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