At 1/13/2011 02:40 PM, Michael Mulcay wrote:
...
The FCC committee was correct as spectrum is the life blood of all
WISPs and conservation of spectrum is absolutely essential.
Of course. I read your presentation, and some of the Reply Comments
and other parties' views. So please take my criticism as constructive.
You shot yourself in the foot with your opening pages. The whole
routine about obstructionism, and the stories about cars being
disassembled near animals, serves to alienate you from the skilled
technical people at the FCC who have to make these decisions. Part
101 is not as politically charged as, say, Part 51. Your story could
easily be construed as an insult. In fact it is hard to construe it
otherwise. This doesn't win cases. (Do you see this as being how
it's taken? "Aw, he called me a name. I guess I'll have to adopt
his position, so he doesn't call me a name again.") FCC submissions,
including WISPAs, are normally very diplomatic.
Second, your repeated references to millions of paths being lost are
clearly hyperbole. Yes, technically, there could be a zillion paths,
but the demand for any one of those paths is miniscule. The only
ones that matter are the ones that people will use.
There are essentially three types of path. Fixed point-to-point
paths, fixed point-to-multipoint, and mobile. Part 101 is about the
first category. WISPs usually deal in the second. CMRS is about the
third. "Auxiliary stations" are essentially a way to turn Part 101
into what it isn't, fixed point-to-multipoint.
Now I *do* agree that the FCC has set aside too little spectrum below
28 GHz for that purpose. IIRC there was once a 10 GHz allocation,
based on the 1980ish Petition of Xerox for what they were planning to
call XTEN but abandoned. This was called Digital Termination Systems
and I don't know if any such licensing still exists, but it was
narrowband. I have a slide set here from 1982 from a company (LDD)
that was building a 10 GHz DTS PtMP system called RAPAC, which shared
technology with their other product, the CAPAC -- probably the first
cable modem! But they tanked. I think the MMDS->BRS band is
authorized for PtMP, but licensed/auctioned, making it
inaccessible. So I do see the need.
But Part 101 is all about using conventional means (narrow beams,
narrow bands) to squeeze in as many PtP users as possible via
coordination, not auctions. It works pretty well. As some of the
Reply Comments noted, the alleged "keyhole" for auxiliary stations
doesn't really exist very often; with high-performance (good F/B
ratio) antennas and modest transmitter power (<70 dBm EIRP, <1 W
TPO), back-to-back stations can coexist. But TDD and FDD also risk
compatibility problems, and most of Part 101 is FDD, while your
proposal is TDD. So it might make more sense to push for more
spectrum elsewhere, rather than use self-defeating hyperbole to fight
Part 101 interests head-on.
--
Fred Goldstein k1io fgoldstein "at" ionary.com
ionary Consulting http://www.ionary.com/
+1 617 795 2701
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