At 1/14/2011 01:31 AM, Michael Mulcay wrote:
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Fred,
Tom DeReggi's comments were business-case based and constructive;
basically exploring whether the Commission's NPRM on auxiliary
stations would benefit the large operators or WISPs or both. In
WSI's opinion the answer is both, but with WISPs getting the higher
business growth percentage. Frankly, I do not see anything in your
position that would benefit the WISP community.
You do not know my position. What I was pointing out was twofold.
One, your technique was bad; two, there are valid reasons (which Tom
has spelled out well) to see the WSI position as not being a certain
win for the WISP community. BTW I am not necessarily opposing all
auxiliary-station use. But your presentation to the FCC doesn't make the case.
Further, I have nearly thirty years of experience working with the
FCC, initially with the Xerox XTEN filing, and later, at Western
Multiplex as VP of Business Development I wrote the request for a
Rule Making and an Immediate Waiver of the Rules pending a Rule
Making to allow unlimited EIRP in the 2.4GHz and 5.8GHz ISM bands.
Both were granted (with the 1 for 3 rule at 2.4GHz) and we were
able to take Western Multiplex from the "Living Dead" (profitable
with no growth) to a "Star Performer" (rapid profitable growth),
growing the company by 25%, 50% and 100% in three consecutive
years. I believe that auxiliary stations can give WISPs the same
type of growth opportunity.
I am guessing that in those cases, you didn't begin a presentation by
putting a pointed set of insults (the whole obstructionism bit) into
the Record. Your slide set might have been entertaining at a WISPA
conference, or as a political broadside aimed at outsiders whose
views of the FCC you wish to lower. But as a presentation to be
mainly read by the professional staffers at the FCC, who are for the
most part dedicated, competent people whose work is fettered by
politics from above, it struck me as counterproductive. They do not
want to be insulted.
Most of my regulatory work is in the Part 51 area (mainly CLECs),
which is predominantly political. What technical questions arise
there are usually resolved on a political, not fact-based, basis,
mainly as cover for an industry position. I still harbor some
illusions that Part 101 and Part 15, to give two examples, are
handled on a somewhat more honest basis, with technical rather than
political judgement being most important. The current version of the
old joke is that the FCC staff is 1500 lawyers and Stagg Newman, but
I know there are really a few other engineers left to help keep Stagg
sane. To be sure, WTB is rather politicized, and my own experiences
with them are not so good, but a lot of that has to do with internal
politics and silos. I think the auctioned spectrum is subject to a
lot more political pressure.
I believe your last paragraph summarizes your view, so I will
address this paragraph.
"But Part 101 is all about using conventional means
Wrong -- Part 101Fixed Service rules are about the use of spectrum
for Fixed Services, fortunately not about "conventional" means as
this would preclude innovation.
I have no problem with innovation. As you might have noted, I think
there's good reason to have more PtMP services, like a new updated
DTS. And indeed I do think that some of the current requirements of
Part 101 Fixed Services lead to excessive cost. Especially outside
of the most congested areas, for instance, smaller antennas, with
less wind loading, would be most useful. My comment on narrowband is
that they require very high spectrum efficiency (hence the whole
issue over adaptive modulation) using narrowband means, which rules
out OFDM-type approaches which might (I'm only guessing) in practice
work as well (using lower interference margins and more FEC, for instance).
(narrow beams, narrow bands) to squeeze in as many PtP users as
possible via coordination, not auctions.
There are two problems with the conventional approach: 1. Narrower
and narrower beams mean larger and larger antennas with the related
dramatic increases in CAPEX and OPEX, and even then they are still
not perfect. 2. The FS market requirement is for higher and higher
speeds requiring higher and higher bandwidths, not narrower and
narrower bandwidths.
I agree. What I'd like to avoid at all costs are auctions, whether
explicit or implicit ("sorry, no more licenses available", so then a
company who has them will be bought by a Wall Street firm for the
sake of resale, essentially a private auction).
It works pretty well.
Actually it works very poorly as demonstrated by the difficulty of
Prior Coordinating new 6GHz and 11GHz paths in cities such as New
York and Los Angeles.
I'm not sure it's working poorly. Those areas are crowded. There's
not much spectrum available. And the FCC's wireline policy,
essentially created by the ILECs to milk their monopolies without
regulation, creates unnecessary demand for terrestrial spectrum in
urban areas. Why do the CMRSs *need* wireless backhaul? In most
countries they'd get fiber from the ILEC (e.g., Carrier Ethernet or
leased E3) at a reasonable price, but US (FCC) policy is totally
messed up. So the non-ILEC CMRS has to pay the ILEC $3k+/month to
hook up one measly cell site (an urban rooftop, a church steeple,
whatever) to a local node. Microwave looks pretty good compared to that.
20 years ago, when optical fiber was first being pulled big time, we
simply assumed that microwave was on its way out, consigned to niche
markets, like rural. Boy were we wrong.
The reason for the congestion is that every licensed station is
given protection from harmful interference and all antennas radiate
and receive signals in all directions, hence the reason for Rule
101.103 and the large antennas are a major contributor to the high
cost of conventional licensed microwave links.
As some of the Reply Comments noted, the alleged "keyhole" for
auxiliary stations doesn't really exist very often
The "keyhole" has nothing to do with auxiliary stations as it is a
contour around any station for a given interferer. Prior
coordination requires that a new applicant check the EIRP at all
angles around the proposed stations for all distances up to 125
miles at angles between five and three hundred and fifty five
degrees, and at all distances up to 250 miles for all angles within
five degrees of the antenna azimuth. This means that there are a
very large number of locations around existing paths where a new
applicant path cannot be deployed because the new path would cause
harmful interference, and as the distance from the new applicant to
an existing path or paths decreases, the number of choices for the
new applicant path also decreases to the point where a new path at
any angle will not prior coordinate. With a "conventional" approach
these locations are unused, they are wasted. But with auxiliary
stations the existing licensee can put the unused locations to
productive use.
Whoa. The coordination requires that the path be *checked*. It does
not mean that a frequency is *blocked* for 125 miles for the full
circle. HUGE difference. If I use a given frequency from say Indy
(say, Henry St., which is probably Ground Zero for congestion) to
McCordsville, somebody looking for a path from, say, Crow's Nest to
Carmel will need to protect that path. But the paths don't mutually
interfere. So they same frequency can probably be used for
both. And a path from Kokomo to Gas City won't interfere. If the
coordinators do give grief on these, then we have a problem with the
coordination rules. Your exaggerated presentation makes these look
"wasted". But actually most of the wasted paths are unwanted, since
there's probably no demand for many fixed paths from Gas City to
Wheeling, or from Wheeling to Leisure, etc. *And the WTB guys know
this.* Mobile of course is very different...
Under Part 101 Fixed rules, each path, when requested, gets
coordinated and given primary status. Or rejected. I'm noting Tom's
concern that auxiliary, by turning PtP into PtMP, may increase demand
for PtP primary licenses, and thus worsen, not reduce,
congestion. And the little guys always lose.
...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."
I will again quote FCC Chairman Genachowski:
"We can't create more spectrum, so we have to make sure it's used
efficiently."
Nobody disagrees with that platitude. The question is "how?" You
support one view, but your arguments were not well made. And from
the PoV of the WISP community, there is risk as well as opportunity.
So, why are you proposing that we do not challenge the big companies
who have vested interests in maintaining the status quo?
I'm not suggesting that we do not challenge the status quo. I'm
questioning how to go about it. Turning PtP into PtMP licenses may
be clever, but it could backfire too. Remember, before there were
FCC auctions, there were non-FCC auctions, as license-holding shell
companies were bought and sold. Do you think any of the last FCC
license lottery winners (remember when MMDS lottery tickets were
being hawked via radio ads for about $10k apiece?) actually wanted to
build networks? Part 101 today is relatively clean in that regard.
The facts are these:
· Spectrum is a finite precious national resource.
Duh.
· Every month thousands of new licenses are issued for
primary stations when many of the services could have been provided
by auxiliary stations.
Maybe, maybe not.
· For every license issued spectrum is wasted and millions
of future paths are blocked, adding to already congested airwaves.
No. Paths, desired or not, are subject to coordination. Interfering
paths are blocked. I do not oppose reopening the standards of
determining interference, if they are no longer realistic. (I claim
no special knowledge here. I know they are extremely
conservative.) As the NPRM states, "An FS
licensee is entitled to prevent another licensee's signal from
traversing its signal pattern pattern if, but only if, that trespass
interferes with the original licensee's ability to receive its signal
at its downlink location.
Thus, for example. another licensee might transit a signal at right
angles to the original licensee's signal, crossing its midpoint,
without creating unacceptable interference. In such a case, our rules
and the frequency oordination process would normally allow the second
link to be deployed."
I have no problem with innovation. And as you might have noted, I
think there's good reason to have more PtMP services, like a new
updated DTS. And indeed I do think that some of the current
requirements of Part 101 Fixed Services lead to excessive
cost. Especially outside of the most congested areas, for instance,
smaller antennas, with less wind loading, would be most useful. My
comment on narrowband is that they require very high spectrum
efficiency (hence the whole issue over adaptive modulation) using
narrowband means, which rules out OFDM-type approaches which might
(I'm only guessing) in practice work as well (using lower
interference margins and more FEC, for instance).
· Auxiliary stations, with their small antennas and low
cost, will for the first time be able to solve the "last mile" cost
barrier, bringing economically viable licensed broadband to
un-served and underserved communities.
Maybe. Maybe not.
· Last but not least, auxiliary stations will give WISPs a
significant business growth opportunity.
I have a suspicion that much larger companies would be more likely to
be the ones to win any battles here.
What you are proposing is maintain the legacy approach, with all of
its drawbacks. How will that conserve spectrum, dramatically lower
the cost of licensed microwave backhaul and access, and benefit WISPs?
You are suggesting a best-case outcome for a proposal that you have
not argued for very well. I am suggesting that there may be better
approaches, and that Tom has a point that your proposal could
possibly backfire on the WISP community.
--
Fred Goldstein k1io fgoldstein "at" ionary.com
ionary Consulting http://www.ionary.com/
+1 617 795 2701
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