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