Hello Jack,

Good to see you're back on track with, IMO, a proper response to the 11GHz
question/concerns.

Your initial comment came off as who cares and we don't have time for this.
John simply dittoed your comments, so what was the group left to believe?  I
apologize if I misunderstood your intent.   

Your questions/response below illustrate the type of post I would have
expected from you in the first place.

Best,


Brad


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Jack Unger
Sent: Tuesday, March 27, 2007 1:33 AM
To: WISPA General List
Subject: Re: [WISPA] FCC requests comment on smaller dishes for 11 GHz

Brad,

I think you may be misquoting or misunderstanding me. No good can come 
from that. Real questions need to be asked and need to be correctly 
answered before we risk our reputation by filing comments with the FCC 
that are technically incomplete or technically incorrect.

Here's a repost of my original post.

****************** Begin Original Post *********************************

It would be good to know the minimum required dish size now and the 
changes that FiberTower is proposing before deciding what to do or say.

I'm not sure this dish-size issue would impact any WISPs so we may want 
to ask ourselves if there are more important issues that we need to be 
focusing on, given the limited time and resources that we have.

I think this is an issue that the licensed microwave vendors will 
probably deal with adequately, without harming our interests. When we 
decide to purchase a licensed 11 GHz link, we'd be buying it from them 
anyway.

Finally, WISPA doesn't have an engineering staff that can adequately 
analyze the technical implications and prepare an informed technical 
response to submit to the FCC.

******************** End Original Post *********************************


NOWHERE did I say that the licensed frequency bands are not important to 
WISPS. Licensed backhauls are very important to WISPs. WISPs SHOULD use 
licensed backhauls wherever interference levels are high, where 
reliability is crucial, where throughput needs are high, and/or where 
full duplex links are needed.

NOWHERE did I say that the focus of the group should be limited to 
unlicensed frequencies only.

TO BE CRYSTAL CLEAR, I will restate each original paragraph and I will 
list the questions that each paragraph is implicitly asking.

****************************************************************************
***

PARAGRAPH 1 - "It would be good to know the minimum required dish size 
now and the changes that FiberTower is proposing before deciding what to 
do or say". In other words, we need to know the minimum dish size now 
and we need to know what dish sizes FiberTower is proposing before we 
can begin to understand if there is any affect on us and before we can 
formulate our position.

QUESTION: SO WHAT ARE THOSE DISH SIZES NOW, BEFORE A RULES CHANGE AND 
AFTER THE PROPOSED RULES CHANGE?

QUESTION: WHAT'S THE TRUE IMPACT, IF ANY, ON US IF THE FCC ALLOWS 
SMALLER DISH SIZES TO BE USED?

QUESTION: ONCE WE UNDERSTAND THE TRUE IMPACT, IF ANY, WHAT POSITION 
SHOULD WE TAKE BEFORE THE FCC?

****************************************************************************
**

PARAGRAPH 2 - "I'm not sure this dish-size issue would impact any WISPs 
so we may want to ask ourselves if there are more important issues that 
we need to be focusing on, given the limited time and resources that we 
have".

QUESTION: DOES A REDUCTION IN DISH SIZE REALLY AFFECT US?

QUESTION: HOW DOES IT REALLY AFFECT US? ARE 11 GHz FREQUENCIES CURRENTLY 
IN SHORT SUPPLY IN THE AREAS WHERE MOST WISPs OPERATE?

QUESTION: HAS ANY WISP EVER BEEN DENIED A LICENSE FOR AN 11 GHz 
FREQUENCY? IF SO, WHERE? HOW OFTEN HAS THIS HAPPENED?

QUESTION: ARE THERE MORE IMPORTANT ISSUES BEFORE THE FCC THAT WE NEED TO 
DEVOTE OUR TIME AND ENERGY TO? WHAT ARE THOSE ISSUES? WHITE SPACE? WISPS 
AS AN INFORMATION SERVICE? FCC's BROADBAND SERVICES SURVEY? CALEA? OTHERS??

****************************************************************************
*

PARAGRAPH 3 - "I think this is an issue that the licensed microwave 
vendors will probably deal with adequately, without harming our 
interests. When we decide to purchase a licensed 11 GHz link, we'd be 
buying it from them anyway".

QUESTION - IF ALLOWING SMALLER DISH SIZES WAS GOING TO CREATE 
INTERFERENCE PROBLEMS WOULDN'T THE COMPANIES THAT MAKE 11 GHz EQUIPMENT 
BE AGAINST THE PROPOSED CHANGES BECAUSE THAT WOULD RESULT IN THEM 
SELLING FEWER LICENSED 11 GHz LINKS AND HAVING HIGHER CUSTOMER SUPPORT 
COSTS?

***************************************************************************

PARAGRAPH 4 - "Finally, WISPA doesn't have an engineering staff that can 
adequately analyze the technical implications and prepare an informed 
technical response to submit to the FCC".

QUESTION - DO WE HAVE THE ENGINEERING KNOWLEDGE TO REALLY KNOW WHAT THE 
TRUE EFFECTS OF ALLOWING SMALLER DISH SIZES WILL BE?

QUESTION - A SMALLER ANTENNA WILL HAVE LARGER SIDELOBES. IS THIS REALLY 
AN ISSUE OR ARE 11 GHz ANTENNAS NORMALLY MOUNTED WITH A FEW FEET OF 
VERTICAL SEPARATION ANYWAY SO THAT A MARGINAL INCREASE IN SIDELOBES WILL 
REALLY HAVE NO IMPACT ON ANYONE ELSE ANYWAY?

QUESTION - SHOULD THE FCC GIVE ANY WEIGHT OR CREDIBILITY TO OUR OPINIONS 
AND OUR GUESSES OR SHOULD THEY ONLY GIVE WEIGHT TO REAL ENGINEERING 
ANALYSIS?

QUESTION - WHO IN WISPA IS AN ENGINEER AND HAS ACTUALLY DESIGNED, 
ENGINEERED, AND DEPLOYED A SIGNIFICANT NUMBER OF 11 GHz LINKS? SURELY 
SOMEONE HAS... WHO IS THAT PERSON? WILL THEY STEP UP AND DO SOME REAL 
ENGINEERING ANALYSIS FOR US ON THIS ISSUE?

QUESTION: WILL THAT ENGINEERING ANALYSIS SHOW THAT THERE IS ANY REAL 
IMPACT TO OUR ABILITY TO OBTAIN AND USE LICENSED 11 GHz LINKS IF THE FCC 
ALLOWS SMALLER ANTENNAS TO BE USED?

QUESTION: WILL ALLOWING SMALLER ANTENNAS ACTUALLY BENEFIT US BECAUSE OUR 
COSTS TO DEPLOY LICENSED LINKS WILL BE LOWER? (SMALLER ANTENNAS COST 
LESS TO BUY AND SMALLER ANTENNAS COST LESS TO MOUNT ON TOWERS).

***************************************************************************

That's it, Brad. Your help would be most appreciated to get real 
answers. If I'm "off the mark" as you believed, that's OK with me as 
long as it leads to an understanding of what the real issues are and 
builds our credibility with the FCC, the manufacturers, and the public 
at large. Real understanding benefits everybody.

Best Regards,
                jack



Brad Belton wrote:

> Agreed.  Just getting caught up on some of my email readings and strongly
> believe Jack and John are off the mark here.  
> 
> 6GHz, 11GHz, 18GHz, 23GHz, 24GHz, 60GHz and 80-90GHz should all be
important
> to us as a group.  Any frequency that can be used by fixed wireless
> operators should be important to the group.
> 
> For Jack and John to assume the focus as a group should be limited to UL
> frequencies is short sighted to say the least.  Many operations, ours
> included, are already utilizing licensed spectrum were we can.
> 
> Best,
> 
> 
> Brad
> 
> 
> 
> 
> -----Original Message-----
> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
> Behalf Of Tom DeReggi
> Sent: Monday, March 26, 2007 2:10 PM
> To: WISPA General List
> Subject: Re: [WISPA] FCC requests comment on smaller dishes for 11 GHz
> 
> Anything related to 11Ghz, should be WISPs concern.  It is my belief that 
> all serious unlicensed ISPs will at some point start to migrate to
Licensed 
> spectrums for backhauls. 11Ghz is one of the few upgrade options available

> for WISP's that designed their existing backhaul to 5.8Ghz functionality. 
> (meaning needing 4ft dish 11Ghz to reach equivellent distances of 5.8Ghz
2ft
> 
> dish links, in practicality).  There really aren't very many Long range 
> backhaul spectrum range options out there.  Relaxing the rules could
result 
> in the inabilty for many WISPs to obtain 11Ghz licenses, because of 
> unavailable spectrum, when they are ready to need it.  A 2ft dish
beamwidth 
> (9-10 degrees) will cover the width of most of a small city at 10 miles. 
> (Sorry I didn't do the Angle math yet).  Compared to that of 4 ft dish 
> beamwidths.  As much as I'd like a 2 ft Dish, how would that effect my 
> future abilty to get a license?  Thats an important question. Fibertower 
> wants 2ft dishes today because they are ready to buy up the licenses
today. 
> Are the rest of the WISPs ready to buy the licenses today? How much
license 
> space is available still? I think some propogation data and current 
> saturation data (number of links / potential for more links) would need to

> be disclosed first to develop a relevant opinion.  And how would the rules

> effect cost? Currently 11Ghz is significantly more expensive to obtain 
> because of dish size. If smaller more advanced dishes were allowed, a 2ft 
> dish that had the characteristics of 3-4ft dishes, would those dishes be 
> more expensive because of their unique better characterisitcs?   The truth

> is, every provider would chose 11Ghz over 18Ghz, if they could get away
with
> 
> a smaller dish. It would likely lead to less use of 18Ghz and 23 Ghz. Is 
> 18Ghz getting saturated? If so it would be relevent to allow 11Ghz to take

> over the load.  But I'd argue that 18Ghz should be near at capacity before

> 11Ghz be allowed to be more leanent in antenna size.
> 
> The bigger fight for smaller antennas is to allow 6Ghz to be allowed to
use 
> 4 ft dishes. 6ft dish requirement is insane. If 6Ghz was allowed to use
4ft 
> dished, it would then give another option for long range, (within a 
> realistic antenna size for roof tops), then justifying the allowance for 
> 11Ghz to have smaller antennas.  The question is, why isn't Fibertower
just 
> using 18Ghz in their applications? Can they prove that 18Ghz is to
limiting 
> or unavailable for them?
> 
> Tom DeReggi
> RapidDSL & Wireless, Inc
> IntAirNet- Fixed Wireless Broadband
> 
> 
> 
> 
> 
> John Scrivner wrote:
> 
> Thank you Jack. You said it better than I could have.
> :-)
> Scriv
> 
> 
> Jack Unger wrote:
> 
> 
>>Dylan,
>>
>>It would be good to know the minimum required dish size now and the
>>changes that FiberTower is proposing before deciding what to do or say.
>>
>>I'm not sure this dish-size issue would impact any WISPs so we may
>>want to ask ourselves if there are more important issues that we need 
>>to be focusing on, given the limited time and resources that we have.
>>
>>I think this is an issue that the licensed microwave vendors will
>>probably deal with adequately, without harming our interests. When we 
>>decide to purchase a licensed 11 GHz link, we'd be buying it from them 
>>anyway.
>>
>>Finally, WISPA dosn't have an engineering staff that can adequately
>>analyze the technical implications and prepare an informed technical 
>>responese to submit to the FCC.
>>
>>jack
>>
>>
>>Dylan Oliver wrote:
>>
>>
>>>I recall some past discussion bemoaning the large dish sizes required
>>>for
>>>licensed links .. I just found this in the latest "Rural Spectrum 
>>>Scanner"
>>>from Bennett Law (http://www.bennetlaw.com/rss.php?vol=13&issue=12). 
>>>Should
>>>WISPA endorse this? I'm not familiar with the details of 11 GHz 
>>>regulation.
>>>
>>>*FCC Seeks Comment on the Use of Smaller Antennas in the 11 GHz Band*
>>>
>>>The FCC has released a *Public Notice* announcing that it has adopted
>>>a *Notice
>>>of Proposed Rulemaking* seeking comment on whether to permit the
>>>installation of smaller antennas by Fixed Service (FS) operators in the
>>>10.7-11.7 GHz band.  The FCC initiated the rulemaking pursuant to a 
>>>Petition
>>>for Rulemaking filed by FiberTower, Inc., a wireless backhaul provider,
>>>proposing to change the technical parameters that would permit the 
>>>use of
>>>smaller FS antennas with reduced mainbeam gain, increased beamwidth, and
>>>modified sidelobe suppression in the 11 GHz band.  The FCC seeks 
>>>comment on
>>>whether FiberTower, Inc.'s proposals would serve the public interest by
>>>facilitating the efficient use of the 11 GHz band while protecting other
>>>users in the band from interference due to the use of smaller 
>>>antennas.  The
>>>pleading cycle has not yet been established.
>>>
>>>Best,
>>
>>

-- 
Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc.
FCC License # PG-12-25133
Serving the Broadband Wireless Industry Since 1993
Author of the WISP Handbook - "Deploying License-Free Wireless WANs"
True Vendor-Neutral Wireless Consulting-Training-Troubleshooting
Phone (VoIP Over Broadband Wireless) 818-227-4220  www.ask-wi.com



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