4. the proposals are evaluated on their benefit to the public
These are the two flawed areas. Who is qualified to make the decission? The
proposals that best show they will benefit the public, will most likely be
the same ones that are selling a vapor solution that will never work. The
realistic providers that are honest about what the technology or for that
matter the business model will deliver are the ones that will lose. The
bigger promisers not deliverers will win.
5. parties are also evaluated on their ability to implement
Once again, support for large single monopoly, apposed to support of
competition of the many small players.
The ones that are best financially capable to implement are not the ones
that are best morally to deliver the targeted result.
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message -----
From: "Patrick Leary" <[EMAIL PROTECTED]>
To: "'WISPA General List'" <wireless@wispa.org>
Sent: Saturday, May 27, 2006 11:45 AM
Subject: RE: [WISPA] Middle Class Spectrum Policy was:3650 equipment
I favor substantial use rules and also agree in rejecting squatters rights.
A method of issuing licenses I like is the following:
1. licenses are broken up into regional and local.
2. the government sets the price in advance
3. competing parties submit proposals
4. the proposals are evaluated on their benefit to the public
5. parties are also evaluated on their ability to implement
6. a proposal is picked, a license awarded, a timeframe set
7. parties failing in the timeframe requirement lose their license
That is a good model in some cases. I also think that auctions have their
place, but have to be carefully managed and evidence of collusion needs to
be punished massively. I also think unlicensed has its place, and I am all
for a registration requirement (not a license, but a registration of
active
base stations for ALL commercial UL operators), which is something I
conceived of and proposed to the Spectrum Policy Task Force back in 2002.
With all do respect John, I do not buy the "power to the people" argument.
And I don't buy that all WISPs are pure and good and have the public
interest at heart. Most WISPs deploy to fill their capacity, they do not
deploy to address equity issues or to make sure that anyone in the cell
that
wants access gets it. Most WISPs are just as much capitalists pigs as the
big guys, only on a smaller scale. And that is fine, but let's not pretend
there is some sort of special nobility just by virtue of being a WISP.
I've
seen my share of folks that I consider noble, but it does not make their
business noble. And I've seen more than my share of opportunist scumbags
praying on customers, abusing rules, etc.
Nothing prevents anyone from creating a business plan that can attract
capital and investment and the government is under no obligation to offer
commercial rights to those that cannot. Many WISPs started very humbly and
succeeded brick by brick and now have multi-million dollar businesses.
If a BWA-dedicated UL is finally created, you should realize that anyone
can
use it, even those companies you revile. There are no "rights" for use by
WISPs only.
Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
-----Original Message-----
From: John Scrivner [mailto:[EMAIL PROTECTED]
Sent: Saturday, May 27, 2006 7:48 AM
To: WISPA General List
Subject: [WISPA] Middle Class Spectrum Policy was:3650 equipment
It would be amazing if one time our government could get spectrum policy
right. Up until now they have not got it right even once regarding
access to spectrum in my opinion. Unlicensed is closer to right than
licensed because it at least allows other entrants into the space other
than just the ultra-rich. It gives back some of the power to the people.
Unlicensed is wrong because it has no possibility of protections at all
for those who use this to build their business. That completely stinks..
License auctions create a "land grab" mentality with little to no
thought given to how people will be served in the long run. We have seen
this fail time and time again.
The right way is for us to finally have a band dedicated to broadband
use with some right to run a little power...please!... for God's
sake!...give us some power one time! It would start as unlicensed with
registration required. As the band could be proven to be substantially
used (serving real customers with actual services) by an operator then
licenses would be issued. A license would be for only one base station
though. If an operator shows he has customers served on a base station
then he can apply for a license. No more blanket region licenses. The
substantial use provision means nobody gets squatters rights. You either
prove you are using the band to serve actual customers on a base station
or you run unlicensed until you can prove substantial use.
Then the incentive is for operators to build out a network and serve
customers as quickly as possible to attain licenses as opposed to buying
large regions and squatting on licenses leaving them unused for years or
even decades as we see now. If they price it too high then people do not
buy service from the operator and the operator cannot get the protection
of a license. Note the operator has the right to serve immediately as an
unlicensed operator and has an incentive to serve customers as quickly
as possible to gain license protections.
I think that the licenses should be contingent upon public good for
perpetuity. If public good is lost in the future (by an operator who
over-prices or sells to a mega-corp who does not care) then the license
could become open again if people request this. Charge too much, lose
your license. Sell to megasuck.net, lose your license. Provide crap
service, lose your license. Note that this does not mean you cannot
operate there if you lose your license. It just means you lose your
exclusive license and right to impose interference protection. It means
competition can move in on you and work toward gaining the license if
you do not do your job. This puts the power right where it should be, in
the hands of the people.
In a 50 MHz band (like 3650) with 10 MHz channels imposed you could
conceivably have up to 5 licenses available for 5 base station in any
one location. If you are an operator who is building good business
relationships you might get all 5 licenses in an area. Maybe not. Maybe
you get 2 or 3 and someone else gets some. The point is that you have
SOME rights if you do a good job and do not screw the customer.
It is time to stop the lack of rights for those building networks on
unlicensed bands and stop the squatting on licenses for those with the
fattest wallets. It is time for the people to be in control of their
spectrum assets. The public good provisions do that. Why should one
federal agency get to tell all the people what they can and cannot do
with one of our country's most valuable assets?
I have a name for this new way of looking at spectrum policy.. I call
this "Middle Class Spectrum Policy" and I would really like to see us
all start moving toward this as a group strategy in the future. If we
attain some control of spectrum under these terms I am reasonably
certain all future spectrum policy would reflect at least the spirit of
the policy as outlined above. Do we want to continue to allow policy to
happen around us or do we want to start building policy that is forward
thinking enough to empower us all?
John Scrivner
PS. If you are reading this and you have not paid your WISPA dues then
go to http://signup.wispa.org/ right now and stop letting others pay to
take care of you in D.C. We need your support!
Matt Liotta wrote:
Splitting up the band will just make it useless and interference free.
-Matt
Patrick Leary wrote:
You make the mistake of assuming that I am talking about an
unlicensed 3.65
product Charles. We would not likely build a UL version of all that.
I am in
complete agreement with you on 3.650 in terms of the end reality and
utility
of the band in a licensed versus unlicensed allocation. That is why I
support essentially splitting the band.
Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
-----Original Message-----
From: Charles Wu [mailto:[EMAIL PROTECTED] Sent: Friday, May 26, 2006
10:46 AM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment
Hi Patrick,
But all the "fancy schmancy" technology you implement won't do @#$@
unless
3650 is licensed b/c interference from 20 other systems in the area
(including several from our GPS-synced FM-based FSK friends) eats you
for
breakfast, lunch & dinner =(
-Charles
-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Patrick Leary
Sent: Thursday, May 25, 2006 4:41 PM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment
A. More power Tom. B. Much more sophistication in the equipment yielding
much higher spectral efficiency and system gain.
Frequency plays a major role, but you need to understand that other
factors
are of almost similar levels of importance. For example, our 802.16e
version
of WiMAX uses SOFDMA with beam forming and 4th order diversity at the
base
station and MIMO with 6 antennae embedded in the self-install CPE
with a SIM
card. Couple that with higher power available in a licensed
allocation and
you get zero truck roll self-install CPE with no external antenna.
Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
-----Original Message-----
From: Tom DeReggi [mailto:[EMAIL PROTECTED] Sent: Thursday,
May 25, 2006 9:23 AM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment
3.5Ghz does,
I find that hard to believe. 2.4Ghz couldn't do it, which is why we
rely on
900Mhz.
What makes 3.5Ghz appropriate for the task?
With 3650 from what I understood, is only supposed to be allowed for
PtP or mobile service only (not indoor) based on the high power
levels allowed.
Not sure whats at the other 3.5G ranges in US.
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message ----- From: "jeffrey thomas"
<[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Thursday, May 25, 2006 4:02 AM
Subject: Re: [WISPA] 3650 equipment
The benchmark is the ability to provide NLOS, portable or fixed
service to at least a 2 mile radius per cell, indoors.
5.8 doesnt really give true NLOS to that distance indoors
5.4 doesnt really give true NLOS to that distance indoors
4.9 doesnt really give true NLOS to that disance indoors
3.5Ghz does, to "portable" devices similar to the equipment used by
clearwire. Airspan for example claims their wimax solution works
indoors to about 3 miles out, which is pretty good IMHO.
When you can deliver a zero truck roll model with 90% or above
availablity, is when operators by the truckload will deploy
equipment. At that point, you will see deployments in the thousands,
like the ones in mexico of 750,000 homes serviced.
-
Jeff
On Thu, 25 May 2006 02:20:23 -0400, "Tom DeReggi"
<[EMAIL PROTECTED]> said:
How do you figure?
You don't think 5.4 is going to solve part of that?
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message -----
From: "Jeffrey Thomas" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Wednesday, May 24, 2006 10:55 PM
Subject: Re: [WISPA] 3650 equipment
Frankly,
The FCC should really hurry up and finish the rules to allow the
industry
to
really take off. The common view with most manufacturers I have
found is
that until there is 3.5ghz or near spectrum available, there will
be small
and limited deployments of wisp size and not many large scale
deployments
outside of 2.5ghz or 700 mhz operators.
-
Jeff
On 5/24/06 6:14 AM, "Charles Wu" <[EMAIL PROTECTED]> wrote:
All the same time, the industry doesn't bother to fill out their
Form 477s also
The sad thing is is that there are long term consequences towards
"flaunting the rules" -- namely the fact that you are just
reinforcing the ILEC argument that unlicensed spectrum just
creates a bunch of "cowboys" that
can't be taken seriously
Heck, even Marlon knows better than to wear his skin-tight pink
flamingo
suit when he represents the industry in DC
-Charles
-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
On
Behalf Of jeffrey thomas
Sent: Tuesday, May 23, 2006 11:37 PM
To: WISPA General List
Subject: RE: [WISPA] 3650 equipment
In the larger scale of things- when you compare this to a carrier
deployment which would deliver thousands of CPE's service, this
is a test. I know
of
one company that has recieved 28 STA's for 14 markets, for over 2000
CPE.
-
Jeff
On Tue, 23 May 2006 21:33:33 -0400, "Gino A. Villarini"
<[EMAIL PROTECTED]>
said:
Do you really think towerstream need 150 field units or cpes to
"test"
a single base station?
Gino A. Villarini
[EMAIL PROTECTED]
Aeronet Wireless Broadband Corp.
tel 787.273.4143 fax 787.273.4145
-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]
On Behalf Of Jack Unger
Sent: Tuesday, May 23, 2006 9:07 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment
Gino,
Is Towerstream doing this - using 3650 to deliver commercial
service?
jack
Gino A. Villarini wrote:
Towerstream anyone ?
Gino A. Villarini
[EMAIL PROTECTED]
Aeronet Wireless Broadband Corp.
tel 787.273.4143 fax 787.273.4145
-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]
On Behalf Of Jack Unger
Sent: Tuesday, May 23, 2006 6:56 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment
Jeffrey,
I have to question the "judgement ability" (or the lack of it)
of anyone who abuses the FCC rules to the extent of taking a
licensed "experimental" system and using it for a commercial,
revenue-generating
purpose. Someone who would do this is (IMHO):
1. Someone with no business sense
2. Someone with no appreciation of (or experience with) the
enforcement powers of the FCC
3. Someone who will likely turn out to be their own worst enemy
4. NOT someone who I could rely upon to provide me reliable,
long-term
WISP service.
jack
jeffrey thomas wrote:
Patrick,
It doesnt change the fact that many have launched "limited"
deployments as a "test" but still charged for the access
service, banking on the fact that the FCC has set the band
aside for unlicensed anyways, and that the chance of the FCC
cracking down on them is very low.
Im not saying this is right, but reality is such that they
will be evenutally amending the rules and the gear according
to my sources that is available today will be compliant. *shrug*
-
Jeff
On Tue, 23 May 2006 12:37:11 -0700, "Patrick Leary"
<[EMAIL PROTECTED]> said:
Exactly, it clearly shows that an operator today CANNOT
launch any commercial services using 3650MHz.
- Patrick
-----Original Message-----
From: Charles Wu [mailto:[EMAIL PROTECTED]
Sent: Tuesday, May 23, 2006 8:40 AM
To: 'WISPA General List'
Subject: RE: [WISPA] 3650 equipment
Read below and you can decide on whether or not you will be
"breaking the law" w/ a 3650 deployment
---------------------------
To: "'WISPA General List'" <wireless@wispa.org>
Cc: <isp-wireless@isp-wireless.com>;
<[EMAIL PROTECTED]>
Sent: Wednesday, February 08, 2006 6:32 AM
Subject: [equipment-l] Experimental Licensing in the 3650 MHz
Band -
Clarifications
Recently, there have been some misleading advertisements
promising turn-key 3.65 GHz licensing services as a means of
avoiding interference in congested license-exempt ISM/UNII
bands. Although the FCC issued adopted rules
back
in March 2005 to open access to new spectrum for wireless
broadband
in
the
3.65 GHz band, a "minor" contention-based requirement has
delayed the
deployment of wireless broadband services in this band as
equipment
manufacturers currently work behind the scenes to iron out the
details.
As
things currently stand, deploying a 3.65 GHz system today falls
under
Subpart 5: Experimental Radio Service of the FCC Rules.
Infrastructure Investment & Experimentation under Part 5
needs to be done strictly from a "curiosity" perspective
rather than one of "commercial network expansion." Part 5
permits experimentation in scientific or technical operations
directly related to the use of radio waves. The rules provide
the opportunity to experiment with new techniques or new
services prior to submitting proposals to the FCC to change
its rules.
Some useful excerpts regarding Experimental Licensing
47CFR5.3: Scope of Service
Stations operating in the Experimental Radio Service will be
permitted to conduct the following type of operations:
(a) Experimentations in scientific or technical radio
research
(b) Experimentations under contractual agreement with the
United
States
Government, or for export purposes.
(c) Communications essential to a research project.
(d) Technical demonstrations of equipment or techniques.
(e) Field strength surveys by persons not eligible for
authorization
in
any other service.
(f) Demonstration of equipment to prospective purchasers by
persons
engaged in the business of selling radio equipment.
(g) Testing of equipment in connection with production or
regulatory
approval of such equipment.
(h) Development of radio technique, equipment or
engineering data
not
related to an existing or proposed service, including field
or factory testing or calibration of equipment.
(i) Development of radio technique, equipment,
operational data
or
engineering data related to an existing or proposed radio
service.
(j) Limited market studies.
(k) Types of experiments that are not specifically covered
under
paragraphs (a) through (j) of this section will be considered
upon demonstration of need
47CFR5.51: Eligibility of License
(a) Authorizations for stations in the Experimental Radio
Service
will
be
issued only to persons qualified to conduct experimentation
utilizing radio waves for scientific or technical operation
data directly related to a use of radio not provided by
existing rules; or for communications in connection
with research projects when existing communications
facilities are
inadequate.
47CFR5.63: Supplementary Statements
(a) Each applicant for an authorization in the
Experimental Radio
Service
must enclose with the application a narrative statement
describing in detail the program of research and
experimentation proposed, the specific objectives sought to
be accomplished; and how the program of experimentation
has a reasonable promise of contribution to the development,
extension,
or
expansion, or utilization of the radio art, or is along lines
not
already
investigated.
For further information regarding experimental licensing, the
FCC has a nice online FAQ that gives a step-by-step how-to on
experimental licensing: http://www.fcc.gov/oet/faqs/elbfaqs.html
-------------------------------------------
CWLab
Technology Architects
http://www.cwlab.com
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