Re: [WISPA] Whitespaces filing
Whitespaces devices should not need to rely on circles on a map as these never quite reflect the reality of coverage. Hills, buildings, noise levels etc. never show up. I know, we use that method for some of our marketing. It's a good estimate, but signal checks are still the only really effective mechanism for finding coverage zones. The TV contours we are talking about protecting are not just simple circles on a map. They are based on the FCC criteria (for which I can not quote off the top of my head, but it is published) that the broadcasters must submit which then defines that particular TV station contour. I have attached a map image for the state of Washington showing all the combined analog and digital TV contours for ALL channels on file with the FCC. Many of them overlap and some look like circles because if you do an RF propagation at some of these sites using 50,000 watts you will get pretty close to a circle result. These contours are part of the criteria we are proposing to use in the goelocation database. Those contours are already defined by the FCC and we are obligated to protect those licensed users for that particular area. It's not a random choice and it's certainly not just a circle drawn on a map. This comes from years of already established RF engineering principles and rules. Some of those defined by the International Telecommunications Union (ITU) and thus by treaty, the FCC and US government are obligated to obey. You can further drill down on this type of data by channel. I also attached images showing only the UHF contours and one for only channels 31 and 32. Keep in mind these images include the current analog stations. Once they go off the air this picture will change a great deal. The maps are just meant to illustrate that this is a much more complex process than just drawing circles on a map. This also should help illustrate exactly what the white space spectrum potential can be nationwide when looked at channel by channel. H. Interesting. From the looks of that map I should have several channels that will work well over the air. We're within what looks like coverage of at least 4 channels. Problem is, we don't get USABLE signal for more than one. You bring up a good point and I'm glad to learn this. I'll try to figure out some new phrasology. But my point isn't changed by it. *I* still have no TV coverage to speak of here so why not use the spectrum for broadband? The new devices should be held to a high standard for OOB emissions. I think there should be two different standards. In one standard the devices aren't allowed to use the adjacent channels. But if a device is able to limit it's OOB emissions sufficiently to protect the broadcasters the adjacent channels should be allowed to be used. It's also time to start implementing some of the Spectrum Policy Task Force's (SPTF) suggestions for improving the way spectrum is used. TV broadcasting has remained basically static for what, 50+ years now? Same channel sizes, same power output etc. With the change to DTV the commission should follow it's own advice and implement receiver standards instead of only transmitter standards. Whitespaces devices AND TV sets/converters should both be held to a minimum OOB rejection level of some kind. I don't know what the receive sensitivity is on the average TV set but based on performance in my local area it's not very good these days. I think I've run into less than 5 homes using over the air TV in the last 2 or 3 years. When it became possible to get local channels via sat. signals everyone moved to the better picture mechanisms that come with non broadcast services. I don't know if you have tried off the air digital TV yet but you should. First of all the current stations are running a fraction of their concurrent analog station power levels. This is to protect adjacent market analog stations on the same channels. Once February comes around they will be turning those DTV stations up to maximum power. I have used a few devices with ATSC digital tuners in them and I can tell you there is one hell of a difference in DTV over analog. It looks just like satellite quality when it works and if you compare it to the same analog broadcast, I have seen some stations look perfect in DTV where I could hardly make out the picture in analog mode. Another thing the DTV broadcasters have the option of doing is to multiplex up more than one programming channel on their broadcast in digital. I have seen many stations run three or four separate channels on their DTV carrier. That up to a 4 fold increase in spectrum efficiency. You may want to reconsider your point on that subject. I've heard that. But out here, there are NO DTV channels currently available. And we're not likely to cancel our satellite service now anyway. But those are issues that the FCC is paid to deal with.
Re: [WISPA] Whitespaces filing
On the multiple TV channels on the same RF channel... I believe in that case, it's 1x HD or multiple SD. In the age of HD, you still only get 1 channel. -- Mike Hammett Intelligent Computing Solutions http://www.ics-il.com -- From: Brian Webster [EMAIL PROTECTED] Sent: Saturday, October 25, 2008 11:52 PM To: WISPA General List wireless@wispa.org Subject: Re: [WISPA] Whitespaces filing Marlon, This is probably one of your best filings to date. Nicely done and well written. I have a few comments and/or suggestions in line. Thank You, Brian Webster www.wirelessmapping.com http://www.wirelessmapping.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Behalf Of Marlon K. Schafer Sent: Saturday, October 25, 2008 1:53 PM To: WISPA General List Subject: [WISPA] Whitespaces filing Hi All, Here is my first draft of an FCC filing on the 04-186 white spaces issue. To file your own comments go here: http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi Enter 04-186 into the blue box. Follow the instructions. The main location for filing docs is: http://www.fcc.gov/cgb/ecfs/ You can search for existing filings there. I'd love to have people's input on this filing. Any and all comments are desired, pro or con. I'll try to file this late on Monday. Dear Ms. Dortch, 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 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. I also agree 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 in meaningful distances. In open ground long distances are needed (30 to 40 mile cell sizes should be an option). In my area we have rolling hills, tree lines as windbreaks and line of site in the 50 to 60 mile ranges. 30 to 40 mile line
Re: [WISPA] Whitespaces filing
today, yeah. But give it a couple of years. marlon - Original Message - From: Mike Hammett [EMAIL PROTECTED] To: [EMAIL PROTECTED]; WISPA General List wireless@wispa.org Sent: Sunday, October 26, 2008 10:09 AM Subject: Re: [WISPA] Whitespaces filing On the multiple TV channels on the same RF channel... I believe in that case, it's 1x HD or multiple SD. In the age of HD, you still only get 1 channel. -- Mike Hammett Intelligent Computing Solutions http://www.ics-il.com -- From: Brian Webster [EMAIL PROTECTED] Sent: Saturday, October 25, 2008 11:52 PM To: WISPA General List wireless@wispa.org Subject: Re: [WISPA] Whitespaces filing Marlon, This is probably one of your best filings to date. Nicely done and well written. I have a few comments and/or suggestions in line. Thank You, Brian Webster www.wirelessmapping.com http://www.wirelessmapping.com -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Behalf Of Marlon K. Schafer Sent: Saturday, October 25, 2008 1:53 PM To: WISPA General List Subject: [WISPA] Whitespaces filing Hi All, Here is my first draft of an FCC filing on the 04-186 white spaces issue. To file your own comments go here: http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi Enter 04-186 into the blue box. Follow the instructions. The main location for filing docs is: http://www.fcc.gov/cgb/ecfs/ You can search for existing filings there. I'd love to have people's input on this filing. Any and all comments are desired, pro or con. I'll try to file this late on Monday. Dear Ms. Dortch, 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 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. I also agree that much higher power levels are needed today in much of the country. If there are trees in the area it takes
Re: [WISPA] Whitespaces filing
Marlon K. Schafer wrote: These data points would include geographic coordinates, antenna beam width, transmitter power, antenna height, antenna polarization and antenna azimuth, which in turn could be used to calculate D/U (desired/undesired) protection ratios, geographic separation or any other defined measure of interference protection, as determined in this proceeding. After the data entry process, ULS would notify the registrant whether the proposed facilities are predicted to cause interference. If no interference to a primary licensee or a previously registered base station is predicted, the facilities could be placed in operation and, as described below, the Commission's database would be updated to show the new base station. If interference to a primary licensee is predicted, the registration would be rejected and the registrant could then propose alternative facilities. Although previously registered base stations would not be protected from interference from subsequent base stations, if interference to a previously registered base station is predicted, the prospective registrant could then propose alternative facilities so that neither party would suffer actual interference. I'm not sure how else to interperate this section Brian. It clearly says that there can be no new stations that will interfere with an existing operator. Primary or registered base station. You missed the following portion of that paragraph: In the unlikely event that no non-interfering base station facilities could be designed through techniques such as location changes, power reductions, antenna polarity changes or channel selection, the registrant and the incumbent registrant would be obligated to negotiate in good faith to coordinate their facilities for a period of 30 days and keep records of their discussions in case the information is needed by the Commission.. The proposal from WISPA basically says: 1) If you ask to use a completely clear channel, the license-light will be granted. .. If no interference to a primary licensee or a previously registered base station is predicted, the facilities could be placed in operation and, as described below, the Commission's database would be updated to show the new base station 2) If you ask to use a channel which would interfere with a TV station, the license-light will be rejected. If interference to a primary licensee is predicted, the registration would be rejected and the registrant could then propose alternative facilities. 3) If you ask to use a channel which would interfere with another license-light user, then the system will notify you that interference is likely and will give you an opportunity to ask for a different channel. If you can't find one, it will let you register anyways, and you and the incumbent will have to work it out. And the incumbent is required to negotiate with you. if interference to a previously registered base station is predicted, the prospective registrant could then propose alternative facilities so that neither party would suffer actual interference. [OR] In the unlikely event that no non-interfering base station facilities could be designed through techniques such as location changes, power reductions, antenna polarity changes or channel selection, the registrant and the incumbent registrant would be obligated to negotiate in good faith to coordinate their facilities for a period of 30 days and keep records of their discussions in case the information is needed by the Commission. -forrest 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] Whitespaces filing
- Original Message - From: Forrest W Christian [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Sunday, October 26, 2008 2:31 PM Subject: Re: [WISPA] Whitespaces filing Marlon K. Schafer wrote: These data points would include geographic coordinates, antenna beam width, transmitter power, antenna height, antenna polarization and antenna azimuth, which in turn could be used to calculate D/U (desired/undesired) protection ratios, geographic separation or any other defined measure of interference protection, as determined in this proceeding. After the data entry process, ULS would notify the registrant whether the proposed facilities are predicted to cause interference. If no interference to a primary licensee or a previously registered base station is predicted, the facilities could be placed in operation and, as described below, the Commission's database would be updated to show the new base station. If interference to a primary licensee is predicted, the registration would be rejected and the registrant could then propose alternative facilities. Although previously registered base stations would not be protected from interference from subsequent base stations, if interference to a previously registered base station is predicted, the prospective registrant could then propose alternative facilities so that neither party would suffer actual interference. I'm not sure how else to interperate this section Brian. It clearly says that there can be no new stations that will interfere with an existing operator. Primary or registered base station. You missed the following portion of that paragraph: In the unlikely event that no non-interfering base station facilities could be designed through techniques such as location changes, power reductions, antenna polarity changes or channel selection, the registrant and the incumbent registrant would be obligated to negotiate in good faith to coordinate their facilities for a period of 30 days and keep records of their discussions in case the information is needed by the Commission.. I didn't miss that. I tossed it out as unhelpful. Location changes? That's not usually going to be an option out here. I'm not going to abandon a current tower site without a fight. And a 30 day delay PLUS however long it takes the commission to issue a ruling to an unlicensed operator? No thanks. There has to be a better way. The proposal from WISPA basically says: 1) If you ask to use a completely clear channel, the license-light will be granted. .. If no interference to a primary licensee or a previously registered base station is predicted, the facilities could be placed in operation and, as described below, the Commission's database would be updated to show the new base station Right. 2) If you ask to use a channel which would interfere with a TV station, the license-light will be rejected. If interference to a primary licensee is predicted, the registration would be rejected and the registrant could then propose alternative facilities. OK. 3) If you ask to use a channel which would interfere with another license-light user, then the system will notify you that interference is likely and will give you an opportunity to ask for a different channel. If you can't find one, it will let you register anyways, and you and the incumbent will have to work it out. And the incumbent is required to negotiate with you. if interference to a previously registered base station is predicted, the prospective registrant could then propose alternative facilities so that neither party would suffer actual interference. [OR] In the unlikely event that no non-interfering base station facilities could be designed through techniques such as location changes, power reductions, antenna polarity changes or channel selection, the registrant and the incumbent registrant would be obligated to negotiate in good faith to coordinate their facilities for a period of 30 days and keep records of their discussions in case the information is needed by the Commission. This whole section is back assward. We should simply say where we want to put in a system and the licensing mechanism should tell us what channels are available. Why should we have to sit there and fiddle with anything hoping that we can land on an open channel? Sorry but as far as I'm concerned this is a very poorly worded and unworkable solution. marlon -forrest 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
