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