Charles,

My new comments are preceded by <jau>.

jack


On 2/8/2011 7:14 PM, Charles N Wyble wrote:
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> On 02/08/2011 02:23 PM, Jack Unger wrote:
>> Comments inline.
>>
>> jack
>>
>>
>> On 2/8/2011 2:09 PM, Blair Davis wrote:
>>> Some serious enforcement is in order.  Major fines for repeated
>>> offense...  $100K or more for 2nd offense...
>> Last month we recommended to the FCC OET that they publicize actions against
>> offenders who they locate. This would help get the message out that this is a
>> serious problem and that enforcement is in fact taking place.
> Is that covered at http://fcc.gov/eb/Orders/Welcome.html or
> http://fcc.gov/eb/FieldNotices/ ?
<jau> I don't know how or if the FCC has acted on our recommendations but I'll 
ask them for more information when we meet with them this Friday.
>>> I'd rather see the TDWR band notched out than any kind of required GPS
>>> and database...
>> Notching may be the ultimate outcome for all new equipment. The disadvantage 
>> is
>> that notching deprives everyone from using the spectrum, even the 90% of
>> operators who are nowhere near a TDWR system.
> Very true.
>
>>> What is going on with the 3.65 stuff?  I still think we need some kind
>>> of license enforcement there...
> Why?
<jau> That was not my comment - best to ask Blair about that.
>> WISPA recently had it's first 3650 Steering Committee meeting and it was 
>> agreed
>> that major work (education, best practices, possible rules changes, etc.) is
>> needed because the interference situation is getting way out of hand.
> Hmmm. Interesting. That's news to me.
<jau> Well, that's what one very large and responsible operator reported.
> Where does one see info about the
> violations?
<jau> As I stated above, I don't know where the current info is published but I 
will ask the FCC.
> Is it happening on private lists or something?
<jau> Some is on the private "Phoenix" email list. I think I've also seen 
interference posts on WISPA's lists but I don't recall the details. You can 
always just ask if anyone is experiencing 365 interference and see what 
responses people give.
> I don't
> recall any complaints on the WISPA general list about it.
>
>   There are
>> also more and more illegal (unlicensed) "bootleggers" using the band. One
>> solution (among many) is to use a regional email list to coordinate between
>> different operators. This is in use now in Phoenix.
> Hmmmm. Well illegal/unlicensed use is a clear enforcement action and
> should be referred to the FCC EB.
<jau> We can't expect much enforcement action from the FCC on 3.65. 1) They 
have 
a very limited enforcement budget that is reserved for interference that is 
caused to (fully) licensed services, 2) They expect us to police ourselves, not 
turn to them.
> Coordination among entities... as I
> recall that was very vague in the R&O.
<jau> Yes it is vague although we supported a filing by the Fixed Wireless 
Communications Coalition last year to make it less vague. Because it is vague, 
it's really up to us, not the FCC. If we don't demonstrate that we can make 
3.65 
litely-licensed spectrum work then we should not hold out of getting any more 
in 
the future.
>
> - -- 
> Charles N Wyble ([email protected])
> Systems craftsman for the stars
> http://www.knownelement.com
> Mobile: 626 539 4344
> Office: 310 929 8793
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-- 
Jack Unger - President, Ask-Wi.Com, Inc.
Author (2003) - "Deploying License-Free Wireless Wide-Area Networks"
Serving the WISP, Networking and Telecom Communities since 1993
www.ask-wi.com  818-227-4220  [email protected]





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