today, yeah. But give it a couple of years..... marlon ----- Original Message ----- From: "Mike Hammett" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]>; "WISPA General List" <wireless@wispa.org> Sent: Sunday, October 26, 2008 10:09 AM Subject: Re: [WISPA] Whitespaces filing
> On the multiple TV channels on the same RF channel... I believe in that > case, it's 1x HD or multiple SD. In the age of HD, you still only get 1 > channel. > > > ---------- > Mike Hammett > Intelligent Computing Solutions > http://www.ics-il.com > > > > -------------------------------------------------- > From: "Brian Webster" <[EMAIL PROTECTED]> > Sent: Saturday, October 25, 2008 11:52 PM > To: "WISPA General List" <wireless@wispa.org> > Subject: Re: [WISPA] Whitespaces filing > >> Marlon, >> This is probably one of your best filings to date. Nicely done and well >> written. I have a few comments and/or suggestions in line. >> >> >> >> Thank You, >> Brian Webster >> www.wirelessmapping.com <http://www.wirelessmapping.com> >> >> >> -----Original Message----- >> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] >> Behalf Of Marlon K. Schafer >> Sent: Saturday, October 25, 2008 1:53 PM >> To: WISPA General List >> Subject: [WISPA] Whitespaces filing >> >> >> 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 TV contours we are talking about protecting are not just simple >> circles on a map. They are based on the FCC criteria (for which I can not >> quote off the top of my head, but it is published) that the broadcasters >> must submit which then defines that particular TV station contour. I have >> attached a map image for the state of Washington showing all the combined >> analog and digital TV contours for ALL channels on file with the FCC. >> Many >> of them overlap and some look like circles because if you do an RF >> propagation at some of these sites using 50,000 watts you will get pretty >> close to a circle result. These contours are part of the criteria we are >> proposing to use in the goelocation database. Those contours are already >> defined by the FCC and we are obligated to protect those licensed users >> for >> that particular area. It's not a random choice and it's certainly not >> just >> a >> circle drawn on a map. This comes from years of already established RF >> engineering principles and rules. Some of those defined by the >> International >> Telecommunications Union (ITU) and thus by treaty, the FCC and US >> government >> are obligated to obey. You can further drill down on this type of data by >> channel. I also attached images showing only the UHF contours and one for >> only channels 31 and 32. Keep in mind these images include the current >> analog stations. Once they go off the air this picture will change a >> great >> deal. The maps are just meant to illustrate that this is a much more >> complex >> process than just drawing circles on a map. This also should help >> illustrate >> exactly what the white space spectrum potential can be nationwide when >> looked at channel by channel. >> >> 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. >> >>>>>> I don't know if you have tried off the air digital TV yet but you >> should. First of all the current stations are running a fraction of their >> concurrent analog station power levels. This is to protect adjacent >> market >> analog stations on the same channels. Once February comes around they >> will >> be turning those DTV stations up to maximum power. I have used a few >> devices >> with ATSC digital tuners in them and I can tell you there is one hell of >> a >> difference in DTV over analog. It looks just like satellite quality when >> it >> works and if you compare it to the same analog broadcast, I have seen >> some >> stations look perfect in DTV where I could hardly make out the picture in >> analog mode. Another thing the DTV broadcasters have the option of doing >> is >> to multiplex up more than one programming channel on their broadcast in >> digital. I have seen many stations run three or four separate channels on >> their DTV carrier. That up to a 4 fold increase in spectrum efficiency. >> You >> may want to reconsider your point on that subject. >> >> 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. >> >>>>>> WISPA's proposal does not give anyone first in rights. We were very >> careful in our wording to not take that position and the use it or lose >> it >> clause was put in there to try and minimize the spectrum campers from >> doing >> what you express (it has always been a concern of mine as well and that >> point was always made clear to the committee). Nowhere does it state >> there >> are first in rights. We have proposed that there are requirements for >> notification of a new site to anyone else on that frequency registered in >> the database and that there is record of such notification so that there >> is >> ample time for both parties to work out their technical details to avoid >> interference to each other. After the 30 days they are still able to >> construct even if there is no response from the other operators. If there >> are interference issues the documentation will help the FCC deal with the >> problem. This is one of those times when two operators could do things >> like >> share their time slot information to best occupy the spectrum. We did not >> try and nail down the full technical details given the time constraints, >> but >> we felt the language was such that it would allow those details to be >> worked >> out later as part of any final order issued by the FCC. >> >> 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: wireless@wispa.org >> >> Subscribe/Unsubscribe: >> http://lists.wispa.org/mailman/listinfo/wireless >> >> Archives: http://lists.wispa.org/pipermail/wireless/ >> > > > >> >> >> -------------------------------------------------------------------------------- >> WISPA Wants You! 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