Just been a bit busy . . .

Haven’t had much time to post here. If interested, you can read my comments to the FCC on why they should give more spectrum to unlicensed access without being a major doofus about it. Or you can read my brief summary (with a few side notes) below.

The FCC has proposed opening up the 3650-3700 MHz band for unlicensed access. A nice little slice occupied right now only by a few Fixed Satellite System (FSS) earth stations. Big set ups on either coast that pump lots of info straight up to satellites. A perfect slice to really open up unlicensed and see what she can do.

The FCC proposed to open up this 50 MHz slice to unlicensed access rather than create a Yet Another Licensed Services (YALS). They proposed to allow fixed devices to operate at 25 watt EIRP (existing unlicensed devices generally operate at 1 watt EIRP, so this is ‘high power’ for unlicensed. By contrast, a full power radio station can operate at up to 50,000 watts and even a “low power” FM station is 100 watts). They proposed to allow mobile devices to operate at 1 watt EIRP.

All to the good, right? After all, this will give more space for lap tops and more power for base stations. With 25 Watts, you can light up a few blocks for mesh networks, or do point to point at a range of about 50 miles with a directional antenna.

But the FCC threw in a few curves. It proposed to create a new “professional certification” for anyone using high power devices. It also proposed that any devices– whether high power or low power — should broadcast its location and contact info on a regular basis. Finally, the FCC asked if it should reconsider its decision not to create YALS.

As I think I’ve said here before, I think create certification requirements for this stuff is a very bad idea. You can follow the link to my comments to see the full reason why. Also, while I’m all in favor of i.d. beacons for high power base stations (they will allow voluntary coordination), I think they are a really, really bad idea for mobile deives. Why?

Question: do you want your laptop to regularly broadcast to the world. “Hi! Here is my position! Here is my name, phone number, address, and email address!” I know I don’t.

So I and a few buddies (all listed on the comments) filed comments saying:

1) Cert requirements for high powered are unnecessary given all the other safeguards and a real bad idea.

2) i.d. beacons on mobile devices are a really, really bad idea.

3) Unlicensed will get broadband deployed more quickly, and more broadly, than YALS.

4) The First Amendment favors unlicensed over YALS.

What is interesting is who else filed and where. The surprise is Intel, which ahs been touting WI-MAX and is supposed to be a big supporter of unlicensed. But Intel filed a brief 3 pages in support of YALS over unlicensed.

“Huh?” I hear you cry. Welcome to the wonderful world of corporate interest. Intel has specific bands in which it wishes to promote unlicensed WI-MAX. Its general posture in those bands is fanatical pro-unlicensed _for those bands_. For other bands, where competitors could get a jump on othe WI-MAX products or where Intel has no advantage in its chips, it is anti-unlicensed and in favor of licensed services (since it will have plenty of lead time to develop chips for the licensed services, since it would take years toget a new licensed service auctioned and online).

So any of you who cherish hopes that our coporate buddies like Intel or Microsoft are going to lead us to the promised land of ubiquitous unlicensed better wake up and smell the Red Bull. Corps do what is best for themselves, not what is in the public interest or even what is intellectually consistent. No shame to corporations for that, but I prefer not to ride in a life boat piloted by someone doing a constant short term cost/beenfit analysis of whether it is worth it to throw me out or not.

OTOH, it was a welcome surprise to see comments from Dave Hughes. For those unfamiliar with him, Dave Hughes is an old wireless pioneer perhaps best known for puting a hot spot on Mt Everest. Hughes spent a lot of time in 1997-99 kicking around D.C. preaching the gospel of unlicensed access. He got frustrated with the slow pace of regulatory change and stormed off. Good to see him back.

An oddball curve were the comments of the 802 Committee of the IEEE. These are the guys who develop the 802.X family of protocols that makes wi-fi possible. Much to my surprise, they want to prohibit mobile devices and allow much higher power point-to-point power to create a network of backbone devices.

I have some serious reservations about this. For one thing, I have found that, as a strategy matter, it is dangerous to go to a friendly agency and say “junk your entire proposal for something better.” Tweaks and corrections are one thing, but this moves in a very different direction from what the FCC initially envisioned. It would require a ‘full stop’ and a rethink by the agency, during which time opponents come in and lobby for what they want.

But even leaving strategy aside, I’m not sure the IEEE approach is a good idea. It smacks of customizing the Part 15 rules for current uses. If we had customized the rules for Part 15 when they were first developed in 1989, we wouldn’t have wi-fi. We’d have super garage door openers. What has made Part 15 great is the flexibility. You can do whatever you want, provided you stick to the power limits and don’t interfere with licensed services.

The FCC will take reply comments until August 27. Naturally, I encourage everyone to tell the FCC what you think (hopefully that you support the comments of NYC Wireless, et al.). At the least, tell ’em that i.d. beacons on mobile devices i a bad idea. You can file a comment at the FCC by clicking here and following the directions. The docket number is 04-151.

stay tuned . . .