Good luck with your individual White Space filing.

I urge everyone who believes they have a better, a more constructive or 
a more practical idea than WISPA's filing to go to the FCC website and 
make an individual filing with the FCC immediately.

Here's the link to file  

It's important to file by next Tuesday, October 28th because that's the 
last day that the FCC is legally allowed to take Comments before they 
vote at their November 4th meeting.

Of course for those of you who believe that the WISPA filing IS good and 
that it DESERVES your support, you can go to the above link and simply 
say "I am a WISP and I support WISPA's  position". It's as easy as that.

Thank you. We appreciate everyones help.

Jack Unger
Chair - WISPA FCC Committee

Marlon K. Schafer wrote:
> Hi All,
> As a member of the FCC committee and a long term DC participant (first went 
> there as a WISP in 2001 or 2002) I feel I have to point out some critical 
> flaws in our proposals.  I said much of this at the committee level but to 
> no avail.
> First, let me say this though.  The filing is masterful.  It's a GREAT 
> document.  My heartburn has nothing to do with the document it's self or the 
> hard work that's gone into it.  My heartburn is content based.
> Well, most of it is anyway.  I have a problem with WISPA changing it's 
> stance from unlicensed to licensed lite without having consulted with the 
> membership on this issue.  Our last team came back from DC and told us what 
> our new position was.  That's NOT what I help found WISPA for.  I could have 
> just stayed with a couple of the other associations that I've been a part of 
> and been man handled like that.
> Lest anyone take this the wrong way, I happen to LIKE the licensed lite 
> concept.  I just don't like having a committee that will make a major change 
> without discussion before hand.  If there was discussion that said we were 
> going to move from unlicensed to licensed lite and I missed it then I missed 
> it.  I know there had been discussion about the idea but nothing voted on by 
> anyone when it came to an official stance.  Not the way to run this railroad 
> in my, not so, humble opinion.
> Now, to the whitespaces issue.
> I have MAJOR problems with the stance on adjacent channels.  We give up 3 
> for 1 every time a TV channel, or microphone etc. fires up in our area.  A 
> TV station goes live and we don't loose the channel that they are on, we 
> loose it and 2 on each side.  This means that in any market that has as 
> little as 1/3rd of the channels in use by licensed operators (TV stations 
> AND mics) will be totally useless for us.  Why not simply set the out of 
> band emissions standards high enough that we CAN use adjacent channels?  I 
> begged for that language, it satisfies both us and the broadcasters.  I know 
> it's not technically possible today.  So what?  Just tonight as I was 
> working on an AP I saw a customer connected at the 18meg speed with a signal 
> level of -96.  Who'd have imagined that would be possible just a couple of 
> year ago?????
> Next, I HATE geolocation as the only mechanism.  I use circles on a map.  I 
> know how inaccurate they really are.  They also change dramatically as the 
> technology changes.  When I started my WISP in 2000 a 15 mile cell size was 
> the max.  And if we got anywhere near 1 meg with a 4 watt EIRP system that 
> also amped the receive signal by 14ish dB we were oh so happy.  Now I can go 
> even further than that and get 2 to 3 megs with NO amp and an eirp of 1 watt 
> or so.  Same exact CPE units that were in place when we pulled the AP'd ap 
> system out.  Actual signal measurement is really the only way to accurately 
> determine interference issues.  Well, OK, I guess one could just put a large 
> enough exclusion zone around the broadcasters to make sure that there is no 
> interference.  Unfortunately that also means we end up with even less market 
> potential.
> Here is my idea for whitespaces.  This is what I'll be personally filing. 
> I'll fine tune it and likely add some ideas that slip my mind right now. 
> I'm still more than a bit miffed that there wasn't even a vote on our filing 
> (I know I'm whining, but I'm well and truly pissed).
> Geolocation should be used until such time as a sensing mechanism can be 
> found that will work.  Lets be honest here guys.  NO one knows IF the FCC 
> will even allow white spaces use let alone with a sensing system.  Just how 
> much R and D do you think was put into this project in this economy? 
> Sensing works great on $60 WiFi cards for God's sake!  (Listen before talk, 
> CSMAK.)  It'll work for TV channels as well.  It'll just take a little more 
> time and effort.  Set a high standard, one that will protect the licensed 
> users and then let the market go to work on the problem.  Once sales 
> opportunities actually exist people will start working on ways to make this 
> happen.
> Licensed lite is a great idea.  There should be NO first in mechanism 
> though.  This leads to those with all of the money getting all of the prime 
> slots and the rest of us sucking hind teet again.  What we should do instead 
> (and I floated this idea as well) is follow the Spectrum Policy Task Force's 
> recommendation and implement time sharing too.  All AP's should require 
> either GPS sync or some mechanism that they do among any other AP's that 
> they can hear.  Each second should be cut into some number of parts.  100, 
> 200, 1000, whatever makes good technical sense.  Then, when all available 
> channels are used up AP's will have to start sharing time as well.
>     This will prevent outages from competitors.  It will encourage 
> manufacturers to stuff as much data into as small of a time slot as possible 
> (improving efficiencies) and best of all, will allow mics and other licensed 
> devices to be built with cheap components and to be used automatically with 
> existing networks with NO outages due to interference!  Just think about how 
> many mics could cover the Indy 500 if they effectively had 1000 channels 
> available in every 6 MHz TV channel!?!?
> Another proposal from the Spectrum Policy Task Force was to set receiver 
> standards.  Today all the FCC looks at is how accurate a transmitter is.  No 
> one  cares about how accurate a receiver is.  Lets use this chance to also 
> set standards for TV receivers.  In the end that should also benefit the 
> broadcasters as they'd be able to start using those adjacent channels 
> instead of leaving them empty.  It's time to start setting standards that 
> drive technological advances.
> We also need to set max channel sizes.  No more of this 40mhz wide channel, 
> always on gear.  There is plenty of ptp licensed spectrum available for 
> those devices.  (Yeah I know that licensed ptp links don't normally use 
> 40mhz, you know what I mean here, no more WMUx type gear.)  Perhaps we 
> should also follow the FCC's own example for 2.4GHz.  The smaller your 
> footprint the more power you can use.  You guys do know that with small 
> enough sectors and proper routing you can run, what is it, 48dB at your base 
> stations?  Yes we worked out that interpretation with the FCC long ago.  You 
> can use smart antenna technology OR routing.  I think most of us figured out 
> that it's cheaper and easier to just build more sites closer to the 
> customers but I've always wanted to see what ringing a tower with 24dB grids 
> for the base station antennas would work like!
> Adjacent channels should be set to a specific OOB standard.  If your device 
> meets that standard, use the adjacent channels.  If it doesn't, then don't 
> use them.  That addresses the problems for the broadcasters and also opens 
> up spectrum for us.  Given time and a market the manufacturers will find a 
> way to make it happen.
> I also think we need to hit the current spectrum shortage much harder. 
> Heck, as far as the FCC is concerned they just gave us over 260mhz of new 
> spectrum!  (5.4ghz and 3650)  Never mind the fact that most of us that need 
> the TV band's can't use the 5.4 band due to it's low power levels.  I have 
> ONE 5.4 gig link and it's a 2 mile backhaul.  Can't even think of using it 
> for any meaningful ptmp system out here.  At Ephrata Wa. just last week I 
> ran a scan on a new Mikrotik AP.  The antenna is a VPol Maxrad 45* unit.  In 
> about 1 minute I picked up 99, no that's not a typo, other AP's!  And it was 
> still climbing!  Oh yeah, this AP is nearly 2 miles from the nearest home or 
> business.  If that'll happen at 2.4 just think of the mess we'll have at 
> 600mhz!  Unlicensed whitespaces devices should ONLY be allowed to connect to 
> a registered base station.  It should be nearly impossible to use 
> whitespaces for home/office WLANs.
>     If whitespaces are allowed to operate in an unlicensed way lets open up 
> the indoor only 5.1ghz band that no one uses for high powered outdoor use.
> I know I'll think of a few other items sooner than later.  I'll add them to 
> my filing with the FCC.  I just wish I had have of the talent that Jack and 
> Steve have for writing these things.  It would be great to make my thoughts 
> look as good as the WISPA filing does.
> laters,
> marlon
> _______________________________________________
> FCCcommittee mailing list

Jack Unger - President, Ask-Wi.Com, Inc.
Serving the Broadband Wireless Industry Since 1993
Cisco Press Author - "Deploying License-Free Wireless WANs"
Read my new EBook-"Minimize Your Microwave Energy Exposure from Cellphones"
FCC Lic. #PG-12-25133 LinkedIn Profile <>
Phone 818-227-4220  Email <[EMAIL PROTECTED]>

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