[CWN-Summit] RE: [Unlicensed_advocates] RE: [Openspectrum] Spectrum updates

Patrick Leary patrick.leary at alvarion.com
Wed Jun 29 17:59:11 CDT 2005


Marlon, a few quick things, first the petitions that I was involved in do
NOT advocate against unlicensed, they advocate to split the band. I am aware
of Motorola's wish to go 100% licensed, but neither Alvarion, Intel, the WCA
or the WiMAX Forum is party to that thinking. In other words, we do not like
the all-or-nothing approach.

Two, the Commission has not "shunned" all the work we involved with WiMAX
have done. That is only the assumptions of those that have not been involved
in the proceedings or otherwise not plugged in to the thinking of those on
the Commission who have authored the R&O. [NOTE: Harold, I do not believe
there is any ex-parte filing, since Alvarion (dumbly in my view) does not
retain legal representation in DC nor was any attorney on our side present.
The meeting was held on April 4 and run almost 2.5 hours. In attendance on
Alvarion's part was me, Duane Buddrius (North American Product Director),
and Mariana Goldhamer (our standards person and maybe second only to Roger
Marks in global standards work). For the FCC were 15 people, generally split
between the Wireless Bureau and the OET.] Anyway, the Commission was very
specifically NOT trying to exclude WiMAX. On the contrary, they were very
much thinking that the rules they created would be suitable for WiMAX (in
fact, their thinking says as much in the R&O) and they were quite dismayed
to learn that it appeared they intended to do the opposite. The FCC people
were not savvy in terms of the scheduled MAC of WiMAX, especially its being
somewhat the antithesis of "contention-based."

I admit to getting tired of hearing that refrain, that the FCC dissed WiMAX.
It only comes from sources ignorant of the reality, from those who have not
read the R&O, and perhaps those who have one "authoritive" trade article too
many. It is also a refrain easy to disprove: "The licensing scheme that we
adopt for this band will provide an opportunity for the introduction of a
variety of new wireless broadband services and technologies, such as WiMax."
That's a direct quote from page 2 of the R&O. So, we have that as evidence
and I have my own first hand hearing from the authors of the R&O. That's
good enough to satisfy me that the "shunned" concept is BS and wishful
thinking on the part of 802.11.



Kind regards,
 
Patrick J. Leary
Assist. V.P., Marketing
Alvarion, Inc.
cell: (760) 580-0080
Skype: pleary
 

-----Original Message-----
From: Marlon K. Schafer (509) 982-2181 [mailto:ooe at odessaoffice.com] 
Sent: Wednesday, June 29, 2005 3:32 PM
To: Patrick Leary; 'Harold Feld'; Network Summit Mailing List; Open
Spectrum; CWN Policy; Unlicensed Advocates
Cc: wireless at wispa.org; FCC Discussion
Subject: Re: [Unlicensed_advocates] RE: [Openspectrum] Spectrum updates

Hiya Patrick,

Very well thought out and well stated note (as usual).

Let me take your points inline from a WISP perspective.  Since I've not 
taken the time to run this past the rest of WISPA I'll not pretend to speak 
for them.  I will, however, talk about some ideas that we will likely float 
on the 3650 issue.  Maybe we can come up with a mutually agreeable platform.

below.....

----- Original Message ----- 
From: "Patrick Leary" <patrick.leary at alvarion.com>
To: "'Harold Feld'" <hfeld at mediaaccess.org>; "Network Summit Mailing List" 
<cwn-summit at cuwireless.net>; "Open Spectrum" <openspectrum at media.mit.edu>; 
"CWN Policy" <cu-wireless-policy at ucimc.org>; "Unlicensed Advocates" 
<unlicensed_advocates at kumr.lns.com>
Sent: Wednesday, June 29, 2005 1:04 PM
Subject: [Unlicensed_advocates] RE: [Openspectrum] Spectrum updates


> Harold,
>
> I wish to correct your comments regarding the "WiMAX Posse" and 3650MHz. I
> am qualified to do so as I was principally involved in the WiMAX Forum
> response (I wrote the first draft), the Intel/Alvarion/Redline petition
> (obviously), and the WCA petition (splitting the band was an idea I tossed
> out).

I think that the two biggest issues here are the idea that the new rules are

NOT Wi-Max compatible.  And the only ones who care deeply about that are 
those that are putting most/all of their eggs into the Wi-Max hype machine. 
(Not that Wi-Max won't be great stuff, I have very high hopes for it, maybe,

someday..... grin)  Secondly, the petitions that have called for this band 
to NOT be unlicensed.  As a WISP I'm VERY well aware of how much activity is

taking place out there in the unlicensed vs. licensed arenas.  The licensed 
crowd is getting a lot of press but not much for customer base.  The 
unlicensed crowd is getting little press but tons of customer base.

>
> Where you are incorrect is in your assumption that our efforts are 
> entirely
> WiMAX centric. While this is partially true, what we (at least Alvarion) 
> is
> most interested in a set of rules that 1) is technology agnostic, 2)
> harmonized with other similar allocations globally, 3) enable true QoS.

First, I certainly don't think you guys are asking for the rules to be 
Wi-Max centric.  I DO think you are miffed that the rules have actively 
shunned the work you've done.  I guess I'd be upset about that too.

As I understand the 3650 rule it looks pretty danged agnostic to me.  All it

really says is that never in this band will a product like the Western 
Multiplex Tsunami or the Motorola Canopy gear be built.  As a WISP I like 
that!  A lot.  For the first time ever, I'll have a band that will guarantee

that I'll be able to offer service.  As a WISP, that's a HUGE deal.

Just cause the rest of the world does it one way doesn't mean that we can't 
do better.  I understand the manufacturer (especially a global one) side of 
this coin.  Thinking in a more entrepreneurial manner though, here's a great

chance for a new small company to come up with a new great idea.

I totally fail to grasp your point with item 3.  How in the world is a 
protocol that prevents one system from knocking another one offline going to

hurt QoS?  Seems to me that this should do nothing but HELP QoS at least in 
relation to how it's handled now.

>
> The "contention-based protocol" requirement is counter productive to the
> intent of the rule

Um, no I don't think so.  it *IS* the rule.  It's also something that the 
WISP industry has asked for for years.  Not this idea specifically but for 
something that allows both innovation, and competition but doesn't do so in 
a manner likely to destroy an earlier investment.

> and also imposed a narrow framework for industry to deal
> with interference issues. In fact, the rule simply cannot work, as I will
> explain later.

I missed the explanation.

> Your post also implies that our community is looking to
> prevent or otherwise be hostile to Wi-Fi. Nothing is further from the 
> truth
> and we prove it in the language of our reconsiderations. In fact, our 
> plans
> actually make the environment more conducive to immediate deployment of
> 802.11-based systems, along with WiMAX and any others, including 
> Motorola's
> (very spectrally unfriendly) Canopy.

I don't read anything in the rules that favors 802.11.  I guess one could 
leap far enough to say that because it's already contention based it's the 
"protocol of choice".  The ruling seemed pretty clear to me though, the FCC 
is looking for creative new ideas on how to accomplish this.  WISPA's filing

made it clear that we are in favor of opening up the pipeline for new ideas 
so this seems like a fairly good way to go about it.

This is a small chunk of spectrum.  I remember you telling me that Alvarion 
wasn't looking at the band in any real sense because it's too small of a 
space to work in and no matter what the FCC did the radios would have to be 
redesigned just for it.  Why the change of position for Alvarion?  Or did I 
just misunderstand your earlier stance?

>
> We (Alvarion) met at length with the staffers at the Wireless Bureau and 
> the
> OET who wrote the rule and we impressed upon them that a better approach
> would be to impose a technology agnostic rule. For example, 802.16 has
> formed Task Group H that is working on unlicensed co-existence. The TG is
> trying to establish a joint task group for this with the 802.11 crowd,
> because the goal of the TG is to come up with a TECHNOLOGY NEUTRAL scheme
> that could be software-applied to any 802.11, 802.16, 802.20, etc. device
> and would allow all the devices to recognize each other and cooperate via
> time slicing. But the 802.11 crowd is rejecting any involvement. In other
> words, it is the 802.11 crowd that is openly hostile (and terrified) of 
> the
> "WiMAX Posse," not the other way around. The 802.11 crowd does not want
> neutral rules, they want protections.

That stinks.

>
> [NOTE: Interestingly, and contrary to the belief of the Wi-Fi folks, the 
> FCC
> folks told us that in no way were they attempting to protect 802.11, nor
> were they attempting to be hostile to 802.16. But it was clear to us that
> they had not realized how problematic was their ruling.]

I still don't see it as problematic per se'.  More difficult than one may 
prefer but certainly not overly so.

>
> In terms of harmonization, must I really have to explain this? U.S.
> allocations are already all over the map and incongruent with global
> allocations. Do we really want another band that forces industry to come 
> up
> with a unique technology patch only applicable to the U.S.

That's an interesting point.  One with many sides to it.  Lets pick this one

apart a bit shall we?

First, the smaller the company the less of an impact this should have. 
They'll have a LOT less "tooling" to do to make changes to their devices.

Second, software defined radio (SDR) technology appears to be right around 
the corner.  It should be very easy to make one platform do a great many 
jobs, perhaps even on the fly sooner than later.  China is coming up with 
their own standards, Japan already has, Europe is different still.  Why 
should the USA knuckle under on this issue?  From a deployment, no 
manufacturing standpoint.  I think we all understand the volume issue.

Third, what's inherently wrong with a band that's small and specifically 
there to foster innovation?  Other than it being a direction of innovation 
that's counter to Wi-Max?

And you say that this band will force the industry to "come up with a unique

technology patch".  What if the "patch" that comes out of this turns out to 
be such a great working idea that all unlicensed bands drift to it?  After 
all, I don't think anyone can disagree with the notion that having both 
contention based and non contention based devices in the same band and with 
the same authority to use the band is a good overall idea.

>
> In any event, the rule is unworkable anyway. Why? It forces "industry" to
> come up with a scheme to avoid interference and enable others to operate,
> but it does not require the various groups to agree and to implement a
> single approach. So tell me in practical terms how such a thing is 
> remotely
> workable? Should I spend a million bucks to design some advanced protocol
> that allows sharing across technologies, only to have it rejected by the
> Wi-Fi crowd, etc. who has no obligation to agree to the technique, no 
> matter
> how neutral?

I happen to think that that would indeed be possible.  After all, you guys 
are all radio manufacturers first, Wi-Whatever (or non Wi-Whatever) second. 
Wi-Fi, Wi-Max, Wi-Nothing are all software choices that ride on top of 
radios.  Heck, look at Karlnet.  They built a more robust protocol that 
could be put onto Lucent Wi-FI radios.  An act that deliberately made them 
non standards based, but built on a standards based platform.  This helped 
make Doug Karl a very wealthy man from what I understand.  If the rules 
didn't have that flexibility in place, that otherwise good idea couldn't 
have happened.

It's funny how much we do think alike sometimes.  Your time-slice idea is an

interesting one.  That's one of the ideas that WISPA has talked about 
floating as a compromise on this issue.  Would you guys support us in this 
idea:  All ap's would have to detect all other ap's within "ear shot".  They

would all chop up a second into equal parts and all have equal time 
available.  A matrix could be built so that busy systems could utilize 
unused time slots belonging to less busy systems.  Or not.  An example would

be if we cut a second into (pulling a number out of my....) 3600 time slots.

The first system in gets all 3600, then there's two using 1800, three using 
1200 etc.

I'd also be in favor of some mandatory channel plans.  If the band were 
limited to 5 MHz channels there'd be 20 non overlapping channels.  Put this 
together with the above mechanism, some cognitive functions similar to the 
new 5.4 band so that radios would automatically try to find an empty channel

and I see a LOT of collocation possibilities along with guaranteed spectrum 
availability.  Pretty cool stuff from a deployment point of view.

>
> Finally, what of QoS? If wireline equivalent QoS cannot be enabled, then 
> the
> band can never create a service competitive against cable or DSL, and
> certainly useless for mobile. These type of half-assed rules force 
> wireless
> broadband to be the low-rent broadband backwater, never more capable of
> providing anything beyond best-effort.

Lets be fair here Patrick.  You can't toss wireline QoS and DSL/Cable or 
even Cellular into the same sentence like that.  There is NO QoS in anything

less than leased line services.  It's just that no one ever reads the small 
print.

I'm certainly not knocking QoS but you are not making a fair comparison 
here.

>
> In the end, the rules in reality do nothing but create a sort of limbo of 
> a
> Mexican stand-off, where the one for sure it that decent use of the band
> won't happen for a long time. ...not unlike 5.4 GHz.

5.4 GHz is totally different.  There are companies with product qued up and 
ready to roll as soon as they are told what the rules will be.  It's got 
nothing to do with their ability to build a product, it's only the ability 
of the FCC to certify it.

>
> If anyone actually read our reconsiderations (the WiMAX Forum's,
> Intel/Alvarion/Redline's, and the WCA's), then one would see that we are
> trying to create an environment where both unlicensed and licensed has an
> opportunity to thrive, an environment where Wi-Fi or WiMAX can be
> immediately deployed (in either the unlicensed or licensed domains), and 
> an
> environment where QoS can be truly offered, ...or not. We went out of our
> way to make our filing technology neutral, though certainly usable for 
> WiMAX
> devices. And if you truly understood the WiMAX vision of "always best
> connected", 802.11 (as well as Bluetooth and advanced cellular) plays a
> vital role.

I did read them and that's not at all what I got out of them.  The WCA, 
Intel, and Motorola (I'd have to re-read it before I'd lump Alvarion/Redline

into this) clearly stated that the band should NOT be unlicensed.  It was 
also stated that the contention based mechanism should be eliminated, 
thereby eliminating 802.11anything as an option.  Not from a regulatory 
standpoint but certainly from a deployment standpoint.  As an operator that 
uses mostly 802.11b based gear I'm very well aware of what happens when 
mixing contention based and non-contention based systems.  For those that 
don't know, think water and oil.....

>
> I challenge you or anyone else to show me in any of the three filings one
> sentence that favors any WiMAX (or even 802.16) over Wi-Fi (or any 
> 802.11).

NOT requiring a contention based mechanism basically destroys 802.11's 
ability to compete in the real world.  Sure it's done all the time now, but 
it's a LOT of work sometimes.  And it's always scary as hell.

> On the contrary, one can pull ample examples where those that only can 
> play
> using 802.11 have direct hostility and fear of any other technology. 
> [Intel,
> as one making perhaps more off Wi-Fi than anyone else, hardly has a
> motivation to destroy 802.11 and any theory otherwise is just plain 
> silly.]

Then why did they file that 3650 should be a licensed band?

This is a complicated issue to be sure.  Personally I'd like to let the 
rules stand for a year or three and see what you guys (generic manufacturer 
type guys) can do with this spectrum.  If no one really comes up with a good

idea then lets revisit the issue and make some changes.

Certainly the rules as written are a compromise but a far better one than 
MMDS or ITFS :-).

respectfully,
marlon

>
> Kind regards,
>
> Patrick J. Leary
> Assist. V.P., Marketing
> Alvarion, Inc.
> cell: (760) 580-0080
> Skype: pleary
>
> -----Original Message-----
> From: Harold Feld [mailto:hfeld at mediaaccess.org]
> Sent: Wednesday, June 29, 2005 10:46 AM
> To: Network Summit Mailing List; Open Spectrum; CWN Policy; Unlicensed
> Advocates
> Subject: [Openspectrum] Spectrum updates
>
> (My apologies for any duplicates people see as a result of cross-posting)
>
> Important doings at the FCC and the Hill this summer.
>
> FIRST, a relatively minor thing but with significant applications.  The 
> FCC
> Enforcement Bureau has declared the use, sale, or marketing of cellular
> jammers illegal.  These devices are manufactured and marketed in other
> countries, but are not made in the U.S.  In addition to invoking the
> requirement that such devices must receive Commission certification under
> Sec. 302A, the Commission invoked Sec. 333 which prohibits interference
> with any signal licensed or otherwise authorized by the Commission.  A 
> copy
> of the declaration is available here:
> <http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-1776A1.doc>
> <http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-1776A1.pdf>
> <http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-1776A1.txt>
>
> This has significant implications for what is being referred to as
> "suppression of rogue APs" and also for devices deliberately designed to
> interfere with wireless networks.
>
> SECOND, as some of you may recall, the FCC opened up the 3650-3700 MHz 
> band
> to a new form of "licensed" access.  Although technically licensed and
> therefore under Part 90 rather than Part 15, the "license" is 
> non-exclusive
> and grants no better rights with users based on past use or priority (no
> "first in time, first in right" usual in traditional "licensing-lie"
> schemes).  The rules also require users to use "contention based 
> protocols"
> to share the band.  The rules permit "licensees" to operate fixed base
> stations of up to 25-watts EIRP in power.  Mobile devices may operate on
> the band at a strength of 1-watt, but must receive an enabling command 
> from
> a stationary base station.  The band has geographic carve outs to protect
> incumbent satellite earth receiver stations.  However, because the new
> devices are a licensed secondary service, the FCC has required the
> incumbents to negotiate with those seeking to operate systems in the
> exclusion zones to operate on a non-interfering basis.  The exclusion 
> zones
> effectively eliminate use in the top 25 market areas in the United States.
>
> Other than the incumbent users located along the coasts and in the 
> midwest,
> the band is unused.  The rules prevent an accumulation of "junk" such as 
> in
> 2.4 GHz or 5.8 GHGz.  Staff have indicated that they regard this as a test
> case whether developers and those using non-exclusive spectrum for
> broadband can genuinely cooperate.  If this model works, it may be used in
> other areas to create opportunities for non-exclusive use alongside
> exclusive licenses (e.g., broadcasting).
>
> Intel has organized resistance to the new rules from what I will call "the
> WiMax posse."  Approximately ten Petitions for Reconsideration were filed,
> most of which advocate for altering the rules to accommodate WiMax (either
> move to true licensing or eliminate the requirement for contention based
> protocols and create a "first in time, first in right" regime so that the
> first carriers to deploy can set up WiMax networks.
>
> I have received inquiries from some tech companies as to whether the WISPs
> and the community wireless communities will "defend" the 3650-3700 MHz
> band.  The influx of hundreds of comments from WISPs and from community
> network supporters had a huge impact on our defeating the proposal from
> Intel to make this a licensed regime in the first place.  Intel is hard at
> work trying to "recapture" the spectrum, and companies considering
> developing equipment for the band are hesitant to do so unless there is a
> sufficient show of interest from the would-be beneficiaries to give them
> confidence the FCC will keep the rules.
>
> MAP will draft oppositions to the Petitions for Reconsideration.  In
> addition, I would like to urge people to file individual comments in
> opposition to the recon petitions.  For those wishing to file comments, 
> the
> docket number remains the same, 04-151.
> Oppositions are due 15 days after the Commission puts the Petitions for
> Reconsideration on public notice in the Federal Register.  Given how fast
> the Fed Reg publication is, we are looking at late July at the earliest 
> for
> Oppositions.  Nothing, however, prevents interested parties from filing at
> any time, as the proceeding is designated "permit but disclose."
>
> In addition to the FCC front, I would be very interested in talking to
> anyone in the open spectrum/open source community about developing open
> source solutions for the 3650-3700 MHz band.  This is a real opportunity
> for open source to get "first mover advantage" in a band.  The IETF
> presents a possible vehicle for a recognized standard that could
> subsequently be adopted by chip set manufacturers.  FCC staff have
> expressed interest in helping open source developers navigate the approval
> process (their certification people are very open and friendly).
>
> THIRD, Congress is considering the digital television
> transition.  Consensus is that this bill represents a "must pass" over the
> objections of the National Association of Broadcasters because they want
> the auction money.  From an unlicensed perspective, however, the DTV
> legislation represents both an opportunity and a threat.  On the
> opportunity side, Congress could either set aside spectrum for unlicensed
> access or order the FCC to set rules to permit unlicensed access in the
> "white spaces."  On the threat side, the NAB is seizing this opportunity 
> to
> get legislative language in prohibiting any unlicensed access in the
> broadcast bands as a danger to the "digital transition."
>
> As members of Congress head home for the July 4 recess, it creates an
> opportunity to educate them about the importance of unlicensed spectrum
> access.  Needless to say, most memebrs of Congress have never even heard 
> of
> "unlicensed spectrum," but education must begin somewhere.  If you can,
> take time to call the in-state office of your Senator or Representative 
> and
> explain that you think the DTV transition should serve ALL Americans by
> getting us all access to spectrum and tell them about the issue.  Even
> better, a fax and a follow up phone call to simply raise the consciousness
> of the possibilities and to make staffers more receptive to the arguments
> of the folks in Washington fighting for unlicensed spectrum will be very
> helpful.
>
> Happy July 4,
>
> Harold
>
> _______________________________________________
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> Openspectrum at listserv.media.mit.edu
> http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
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