I can tell you myself that I have personally spent hundreds of hours
toward this effort, as has Marlon. As with any group effort there is
no way to please everyone. After exhaustive discussions between
everyone over 3 plus years our FCC committee worked together to
develop a stance. I believe that within our committee Marlon is the
only person who does not support the WISPA filing 100%.  There is no
way to have a vote for everything and frankly we usually see low
turnout for votes or surveys. What we do is have open discussions with
everyone and we try to develop a consensus. This discussion has been
taking place since the beginning of WISPA and nobody has been denied a
chance to speak their wishes regarding this proposed filing.

Please read the plan delivered in the WISPA filing and see what we
have done. We have all developed a plan that EVERYONE except AT&T and
Verizon will support. The only people who cannot live with or should
not support our filing are those who are only happy with having their
own ideas supported exclusively every time. We cannot allow one
person's ideas to control what we file as an organization. We have not
done this with this filing. Our filing represents everyone's ideas as
accurately and fairly  as anyone could have ever done.

I will never try to downplay Marlon's role, or my own for that matter,
but to say this was not a joint consensus position, as Marlon has
said, is just not right. Every part of this has been given lengthy
discussion, thought and effort and it represents a real way for us to
use this band efficiently and effectively to deliver broadband. It is
superior to "wild west" unlicensed-only policy and has every other
advantage of unlicensed supported. In fact it has provisions for pure
unlicensed represented in the plan.

When we get our policies supported in the final FCC Report and Order
of the TV Whitespace then everyone here should know you all played a
strong role in developing what was delivered to the FCC. You should
know that with this policy WISPs will finally be represented fairly in
spectrum policy.

Please read our filing and let your own decision making process decide
whether this filing deserves your support. I know it does even if many
of my own ideas were not part of the final filing. It is the plan for
our future and we should all support it fully.

If there are things you would like to see done differently then by all
means speak your mind with your own filing. We have delivered the
tools directly to you to allow you to speak your mind with the link to
the comment reporting process and instructions on how to do so. Nobody
is being denied a voice. I believe it is possible for all of us to say
we like this in the WISPA filing and that in the WISPA filing but
maybe we wanted to see this added or that changed or this removed. I
see nothing to gain in us arguing amongst ourselves about the process
which led us to this filing. It is the best filing we have ever made
as an organization in form and content and we need to show our support
for it.

With sincerest respect for all,
John Scrivner



On Fri, Oct 24, 2008 at 9:44 AM, Mike Hammett <[EMAIL PROTECTED]> wrote:
> Isn't that what the elected are supposed to do?  Make decisions as to what
> they feel their constituency wants without directly asking them every time?
> If you don't like whomever was voted in, you vote someone in that will speak
> more in line with what you desire.
>
> I would love to hear what others have to say on this issue before I file my
> own comments.  I was going to file saying "Yup, I agree with WISPA" until
> Marlons comments.  Now I want to know what others think.
>
>
> ----------
> Mike Hammett
> Intelligent Computing Solutions
> http://www.ics-il.com
>
>
>
> --------------------------------------------------
> From: "Marlon K. Schafer" <[EMAIL PROTECTED]>
> Sent: Friday, October 24, 2008 1:29 AM
> To: "WISPA General List" <wireless@wispa.org>
> Cc: <[EMAIL PROTECTED]>
> Subject: [WISPA] Raining on the whitespaces parade
>
>> 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
>>
>>
>>
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