Here's version number 2:

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 (sp?) 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:

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.

This may also be a good time to tie the right to use spectrum to the 
existing reporting requirements.  I disagree that the government has any 
business requiring compliance with the form 477.  It's more important that 
coverage zones be tracked than customer bases.  And if the government wishes 
to know such information they should spend the time and money to gather the 
data, not pass those expenses onto us.  However, I can see a case being made 
that only those that follow the rules and file their 477's should have 
access to any possible new bands.  I'm not advocating for or against this 
stance, just tossing out the idea for consideration.

I also agree with WISPA, fiber tower and others,  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 at meaningful distances.  In open 
ground long distances are needed (30 to 40 mile cell sizes should be a 
viable option).  In my area we have rolling hills, tree lines as windbreaks 
and line of site in the 50 to 60 mile range.  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.  I also understand that the current 
contour mechanism used for TV station coverage zones are not just circles on 
a map.  They do not reflect reality either.  According to a map prepared by 
Brian Webster of WISPA's FCC committee I should have access to nearly 10 
over the air stations.  I can promise you that there are not anywhere near 
that many stations showing up on my TV set.  At least there weren't a couple 
of years ago when I got my local stations via satellite.

Any new Whitespaces 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, adjacent channel use should be allowed.

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.  It's clear that DTV signals will result in better picture 
quality, until there is no picture at all.  No more snow, it'll work or not. 
Some people think that it's likely that the public will go back to broadcast 
TV due to it's superior quality to compressed cable or satellite signals. 
This may be true one day, I think that setting tight adjacent channel OOB 
standards and appropriate TV receiver standards both systems can exist and 
service the public need nicely.

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 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 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.  On the other hand, 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 

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.

I don't think it's fair to rule out sensing technologies just yet.  How much 
effort was really expended on the concept yet?  As a manufacturer I'd not 
have put very much time or money into the problem when there is no actual 
need for it yet.  What would have happened by now if, in 2004, the 
commission would have said, something like:  "If, in November of 2008, there 
are effective sensing devices we will allow their use in TV Whitespaces." 
I think we'd have seen a LOT more work on Whitespaces specific devices.  As 
it is the only resource a smart company would have put into this project is 
play time and play money.  The kinds of things that we try out in a 
production environment just to see if we can make it work.  If we learn 
something for it, that's great, if we don't it was still fun to try.  But it'll 
only be done with otherwise excess funds and spare time.  Set the standards 
high then lets see what the market can come up with.

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 a regulatory environment 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 

    Set receiver standards.

    Allow for market innovation by setting standards based almost 
exclusively on device emissions rather than defining how that's 

    Protect any existing operator be that a broadcaster or a network 

    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 
technological innovation.  And, by using ATPC and time sharing we'd also 
protect any new networks from predatory products.

Thank you for your concideration,

Marlon K. Schafer

(509) 988-0260 cell

Owner, Odessa Office Equipment

Founding board member, WISPA

FCC Committee member, WISPA

WISPA Wants You! Join today!
WISPA Wireless List:



Reply via email to