Steve Stroh comments on FCC 04-186 (White Spaces)

[David Farber <dave () farber net>]

Begin forwarded message:

From: dewayne () warpspeed com (Dewayne Hendricks)
Date: October 28, 2008 8:37:25 AM EDT
To: Dewayne-Net Technology List <xyzzy () warpspeed com>
Subject: [Dewayne-Net] Steve Stroh comments on FCC 04-186 (White Spaces)

[Note:  This item comes from friend Steve Stroh.  DLH]

From: "Steve Stroh" <steve () stevestroh net>
Date: October 27, 2008 9:26:06 PM PDT
To: "Dewayne Hendricks" <dewayne () warpspeed com>
Subject: Thought you'd enjoy this

My comments on 04-186.

I just thought I'd throw my hat in the ring.

It's public record now (or will be soon), so if you want to post on
Dewayne-Net, feel free. I'll post it on BWIA News in the morning.


Thanks,

Steve
------

In the matter of FCC-04-186

Comments of:

Steven K. (Steve) Stroh
P.O. Box 84
Redmond, WA 98073
425-939-0076
steve () stevestroh net

I am Steven K. (Steve) Stroh and I am providing these comments to the
FCC on the matter of Television Broadcast Spectrum "White Spaces" -
FCC-04-186. The informal comments that follow are my personal views as
a US Citizen and a person with some experience in the use of wireless
technologies to provide Broadband Internet Access.

Disclosure:
I am a (lapsed) member of the Wireless Internet Service Providers
Association (WISPA) and perhaps (uncertain of my status) a member of
Part-15.org, both of which have filed comments with the FCC in this
matter. While I am a member of the former's standing FCC Committee, I
have not actively participated in, nor actively followed that
committee's deliberations nor participated in the formulation of their
position or comments to the FCC. I do not necessarily support, nor
dismiss either organization's comments or views.

Background:
Although I received formal training in electronics, my primary
technological background relevant to the subject of license-exempt use
of "White Spaces" is considerable hands-on experience in wireless data
communications using Packet Radio as a licensed Amateur Radio Operator
– N8GNJ. As a Ham, one learns a LOT about how radio communications
REALLY works – the theory, the practice, the technology. My primary
professional background is as a Systems and Network Administrator, and
later, as a writer on various technology subjects, primarily Broadband
Wireless Internet Access.

As an Amateur Radio Operator, I participated peripherally in a Special
Temporary Authority (STA) operated by various Amateur Radio
organizations to experiment with the use of Spread Spectrum
technologies in Amateur Radio. That experience piqued my curiosity
about the use of wireless data communications, which led me to
self-educate (via the early commercial Internet) on the topic of what
I came to call Broadband Wireless Internet Access, later standardized
into technologies and "brands" such as WiMAX and Wi-Fi. At a point
where I had learned a lot about the subject, I proposed a column on
the use of wireless technologies in providing Internet Access to
Boardwatch Magazine. I began writing my "Wireless Data Developments"
column in April, 1997. That column ran for almost five years, and led
to a number of other writing opportunities, speaking engagements at
conferences, consulting work, and participation as a commenter and
appearance on a panel of the FCC's Spectrum Policy Task Force. I
started, and continue to write one of the earliest blogs on the
subject of Broadband Wireless Internet Access (now titled Broadband
Wireless Internet Access / WiMAX News) at www.bwianews.com.

One of my last opportunities to write for Boardwatch was a
little-noticed article, in that little-noticed publication, in
January, 2002, was an article titled "Wireless Smart Radio, Heavy
Lobbying Would Bring Wireless ISP Band." In that article, preserved
online via the Internet Archives at
<http://web.archive.org/web/20021212225707/http://www.ispworld.com/boardwatchonline/2002/jan02/technology-wireless.htm 
>

In that article, I proposed the essential elements of what has now
come to be known as "White Spaces". The primary points I made were:
* There was, and would continue to be, ample unused portions of
spectrum in the portions of bands allocated to television
broadcasting;
* Some simple rules, such as detecting actual television broadcast
transmissions, would reasonably insure that there would be a minimum,
if any actual interference*;
* License-exempt use would be entire feasible if those rules were
embedded into the radios;
* That the most useful purpose for "White Spaces" would be by those
providing Broadband Internet Access;
* That the primary obstacle to implementing "White Spaces" would be
political objections, not technological obstacles.

I am comfortable in saying that I have been seriously considering
"White Spaces" ever since, and considerably longer than most, and I
have given considerable thought to the various approaches that have
been outlined for implementing "White Spaces".

Thus, I commend the Commission for their research and apparent
willingness to seriously consider the possibility, and more
importantly, the potential of "White Spaces" in the face of the
(totally predictable) political opposition from the broadcasters and
their cronies. I honestly didn't think that 04-186 would actually be
acted upon by the FCC – at least in this decade.

My primary conclusion from more than six years of "mulling over" the
possibility of "White Spaces" is that "spectrum sensing" should be the
primary method of insuring non-interference with television
broadcasting. Television transmitters are very powerful, even "low
power" stations, and their transmission systems are always very
well-engineered to insure uniform coverage over their intended service
area. Therefore, it's reasonable to posit that a "White Spaces" device
could reasonably be expected to "hear" a television transmitter's
signal – well enough to "know" that a particular television channel is
in use for television broadcasting and "the rule" embedded into the
radio would be, of course, "if you hear a television signal, even if
it's weak, don't use that channel".

That there were some issues in the "spectrum sensing" capabilities of
the prototype "White Spaces" devices that the Commission's technical
personnel recently tested is, in my opinion, merely an artifact of
very early technology. The first Wireless LAN / Broadband Wireless
Internet Access devices weren't exactly a rousing technological
success either. What was being tested in those prototype "White
Spaces" devices was the concept – COULD license-exempt "White Spaces"
devices be made to work – was the CONCEPT valid? From my reading of
the FCC's most recent report on the testing of prototype
license-exempt "White Spaces" devices, the answer is Yes – the concept
IS valid and could be made to work with good-enough technology. And
thus the next step for the Commission is create rules that allow the
"White Spaces" concept to be realized. Creating the "good-enough"
technology is for industry to create in the wake of  Commission rules
for "White Spaces" operations – exactly like what happened for the
first wireless broadband devices in the wake of the commission's
revision Part 15.247 in 1985.

My particular experience and judgment combine to conclude that
"spectrum sensing" combined with "beacons", is a good compromise
solution to the issue of wireless microphones, which, essentially,
"squat" on vacant television channels, as well as other non-television
use of television broadcast spectrum. A "beacon" could transmit at
higher power levels than wireless microphones, using a robust
modulation technique (so the beacon's transmitted power level wouldn't
need to be anywhere near that of a television broadcast transmitter).
The information transmitted in the beacon could "explain" to "White
Spaces" devices which television channels should not be used in a
particular area. Like wireless microphones are supposed to be (but
rarely are…) such beacons should be licensed / registered with the FCC
to curb the potential for abuse by broadcasters and competing
providers of Broadband Internet Access.

The use of "spectrum sensing" will allow "White Spaces" technology,
systems, and devices to evolve much more rapidly than they would
otherwise be able to if "geolocation database" was mandated for each
white space devices. It seems unlikely that Wi-Fi, Wireless ISPs, or
cordless phones could ever have come into being if each device and
system was burdened with the requirement of a full-time Internet
connection, a GPS receiver, or an embedded database of "all the places
you're not allowed to transmit" (or, alternatively, the few places the
device WAS allowed to transmit… at the time of manufacture).

Much of my writing about Broadband Wireless Internet Access over the
past decade has focused on the small Wireless Internet Service
Providers (WISPs) such as those represented by WISPA and Part-15.org.
While there are small WISPs serving metropolitan areas, WISPs are much
more prominent… and vital… in non-urban and rural areas. WISPs often
provide the only alternative to expensive and (generally)
poor-performing satellite-based Broadband Internet Access.  For WISPs,
and indeed, any entity (including individuals) with a mission to
provide Broadband Internet Access, such as Indian Nations, remote
villages, even ships and oil platforms offshore, license-exempt use of
"White Spaces" would prove to be far more effective in providing
Broadband Internet Access than current spectrum and technologies.

In my consulting, I've been asked to help out on various proposals to
implement Broadband Wireless Internet Access and one constant in many
of my consultations has been that the lack of suitable spectrum has
stymied many worthy attempts at providing Broadband Wireless Internet
Access to areas where Broadband Internet Access is otherwise
unavailable or unaffordable. One example that I was peripherally
involved in was that Wal-Mart was at one time interested in setting up
"cell sites" at each of their stores to provide reasonably-priced
Broadband Internet Access via wireless to the communities surrounding
each store. Wal-Mart had enough scale and financial resources to
provide the needed high-speed "backbone" links (already in use at each
store) and to construct the towers and radio systems. What ultimately
stymied these proposals was that the license-exempt spectrum that was
available at the time could not provide sufficient "penetration",
scale, and quality of service to make a compelling business case.
"White Spaces" would make such a system entirely feasible. (I have no
affiliation whatsoever with Wal-Mart.)

Conclusion:
I commend the Commission for its continual adaptation of the original
Part 15.274 rules and regulations for license-exempt devices and
systems, and their courageous stand not to "pick winners" in the
numerous "turf battles" that inevitably arose from the competing and
at times incompatible uses of ISM and UNII bands. That approach led me
to posit a theory I call "The Darwinian Effect Of License-exempt
Wireless". Briefly, that is that license-exempt communications devices
that are "competing" in a "competitive ecosystem" such as the ISM and
UNII bands must continue to evolve to perform better, cost less, and
be "robust" because not only of the environment but also because of
the intense competition of many vendors and different technological
approaches.

Initially, the Part 15.247 rules were extremely confining. But
technology – incredible advances in cost-effective digital signal
processing, computing "horsepower" and memory capacity, algorithms, as
well as incredible advances in semiconductor manufacturing, materials
research, and resurrection of formerly-impractical technologies such
as MIMO and OFDM, overcame those otherwise-crippling limitations.
Competition… and demand… did the rest. I watched (and discussed, at
length, with a number of FCC personnel) how the Commission come to
understand that "loosening" the Part 15.247 rules would result in even
higher usage and economic activity. They did… and it did.

I believe that the result will be similar with LICENSE-EXEMPT use of
"White Spaces" if the Commission has the courage to implement minimal
rules that are biased towards the future, such as requiring (perhaps
quite strict, and thus a "technological stretch" – at first) "spectrum
sensing" approach, instead of an "only-lawyers-could-love-it"
"geolocation database" requirement. The United States invented the
Internet. With White Spaces, the US could re-invent the Wireless
Internet.

* Paul Baran formulated prescient "Kindergarten Rules" for
license-exempt wireless devices -
<http://www.winlab.rutgers.edu/~crose/baran.html>RSS Feed: <http://www.warpspeed.com/wordpress 
>




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