OK, makes sense to me. I'm glad you are on top of all these things. You do a great job Marlon.
-----Original Message----- From: Marlon K. Schafer (509) 982-2181 [mailto:[EMAIL PROTECTED] Sent: Friday, June 16, 2006 12:31 PM To: 'WISPA General List' Subject: Re: [WISPA] Re: 1st draft Spectrum Sharing Test-bed 06-89.doc
I specifically left out the whitespaces because they are already on the table and may see movement at any time. I didn't want to put another 2 year hold on them....
----- Original Message -----
Sent: Thursday, June 15, 2006 7:49 PM
Subject: Re: [WISPA] Re: 1st draft Spectrum Sharing Test-bed 06-89.doc
Marlon, I just read it. I have many installs, I'm an old guy, I'll respond Sunday. and it "Looks good to me". Accept there is no or little mention of the TV White Spaces, I think they would be perfect for a project like this. And Baseline testing prior to the experiment is an absolute must.
>-----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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