[Cu-wireless] [firstname.lastname@example.org: I testified before the FCC today - some serious comments]
dyoung at ojctech.com
Thu Aug 1 20:07:29 CDT 2002
This concerns regulation in the unlicensed bands. It comes from the
I monitor the list because ccassionally a gem like this appears on it,
but the traffic is high and the S/N ratio is very low. It's almost more
than I can keep up with, and I've only been reading it for about a week.
Maybe we can rotate gem-hunters through?
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From: Patrick Leary <patrick.leary at alvarion.com>
To: isp-wireless at isp-wireless.com
Subject: I testified before the FCC today - some serious comments
Date: Thu, 1 Aug 2002 17:48:51 -0700
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As an invitee of the FCC's Spectrum Policy Task Force, I participated today
as a panelist wherein the topic was essentially evolving unlicensed rules.
The sessions today were well attended by some press, some interested public
parties, and FCC personnel including some senior officials like Ed Thomas,
division chief of OET. Ed Thomas made the keynote and emphasized the high
visibility and priority that the Task Force is placing on unlicensed bands.
He said that following all these sessions and public workshops, the Task
Force is to quickly draw up a set of conrete recommendations for major
Most commentary revolved around unlicensed bands as transport for broadband,
but it was clear that architectures in mind were very dissimilar, with some
implying broadly meshed systems and/or public access LANs. It was sadly
clear, that few in attendence had any meaningful understanding that
unlicensed systems were being used to create broad geographical broadband
coverage throughout the US.
If I could sum the overall theme where all panelists in all sessions seemed
to agree, it was that the rules should be modified (or applied to a new
unlicensed band) that promote innovation. Specifically, enable rules that
allow for embedded intelligence to maximize efficiency. When asked "if you
were to decide on a set of rules for the new band and had to decide today,"
I said we need a sub-1GHz band dedicated for packet-based networks whereby
the technical rule would be a logrithmic type rule that takes into account
ratios of time domain, spatial efficiency, and bits/hertz, to calculate max
EIRP coupled with ATPC and dynamic channel selection. Agreement was echoed
by Proxim's CTO on at least the technical rule. When it was posited that
this would be too complex, a number of us said it was not, and was in fact
relatively simple and would foster innovation. In my opinion, Microsoft and
Cisco limited their comments to very general abstractions about unlicensed
being the likely primary means for end device broadband access (ascribed to
things like pda's and mobile computing NOT WISP activity). Agere's guy, Carl
Stevenson (also and IEEE fellow), was there also on behalf of the WECA LAN
crowd and had no comments specific about WISP activity.
All also agreed that no policy should protect legacy systems indefinitely,
and that within reasonable lifecycles, systems should have to keep abreast
of advancements that promote better spectrum usage but such should ideally
allow for backward compatibility.
Much of an earlier panel discussed the threat of "meltdown" in unlicensed
bands due to supposed congestion (and, thankfully, all agreed there was
little proof). I, as an audience member on this occasion, asked folks the
following: "If I walk into a crowded Egyptian bazaar with no shoes and I cut
my feet or my toes were stepped on, is this a band congestion problem, or a
problem with the 'technology' of choice - in this case chosing no shoes? I
expanded by saying that if 2,000 of the 3,000 people did not wear shoes and
all got their toes stepped on, but I walked around with steel-toed shoes and
am fine, does this still not prove that the problem is one of technology,
not of actual band congestion? The point being, the reality of congestion in
2.4GHz exists where inadequate technology or design is used, and no policy
should be made that protects a legacy techology, even when that technology
achieves scale due to wide adoption of a standard as that penalizes
innovation of more advanced and successful technologies. This analogy
brought nodding heads among most of the panelists.
After hearing the "meltdown" term too many times, I cautioned that all
hyperbolic claims like "meltdown," and the converse, that unlicensed is the
savior technology, all need to be viewed with a question about where such
phrases originate in the sense that do those claiming "meltdown" have a
vested interest in its failure and thus in propagating the claim.
During the debate about rules etiquette, I made the joke about my not being
burdened with a PhD and that enabled be to view some things differently,
such as the FCC and panelists needing to be aware that rules sufficient for
licensed will not automatically translate well in an unlicensed model.
Specifically, I made note that sociologically, a great many implementors in
unlicensed behaved differently and with less attention to rules (no offense
to those that follow rules, but we all know many do not, and I'm not talking
about making your own cables or other minor matters, I am talking about
tossing on external amps at every link and other ugly rookie mistakes) so it
would be better to have as many "etiquette" and "cooperation" rules to be
achieved electronically by means of embedded intelligence.
There was a moment where I felt as if I were a lone person shouting in the
forest when discussing unlicensed as infrastructure and the need to better
define a professional installer clause. I got the clear impression that many
in the audience, the moderator (from Telcordia) and a few of the panelists
had little concept of unlicensed systems being deployed as near carrier
grade broadband infrastructure, not simply some cute little public LAN,
home/neighbor network sharing, or 2 dimensional mesh. I got the distinct
impression from many that they believe that somehow broad geographic
cell-type architectures was something that existed in only licensed bands.
That was the darkest point in the session for me and tells me the unlicensed
vendors of wireless broadband and all you unlicensed operators have still
largely failed to make the public case that professional systems exist.
WHAT FOLLOWS is my opinion alone based on my observations:
In simple summary, it is clear small WISPs are mostly invisible except for
the limited efforts some of us have been able to manage. The WLAN vendors
(including those that many of you choose for your wireless broadband
solution) DO NOT recognize you exist. Without a very strong effort (which
does not include mass e-mailing FCC officers) on the regulatory front, WISPs
- people running for profit unlicensed wireless broadband businesses -
should not expect their concerns and needs to on the minds of policy makers.
I have not been loud heretofore in urging you to help fund the WCA LEA
activities that are in your interest - namely the Regulatory Reform Project.
This is the ONLY organization trying to have a regulatory impact with real,
After this chance passes you by, you will have no more in the long,
forseeable future. Your choice. Unless of course you think the FCC has major
policy re-writes everyday. Weeks ago in Boston, Dr. Marcus opened the door
to this community. If it turns out in the ensuing months that WISPs as a
whole chose to blow him off and not step up and cross the threshold of
opportunity, do you really think the FCC will give flip about you again?
Regards to all,
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David Young OJC Technologies
dyoung at onthejob.net Engineering from the Right Brain
Urbana, IL * (217) 278-3933
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