Michael, I'd welcome your response on my comments in this Email.....
First, I'll mention... WISPA's FCC committee filed comments in support of Auxillary Station use in sub 13Ghz bands. This support was based on the benefits made possible by the methodology, where most concluded that the benefits outweighted any negatives. However, I personally am a bit more sceptable to Auxillary station use. I believe in some cases it clearly would be beneficial, but it also had the potential to be harmful if there were not some limits imposed. I read your presentation, and it makes many good points. The most relevent point in which I agree is..... "Every mopnth thousands of new licenses are issued fo primary stations when many of the services could have been provided by auxilary stations ... and for every license issued.... millions of future paths are blocked". But there is also a flip side, that is possible that is ignored in that comment. The Wireless Strategies's position is based assuming that people would use Auxilary stations instead of buying a primary path, if it was possible to accomplish the desired link with an Auxilary station. I would argue that that is not likely the case and does not match behavior in the industry observed through history. Instead, obtaining spectrum is like a land fight, with the goal to obain as much as possible as fast as possible. As those ending up with the most spectrum rights when spectrum runs out will be the one standing with the most potential to grow, over those that were not lucky enough to obtain such spectrum because they were slower financially. It is my belief that ALL prospective stakeholders are likely to ALWAYS buy the Primary Path rights, if it is still possible to obtain a primary path right. Why? Because its cheaper to buy PArt101 spectrum than Auctioned spectrum. Especially, if it can be multi-used for PtMP. In actuality, many stakeholders might buy Part101 primary licenses that they dont even need, because the value of the PTMP auxilary station use of the path may far exceed the cost of a PArt101 single primary path license. In otherwords, Allowing Auxilary stations, could encourage a race to buy up all the remaining sub 13Ghz PArt 101 spectrum as soon as possible. With Auxiliary station use, a stakeholder could count the number of buildings/homes servable and estimate the odds of obtaining customers, and because when the primary path license price is divided by the number of businesss/homes servable yeilds a cost so low per building, it more likely large companies will buy licenses way before they actually need them. For example, lets say a provider finds a new prospective customer that needs 20mbps. This is a link that could very easilly be served via Unlicensed Part-15 spectrum or via a small licensed channel (such as 5-10Mhz). However, instead this 20mbps order becomes an opportunity to fund the purchase of a 300mbps 40Mhz PArt101 License, even though it is more than is needed to serve the client order. $3000 license fee is a small price to then be able to have licensed Spectrum to serve PTMP. As well, with the intent to share tower radios between multiple remote CPE buildings, the justification for larger capacity channels is there. So stakeholders would chose 40Mhz channels over 10mhx channels even when they aren't needed. Your presentation charts are flawed because it does not show how many combinations of links would be possible if license holders selected smaller channel licenses, which would enbable more combinations of PTP links that would not interfere. At the end of the day, those that already own all the Part101 licenses in an area would have unjust rights to use Auxilary station in the area over others. The rate these pre-existing license owners paid, may have been based on single link, and it would be unfair for them to gain PTMP rights with out additional license payments. In other words, LArge Telcos like Sprint, ATT, FiberTower would gain new PTMP spectrum via Auxilary stations (meaning to cover additional areas with existing licenses) for FREE when they are the ones that can afford to Auctioned spectrum, but yet smaller companies that ahve a hard time affording PArt101 licenses would not gain ease in buying primary spectrum faster. What I'd suggest is Auxillary station rules that would promote the use of Auxilary stations first isntead of Primary, and that would also assess a cost to Auxilary stations high enough, that stakeholders would not increase the rate of buying a primary license based on the value of auxilary stations potential. For example, what if an Auxilary station license would cost 1/4 the price of a PArt101 primary license? It would encourage stakeholders to use Auxilary stations first. It would also enable more efficient use of PArt101 spectrum. But the cost is still high enough that stakeholders would not pre-buy part101 spectrum with out actually need, because the Auxilarystation financial benefit is limited, and a primary license purchase would need to be justified on the PArt101 primary license need alone. It would also make Part101 licenses more affordable for small companies, because they could spread the cost of a Part101 primary license over 3-4 customer orders. My point here is that.... There is a huge need for PTP backbone spectrum, that is NOT shared with multiple points. It is a substantion need that every ISP or WISP needs to get high capacity to its remote cell sites. It requires 300-400mbps backbones in today's INternet Broadband world. This PTP spectrum is in shortage. The last thing we want is to repurpose PTP spectrum to PtMP at the expense of it no longer being available for PTP. The last thing we want to do is give the first in LArge Telco an advantage to gain cheap spectrum with out small operators able to do the same, because someone else already owns the license. Instead, I'd argue whether the existing license holder really needs the fulll width license channel they are using. The beauty of Part101 spectrum is most people wont buy it until they think they need it, so its available for those that may need it in the future.. Giving Auxillary station use may change that mentality. In my opiinon, in order to support Auxilary stations, we must assess a fair cost to each Auxilary station license, or give every party the right to deploy equipment in the area that would not cause interference to the primary holder. For example, that area unserved by the primary beam, could be allocated for unlicensed secondary use at low power, at a power level not possible to interfere with the primary. That would allow all providers to gain access to that vacant area. What I think is that owners of PTP licenses dont have enough free capacity to share it with PTMP. Instead, they are likely to just buy two links. One that can be used in PTMP, and one that can be used for dedicated backbone. Thus buyign twice as many licenses than they previously needed. The second thing I see happening is that pre-existing license holders will build fiber to their towers for backhaul, so they no longer need their PArt101 licenses for backhaul. But instead of returning the PArt101 licenses back to the FCC pool of available channels, they will unjustly keep them for auxilary stations a different purpose than the part101 license was originally granted for. This would give pre-existing part101 license holders unfair access to hord spectum meant for another purpose. If these tower gain fiber, the Spectrum should be given back so those that dont have fiber can use the spectrum for PTP. I recogize that Auxilary station may have different models of use. For example, 1 might be to sahre a single radio on a tower between multiple end points. Another example might be to use seperate radios, but have the auxilary station use radios at lower power that would not interfere with the primary link. I'm concerned that license applicants will select wider beam dish antennas at their shared tower side, calculating that they'll gain better coverage for Auxilary stations, thus once against reducing the number of possible PTP links in an area. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband ----- Original Message ----- From: michael mulcay To: 'WISPA General List' Sent: Sunday, January 09, 2011 9:03 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question In comments and reply comments to the FCC's NPRM WT Docket 10-153; AT&T, Verizon and Comsearch et al are proposing that the FCC impose unnecessary regulation on the operation of radios with adaptive modulation and they oppose the FCC's proposal to allow the use of auxiliary stations in licensed frequency bands below 13GHz. The FCC's auxiliary station proposal would permit the use of small antennas and make it feasible to operate PTP and PTMP. This would make it possible for equipment manufacturers to re-band their unlicensed band equipment to operate in licensed bands with small antennas, thereby lowering licensed microwave CAPEX and OPEX (Exalt has already re-banded their TDD equipment to operate in the 5.9 - 6.4GHz and 10.7 - 11.7GHz licensed bands). With a ruling by the FCC to not impose unnecessary regulation on adaptive modulation and to allow the use of auxiliary stations, WISPs would have the tools to compete in all markets, including the rapidly growing licensed microwave markets for backhaul and access. Power Point slides used by WSI at its December 8th 2010 ex parte meeting with the FCC, opposing additional regulation on adaptive modulation and supporting the use of auxiliary stations, are attached. Mike Wireless Strategies Inc. 831-601-0086 From: [email protected] [mailto:[email protected]] On Behalf Of Tom DeReggi Sent: Friday, January 07, 2011 11:22 AM To: WISPA General List Subject: Re: [WISPA] 11Ghz Licensing Warning Question On a License application, one must state the modulation that they will use or state that they will use adaptive modulation. Legally one is supposed to configure their equipment for what was approved. And there are reasons for that, regarding the freq Coordination. For example.... If in QAM 256, one must have a lower noise floor and a higher signal to acheive reliabilty. For example... a link might state to operate at -35 and as low as -64 in rain fade, and maintain a SNR of 30db, so no one else can generate over a -94 noise floor, or they would interfere. If in QPSK, one might say they can operate at a sensitivity as low as -90. and only need 10db of SNR. That would mean either that.... Others could deploy if they did not generate more than -100 noise floor, or that if the Primary link operated at -35, as low as -64 in rain fade and maintain SNR of 10db, that the someone else could deploy without causing interference if theey did not generate a noise floor over -75. Either way, there is a big difference between -75 and -100 and -94. What level can a new license holder broadcast at, if the specs of other license holders are not consistent? If a licensee was able to put there gear on any modulations, it would require others new licensees to plan for worst case, and not generate noise higher than -100, limiting them. Thus it would only be fair if the provider actually used Adaptive modulation. The question them come ups, if one states adaptive modulation, but then does not use it, what harm is there and who would know ? After all it could allow the provider to also lower there transmit in non-rain cases. If someone states 256QAM, and does Adaptive modulation anyway, isn't it just giving risk to the one that stated incorrectly? So yes, I support allowing flexibilty in setting adaptive modulation or not, after the fact. The original license holder should be able to maintain flexibilty. Tom DeReggi RapidDSL & Wireless, Inc IntAirNet- Fixed Wireless Broadband ----- Original Message ----- From: michael mulcay To: [email protected] ; 'WISPA General List' Sent: Friday, January 07, 2011 7:54 AM Subject: Re: [WISPA] 11Ghz Licensing Warning Question Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you lock the equipment in a non adaptive mode? Mike Wireless Strategies Inc 831-601-0086 From: [email protected] [mailto:[email protected]] On Behalf Of Scott Carullo Sent: Thursday, January 06, 2011 2:46 PM To: [email protected] Subject: [WISPA] 11Ghz Licensing Warning Question Comsearch has this to say on one of the sites in coordination, anyone know what it is supposed to mean? They are closed now, I'm not being patient sry :) Path Warnings Document FCC Rule Part(s) Description Result / Action N/A site1 Radio Equipped with Adaptive Modulation. Review Radio Parameters N/A site2 Radio Equipped with Adaptive Modulation. Review Radio Parameters 101.31 (b) (1) (ii) site1 - ASR may be required based on C/L Height. Verify/Change Antenna Height or File with FAA N/A site1 Failed Glide Slope or Height requirement. Verify/Change Antenna Height or File with FAA Thanks Scott Carullo Technical Operations 855-FLSPEED x102 ---------------------------------------------------------------------------- -------------------------------------------------------------------------------- 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/ ------------------------------------------------------------------------------ -------------------------------------------------------------------------------- WISPA Wants You! 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