>From: Marlon K. Schafer (509) 982-2181 [mailto:[EMAIL PROTECTED]
>Sent: Thursday, June 15, 2006 06:37 PM
>To: 'Ken DiPietro'
>Cc: 'WISPA General List', 'POSTMASTER'
>Subject: [WISPA] Re: 1st draft Spectrum Sharing Test-bed 06-89.doc
>Of for God's sake! Only one response and that's not even from a WISPA
>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.
>(509) 982-2181 Equipment sales
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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
>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
>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
>> 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
>>> 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
>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
>> 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
>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
>> 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.
>> Wireless solutions - not concessions.
>> 1044 National Highway LaVale MD 21502
>> Tel# (301)789-2968 Cell (301)268-1154
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