When you submit it send a copy to me for filing for the day I have to go
and do battle up here.
You have a Good Day now,
Carl A Jeptha
http://www.airnet.ca
office 905 349-2084
Emergency only Pager 905 377-6900
skype cajeptha
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.
Marlon
(509) 982-2181 Equipment sales
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) And I run my own wisp!
64.146.146.12 (net meeting)
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam
----- 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
Marlon,
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.
Absolutely.
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.
Agreed.
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:
http://www.panix.com/clay/scanning/frequencies.html
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.
Okay...
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.
Grin.
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.
Ken
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