Brad,

Tom, Dang you got this all wrong. Let's make sure we understand what
Alvarion's comments said so everyone understands. Our comment breaking the
band in two was to strip rural and suburban from the top 100 US markets. Top 100 markets split in two 25 Mhz chunks and licensed with the REST of the US
being UL. There is plenty of broadband in those top 100 markets. The FCC's
intent for the 3650 band is suburbs and rural access.

Thanks for correcting that. I forgot that little detail, that makes a BIG difference for MANY WISPs.

However, I do not share Alvarion's view for several reasons.

1) 3650 is meant as a backhaul band first. Most secondary markets still need to get their Internet Transit cost effectively from some where, to be successful. I do not liek it when secondary markets are held hostage by the local telcos and limited number of fiber carriers in their secondary markets. Most WISPs in secondary markets will backhaul in their Internet Transit from the closest major city market, so they can get the best price on their transit. If 3650 was not meant as a backhaul band, I would not have this view. Preventing its unlicenced use in the TOP 100 Markets means, that secondary markets can't use the 3650 rqange for the primary purpose getting cost effective bandwidth from the top 100 markets to the secondary markets.

2) I serve a top 100 market. Helping the rest of the rural world does me no good. In top 100 markets is where unlicensed is showing to be in the most shortage, therefore most needy of new unlicensed spectrum. (This may be a mute point, as some have stated that my region (maryland/DC) is uneligible for 3650 based on proximity to pre-existing land stations. I have not confirmed this.)

3) One of the biggest mistakes being made in legislation and policy today in my opinion is officials are breaking down segments of consumers by rural, suburban, urban. The problem is "Underserved". I argue that there are near as many underserved consumers (in percentile) in Urban America as there are in Rural America. Hole in coverage that DSL/Cable providers will likely NEVER have priority to serve.

4) I also believe that the TOP 100 markets are the most valuable. And giving those markets to the larger players that can afford buying the exclusive license, is giving the larger player an advantage to grow, and liekly help them more easilly move into the secondary markets to kill the secondary market providers eventually. WISPs need to high income of Urban density to subsidize their growth as well as just the rural markets that nobody else wants.

" There are MANY WISPs ready to go and test the 3650 allocation, but it is
the manufacturers that are squashing the viabilty of the band by not having
the balls to make gear to meet the specification."

That's just not correct. What we don't want to do is build a product that
you'll have to rip out and replace because it doesn't meet the future
spec.... when we finally get a ruling on what the product should look and
smell like then most will invest and deliver a product.

Yes but the reason that there is not a "final ruling" and uncertainty is because manufacturers and special interests are protesting the final ruling that had already been made once. Also take note, I am NOT specifically targeting Alvarion on this complaint of mine. I was directing it to all manufacturers in the industry. I guess I can't blaim manufacturers, as it is a lot of money to invest, to build a new product, when there is uncertainty in the spectrum. But then again, that is why I made the cheap shot and added "have the balls to". Its a gutsy move to invest, and be the first to lead the way, in an uncertain market.

"Its not only important to incourage innovation and more efficient use of
technology but also more innovative and efficient Policy.  The attempted
3650 rules were to foster improved policy.  Why would anyone fight that?"

The 3650 is a rural broadband play getting you access to your own spectrum
to serve those customers without having to compete with baby monitors and
wifi gear on every street corner.

Innovation won't take place unless the FCC
takes a stand on technology.

Unfortuneately, that is what we are learning through this experiement. The FCC was trying to leave that up to the manufacturers and innovators. But that part of the science experiment is failing. I agree the FCC is going to have to take their stance.

IMHO what we don't need is a bunch more
inefficient 20 mhz spectrum hogs at sub 10 meg speeds or worse.

That I fully agree with. But I do not think licensing the spectrum or splitting the band will solve that problem.
I am in favor of most suggestions that incourage that.
I am in favor of setting rules that require a certain level of efficiecy in the technology used. Not necessarilly OFDM specifically, but a requirement to have X number of mbps per X mhz of spectrum, equivellent to the higher speed modulations of OFDM.

Alvarion is fighting improved policy is a stretch.

I'll go as far as saying Alvarion has always been one of the LEADING contributors/supporters to incourage improved policy for the industry. If not the definitive #1 supporter. And that I thank and recognize Alvarion for. But on 3650, I did not share Alvarion's views. A lot of time went into 3650, debating what should be offered, before it was offered. Many thought it to be a gift to independant ISPs. To protest the allocation, was indirectly almost a protest against WISPs, and it didn't help to add in "licenced", which was NOT the initial intent for the band. Allthough many WISPs will convert to partially licenced where applicable as they grow, the bulk of WISPs today are not Licensed operators. So giving it to Licensed does not infer benefit to WISPs. 3650 was the first attempt to give better than unlicenced to the WISP industry who deserved to have it, after their stunning success at struggling with junk band spectrum for so long.

Tom, I really think you need to reread our filings or maybe stop listening
to those who may have an axe to grind. Brad

Its very possible that Alvarion's views were made in the intent to cause possitive change for the benefit of all. But I did not get that impression based on my views that I expressed earlier in this post.

Tom DeReggi
RapidDSL & Wireless, Inc

-----Original Message-----
From: Tom DeReggi [mailto:[EMAIL PROTECTED]
Sent: Tuesday, May 30, 2006 9:37 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

In other words, the number of
licenses is infinite.

Yes, but you leave out that there is a requirement to attempt to coexist, or

cooperate to attempt to co-exist.
And it brings out into the open, all possible interferers, where they are
located, and how to contact them.

It will be an interesting science project, to see if registration apposed to

operation in stealth mode (typical unlicened) helps or hinders the ability
for more providers to cooexist.  And quite honestly, I think its an
experiment that has to be had, t oreally see what happens. The outcome could

help shape the viabilty of future spectrum policy.

One thing I definately did NOT agree with, was Alvarion's FCC comments
suggesting breaking the band in two. The band MUST stay for one cause. The
reason is that people need the ability to move and adapt within their
available spectrum range channels. Narrowing channel selection down to the
point where all channels are used to get 360 degrees, is foolish, and just
repeats the limitations of the existing 5.8Ghz band, that has twice the
spectrum range.  I also beleive that basing a business model or rules on 5
Mhz channels, the maximum smallest viable size that would make sense, is
also foolish, as it leaves little room (overhead) for margin.

However, I was in favor of limiting channel width to 10 Mhz, but not any
requirement that required channel size less than 10 mhz.
This level, incourages efficient systems, without excessive limitations. I
also did not care if it stayed contention based or time based, as long as it

all just stayed the same method, all contiguous space for the same purpose.

I also was strongly against Full licensed. As the only thing that benefits
is the huge telecom company, single provider's use models, and exclude
competiton and possible innovators. The whole point in 3650 was to attempt
to find a balance between licensed and unlicenced.

I felt Alvarion's position on this spectrum range's use was very harmful to
Alvarion's reputation.  Its not only important to incourage innovation and
more efficient use of technology but also more innovative and efficient
Policy. The attempted 3650 rules were to foster improved policy. Why would

anyone fight that?

The only flaw with the 3650 allocation, is the stipulation for Contention
based, without a contention based hardware platform available or in
engineering phase designed for the spectrum range. Its was innovative rules

prior to innovative technology, and therefore left unused.

There are MANY WISPs ready to go and test the 3650 allocation, but it is the

manufacturers that are squashing the viabilty of the band by not having the
balls to make gear to meet the specification.

I also do not support the use of more than half the band for a single PtP
link. The reason is that PtP links already are much more capable of using
higher modulations, based on higher power more directional antennas to
escape the noise and improve SNR.  When the whole band is allowed for PTP,
it replicates the same flaw as existing unlicened where a single PTP radio
can be pointed at a cell site, or pass through a cell site, and totally
destroy it without anywhere for the existing provider to temporarilly move
to, until resolved.


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


----- Original Message ----- From: "Patrick Leary" <[EMAIL PROTECTED]>
To: "'WISPA General List'" <wireless@wispa.org>
Sent: Tuesday, May 30, 2006 10:49 AM
Subject: RE: [WISPA] 3650 equipment


Matt,
I am not sure you understand the rules as written in terms of the light
licensing. Whatever goes unlicensed with the light licensing
(registration)
compenent, whether it is the whole 50MHz of band or some portion there of,
there is no exclusivity. That means that any number of people can apply
for
get a license for the exact same location. In other words, the number of
licenses is infinite.

Patrick Leary
AVP Marketing
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243

-----Original Message-----
From: Matt Liotta [mailto:[EMAIL PROTECTED]
Sent: Tuesday, May 30, 2006 4:34 AM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

There is only 50Mhz available if I recall, so how many licensees can
their be if each is given multiple 5Mhz channels? If only one or two
companies are allowed to play in a given market then I expect 3.65Ghz to
miss the market.

-Matt

Patrick Leary wrote:

Matt, with WiMAX, a 5GHz channel is enough to deliver over 17Mbps net (ftp type net) per sector. I was not referring to 5MHz licenses as you assumed,
but only 5MHz PMP gear qualifying for use. You could use 20MHz if you
wanted, but each radio itself would use no more than 5MHz unless it was a
PTP radio.

Patrick

-----Original Message-----
From: Matt Liotta [mailto:[EMAIL PROTECTED]
Sent: Friday, May 26, 2006 7:59 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

The radios that exist for 900Mhz today barely qualify from a delivered
bandwidth perspective. We hardly ever lead with a 1.5Mbps service, but
sometimes are forced to sell just 1.5Mbps because we can only make the
shot with 900Mhz. If we were limited to 5Mhz with a 3.65Ghz radio then I
don't see why we would use them at all. 10Mhz would at least be
interesting, but that is too much channel space for multually exclusive
spectrum. About the only interesting thing you can do with 5Mhz is a
WiMAX mobile service, but it would never compete with a similar service
operating in 2.3Ghz or 2.5Ghz (not that I think a 5Mhz WiMAX mobile
service in those bands does much to compete with 3G anyway).
Ultimatelly, I think a 5Mhz license is only going to create "3G me too"
services that aren't that interesting. I know all the radio manufactures
would love that since services that target individuals sell more radios,
but alas, I am not a radio manufacture.

-Matt

Patrick Leary wrote:



Respectfully, I do not agree. Look how much is done in UL with just 26MHz


in


900MHz, most of which is not useable due to the noise of high power
primary
users and consumer devices. Also, rural customers and operators should
have
the ability to achieve high QoS services and not merely best effort.
Splitting the band leaves some room for both types of services.

I would also prefer the UL part of the split to be broken up into
something
like 5MHz channels so gear is not sold into the market that will use the
entire swath of band from one radio UNLESS it is a P2P radio, in which
case
the entire range should be usable.

Patrick

-----Original Message-----
From: Matt Liotta [mailto:[EMAIL PROTECTED]
Sent: Friday, May 26, 2006 12:58 PM
To: WISPA General List
Subject: Re: [WISPA] 3650 equipment

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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--
Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc.
Serving the License-Free Wireless Industry Since 1993 Author of
the WISP Handbook - "Deploying License-Free Wireless WANs" True
Vendor-Neutral WISP Consulting-Training-Troubleshooting
Our next WISP Workshop is June 21-22 in Atlanta, GA. Phone (VoIP
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