major fines for repeated > offense... $100K or more for 2nd offense... Last month we recommended to the FCC OET that they publicize actions against offenders who they locate. This would help get the message out that this is a serious problem and that enforcement is in fact taking place. > I'd rather see the TDWR band notched out than any kind of required GPS > and database... Notching may be the ultimate outcome for all new equipment. The disadvantage is that notching deprives everyone from using the spectrum, even the 90% of operators who are nowhere near a TDWR system. > Maybe then we can get the rest of the band back to non-DFS rules. And > they can stop lumping 5180-5320 into these rules as well. It's unlikely DFS will ever go away because there are military radars throughout the 5250 - 5600 range and DFS will always be needed to avoid interfering with them. > And since we are talking about new rules... > > What is going on with the 3.65 stuff? I still think we need some kind > of license enforcement there... WISPA recently had it's first 3650 Steering Committee meeting and it was agreed that major work (education, best practices, possible rules changes, etc.) is needed because the interference situation is getting way out of hand. There are also more and more illegal (unlicensed) "bootleggers" using the band. One solution (among many) is to use a regional email list to coordinate between different operators. This is in use now in Phoenix. jack > On 2/8/2011 4:47 PM, Jack Unger wrote: >> In spite of the noteworthy efforts on the part of many WISP operators and in >> spite of a temporary decrease in the levels of TDWR interference reported to >> us >> by the FCC, the TDWR interference situation has unfortunately deteriorated. >> The >> FCC now reports that some locations (New York, Chicago, Denver and Dallas) >> that >> were recently “cleared” of interference are once again experiencing >> significant >> interference problems. The TDWR interference in San Juan Puerto Rico is so >> bad >> that the TDWR system had to be shut off by the FAA. This is not good news >> because the FAA is pushing the FCC to solve these interference problems once >> and >> for all. >> >> Voluntary database registration has unfortunately not proven to be effective >> enough. There are still some operators who apparently have not heard about >> the >> TDWR interference problem and some who have simply failed to bring and keep >> their systems in compliance. On the supply-chain side, there are several >> manufacturers and distributors who did take positive, affirmative and >> responsible action to help address the problem however they were they in the >> minority. Most manufacturers and distributors did not “step up to the plate” >> with customer education or software upgrades. Because airline safety is a >> very >> important issue, it only takes a few “bad actors” to cause significant >> problems >> for everyone else. >> >> The FCC is under strong pressure to take steps to solve the interference >> problem >> for good. The FCC Office of Engineering and Technology has started drafting a >> Notice of Proposed Rulemaking (NPRM). We don’t know yet what new rules the >> FCC >> will propose. They could require that the 5570 to 5680 frequency range be >> “notched out” for all new equipment. This would mean that we would lose the >> use >> of 110 MHz of spectrum. Another possibility is that TDWR database >> registration >> will be required of all WISPs instead the current voluntary registration for >> WISPs located near TDWRs. A third possibility is that all new equipment might >> have to automatically log into a geo-location database (similar to the TV >> White >> Space database) and receive a list of allowable frequencies. Nearby TDWR >> frequencies and a guard band around the TDWR frequency range would be >> prohibited. >> >> The FCC OET has agreed to meet with us to listen to and discuss our >> suggestions >> about ways to address the problem and what new rules should be proposed in >> the >> NPRM. I’ve prepared a short online survey for WISPA Members to see what new >> rules they prefer and what suggestions they have. Please take a few minutes >> today to review this survey and give me your feedback before I publish this >> survey to our Members. I expect that there will be a variety of opinions and >> possibly additional solutions. WISPA’s policy will be guided by whatever the >> majority of WISPA Members say they want. >> >> Here’s the link to the survey< http://www.surveymonkey.com/s/HPCC7BL> >> >> Most of us do not want new rules and regulations however the bottom line is >> that >> we need to save this spectrum. 110 MHz of 5 GHz spectrum is too valuable to >> just >> give up. We have to fight too hard to acquire spectru
