It looks good to me


Marlon K. Schafer (509) 982-2181 wrote:
Of for God's sake! Only one response and that's not even from a WISPA member!!!!

Can I at least get a "looks good to me" response if you guys aren't going to take the time to give me some feedback on what to say on this issue?

Ken, my comments below.

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----- Original Message ----- From: "Ken DiPietro" <[EMAIL PROTECTED]>
To: "Marlon K. Schafer (509) 982-2181" <[EMAIL PROTECTED]>; "John Scrivner" <[EMAIL PROTECTED]>; "John Scrivner" <[EMAIL PROTECTED]>
Sent: Wednesday, June 14, 2006 9:42 AM
Subject: Re: 1st draft Spectrum Sharing Test-bed 06-89.doc


Comments in-line, just where you'd expect to find them.

Marlon K. Schafer (509) 982-2181 wrote:

1 a: We believe that there should be multiple tests run at the same time but in different areas. Possibly on a rotating basis so that each test can be run via different technologies in different environments. We believe that any new technologies should be open to testing on a non interference basis.

I would leave this alone - let the FCC decide how this aspect of the test should be run. I can see value (for example) of two competing tests being run in the same area to show how the interference issue can be measured and possibly ignored due to lack of any tangible problem.

Part of the problem with this whole idea will be the incombants not wanting to share. We also want to see valid data on what happens to the incombant. This means that we need to limit the possibilities of harmful interference.

At least that's my take on it.

1 b: We believe that the biggest challenge is going to be creating a technological and regulatory environment that’s auto correcting. We want to see spectrum fully utilized. However, changing technology would require constantly changing rule sets if it were to be too granular. Too loose and the rules will get abused. We’d like to see a balance that sets the rules in such a way that people can build/use devices that use any open spectrum that they can find. Inefficient radios that don’t keep up with technological advances should be encouraged to leave the market at some point though. Possibly by setting a certification sunset. Certainly all existing devices would be grandfathered, new ones would have to be recertified after x years (3 to 5???) though.

I find this to be a dangerous precedent. If full use of spectrum is the goal, it seems that the License Exempt "experiment" has done a pretty good job of pushing the limits of that goal.

Yeah, we've done well so far.

From my perspective, I would like to see a "loosening" of the rules in specific bands that are easily accessible using off the shelf WiFi equipment. In addition, I want to see the 6GHz band have the six foot antenna rule stricken from the regulation and a reasonable EIRP mandated (like 4 watts plus unlimited antenna gain?) so that we can start to use a "clean" band to deliver communications services in any area that interference would not be a problem is. As a specific example, I would guess (no, I haven't confirmed it) that there is zero usage of the 6GHz band in my area or if there is it is localized for long distance PtP links and anything I would deploy here "on the ground" would not affect these PtP links with their very high gain antennas.

Those are all good points but not the point of this nprm as I read it.

2: We think that multiple tests should be allowed to run simultaneously in many markets around the country.


3: Tests should span from fallow to highly used spectrum. We believe that one of the criteria should be equipment availability. There are radios already on the market that will operate in the 2.5 GHz band. This should make modifications to the operating software much easier and less expensive for at least one phase of the tests. We think that all spectrum should be looked at honestly. Important but not mission critical cases should be looked at. ie: Radio navigation should be off limits, but the local plumber’s VHF channels should not. *IF* the plumber detects unusual interference on his band he should be able to contact the testing party and first verify the interference and secondly make them stop causing it.

The typical Atheros powered WiFi radio has the ability to access from 2312 to 2732 in the 2 GHz channels and from 4920 to 6100 in the 5 GHz mode. It is these bands that I believe we should concentrate on because the rest of the entire spectrum is essentially unapproachable from a WISP standard. That doesn't mean we can't also ask to use any of the other bands but the question of how we best use this opportunity for the betterment of WISPs is what WISPA is dedicated to doing.

True. But by focusing on wifi too much we'd limit the scope of the tests. Personally I'd like to see something done in the sub gig range.

And who knows what products or ideas are floating around out there right now that would't be able to use those products.

Also, I think it's a no brainer that people do some testing of new things with those chip sets. But why would we want those to be all of, or even most of the tests?

4: We believe that a component of the test should be non spectrum specific (other than ruling out life critical or mission critical spectrum). Barring that option, we think that the spectrum used should be some that’s mostly fallow and some that’s in use.

Here we disagree. I believe what we should be trying to prove (among lesser things) is that a lower power underlay - even in locations where the band we wish to use is in use - can be utilized more fully without any measurable effect to the primary user. The advantage WISPs would gain from this is immeasurable. We need to identify exactly what spectrum we are interested in using that (as you said) is non-mission critical but is accessible through the country code setting in standard off-the-shelf WiFi equipment. The key point is to ask for those specific frequencies.

First, we do agree on this. Please note that some spectrum in use was specified. Just not most...

Also, again, I don't believe that doing all or even most of the testing with wifi gear is a good idea. What do others think???

4 b: We do not think that the commission should specify spectrum usage. That should be left up to the experimenters. Those running the experiments should us compatible technologies in a given market though. Some markets should be narrow band, some wide band, and some with a mix of both.


5: We see no reason that the existing experimental licensing scheme can’t be used. We do think that the commission should take a hands off approach as much as possible. As long as significant ongoing interference isn’t an issue the experiments should be allowed to try various technologies in various bands. We do believe that all data gained in this research should be publicly published to the greatest extent practical without jeopardizing intellectual property concerns unduly.

Here I disagree. I would strongly urge that a new licensing method be created or the existing experimental licensing regulations be rewritten to allow for the commercial use of this spectrum during these tests. I believe the only way we can truly simulate a heavily loaded network is by loading it up with real users. There is no substitute for this in my opinion.

That's a good point. I don't think it matters though. This is only a two year test. And it's not to trial gear, it's to develolope it.

The fact that the gear needs to work for commercial purposes is a good one. Would you, as a customer, be willing to pay for access with gear that's not even to the alpha level yet and would have to be yanked out after 2 years?

Oh yeah, don't forget that at any time it's subject to being turned off at any time?

I think you bring up a good point, but in this case it's a non issue.

6: If the goals of this program are to ***learn*** what is possible with today’s technology or that currently still in development there should be no geographic limitation. Perhaps, if it’s deemed a necessary evil, the experiments could be split into time frames. The 1^st year in a rural setting and the second year in an urban setting if the experimenter so desires.

I would suggest this might be one way of doing this but I would also suggest that a more thorough method of conducting these test would be for the full two-year testing phase to be conducted in both rural and urban environments for the full time. By providing the two year window innovation will be encouraged and the necessary time frame to fully document any variations will be allowed. This is critical to ensure that no experiment will be rushed and results may not be fully realized. I would support geographical limitations in areas where the requested band is in use by mission critical industrial applications or perhaps alternately suggest that as method of oversight be instituted where any measurable interference would cause either the suspension or termination of the test in that specific band in that area.

Yeah, I thought about that too. My idea here was to allow for more than one tester in each area but not open everyone up to interference etc. from each other. Or issues related to spectrum access from an incumbant point of view.

7: The commission should, before the experiments take place, have a moderately detailed understanding of the tests to be run and the results sought. ie: Can a “Wi-Fi” network switch channels quickly enough to avoid noticeable interference with the local taxi dispatch radio network?

I would also suggest that a measurement be provided of the noise floor in the requested range and that any addition of new equipment that shows up in the area be notified of the testing being conducted there. As far as I know there is no "off-the-shelf" WiFi radio that can interfere with taxi frequencies which are set at 157.530 - 157.710, 152.270 - 152.450, 452.050 - 452.500 and 457.050 - 457.500 as defined here:

I like the idea of some sort of base line tests in an area first.

8: All candidates should be granted access to this system but only 1 or 2 in any given market. (Market being defined in this context as within the greatest possible range of interference. Or, stated another way, so that only one at a time could possibly be the source of interference in a given geographic area.) Candidates should demonstrate the ability to actually produce some new device or technology for these tests. Hacking a Linksys wireless router is not sufficient experimentation for the purposes of this test-bed.

I would suggest that "hacking a Linksys router" would be an excellent way to become involved in this test and would argue that this language should be stricken. Aside from the frequencies that are accessible many different power levels as well as modulations are available very inexpensively by utilizing this method. Please leave as much room for experimentation as possible.

I disagree with that. There's plenty of that going on already. No need to do more of it. Lets use this proposal to have people try other new things.

9: The same should be used for both federal and non federal primary users. They should know who’s experimenting and what the goals are and what to watch for on their band. Primarily they should know who to contact in the case of a problem affecting their ability to use their spectrum.

I strongly support this language and would add that the burden of contacting the primary user and supplying the necessary information be place in the experimenter. Additionally, I would also mandate that any time a new piece of experimental equipment be deployed the primary user be notified, in advance, of the action so they can be ready in case anything does happen.

10: The primary goal should be one of pushing the technological envelope while maintaining an interference free environment for the primary user.

Absolutely! Well said!

11 and 12: We believe that the test-bed program should be open to any companies that can put forth a good program and supply the resources needed for the tests that they wish to run. The commission should not pick and choose. The FCC’s role should be limited to the enforcement of the test parameters. Meaning that the FCC should make sure that any tests run do not create harmful interference on any sort of ongoing basis that makes the primary users spectrum substantially unusable.

I would change company to "entity" allowing for individuals to experiment if they so choose.

I've got mixed emotions about that. I don't have a problem with individuals doing some testing. But I can see more potential trouble coming from too many testers in any given area. That may also make the test results less valuable.

Maybe both should happen. After all, once deployed it's unlikely that any new technology would be isolated to a single operator in any given area.

Thoughts from the group?

13: The ability to develop and field test new technologies should be it’s own incentive.


14: It seems to us that the testing parties all have a price to pay for this opportunity. One of those prices is that they need to make most of their data available to the public. If they don’t like that they can stay in the lab and do their own “behind closed doors” testing.

I agree with this except who defines what the level of documentation should be? If I choose to not take explicit notes will I be penalized? You might want to rethink this remark before it grows into something that comes back to haunt the little guy.

Those are certainly good points and details that will have to be worked out.

15 and 16: This needs to be handled on an individual test basis. Overall, the commission could come up with a report condensing all of the findings of all of the tests. We think this would be a good basis for a group of policy decisions that would be focused on using the most promising advancements to insure the most effective use of RF spectrum.

This I do not understand. Where does this data come from and where is the standard form we are all supposed to fill in? Where the value is in this test is where the primary users indicate that they have or not had any interference in their spectrum during the tests. If there has been an experiment conducted in any given area it is not up to the experimenter to prove there was no interference, they simply cannot do this, it is the primary user that needs to show spectrum has been encroached on.

Those are all policy issues that the commission would have to decide on. Personally, I don't think that the incombant should have to prove anything but harmful interference.

17: Again, we believe that predetermining the results of the tests is dangerous ground. The tests should be run, the downside is far overshadowed by the upside. After the tests are run an educated position can be made. Much like the Spectrum and Broadband Wireless task forces first gathered data then made recommendations.

I read this question in a completely different manner than your reply would indicate. I see this as asking if the results of this testing should be made permanent or should the regulations be reinterpreted as opposed to "predetermining the results" and I would urge you to reread this section. I might be mistaken but that is how I read it.

They asked if permanent rules changes should be made based on the results of these tests. I'm simply saying that we should wait and see what, if any, usable results we get before anyone decides to change any rules here...

18: Absolutely. Just like they have to for certification today. If they don’t want to take advantage of real world test results they can run all of the lab tests they want. If we’re going to risk our businesses we have every right to at least most of the available data.

This is a slippery slope. Who defines what is a complete report? Would you say your writing and reporting skills can match the level of an Alvarion or a Verizon? I am firmly against locking out smaller people (like myself) from these tests - which is how I interpret what you are asking for here.

Again, those are issues for the commission to decide.

Should results be published and made available to everyone publicly? Absolutely! Should a level of testing documentation be mandated that equals or exceeds the procedure required for certification? Are you kidding? Every WISP I know of would be shut out of these tests if this were the case. Who are you representing here?

That's not what I said. I simply said that the test should be complete with detailed results and that those results should be available to the rest of us.

You've done a pretty good job of responding to the FCC. I have made several suggestions that you may choose to ignore however, I will be filing my own response including exactly what I have written here. I would like to think we might be in agreement but past history has taught me other wise.


And that's why everyone has input here. But in the end, what WISPA files will be what it's membership wants. If you, or anyone else, wants to change what WISPA stands for you have to join.

In the mean time, we'll take all of the good ideas we can get!

Good luck and excellent work - keep it up.

Thanks.  And thanks for the ideas.


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