Make sure to comment to the fcc about this. Get involved and ensure your voice 
is heard. 



"Fred Goldstein" <[email protected]> wrote:

>At 9/23/2010 04:50 PM, Brian Webster wrote:
>
>>If you are on a high mountain and there are also a lot of other high 
>>locations around you your HAAT number could still be low. If however 
>>you are on a high mountain and the rest of the area all the way 
>>around your site is much lower, your HAAT figure will go up. Sites 
>>built on side hill locations with the hill rising above in part of 
>>the radius will greatly reduce the HAAT number.
>>
>><http://www.fcc.gov/mb/audio/bickel/haat_calculator.html>http://www.fcc.gov/mb/audio/bickel/haat_calculator.html
>
>A subscriber's house is wherever it is, and under the new rule, they 
>are just not allowed to subscribe if it is more than 76 meters 
>AAT.  This doesn't have to be on top of the high mountain.  If you 
>have RadioMobile, you can click around some potential sites and use 
>its US-mode HAAT function.  I found a lot of places that would be 
>shut out.  Try the "hill towns" in Berkshire County, MA, or just to 
>its east, so see what I mean.  Heck, these are so hilly and woody 
>that the VHF channels look most attractive.  (Not that they're 
>available; only one upper-VHF is actually vacant there.)  Only a 
>handful of channels meet the white space criteria there to begin 
>with.  I have the FCC's contours showing in MapInfo so I can click 
>anywhere on its map and see which contours I'm within.  And of course 
>for co-channel, I have to look for contours about 10 miles beyond.
>
>If a significant number of subscribers are shut out, not to mention 
>the necessary access points to reach them, then we're stuck again on 
>900 MHz, which is pretty busy.  So even with a white space access 
>point to reach the low houses, we'd need the 900 too to reach the 
>high houses.  How silly.
>
>>
>>"How is the HAAT determined?   A HAAT value is determined by taking 50
>>evenly spaced elevation points (above mean sea level [AMSL]) along at least
>>8 evenly spaced radials from the transmitter site (starting at 0 
>>degrees [True North]). The 50 evenly spaced points are sampled in 
>>the segment between 3 to 16 km (formerly 2 to 10 miles) along each 
>>radial. The elevation points along each radial are averaged, then 
>>the radial averages are averaged to provide the final HAAT value. 
>>Terrain variations within 3 km (2 miles) of the transmitter site 
>>usually do not have a great impact on station coverage."
>>
>>Brian
>>
>>
>>
>>
>>
>>
>>From: [email protected] [mailto:[email protected]] 
>>On Behalf Of Fred Goldstein
>>Sent: Thursday, September 23, 2010 4:36 PM
>>To: WISPA General List
>>Subject: Re: [WISPA] Transmit Antenna Height
>>
>>This item alone may be the show-stopper, the poison pill that makes 
>>it useless to WISPs in much of the country.
>>
>>In places where the routine variation in elevation is more than 75 
>>meters, there will be houses (subscribers) that are more than 76 
>>meters AAT.  I notice this in the areas I'm studying, both in the 
>>east and in the upper midwest.
>>
>>In a place like Kansas, nobody is >75m AAT.  But in the woody 
>>Berkshires of Western Massachusetts, the UHF space is needed to get 
>>through the trees, and a significant share of houses are >75m 
>>AAT.  Also, if you want to cover a decent radius, the access point 
>>needs to be up the hill too.  75 meters isn't a mountaintop; it's 
>>just a little rise.
>>
>>It makes no sense to absolutely ban fixed use at a site that is 100m 
>>AAT if the nearest protected-service contour is, say, 50 miles 
>>away.  A more sensible rule would be to follow broadcast practice, 
>>and lower the ERP based on height, so that the distance to a given 
>>signal strength contour is held constant as the height rises.  Hence 
>>a Class A FM station is allowed up to 15 miles, and if it is more 
>>than 300 feet AAT, then it is allowed less than the 3000 watts ERP 
>>that apply at lower heights.
>>
>>Maybe the lawyers want to have more petitions to argue over.
>>
>>At 9/23/2010 04:07 PM, Rich Harnish wrote:
>>
>>
>>65. Decision. We decline to increase the maximum permitted transmit 
>>antenna height above ground for fixed TV bands devices. As the 
>>Commission stated in the Second Report and Order, the 30 meters 
>>above ground limit was established as a balance between the benefits 
>>of increasing TV bands device transmission range and the need to 
>>minimize the impact on licensed services.129 Consistent with the 
>>Commission's stated approach in the Second Report and Order of 
>>taking a conservative approach in protecting authorized services, we 
>>find the prudent course of action is to maintain the previously 
>>adopted height limit. If, in the future, experience with TV bands 
>>devices indicates that these devices could operate at higher 
>>transmit heights without causing interference, the Commission could 
>>revisit the height limit.
>>
>>66. While we expect that specifying a limit on antenna height above 
>>ground rather than above average terrain is satisfactory for 
>>controlling interference to authorized services in the majority of 
>>cases, we also recognize petitioners' concerns about the increased 
>>potential for interference in instances where a fixed TV bands 
>>device antenna is located on a local geographic high point such as a 
>>hill or mountain.130 In such cases, the distance at which a TV bands 
>>device signal could propagate would be significantly increased, thus 
>>increasing the potential for interference to authorized operations 
>>in the TV bands. We therefore conclude that it is necessary to 
>>modify our rules to limit the antenna HAAT of a fixed device as well 
>>as its antenna height above ground. In considering a limit for 
>>antenna HAAT, we need to balance the concerns for long range 
>>propagation from high points against the typical variability of 
>>ground height that occurs in areas where there are significant local 
>>high points – we do not want to preclude fixed devices from a large 
>>number of sites in areas where there are rolling hills or a large 
>>number of relatively high points that do not generally provide open, 
>>line-of-sight paths for propagation over long distances. We find 
>>that limiting the fixed device antenna HAAT to 106 meters (350 
>>feet), as calculated by the TV bands database, provides an 
>>appropriate balance of these concerns. We will therefore restrict 
>>fixed TV bands devices from operating at locations where the HAAT of 
>>the ground is greater than 76 meters; this will allow use of an 
>>antenna at a height of up to 30 meters above ground level to provide 
>>an antenna HAAT of 106 meters. Accordingly, we are specifying that a 
>>fixed TV bands device antenna may not be located at a site where the 
>>ground HAAT is greater than 75 meters (246 feet). The ground HAAT is 
>>to be calculated by the TV bands database using computational 
>>software employing the methodology in Section 73.684(d) of the rules 
>>to ensure that fixed devices comply with this requirement.
>>
>>130 The antenna height above ground is the distance from the antenna 
>>center of radiation to the actual ground directly below the antenna. 
>>To calculate the antenna height above average terrain (HAAT), the 
>>average elevation of the surrounding terrain above mean sea level 
>>must be determined along at least 8 evenly spaced radials at 
>>distances from 3 to 16 km from the transmitter site. The HAAT is the 
>>difference between the antenna height above mean sea level (the 
>>antenna height above ground plus the site elevation) and the average 
>>elevation of the surrounding terrain.
>>
>>67. In reexamining this issue, we also note that the rules currently 
>>do not indicate that fixed device antenna heights must be provided 
>>to the database for use in determining available channels. It was 
>>clearly the Commission's intent that fixed devices include their 
>>height when querying the database because the available channels for 
>>fixed devices cannot be determined without this information.131 We 
>>are therefore modifying Sections 15.711(b)(3) and 15.713(f)(3) to 
>>indicate that fixed devices must submit their antenna height above 
>>ground to the database.
>>
>>68. We continue to decline to establish height limits for 
>>personal/portable devices. As the Commission stated in the Second 
>>Report and Order, there is no practical way to enforce such limits, 
>>and such limits are not necessary due to the different technical and 
>>operational characteristics of personal/portable devices.
>>
>>  --
>>  Fred Goldstein    k1io   fgoldstein "at" ionary.com
>>  ionary 
>> Consulting                <http://www.ionary.com/>http://www.ionary.com/
>>  +1 617 795 2701
>>
>>
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>
>  --
>  Fred Goldstein    k1io   fgoldstein "at" ionary.com
>  ionary Consulting              http://www.ionary.com/
>  +1 617 795 2701 
>
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