I disagree that the market is (directly) rewarding "survival of the 
nastiest" - it's rewarding systems that are designed to survive in a mixed 
environment. If that behavior is perceived as "nasty" by systems that are 
less robust, oh well.

But there's a tradeoff - systems whose primary feature is survivability 
will eventually fall out of favor because their performance will not be 
acceptable and the users of such systems won't be able to sell services 
based on that lower level of performance.

My "Darwinian Effect of License-exempt Wireless" encompasses not just the
technological evolution of license-exempt systems, but also the economic
evolution of license-exempt systems. It's not enough to be merely "more
survivable" - there's an intense ECONOMIC imperative to be
better-performing, more cost-effective... otherwise the systems won't get

We've seen what happens to systems that are "survivable" but don't evolve 
their performance - two that immediately come to mind are RadioLAN and 
Airdata WIMAN; both were very robust, but didn't offer competitive 
performance over time. Older product lines eventually fall victim to 
newer, higher-performance, more cost-effective product lines... often from 
entirely new vendors.

The beautiful thing about the ISM/UNII rules is that no one can be
EXCLUDED; you're permitted to TRY just about anything that follows the
relatively simple and basic rules. That's what enables the Darwinian
Effect. The risks are WELL known... at least they should be, by anyone
wanting to try to make a business using the ISM/UNII bands. If the risks
aren't to one's liking, well there's always the licensed alternative - 
little technological risk, but huge economic risk from the cost of the 

Understood that the risk/reward of license-exempt spectrum might not be
high enough for the biggest players to make multi-million dollar
investments into license-exempt spectrum. But... the HUGE market means
that smaller players seem to keep being willing to try, and that more than
balances out the seeming lack of investment from the largest players. For
example, though Alvarion deigns to participate in the municipal mesh Wi-Fi
business, that doesn't seem to be hurting that business as that leaves
lots of room for smaller players - Tropos, SkyPilot Networks, BelAir
Networks, etc., all offering ample innovation and good performance in 
providing a service that the conventional wisdom says that wasn't 



On Thu, 20 Apr 2006, Patrick Leary wrote:

> Tom,
> You correctly identify the Achilles Heel of modern day UL -- the survival of
> the nastiest phenomenon. The Part 15.247 rules give equal standing to all
> types of systems, regardless of how spectrally gluttonous or abusive. The
> problem with this is that it rewards downward innovation (i.e. dumb and
> inefficient), offering no incentives for developers to invest R&D to come up
> with more efficient, higher performing PMP techniques. There is no reward
> for high performance, especially in PMP where devices are most vulnerable to
> interference. This is a genuine reason why there is so little real
> investment in PMP UL. I am not talking about the creative, small market
> developing and tinkering that goes on, but rather the multi-millions of
> serious R&D investment such as that seen on the licensed side. 
> As well, the logical extension of this problem is that WISP operators
> themselves are not rewarded in a spectrum sense by using the most efficient
> systems. 
> [I should insert a note here that recognizes that bringing to market a
> system that might be considered spectrally abusive so that it itself
> survives, all while conforming perfectly within the regulations, may be
> considered to be an entirely sound, even smart, competitive strategy -- the
> rules do not require me to play well with others, so I'm going to do
> everything I can to make sure I do not, within the rules of course. However,
> markets are not fond of investing in R&D to get around artificial problems,
> i.e. problems created by easily manipulated regulations.]
> Back in 2002 I was one a few panelists representing the UL BWA market (Steve
> Stroh was there too on another panel) on the FCC's Spectrum Policy Task
> Force. The panel I was on was to recommend and debate the evolution of the
> UL bands. Most were up there thinking WLAN, not WMAN, and they did not even
> understand the implication of their proposals in the outdoor, metro scale
> world of wireless. A few were up there saying we needed more power for
> rural. 
> My input regarded changing the rules to allow for some type of sliding
> higher power rules based on better efficiency, and that efficiency could
> come any number of ways, through better and more narrow, high quality (good
> emitters, without lots of spurious noise) antennas, higher sensitivity and
> intelligence, better capacity per MHz (especially better packet per second
> type efficiency), etc. The better one performed, the higher power allowed. 
> To do this, in my head I was thinking that a base line point of measurement
> would be some type of low performing product connected to an omni. Put that
> same radio on sector, you get more power. Put a more efficient radio on that
> omni, you get more power. Put a really efficient radio on a well-performing
> on a well-performing, narrow beam antenna and gets lots of power. Etc. Etc.
> I am sure smart people can come up some type of algorithm that incorporates
> most of the variables that and make something efficient, while leaving room
> for the formula to advance to accept new techniques that create efficiency.
> Such a rule would give operators incentive to employ the best systems since
> such would require the least number of cells and such. And suppliers would
> be continually encouraged to invest and innovate, because we'd know that the
> market would be encouraged to support new technology for the rewards in
> power and performance to be gained.
> Another great thing about these proposed rules was that they are technology
> neutral (the FCC does not like to specify technology these days). The rules
> simply would have been some type of math formula where the answer was always
> a reference to allowed power output (EIRP).
> I also wanted a registration rule, very similar to what the FCC called out
> for 3650MHz. I wanted it low fee (but enough to provides monies for rules
> enforcement), non-exclusive, and open, with only registration (not
> licensing) of infrastructure nodes and their locations.
> At the time, I really do not think most in the room or at the Commission
> fully grasped what I was getting at. Maybe I did not articulate it well
> enough (though it was all captured on video and remains archived on the FCC
> web site). But, I still think that such rules have the best chance of
> bringing about a positive revolution in UL BWA.
> Regards,
> Patrick


Steve Stroh
425-939-0076 - [EMAIL PROTECTED] -

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