Did 3.65 GHz Really Cause TV Interference In Philly? Why I'm Skeptical.

Harry Jessell over at TVNEWSDAY has this story about a possible interference problem between operation of 3.65 GHz band equipment and the neighboring C-Band satellite receiver operated by CBS-owned KYW in Philadelphia.

According to the article, KYW experienced interference on its C-Band downlink near the 3.70 GHz frequency in February 2008, and resolved the problem by shifting to a higher frequency. The interference stopped a short time later, then flared up again in September, prompting KYW to call the FCC. That seems to have taken care of the problem, indicating it was a byproduct of some human operation addressed by the FCC enforcement — although possibly not. According to the article, the FCC won’t talk about it — which is standard procedure in an enforcement complaint.

According to the article, KYW Chief Engineer Rich Paleski thinks the problem was a “WiMax operator” using the 3.65 GHz. Paleski worries that 3.65 GHz will not be compatible with C-Band satellite downlink operation and warns “that should concern every station that imports programming via C-band satellite, which is to say just about every station in the United States.” He wants all television broadcast engineers to be alert for interference in the lower part of the C-Band near 3.70 GHz.

Given the rule limitations on use of the 3.65 GHz band, I am extremely skeptical of Paleski’s conclusion. Why? Because given the rules for operation in the band, no one should have been operating on the band in Philadelphia. And even they were operating illegally, they would have needed to hack the equipment to get within 25 MHz of 3.70 GHz, or have anything like the power needed to cause the kind of interference Paleski reports.

Given the growing popularity of the 3.65 GHz band for WiMax (as evidenced by projects like these), I think it’s important to look at this very carefully and not go leaping to conclusions. The 3.65 GHz band holds out a lot of hope for rural broadband by wireless ISPs (WISPS) running small businesses and priced out of licensed spectrum. Before anyone starts speculating from this single incident that use of 3.65 GHz poses a danger lets take a careful look at some of the facts around the use of 3.65 GHz and why I don’t think this is an industry-wide issue. It’s always easy to blame the new neighbor — especially when you think “their kind” is trouble. But how likely is it really?

More below . . .

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How To Give America Wireless Broadband For Christmas 2009 — the Lesson from 3.65 GHz Deployment.

Granted for me it would be Chanukah not Christmas, but I think a real kick ass wireless network with oodles of competition and nifty new gadgets would make such a good present for America for Christmas 2009. And, as the reports from the field on the piece of wireless spectrum the FCC opened up last June show us, the FCC can bring it to us by opening the broadcast “white spaces”.

Sascha Meinrath, a serious partner in crime in spectrum reform, has some data from the field on deployment of equipment in the 3.65 GHz band the FCC finally opened for real in June 2007. Now, a mere 6 month later, Sascha reports on wireless ISPs (WISPs) using this band in the field to deliver broadband. As Sascha writes:

WISPs have been leading the charge and people are reporting 15km non-line-of-sight (NLOS) connectivity with 3650-3700 MHz (operating at 10W) — which is a huge boost over 802.11. Meanwhile, capacity seems to be hovering around 15 MB per 7.5 MHz (or 20MB per 10MHz) — so 100MB connections over 15km without line of sight are quite feasible using this band. All in all, that’s pretty impressive for first-generation equipment. The equipment vendor Aperto is claiming that their new equipment will get 20MB per 7MHz (so you can see the development curve is already fairly steep).

To give you a feel for the real-world implications, folks testing things out reported, “6mb/s indoor at 2 miles NLOS. The base station was a 1 sector install using diversity at approximately 50ft up on tower using 120 degree sectors” — try to get that with an 802.11 access point.

Allow me to draw a few policy implications from this. The lead time from settling the rules to actual deployment of services took six months. By contrast, we have not yet seen any significant deployment in the AWS spectrum auctioned 18 months ago. Yes, some of that was due to the delay of some government licensees in migration. But much also has to do with the nature of licensed v. unlicensed networks. Licensed networks require huge investment of time, resources, standardization of equipment, etc., etc. By contrast, unlicensed networking equipment can be built, certified and deployed effectively relatively quickly.

Policy makers should take note of this in the debate over the broadcast white spaces, aka the vacant channels on the broadcast dial. Broadcasters and some large carriers (like Sprint and T-Mobile) want to see the white spaces licensed rather than opened to unlicensed use. The current broadcast spectrum auction will not begin to bear broadband fruit until 2010 or 2011 at the earliest. And if the FCC were to decide to license the white spaces, we could expect similar lengthy delays while the FCC devised auction rules, held an auction, then waited for the winners to (hopefully) deploy something useful.

Given the continued laggard pace of our national broadband, shouldn’t the FCC learn from its success in the 3.65 GHz band? Licensed and unlicensed networks complement each other, each offering different capabilities. We have taken the first steps toward building the licensed wireless networks in the broadcast spectrum. Why not unleash unlicensed in the white spaces? If the FCC approved rules now, it would practically guarantee that devices could be certified and deployed as soon as we completed the digital transition. Indeed, given the backing of the broadcast white spaces by so many different developers, as compared to the relatively modest backing for 3.65 GHz, the probability of seeing a plethora of wireless networking devices and consumer products available to Americans by Christmas season 2009 rises to almost a certainty. By contrast, we will be lucky if the winners of the 700 MHz licenses will have broken ground on their first towers by then.

Doesn’t America deserve a kick ass wireless network for Christmas 2009? I think so. And if the FCC applies the lesson of its 3.65 GHz success to the broadcast white spaces, we can have one.

Stay tuned . . . .

The 700 MHz Band Auction, Part IIIa: The Classic Pattern and the Mid-Range Competitors

To begin our analysis of strategic options for major actors in Auction 73, 700 MHz Band, it is useful to look at the footprints established by many of those actors in two previous Lower 700 MHz auctions (Auction 44 and 49) and the AWS-1 auction (Auction 66):*
Cellular Market Areas (CMA) Map for Auction 44
Economic Area Groupings (EAG) Map for Auction 44
Cellular Market Areas (CMA) Map for Auction 49
Economic Area Groupings (EAG) Map for Auction 49
Cellular Market Areas (CMA) Map for Auction 66
Economic Areas (EA) Map for Auction 66
Regional Economic Area Groupings (REAG) Map for Auction 66

The Classic Pattern

The classic pattern for an RTC and for most CLECs and WISPs in these auctions is that of Agri-Valley: expansion through Auctions 44, 49 and 66 to attempt to match its landline footprint with CMA acquisitions. In Auction 66 Agri-Valley went for and failed to obtained consolidation in Flint, Lansing, Saginaw, Muskegon, Gogebic, Alger, Cheboygan, Roscommon, and Cass. Expect Agri-Valley to continue this pattern in Auction 73. The same holds true for Whidbey Telephone in Maine in Auction 49, for Hemingford Cooperative in Nebraska, Wyoming, and Colorado in Auction 66, Bluegrass Cellular In western Kentucky in Auction 44, Union Telephone in Wyoming and Colorado in Auction 44 and 66, East Kentucky Network in eastern Kentucky in Auction 44, Fidelity Communications in Missouri in Auction 66, KTC AWS in South Dakota in Auction 66, Public Service Wireless in Georgia in Auction 66, Redwood County Telephone Company in Wisconsin and Minnesota in Auction 44, 44, LL License Holdings in Iowa, North Dakota, South Dakota, Minnesota, and Nebraska in Auction 66, Grand River Communications in Iowa in Auction 44, and Iowa Telecommunications in Iowa in Auction 66. This pattern will continue to hold in Auction 73, and will hold for the vast majority of new entrants in Auction 73: their action will be in the CMAs and to a much lesser extent in the EAs.

More below…

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We Win Again On 3650-3700 MHz. So What Does It Mean?

Back in 2004-05, a bunch of us fought to open up the 3650-3700 MHz band for unlicensed use (Sometimes refered to as 3.65 GHz rather than 3650 MHz). While we did not get “pure” unlicensed, the FCC’s “hybrid unlicensed” regime gave us pretty much everything we wanted.

In August 2005, a group of tech firms led by Intel filed a Petition for Reconsideration. This group, which I dubbed the “WiMax Posse,” wanted the Commission to reverse itself and optimize the band for WiMax operations. Notably, this meant adopting a licensing regime instead of the open spectrum rules we won in March 2005.

By this time, Powell had left and been replaced with Kevin Martin. Martin had earned the eternal scorn of Netheads by deregulating DSL (actually a process begun by Powell). And, unlike Powell, Martin had no record of support for open spectrum. So even though the WiMax Posse and the various licensed wireless providers who came in to support them raised no new arguments, no one knew whether Martin would reaffirm the 2005 rules or side with the licensed spectrum/WiMax posse.

So I let out a huge sigh of relief and felt a modest sense of accomplishment when the FCC issued an Order denying the WiMax Posse Recon Petition and basically reaffirming our March 2005 win. Commissioner Adelstein had a very nice concurring statement highlighting the important roll played by WISPs and Community Wireless Networks (CWNs) in getting wireless connectivity to rural and underserved urban communities.

So what does this mean for wireless deployment for WISPs, CWNs, and muni systems? How do I read the FCC tea leaves in light of last month’s FCC decision terminating two important open spectrum proceedings? See below . . . .

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Please distribute this broadly.

At 2 p.m., I participated in a conference call hosted by the FCC Chief of Staff on how network operators providing service with license exempt spectrum can assist in re-establishing critical voice, data and video service in areas devestated by Katrina.

Part-15.org is taking
the lead in organizing volunteers and donations of equipment from individuals,
WISPs and community wireless networks. Companies such as Cisco and Intel are
also heavily involved.

can volunteer or describe contributions through www.part-15.org (there is a link
on the front page).

There is freely available software and instructions on how to convert a computer and wireless router into a mesh network node from the Champaign Urbana Wireless Network. Their website is http://www.cuwireless.net/

The FCC will remain open throughout the holiday weekend to address the crisis. Coordination efforts are ongoing, but part-15.org hopes to have a preliminary asset list for coordination with federal authorities by Noon Saturday 9/3/05. It would therefore be enormously helpful to hear from people who can donate equipment or time, even if they cannot provide the equipment or time until a later date.

Harold Feld
Senior VP
Media Access Project

3650 Band Up for grabs again

Haven’t posted much, as I’ve been busier than I can imagine, and a big computer crash in our office from last weekend into Tuesday put me waaaayy behind.

Fortunately, my good buddies and folks who actually deploy stuff (as opposedto us lawyers) Sascha Meinrath and Steve Ronan (both involved with CTCNet, as well as Sascha’s role with CUWN have sounded the alarm for me.

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Tales of the Sausage Factory: FCC on Wireless–Mostly Snooze But Some Stuff I Can Use

Lost in all the hoopla last week on the Multicast Must Carry Vote (which I can explain in a future column) was the FCC’s Broadband Wireless Report. It’s conclusion – Wireless Broadband Is Good. Policy recommendations: Stay the Course.

Well, it’s a _bit_ more than that, but not much. See below….

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Tales of the Sausage Factory: Action Alert on Broadband

I’ve been distributing this for anyone interested in using unlicensed spectrum in the broadcast bands.

BTW, due to major issues going on at work (we are losing one of our three attorneys and reorganizing), I’m likely to post terse, infrequent things over the next month or two. Sorry. I swear I’ll keep trying.

Stay tuned . . . .

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