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What is baseline testing in your
context?
----- Original Message -----
Sent: Thursday, June 15, 2006 7:53
PM
Subject: Re: [WISPA] Re: 1st draft
Spectrum Sharing Test-bed 06-89.doc
In fact I can't believe baseline testing is not a prerequsite,
hell I still can't spell.
>-----Original Message-----
>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
>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
>>
>> --
>> New-ISP.net/NextGenCommunications.net
>> Wireless
solutions - not concessions.
>>
http://www.nextgencommunications.net
>> 1044 National Highway LaVale
MD 21502
>> Tel# (301)789-2968 Cell
(301)268-1154
>>
>>
>>
>>
>
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