Hi All, Here is my first draft of an FCC filing on the 04-186 white spaces issue. To file your own comments go here: http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi
Enter 04-186 into the blue box. Follow the instructions. The main location for filing docs is: http://www.fcc.gov/cgb/ecfs/ You can search for existing filings there. I'd love to have people's input on this filing. Any and all comments are desired, pro or con. I'll try to file this late on Monday..... Dear Ms. Dortch, Odessa Office Equipment is one of the nations first WISP operators. We started our ISP in the spring of 1997 and installed our first wireless system in the winter of 1999/2000. We now cover parts of 4 counties in eastern Washington state. The bulk of our coverage is in western Lincoln and eastern Grant counties. Lincoln county has approximately 10,000 citizens with Grant county coming in at about 40,000. These are also some of the geographically largest counties in the state. We have roughly 6000 square miles of coverage serviced by about 30 transmit sites, most with multiple access points. Due to the low power restrictions in the 5.3 and 5.4 GHz bands we are not able to use those bands to service customers in any meaningful fashion. Almost all of our network has been built using WiFi based devices at 2.4 GHz. This has been mainly due to cost and range considerations. However, as you know the tragedy of the commons has created a huge problem in the 2.4 GHz band. When I first started operations there were a large number of cell phone and public safety backhaul systems in place. Mainly using Western Multiplex (or the older Glenair gear) always on systems that typically used all or most of the band per link. Naturally most of those systems were also located on the higher ground that we also needed to use. Over the years we have gotten quite good at using coverage zone, antenna polarity, and power level tuning to allow us to operate in that environment. But now, most of those systems have been replaced with licensed point to point links. In their place we see a HUGE number of unlicensed devices. In my home town of Odessa a brief scan (about 60 seconds) for WiFI access points done by only one of my AP's shows that it detects around 80 other AP's. This may not seem like many, but please remember that Odessa is in a bowl, nothing is being detected from out of town and there are less than 1000 people living here! In Ephrata, that same test, done from a distance of about one mile and with a 45* sector netted 99 AP's in a one minute scan! We are also seeing a significant problem with system to system interference. Or, self inflicted interference. Due to practical client per AP limitations and interference rejection we often have more than one AP per site. For more info on this problem and how we try to deal with it please see: http://www.wi-fiplanet.com/tutorials/article.php/3756431 As you can see, a better standard in an outdoor friendly band is desperately needed if we are to meet the next decade's needs in the broadband industry. As the only viable 3rd rail of broadband the FCC should insure that WISPs can continue to service rural un or under served markets as well as force competition in more dense markets. By and large I agree with WISPA's stance on Whitespaces. A licensed lite approach brings several self evident advantages to the table. I fully support the concept. Knowing that almost all WISPs are self funded and often self staffed it's important that care be taken to insure that any licensing mechanism is inexpensive in both dollars and time. I also agree that much higher power levels are needed today in much of the country. If there are trees in the area it takes power to penetrate them in meaningful distances. In open ground long distances are needed (30 to 40 mile cell sizes should be an option). In my area we have rolling hills, tree lines as windbreaks and line of site in the 50 to 60 mile ranges. 30 to 40 mile line of site is commonplace. We have to reach out a LONG way and be able to plow through the windbreaks (sometimes several). We also have to have sufficient capacity on those long range networks to use them as feeds to repeaters as we shoot down the canyons in our area. Personally, I'd like to see extremely rural areas allowed to use even more than 20 watts of transmit power at the radio. I'd like to see a scale, something like 200 miles from a top 50 MSO, 40 watts. Less than 200 miles 20 watts. Maybe 10 or 20 miles would be 10 watts or less. I'd also like to see a geolocation and/or sensing mechanism put in place under the rules. Set reasonably high standards of protection for the broadcasters then let the manufacturers find ways to meet the standards. Allow 20 watts for geolocation and 40 watts when sensing works the way it's supposed to. Whitespaces devices should not need to rely on "circles on a map" as these never quite reflect the reality of coverage. Hills, buildings, noise levels etc. never show up. I know, we use that method for some of our marketing. It's a good estimate, but signal checks are still the only really effective mechanism for finding coverage zones. The new devices should be held to a high standard for OOB emissions. I think there should be two different standards. In one standard the devices aren't allowed to use the adjacent channels. But if a device is able to limit it's OOB emissions sufficiently to protect the broadcasters the adjacent channels should be allowed to be used. It's also time to start implementing some of the Spectrum Policy Task Force's (SPTF) suggestions for improving the way spectrum is used. TV broadcasting has remained basically static for what, 50+ years now? Same channel sizes, same power output etc. With the change to DTV the commission should follow it's own advice and implement receiver standards instead of only transmitter standards. Whitespaces devices AND TV sets/converters should both be held to a minimum OOB rejection level of some kind. I don't know what the receive sensitivity is on the average TV set but based on performance in my local area it's not very good these days. I think I've run into less than 5 homes using over the air TV in the last 2 or 3 years. When it became possible to get local channels via sat. signals everyone moved to the better picture mechanisms that come with non broadcast services. The SPTF also suggested that we start looking at time sharing as well as spectrum sharing. I'd suggest that all AP's be required to sync transmit cycles with each other, much the way that the Motorola Canopy product currently does in 5 GHz. A second should be carved up into x time slots. As VoIP calls need delays of 200ms or less I'd suggest that a second be cut up into at least 50 time slots. 100, maybe even 500 would likely be even better. Each AP would be allowed to use all time slots as long as it didn't need to share space with another system. When another system needed to use the same channel (lets say we're operating in an area that TV channels and adjacent channels have only left 4 available channels) each AP would split the available time slots. This would, for all practical purposes, eliminate base station to base station catastrophic interference like that from the self inflicted interference article mentioned above. It would also place some level of pressure on the manufacturers to create devices able to push as much data as possible down the pipe in as short of a time as possible. All Whitespaces devices should act as an intelligent network. All CPE devices should sense and report to the AP's. The AP's should sense and be aware of other AP's in the area. The AP's should then use the information that they've gained to automatically set channels, power levels, time slots etc. on the fly and without operator intervention. All Whitespaces AP's should also issue owner contact information as well. WiFi systems will tell scanners what channel they are on, what their name is, MAC address, IP address etc. I think these new devices should NOT have the option of hiding. They should tell anyone that has the right tools to look, what channels they are on and who owns them as well as how to contact that owner (via phone and/or email address). ATPC (automatic transmit power control) should also be built into Whitespaces devices down to the transmission level. With base stations dictating who will transmit at what time it should be reasonable to expect the AP and client to only transmit at the power levels needed to maintain stable connections based on receive signal levels at each device. With ATPC we should be able to run our systems at 5 to 10 dB of fade margin and still maintain great links. Time slot mechanisms that prevent system to system competition for broadcast times would also help to limit the amount of fade margin that's needed. WISPA's proposal to give first in rights to those that build first is a bad idea. It effectively gives large companies or well funded venture firms a nearly exclusive hold on the most lucrative markets. That will also effectively stifle innovation and competition in a few short years. The time slot mechanism allows for competition while also protecting existing investments. I say this as the operator that was first in in most of my current markets. On one hand I'd love to have been able to keep others out of my areas, as a successful entrepreneur I understand the value of consumer choice. I've got very mixed opinions on personal portable devices and WLANs. I don't think that the propagation properties of sub 1 GHz bands make for a particularly good home or business LAN mechanism. If low powered 2.4 GHz devices will travel through walls and trees and still create interference within the band at distances far greater than they are said to go, how bad will the tragedy of the commons become for Whitespaces devices? Plus there is already a LOT of spectrum available for WLANs. In fact there is a 5.1 GHz indoor ONLY band that should maybe be tweaked to encourage more utilization. If personal portable devices are to be allowed they should only be allowed to link with registered base stations. This would help to avoid the tragedy of the commons while also giving the benefits of mass market production economies of scale. Personal portable devices could also then be reasonably allowed to use much higher power levels and have far greater ranges than have been suggested thus far. MAN and public safety networks would then become a practical reality. The Commission should also take this opportunity to set new max channel size limits on systems. We should not ever have devices that transmit on large channel sizes even when they have no payload to deliver. Again, this should be used as a chance to design mechanisms intended to drive innovation and efficiencies into the available spectrum. In a nutshell Whitespaces devices should: Allow for either or both geolocation and sensing. Not allow for personal portable or indoor only networks. Set high standards of incumbent protection but not disallow any unused spectrum. Set receiver standards. Allow for market innovation by setting standards based almost exclusively on device emissions rather than defining how that's accomplished. Protect any existing operator be that a broadcaster or a network operator. Foster innovation in spectral efficiencies. Set max channel size limits. These suggestions, if properly implemented would strongly protect the current licensed users as well as encourage tremendous new opportunities. And, by using ATPC and time sharing we'd also protect any new networks from predatory products. Thank you for your consideration, Marlon K. Schafer (509) 988-0260 cell Owner, Odessa Office Equipment Founding board member, WISPA FCC Committee member, WISPA Former FCC Committee chairman, WISPA -------------------------------------------------------------------------------- WISPA Wants You! Join today! http://signup.wispa.org/ -------------------------------------------------------------------------------- WISPA Wireless List: [email protected] Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
