[CWN-Summit] RE: CWN-Summit Digest, Vol 11, Issue 8

Jim Snider Snider at newamerica.net
Thu Jun 30 13:28:25 CDT 2005


In response to section 1 of Harold's spectrum update, I think the FCC's
jamming rule can be read more than one way. It only specifically bans
jamming in the cellular mobile phone bands.  That seems to leave open
the question of jamming in the other bands.  It also appears to be
confusing because it doesn't mention any exemptions to its rule.  For
example, the president of the U.S. doesn't go anywhere without the
ability to jam all frequencies.  Where is this exemption in the rules?

I believe that the status of jamming is quite important to the
unlicensed community because it is a form of unlicensed use of spectrum.
Indeed, my guess is that, excluding the U.S., jamming might be the most
widespread form of legal unlicensed use in the world today.

--Jim


J.H. Snider, Ph.D.
Senior Research Fellow 
New America Foundation 
1630 Connecticut Ave., NW 
Washington, DC 20009 
Phone: 202/986-2700 
Fax: 202/986-3696 
Web: www.newamerica.net 
E-mail: snider at newamerica.net 
(Also see my new book on digital TV policy and politics
www.spectrumpolicy.net)


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Today's Topics:

   1. Spectrum updates (Harold Feld)
   2. RE: [Openspectrum] Spectrum updates (Harold Feld)
   3. RE: [Openspectrum] Spectrum updates (Patrick Leary)
   4. Re: [Unlicensed_advocates] RE: [Openspectrum] Spectrum
      updates (Marlon K. Schafer (509) 982-2181)
   5. RE: [Openspectrum] Spectrum updates (Patrick Leary)
   6. RE: [Unlicensed_advocates] RE: [Openspectrum] Spectrum
      updates (Patrick Leary)
   7. RE: [Unlicensed_advocates] RE: [Openspectrum] Spectrum
      updates (Patrick Leary)


----------------------------------------------------------------------

Message: 1
Date: Wed, 29 Jun 2005 13:45:30 -0400
From: Harold Feld <hfeld at mediaaccess.org>
Subject: [CWN-Summit] Spectrum updates
To: 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>
Message-ID: <6.1.2.0.0.20050629123443.0d5b8268 at mail.his.com>
Content-Type: text/plain; charset="us-ascii"; format=flowed

(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



------------------------------

Message: 2
Date: Wed, 29 Jun 2005 17:04:24 -0400
From: Harold Feld <hfeld at mediaaccess.org>
Subject: [CWN-Summit] RE: [Openspectrum] Spectrum updates
To: Patrick Leary <patrick.leary at alvarion.com>,	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>
Message-ID: <6.1.2.0.0.20050629162753.095a1e20 at mail.his.com>
Content-Type: text/plain; charset="us-ascii"; format=flowed

At 04:04 PM 6/29/2005, Patrick Leary wrote:
>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).
>
>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.

Patrick:

I understand that the rules are technically "technology agnostic," but 
everyone I have spoken
to has interpreted the filings as directed at promotion of WiMAx.  This
is 
based not merely on assertions
within the comments that making the band WiMax compatible would provide 
positive public interest benefits,
but on the nature of the parties filing.

I will further add that the efforts of parties to recapture 3650-3700
for 
licensed use is having a very negative impact
on the efforts to get unlicensed access elsewhere, such as the broadcast

bands.  If Alvarion, WCAI, Intel, etc. are
concerned about the long-term future of non-exclusive shared spectrum 
access, particularly in the television bands,
I strongly urge you to rethink your position and start making some 
political inquiries.  Especially in the current FCC,
which is at best neutral toward unlicensed, this sort of active
internicine 
warfare only helps the NAB build its case.

>The "contention-based protocol" requirement is counter productive to
the
>intent of the rule and also imposed a narrow framework for industry to
deal
>with interference issues.

Actually, the intent of the rule was to deal with the "Canopy 
Problem."  And it wasn't just us.  I had a meeting with
then-Commissioner 
Martin in which he explained that lots of people wanted unlicensed for 
routine stuff like meter reading, but were afraid that if they weren't 
"always on" they would never be able to get back on because other people

insisted on being "always on."

Contention based protocols deals with this problem in a neutral way that

does not require any FCC intervention.

>In fact, the rule simply cannot work, as I will
>explain later. 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 do not mean to imply that you are "hostile" to wifi.  Many of you 
manufacture wifi equipment, after all.  No, the problem is that the
vision 
you describe for the band is one that is neither sensible for the band, 
given the exclusion zones for incumbents, nor compatible with the vision
of 
my community wireless/public interest clients, which is a band that
allows 
easy entry at the lowest possible price.  The vision you propose for the

band is essentially a carrier-style vision in which 3650-3700 MHz
becomes 
an auxiliary band for licensed WiMax or other licensed technologies.
The 
rules proposed on reconsideration do not (in the opinion of those more 
qualified to judge than I) further the ability of multiple small
operators 
to share spectrum cheaply and efficiently.

>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.

The current rule is "technology agnostic."  Any contention-based
protocols 
capable of sharing the band may be used.
Also, could you please provide a link to the ex parte of the meeting?  I

confess my workload of late has kept me from following the docket as 
closely as I would like.

>  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.

Well, I cannot speak directly to IEEE politics from any personal 
experience.  But from what I have heard second hand, the 802.11 crowd
are 
saying "we could slap together something that would satisfy the FCC
today, 
why should we embark on a process that will delay deployment?"

I understand this will be the subject of considerable debate at the July

meeting in SF.  I look forward to hearing about the outcome.


>[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.]

The division of this into 802.11 v. 802.16 camps is only relevant to the

basic question of how multiple users can co-exist within the band.  In
an 
802.16 universe, it is profoundly difficult to envision multiple users, 
particularly in mesh networks.  But even excluding mesh, without 
contention-based protocols, the incentive is to blast your transmitter
all 
the time.  The issue is not 802.11 v. 802.16. Any technology, regardless
of 
whether it is an IEEE approved standard, that allows multiple users to 
share the space by resolving the "I want to speak but someone else is 
speaking" problem is permitted.

WiMax is a perfectly fine technology for what it is intended-- a
national, 
licensed band.  Why must every available frequency be made "WiMax
friendly" 
anymore than every available frequency should be "broadcast friendly" or

"PCS friendly."  The FCC set aside 50 MHz of spectrum, with geographic 
carve outs from the top 25 markets, to try an experiment in frequency 
coordination.  It did this based on comments from hundreds of smaller 
entities that they wanted something like this for the purpose of
bringing 
broadband to rural areas and low income areas served by low-power mesh 
networks or higher-power hub-n-spoke in rural areas.  They did it in 
response to industrial users and others saying they wanted a place where

they couldn't be squeezed out by "always on" transmitters.

>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.

So leave it to the niche players and the open source folks.  The
exclusion 
of the most profitable DMAs already makes it a hard sell for this band
in 
the U.S.

>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?

THIS is the critical question, and the one upon which the future of 
non-exclusive use of spectrum hinges.

>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.

Again, you re-iterate the argument for licensing.  If what you say is
true, 
that market-based coordination is impossible and that QoS is impossible
in 
an market-based environment, then unlicensed spectrum (or any other
scheme 
for non-exclusivity) is doomed.  Period.
As an aside, there are many situations in which "best efforts" is a 
perfectly acceptable QoS, and anyone who wants better needs to find
another 
provider.  The QoS argument goes back to the 1980s and 1990s, when
TCP/IP 
was never going to be as good as what carriers could provide, so why 
bother?  Tuenred out that cheap, ubiquitous and end-user defined trumped

QoS for enough people to make it useful.

Every market has licensed, fixed wireless providers.  Why must 3650-3700

seek to replicate these conditions?  Many, many people have said they
will 
be happy with what they can get NOW rather than rely on a few licensed 
carriers selling high-priced services, even if that means a step down in
QoS.

And, if history is any guide, the QoS will improve as people use the
band 
and try to solve the problem.  The inability to conceive the perfect
answer 
today says nothing about what clever folks on the ground will develop
tomorrow.

Harold


>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.
>
>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 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).
>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.]
>
>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
>
>_______________________________________________
>Openspectrum mailing list
>Openspectrum at listserv.media.mit.edu
>http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
>
>This mail passed through mail.alvarion.com
>
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------------------------------

Message: 3
Date: Wed, 29 Jun 2005 13:04:41 -0700
From: Patrick Leary <patrick.leary at alvarion.com>
Subject: [CWN-Summit] RE: [Openspectrum] Spectrum updates
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>
Message-ID:
	
<A494A015B8AD8B49A6D9EECE8302648D01E18361 at KINNERET.breezecom.com>
Content-Type: text/plain

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).

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.

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

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.

[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.]

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.  

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? 

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.

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.

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 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).
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.]

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

_______________________________________________
Openspectrum mailing list
Openspectrum at listserv.media.mit.edu
http://listserv.media.mit.edu/mailman/listinfo/openspectrum
 
 
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------------------------------

Message: 4
Date: Wed, 29 Jun 2005 15:32:11 -0700
From: "Marlon K. Schafer (509) 982-2181" <ooe at odessaoffice.com>
Subject: [CWN-Summit] Re: [Unlicensed_advocates] RE: [Openspectrum]
	Spectrum	updates
To: "Patrick Leary" <patrick.leary at alvarion.com>,	"'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>
Cc: FCC Discussion <fcc at wispa.org>, wireless at wispa.org
Message-ID: <003301c57cfa$649e95b0$0c929240 at marlon>
Content-Type: text/plain; format=flowed; charset="iso-8859-1";
	reply-type=original

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
>
> _______________________________________________
> Openspectrum mailing list
> Openspectrum at listserv.media.mit.edu
> http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
>
> This mail passed through mail.alvarion.com
>
>
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------------------------------

Message: 5
Date: Wed, 29 Jun 2005 15:37:26 -0700
From: Patrick Leary <patrick.leary at alvarion.com>
Subject: [CWN-Summit] RE: [Openspectrum] Spectrum updates
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>
Message-ID:
	
<A494A015B8AD8B49A6D9EECE8302648D01E1836F at KINNERET.breezecom.com>
Content-Type: text/plain

Thanks for the thoughtful reply Harold. So much to reply to!

I remember the arguments about TCP/IP or Ethernet vs. ATM or token ring
or
etc. for that matter. But all those cases do not actually apply, as the
"spectrum" in those situations happens to be encapsulated in wire or
glass
and it is not like the general public had the ability to physically tap
into
those lines. However, in a shared spectrum environment that is
essentially
what is happening. I agree (assuming you do as well) that the old Part
15
rules actually play to the lowest common denominator -- the dumbest and
most
brutal systems wins. Accordingly, investing in "nicer, more efficient,
and
smarter" is a risky game. 

And I agree that the rules for 3650MHz-3700MHz have many favorable
components. I especially like the registration requirement, since the
practical result is no garage door openers, cordless phones, or other
consumer devices will exist in the band. And it also at least makes one
aware of who, where and what else is out there and gives a prayer of
chance
of coordination. So even from the start, it is a much cleaner slate. Add
to
that the "contention" requirement and the clear intent to refuse to
certify
systems whereby it seems to be designed to prevent other systems from
working, and yes, it makes for a nice place to experiment.

But who wants to experiment (other than the academics)? WISPs and others
want to be able to deploy gear and sell services. And they want to be
able
to do so with a level of quality that gives them some chance to compete.
Consumers want service (at the most base) and high quality choice (once
the
base need is met), not experiments. 

Our reconsideration does just that: it enables those in the most rural
areas
to deploy immediately, without need for the contention requirement. Such
really is not necessary in rural areas; the market will not sustain
enough
wireless competition to make the frequency unusable. And our filing
gives
WISPs a choice they will NOT otherwise have. They can go with an 802.11
variant OR they can choose Canopy or they can choose some WiMAX or
802.16
variant or whatever. The current rules strip them of that choice.

And even if the Wi-Fi crowd does not join the .16h unlicensed
co-existence
effort (only fear and anti-competitive behavior prevents them from doing
so,
certainly not any lofty "public good" argument) we will still come up
with a
protocol (Alvarion chairs the TG) because we know it is the long term
interest of the license-exempt market (where we still gain about 50% of
our
revenue).

I do not know to whom you have spoken about the reconsiderations, but if
all
they interpret is WiMAX, WiMAX, WiMAX, then they are reading it with
tinted
glasses. While sure we wish for the band to WiMAX POSSIBLE (after all,
we
are about the only domain in the world where this band cannot be used
for
technologies like WiMAX, but NOT EXCLUSIVE to WiMAX), we are not asking
for,
nor can it be even remotely interpreted that we are asking for WiMAX
favoritism or exclusivity.

You ask "why must every band be WiMAX compatible?" Oh I don't know, why
does
ANY band need to be 802.11 favored?

The U.S. continues to drop in the global broadband rankings -- 16th last
I
read. And it is not our lack of unlicensed spectrum that is exacerbating
the
problem. The U.S. has as much or more unlicensed as about anyone. But
one
could very easily argue that the market's lack of access to suitable
licensed spectrum does play a role, though the extent is fairly
debatable.

Our filing enables ample, in fact more, opportunity for unlicensed rural
WISPs, with less barriers than the FCC R&O. We asked for full (i.e. ALL
50MHz in rural areas) unlicensed, while retaining the exclusive zones
and
registration. The message to WISPs with our filing is "go get 'em" --
build
out the rural space where no others can make a go of it. But our filing
also
enables larger groups who might have the audacity to aggressively deploy
given the ability to deliver wireline equivalency (or better) QoS in the
MSAs. What's the foul here? People in those MSAs already have a duopoly
of
"choice" for their broadband. Our proposal will enable the consumer to
have
real choice for high quality broadband. Leaving the urban areas for
unlicensed does zip to benefit consumers and it does not break the
duopoly
in the dense markets. 

In summary, our reconsideration, regardless of opinions about our
intentions, enables:
1. more choice for consumers
2. more choices for unlicensed WISPs (Wi-Fi or WiMAX or etc. today)
3. faster time to market for all operator flavors
4. the ability to deliver high QoS where the duopolies already dominate
5. major investment to the space
6. global economies of scale

By contrast, the R&O does not of these.


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 2:04 PM
To: Patrick Leary; Network Summit Mailing List; Open Spectrum; CWN
Policy;
Unlicensed Advocates
Subject: RE: [Openspectrum] Spectrum updates

At 04:04 PM 6/29/2005, Patrick Leary wrote:
>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).
>
>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.

Patrick:

I understand that the rules are technically "technology agnostic," but 
everyone I have spoken
to has interpreted the filings as directed at promotion of WiMAx.  This
is 
based not merely on assertions
within the comments that making the band WiMax compatible would provide 
positive public interest benefits,
but on the nature of the parties filing.

I will further add that the efforts of parties to recapture 3650-3700
for 
licensed use is having a very negative impact
on the efforts to get unlicensed access elsewhere, such as the broadcast

bands.  If Alvarion, WCAI, Intel, etc. are
concerned about the long-term future of non-exclusive shared spectrum 
access, particularly in the television bands,
I strongly urge you to rethink your position and start making some 
political inquiries.  Especially in the current FCC,
which is at best neutral toward unlicensed, this sort of active
internicine 
warfare only helps the NAB build its case.

>The "contention-based protocol" requirement is counter productive to
the
>intent of the rule and also imposed a narrow framework for industry to
deal
>with interference issues.

Actually, the intent of the rule was to deal with the "Canopy 
Problem."  And it wasn't just us.  I had a meeting with
then-Commissioner 
Martin in which he explained that lots of people wanted unlicensed for 
routine stuff like meter reading, but were afraid that if they weren't 
"always on" they would never be able to get back on because other people

insisted on being "always on."

Contention based protocols deals with this problem in a neutral way that

does not require any FCC intervention.

>In fact, the rule simply cannot work, as I will
>explain later. 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 do not mean to imply that you are "hostile" to wifi.  Many of you 
manufacture wifi equipment, after all.  No, the problem is that the
vision 
you describe for the band is one that is neither sensible for the band, 
given the exclusion zones for incumbents, nor compatible with the vision
of 
my community wireless/public interest clients, which is a band that
allows 
easy entry at the lowest possible price.  The vision you propose for the

band is essentially a carrier-style vision in which 3650-3700 MHz
becomes 
an auxiliary band for licensed WiMax or other licensed technologies.
The 
rules proposed on reconsideration do not (in the opinion of those more 
qualified to judge than I) further the ability of multiple small
operators 
to share spectrum cheaply and efficiently.

>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.

The current rule is "technology agnostic."  Any contention-based
protocols 
capable of sharing the band may be used.
Also, could you please provide a link to the ex parte of the meeting?  I

confess my workload of late has kept me from following the docket as 
closely as I would like.

>  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.

Well, I cannot speak directly to IEEE politics from any personal 
experience.  But from what I have heard second hand, the 802.11 crowd
are 
saying "we could slap together something that would satisfy the FCC
today, 
why should we embark on a process that will delay deployment?"

I understand this will be the subject of considerable debate at the July

meeting in SF.  I look forward to hearing about the outcome.


>[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.]

The division of this into 802.11 v. 802.16 camps is only relevant to the

basic question of how multiple users can co-exist within the band.  In
an 
802.16 universe, it is profoundly difficult to envision multiple users, 
particularly in mesh networks.  But even excluding mesh, without 
contention-based protocols, the incentive is to blast your transmitter
all 
the time.  The issue is not 802.11 v. 802.16. Any technology, regardless
of 
whether it is an IEEE approved standard, that allows multiple users to 
share the space by resolving the "I want to speak but someone else is 
speaking" problem is permitted.

WiMax is a perfectly fine technology for what it is intended-- a
national, 
licensed band.  Why must every available frequency be made "WiMax
friendly" 
anymore than every available frequency should be "broadcast friendly" or

"PCS friendly."  The FCC set aside 50 MHz of spectrum, with geographic 
carve outs from the top 25 markets, to try an experiment in frequency 
coordination.  It did this based on comments from hundreds of smaller 
entities that they wanted something like this for the purpose of
bringing 
broadband to rural areas and low income areas served by low-power mesh 
networks or higher-power hub-n-spoke in rural areas.  They did it in 
response to industrial users and others saying they wanted a place where

they couldn't be squeezed out by "always on" transmitters.

>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.

So leave it to the niche players and the open source folks.  The
exclusion 
of the most profitable DMAs already makes it a hard sell for this band
in 
the U.S.

>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?

THIS is the critical question, and the one upon which the future of 
non-exclusive use of spectrum hinges.

>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.

Again, you re-iterate the argument for licensing.  If what you say is
true, 
that market-based coordination is impossible and that QoS is impossible
in 
an market-based environment, then unlicensed spectrum (or any other
scheme 
for non-exclusivity) is doomed.  Period.
As an aside, there are many situations in which "best efforts" is a 
perfectly acceptable QoS, and anyone who wants better needs to find
another 
provider.  The QoS argument goes back to the 1980s and 1990s, when
TCP/IP 
was never going to be as good as what carriers could provide, so why 
bother?  Tuenred out that cheap, ubiquitous and end-user defined trumped

QoS for enough people to make it useful.

Every market has licensed, fixed wireless providers.  Why must 3650-3700

seek to replicate these conditions?  Many, many people have said they
will 
be happy with what they can get NOW rather than rely on a few licensed 
carriers selling high-priced services, even if that means a step down in
QoS.

And, if history is any guide, the QoS will improve as people use the
band 
and try to solve the problem.  The inability to conceive the perfect
answer 
today says nothing about what clever folks on the ground will develop
tomorrow.

Harold


>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.
>
>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 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).
>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.]
>
>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
>
>_______________________________________________
>Openspectrum mailing list
>Openspectrum at listserv.media.mit.edu
>http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
>
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------------------------------

Message: 6
Date: Wed, 29 Jun 2005 15:59:11 -0700
From: Patrick Leary <patrick.leary at alvarion.com>
Subject: [CWN-Summit] RE: [Unlicensed_advocates] RE: [Openspectrum]
	Spectrum	updates
To: "'Marlon K. Schafer (509) 982-2181'" <ooe at odessaoffice.com>,
	'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>
Cc: FCC Discussion <fcc at wispa.org>, wireless at wispa.org
Message-ID:
	
<A494A015B8AD8B49A6D9EECE8302648D01E18370 at KINNERET.breezecom.com>
Content-Type: text/plain

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
>
> _______________________________________________
> Openspectrum mailing list
> Openspectrum at listserv.media.mit.edu
> http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
>
> This mail passed through mail.alvarion.com
>
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Message: 7
Date: Wed, 29 Jun 2005 16:09:42 -0700
From: Patrick Leary <patrick.leary at alvarion.com>
Subject: [CWN-Summit] RE: [Unlicensed_advocates] RE: [Openspectrum]
	Spectrum	updates
To: "'Marlon K. Schafer (509) 982-2181'" <ooe at odessaoffice.com>,
	'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>
Cc: FCC Discussion <fcc at wispa.org>, wireless at wispa.org
Message-ID:
	
<A494A015B8AD8B49A6D9EECE8302648D01E18371 at KINNERET.breezecom.com>
Content-Type: text/plain

By the way, I definitely would not favor any "first in" rights in any
spectrum that is unlicensed. Never. Never. First in says nothing of
quality.
First in would protect the status quo and leave no room for improvement;
it
lends no motivation to improve. First in also might be a charlatan, a
scam
artist, a RF-ignorant group, or it might even be a good WISP. In any
event,
first in is idea we'd never support. In fact, I argued vehemently
against it
during this process the few times it cropped up.

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
>
> _______________________________________________
> Openspectrum mailing list
> Openspectrum at listserv.media.mit.edu
> http://listserv.media.mit.edu/mailman/listinfo/openspectrum
>
>
> This mail passed through mail.alvarion.com
>
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