It's quite unfortunate IMO but I've concluded that this is a typically American problem. In America the courts broke up the Bell system thinking that it'd be better for the average American to have local phone companies competing with each other. Only here in America does the FCC license any technology the carriers wishes to deploy, resulting in them competing with each other (whatever technology cellphone you carry, there are more towers of different technology that any given cellphone can't access compared to those it). Europe learned almost 2 decades ago that to compete with the United States they needed to mandate compatible technologies that would insure interoperable services to users (things like GSM).

For the benefit of all, I wish the FCC would open any/all new bands (3.6, 5.4 thru 5.7, etc) mandating a compatible technical solution, or at minimum one that required all equipment to play nice.

Nobody wants to through away the investment that they have made already, and as that investment increases, it gets harder.

Right. Too much of a hardship to change rules in bands once deployed. But all new bands should require compatability rules. I just don't see our FCC seeing things this way. There are too many that believe a free-for-all in the market serves the public best. I don't agree.

Rich

----- Original Message ----- From: "Tom DeReggi" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Friday, April 21, 2006 6:05 PM
Subject: Re: [WISPA] UL WiMAX update


Steve,

In theory, I fully agree with your view.

The problem is that theory does not always play out in the real world. 5 years later, I still have 10 mbps gear, and very few places that can risk using faster gear. (although we are finding ways, such as getting higher power with PtP to use faster gear reliably, of course we are also wasting spectrum because channels used up with only some of the bandwdith being used, not being able to average its use over PtMP.)

The problem is that the longer the FCC waits to impose better rules, the harder it gets for the industry to accept the rules. Nobody wants to through away the investment that they have made already, and as that investment increases, it gets harder.

The problem with the rules as they are now, true Darwinism, is that it forces WISPs to be in competition with WISPs, instead of WISPs bandwdith togeather to be in competitions with other industry segments like Telcos and Cable companies. And the inner struggle forces WISPS to be less competitive as an industry in the end. This can not be a good thing for an industry, allthough it may be most ethical for evolutionists.

Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband


----- Original Message ----- From: "Steve Stroh" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Thursday, April 20, 2006 1:04 PM
Subject: RE: [WISPA] UL WiMAX update



Patrick:

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
bought.

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
licenses.

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
possible.


Thanks,

Steve


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] - www.stevestroh.com


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