Well said.

Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband


----- Original Message ----- From: "Patrick Leary" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Tuesday, February 06, 2007 1:52 PM
Subject: [WISPA] Widespread abuse of FCC rules, a list...was TV white spaces


Here are few raw comments that might fray some nerves:

1. The FCC is not a baby sitter.
2. Mature operators (and industries as a whole) follow the rules as a
matter of course and expected cost of business.
3. You are not the public, you are commercial operators financially
benefiting off the public's free spectrum and you off all users should
thus be a responsible steward of that spectrum.
4. Those not following the rules have no ethical standing to complain
about other illegal use, predatory competitors, lack of spectrum, etc.

As someone who has argued for WISP compliance for years, I've certainly
been alarmed by what I see as a new level of non-compliance. WISPs are
now commonly assuming the FCC's lack of enforcement is tantamount to its
approval of abuse. The general attitude is now that there is but one
rule: "Don't exceed the power limitations." Everything else has become
fair game.

Here is a list of things I see that lend anecdotal evidence, if not
actual, that abuse is reaching new levels:

- many WISPs now believe it is no big deal to use 4.9 GHz to carry some
commercial traffic (Hey, there's excess capacity so what's the big deal,
right?...)
- use of STA's to commercially use spectrum is openly being advocated
(this is partially responsible for an over 6 month wait in STA filings)
- illegal vendors now operate in the clear with prominent U.S.
distribution (They must be legal if they have a store front and it only
hurts other vendors anyway...)
- "build your own base station" type Google ads are rampant

Call me an alarmist, but this accelerating trend is disturbing and such
attitudes easily even have the potential to infect safety issues (hey,
OSHA rules must not be that big a deal either).

We must all appreciate that many violating the rules do so out of
ignorance, but that as an excuse. Groups like WISPA should take firm
stands on subjects like this. You should strongly encourage compliance,
lead the way and educate. You should fight the ignorance that allows for
relativism and "creative interpretation" of the rules. You should also
not cave to the hard luck excuses that "I'm a small guy and can't afford
to follow the rules." (Your response to such should be to point to
funding sources/advice or otherwise tell them that there is a minimum
cost to legally participate in this business and that following FCC
rules is a minimum expectation as responsible stewards of the public's
free spectrum.) And finally, WISPs should not treat knowingly illegal
operators as equals because in fact they are liabilities to you and the
industry at large.

And yes, of course I have skin in the game but that in no way alters
anything here or devalues my comments. If anything, as a legal vendor
with a long professional reputation of compliance and scores of legal
operator partners, and as an individual who has been beating this drum
for 7 years, it should only increase the weight of my comments.

Sincerely,

Patrick Leary
AVP WISP Markets
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
[EMAIL PROTECTED]

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Dawn DiPietro
Sent: Tuesday, February 06, 2007 9:26 AM
To: WISPA General List
Subject: Re: [WISPA] TV white spaces

All,

Remember, it only takes a few bad apples to make the whole industry look

bad.
Think about that the next time anyone wants to complain about the rules.

Regards,
Dawn DiPietro


Patrick Leary wrote:

I hope it does go UL, but I have also heard some recent rumblings that
the FCC is concerned with what seems like a widespread deterioration of
WISPs following the rules. The phrase I recall is something along the
lines of "Damn it, these things are not guidelines."

From my view it is true. I see it in conversations that go beyond the
usual, "if you just stay within the power no one cares" to now where
people seem to via the STA process as a round-about tool to get access
to and use spectrum that does not commercially exist.

Letting loose the same level of abuse in the TV bands is something that
will cause real problems for the FCC should broadcasters be affected.

The WISP industry must do a better job of policing itself and
discouraging the slippery slope.

Patrick Leary
AVP WISP Markets
Alvarion, Inc.
o: 650.314.2628
c: 760.580.0080
Vonage: 650.641.1243
[EMAIL PROTECTED]
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Jack Unger
Sent: Monday, February 05, 2007 11:22 PM
To: WISPA General List
Subject: Re: [WISPA] TV white spaces

Steve,

I appreciate your insight into the possibility that license-exempt
white

space use might actually materialize. I very much hope that it does.

jack


Steve Stroh wrote:


Jack:

Consider...

To the television broadcasters, WISPs using this spectrum in a "we'll





stay out of the way of any television broadcasting activity" manner


is


the lesser of several other evils; television broadcasting has  been
steadily losing ground now; first 800 MHz was carved out of  Channels
70-83, and now the 700 MHz bands are being carved out of  Channels
52-69. The trend is clear, and while it's one thing for  powerful
terrestrial broadcasting to "share" spectrum with low-power
license-exempt usage, it's quite another for communications use to do





the same. If the broadcasters play things right (and it appears they
are "bending" towards white space license-exempt usage, but very much





on THEIR terms...) the license-exempt usage of television white space





may serve to "pollute" the remaining television broadcast spectrum
sufficiently to prevent future reallocation (for at least another
decade or so).

Intel, Microsoft, Cisco are some of the names being bandied about as
advocates for license-exempt use of white space television broadcast
spectrum.


Thanks,

Steve



On Jan 24, 2007, at Jan 24  09:21 AM, Jack Unger wrote:



Likelihood of unlicensed???

My guess is that the established communications carriers and the
broadcasters will fight the concept of license-free use of this
space. I expect it will come down to who lobbies Congress most
effectively.

--
Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc.
Serving the License-Free Wireless Industry Since 1993
Author of the WISP Handbook - "Deploying License-Free Wireless WANs"
True Vendor-Neutral WISP Consulting-Training-Troubleshooting
Newsletters Downloadable from http://ask-wi.com/newsletters.html
Phone (VoIP Over Broadband Wireless) 818-227-4220  www.ask-wi.com



---

Steve Stroh
425-939-0076 | [EMAIL PROTECTED]
Writing about BWIA again! - www.bwianews.com










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