Dear colleagues,
Here are some first draft comments
(in red) against the FCC public consultation document. These are in the form
of bullet points that we will request 802.18 to take into account. The
finalised comments will be e-mailed to Carl Stevenson and recorded in an
802.16 WG document. Please send any further points / refinements for
finalization tomorrow. Indications of support would also be
useful.
1.
To what extent are both licensed and unlicensed
wireless broadband networks providing an alternative facilities-based platform
to other broadband services, including cable and DSL? To what extent
have wireless broadband service providers increased broadband access and
competition in rural and underserved areas? If so, are regulatory
changes needed to promote or advance these trends?
WG 802.16 Draft Response points:
- The fixed systems compliant
with the 802.16 standard are ideally suited and targeted to provide a viable
alternative to other "wired" broadband delivery methods.
- More widespread adoption of wireless
access technology has been hampered by a lack of affordable backhaul
particularly in rural areas.
- Regulatory developments should consider
and address the backhaul issue as well as the "last mile"
access.
2.
Does the Commission currently provide sufficient
spectrum suitable for wireless broadband networks? Is the relative
availability of spectrum for licensed services or unlicensed devices
appropriate? If not, how so?
WG 802.16 Response points:
- Spectrum available either now or in the
future, whether on a licensed or unlicensed basis should be in harmony with
allocations in other parts of the globe.
- Recent developments have greatly
increased the availability of unlicensed spectrum but in isolation this may
not be sufficient. Licence exempt spectrum minimizes the entry barriers for
potential operators but to some extent this is offset by the lack of
protection from interference. Therefore the availability of licence exempt
spectrum should be balanced with licensed spectrum providing a migratory
path for greater protection through "exclusive" assignments. This might be
specifically true for longer range systems like those standardized in
802.16.
- More spectrum for licensed
services would be beneficial. The standardization of systems operating in
licensed spectrum is a major element of the 802.16 standard.
3.
Do the services offered using unlicensed devices
and those using licensed networks complement each other? If so, how?
WG 802.16 Response points:
- For an operator wanting to
provide a complete basket of services then operation under the two licensing
conditions may be helpful. Operation within either licence exempt spectrum
or licensed spectrum might allow for a variety of service "grades" helping
to encourage competitive offerings addressing differing sectors of the
market.
- The 802.16 standard provides
for fully scheduled traffic to provide close control over the grade of
service. It might be argued that licensed spectrum is more consistent with
this feature.
4.
There are several different regulatory approaches
that determine access to the spectrum for wireless broadband service
providers. Service providers using networks composed of unlicensed
devices do not pay for access to the spectrum, but must not cause interference
and must share the spectrum with other operators of unlicensed devices,
whereas access to other spectrum is obtained through licensing after
successful bidding at auction. In addition, some spectrum has been made
available on a first come, first served basis. Has the method for access
to spectrum affected the development of wireless technologies and the
provisioning of wireless broadband services? If so, how?
WG 802.16 Response points:
- The application of auction procedures
have lead to examples around the world where legal considerations and
obligations have carried greater weight than common sense spectrum
management. This can lead to non-optimal or delayed spectrum access for new
operators (or new technology) that is difficult to resolve in a timely
manner.
- Alternatively first come, first served
procedures can also lead to spectrum locked up in a way that similarly
restricts the access.
- For wireless broadband to be successful,
potential operators must have access to spectrum when they need it and in a
way that is consistent with a growing network.
5.
Wireless broadband offers clear advantages over
other broadband alternatives in terms of both portability and mobility.
Do the Commission's rules effectively provide for or account for these
capabilities? Could these rules be more flexible? If so, how?
WG 802.16 Response points:
[Personally I'm less
familiar with the UNII band operation and MMDS in the
US than others may be - can someone
provide insight for a response here?]
6.
Are there regulatory incentives that would foster
continued investment in and deployment of state-of-the-art technologies?
If so, what are they? Are the incentives different for licensed services
as compared with services offered using unlicensed devices?
WG 802.16 Response points:
- The regulatory framework should provide
a perception of ready access to spectrum of the appropriate "quality" for
wireless broadband services to support the standardization efforts of 802.16
participants.
- The spectrum (and licensing
framework) should be seen in the context of an overall spectrum allocation
strategy that properly accounts for the potential for future growth in terms
of services and user demand development.
7.
We seek comment on the extent and nature of the
deployment of wireless broadband services. For example, we are
interested in data regarding market penetration rates; the geographic
distribution of wireless broadband services; the extent of competition in the
areas in which wireless broadband is deployed; and whether licensed services,
unlicensed devices, or a combination of both licensed service and unlicensed
devices are used; and the types of technologies used in the networks
deployed.
WG 802.16 Responses:
[Are there any
marketing guys who might be in a better position to comment?]
8.
With the continued development of new technologies
and network configurations, including mesh networks and integrated wireless
broadband networks and devices that use both licensed and unlicensed spectrum,
are there any rules that require review for updating or increased
flexibility?
WG 802.16 Response points:
- Possibility for higher power in
unlicensed bands.
- Is there enough flexibility to provide
either access or backhaul services?
9.
We also seek comment on the types of applications
associated with wireless broadband deployment.
a.
What types of applications are or will be offered
over wireless broadband networks? Are they similar to the applications
of the wired Internet (email and web surfing), or are other, more
personalized, niche applications being developed? Do the applications
differ between licensed and unlicensed networks? What is the
relationship between network operators and content providers?
b.
What are typically available data rates, and at
what pace are they increasing?
c.
Is the traffic associated with wireless broadband
more typically symmetric or asymmetric? Does the relative distribution
of these traffic patterns affect the required bandwidth for wireless broadband
systems? If so, how?
d.
What is the distribution of wireless broadband
between fixed, mobile, and portable installations?
WG 802.16 Response points:
- 802.16 standardised systems provide
operators with the capability to address the flexibility requirements for a
range of traffic demands envisaged for many services.
10.
While we are interested in these deployment data
across larger geographic regions and on an aggregate basis, we are also
interested in information about wireless broadband deployment in specific
communities -- rural or urban, large or small, and in varied geographic
regions. With a view toward using successful deployments as models or
examples for other service providers or communities, have there been pilot or
full-scale programs that have been particularly innovative or successful in
terms of increasing access to broadband through wireless facilities?
WG 802.16 Response points:
Does anyone know of
any in the US? I could probably find some community
network examples in the UK and I know there are US examples
that have been quoted previously in work on this subject.
11.
Are there ways in which federal wireless broadband
policies could facilitate better available policy options for states and
municipalities? If so, how?
WG 802.16 Response points:
Quite frankly I
haven't a clue on this one.
12.
What barriers (information, infrastructure) to
entry remain for WISP entrepreneurs particularly for unlicensed
services? To the extent identified, how can government address these
issues?
WG 802.16 Response points:
Probably the backhaul
issue identified in response to number 1. Are there alternative ways that
backhaul services could be supplied or subsidised in the US?
Barry Lewis
Tel: +44 1276 479087
Cell: +44 7947 496588
mailto:
blewis@redlinecommunications.com
www.redlinecommunications.com