Jack, My read is 100% the same: any system with a protocol that can sense AND try to avoid other resident systems, like or dissimilar in protocol, will be allowed to operate across the entire band.
WiMAX, scheduled Canopy, and any other system that can be synchronized -- i.e. automatically "cooperate" -- with like systems, but cannot sense and deal with other resident systems are confined to the lower 25 MHz. However, it is worthy to note that WiMAX can be deployed in the lower 25 MHz then be allowed to use the entire 50 MHz at a later date IF the installed system can at some point be upgraded to deal with "non-restricted" products. 806.16h, which will meet this burden, is expected be a software upgrade that will be able to be applied to 802.16e products. In the end, the FCC strove to strike a balance between QoS capable technology vs. fast time to market. In the end I think the band gets populated quickly and there will be a point at which systems with "cooperate" so much via their contention systems that actual real bandwidth availability will take some careful management not dissimilar from the P15 bands. The only problem is that this time around, the R&O language tells WISPs that others MUST cooperate so all will have more legal standing to bring others to the table. This actually will be a new challenge for WISPs as it forces them into the legal arena more fully than P15, which is basically a free for all. The real winners are our friends in the legal profession. I submit (Larry, et al) that a modest nice little practice can be made by providing 3650 arbitration services. :) Patrick Leary AVP WISP Markets Alvarion, Inc. o: 650.314.2628 c: 760.580.0080 [EMAIL PROTECTED] -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Jack Unger Sent: Thursday, June 07, 2007 2:43 PM To: WISPA General List Subject: [WISPA] Re: [WISPA FCC] FCC 3650 band response today.. As I read it, the FCC says that contention-based protocols that are capable of detecting signals that are using *both* *similar* and *non-similar* protocols (and thereby deferring transmission to avoid generating interference) can be legally used over the entire 50 MHz band but protocols that are capable of detecting *only similar protocols* or that are *scheduling-based *must be used only in the bottom 25 MHz. Other things being equal, this means that the bottom 25 MHz will be noisier (more dissimilar non-CSMA protocols allowed) and the top 25 MHz will be quieter. The examples the FCC used (I know it seems funny or maybe ironic, depending on your point of view) is that WiMAX is limited to the bottom 25 MHz because it uses a scheduling protocol which does not listen for transmissions that use other protocols before it (WiMAX) transmits. In comparison, Wi-Fi-like protocols *do* listen before transmitting and are capable of detecting the presence of other (non-Wi-Fi) protocol transmissions and deferring their own transmission until the channel is quiet. Wi-Fi-like protocols therefore *can be* used across the entire 50 MHz band. It looks like only certified products will be allowed. It seems to me that Mikrotik or other software (with proper channel/power restrictions built in) combined with a Ubiquiti 3.6 GHz card could serve as the basis for a line of reasonably-priced full-band WISP equipment. If CSMA is disabled then only the bottom half of the band will be usable and likely only if the Point Coordination Function (PCF) is enabled for the entire system. jack Patrick Leary wrote: > I would hope any WISP worth serious about its being a business (versus a > hobby) should be at least roughly familiar with the issue and the fact > that a decision was being re-evaluated. > > At my read, it looks like ALL listen-before-talk type BWA products will > be certifiable under the rule for use in all 50 MHz. But -- and yee haw > for this -- no license is provided WITHOUT the operator entering the FCC > equipment authorization number for the intended product. This means this > band will be largely free from illegal systems -- if a vendor wants to > play in the space, they have to do the minimal work required to make > themselves legal to do so. All should rejoice at this. > > Patrick Leary > AVP WISP Markets > Alvarion, Inc. > o: 650.314.2628 > c: 760.580.0080 > [EMAIL PROTECTED] > > -----Original Message----- > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On > Behalf Of Doug Ratcliffe > Sent: Thursday, June 07, 2007 1:09 PM > To: 'WISPA General List' > Subject: RE: [WISPA] Re: [WISPA FCC] FCC 3650 band response today.. > > I just hope systems like Mikrotik w/ Ubiquiti SR3s/ XR3s(eventually) can > be > made certified under 3650. That will keep the equipment low priced AND > able > to use the whole band. And in CSMA disable mode, only the lower half of > the > band. > > I think that in major cities 3650 coordination may become an eventual > issue > if the major carriers jump on this (like cell, Clearwire, etc). But > most > rural and small WISPs will never even hear about this band for a long > time, > keeping it open for those who know a lot longer. > > Less likely will it be that those WISPs will even know what to file, > seeing > as they probably didn't even file a 477 or CALEA form. > > -----Original Message----- > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On > Behalf Of Patrick Leary > Sent: Thursday, June 07, 2007 3:57 PM > To: WISPA General List; FCC Discussion > Subject: RE: [WISPA] Re: [WISPA FCC] FCC 3650 band response today.. > > Very interesting clarifications that will be immediately beneficial to > WISPs and others looking to deploy in the band. The big wild card and > open question in my view is the cooperation requirement. The Commission > extensively uses the language about being "required" to cooperate, but > does not fully define what that means and to what extent or any > consequences of not doing so. Does it mean the existing operator MUST > re-work an existing channel plan to accommodate every new entry? This is > one of many open and important questions. And these questions only > become more acute in the lower 25 MHz restricted portion. That rule > clearly allows any TDD product that can sync with any other like > operator, i.e. Canopy, .16e WiMAX, and any number of other TDD products. > But the rule still requires these distinct entities to "cooperate" on > some level even though there is no way for them to cooperate via gear > short of channel isolation, which is not mandated. > > So that part of the rule will be an enforcement AND legal mess over > time. > > All that said, I am glad to see it finally out and happy that the FCC > put some effort into the clarification. > > Patrick Leary > AVP WISP Markets > Alvarion, Inc. > o: 650.314.2628 > c: 760.580.0080 > [EMAIL PROTECTED] > -----Original Message----- > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On > Behalf Of Jack Unger > Sent: Thursday, June 07, 2007 12:21 PM > To: wireless@wispa.org; FCC Discussion > Subject: [WISPA] Re: [WISPA FCC] FCC 3650 band response today.. > > Only FCC Commissioner Jonathan Adelstein added comments to the 3650 band > > Memorandum Opinion and Order published today. > He said: > > ________________________________________________________________________ > _______________ > > *"A little over two years ago, I was very pleased to support the > Commission's innovative > decision to make the spectrum in the 3650-3700 MHz (3650 MHz) band > available on a licensed, > but non-exclusive, basis. In many respects, this was a bold statement. > We wanted to take > advantage of the success of the WiFi movement and take it to another > level. We wanted to find > the right balance between a licensing model for traditional, area-wide > mobile systems and a > model for unlicensed, consumer-based services. Our licensing regime for > the 3650 MHz band > will serve as a wireless highway between small towns and the big city - > it will facilitate the > delivery of broadband to all corners of the country by serving a > different user group, one that > often is driven by more localized, community based needs. > > Since our initial decision, I have talked often about the public > interest benefits of the new > licensing rules for the 3650 MHz band. I have spoken with many > supporters of our decision, and > with those who believe the band would be better used on an exclusive > basis. But I remain > convinced the hybrid licensing approach that we first adopted for the > 3650 MHz band is the > correct one, and I enthusiastically support our reconsideration order > today. > > During my time at the Commission, I have pushed for flexible licensing > approaches that > make it easier for community-based providers to get access to wireless > broadband opportunities, > and the rules we affirm for the 3650 MHz band should help make wireless > broadband services > available to a large number of new users. Today, we uphold our earlier > decision to put in place a > regime that doesn't rely on first in time and provides equal access to > all. I have heard from > representatives of the Community Wireless Network movement about our > 3650 MHz licensing > rules, and they are thrilled with the hybrid approach and the positive > impact it will have on their > efforts to deploy broadband networks in underserved communities around > the country. > > So, once again, I wholeheartedly support our 3650 MHz licensing > decision. Of course, > only time will tell if this unique approach will result in increased use > > of this spectrum band. But > I think that given the success of unlicensed wireless networks, we are > on the right track, and our > creative spectrum management approach is well justified. > *_______________________________________________________________________ > ______________ > > > Dan Lubar wrote: > >> Greetings everyone.. >> >> I wanted to make everyone aware of today's published response from the >> FCC regarding the reconsideration of its 3650 NPRM.. >> >> http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-99A1.pdf >> >> Note that the petitions for reconsideration of this rule making have >> been denied and 3650 band usage in the United States is now one step >> closer. >> >> Respectfully, >> >> Dan Lubar >> RelayServices >> _______________________________________________ >> FCC mailing list >> [EMAIL PROTECTED] >> http://lists.wispa.org/mailman/listinfo/fcc >> >> -- 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 FCC Part 15 Certification for Manufacturers and Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ ************************************************************************ ************ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals & computer viruses(190). ************************************************************************ ************ ************************************************************************ ************ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals & computer viruses(43). ************************************************************************ ************ ************************************************************************************ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals & computer viruses(84). ************************************************************************************ ************************************************************************************ This footnote confirms that this email message has been scanned by PineApp Mail-SeCure for the presence of malicious code, vandals & computer viruses. ************************************************************************************ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
