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The FCC wants you!!!
If you know American ISP's who don't normally hang out on ISP mailing lists or if you have any contacts in the educational system who are concerned with the cost of technology, then please forward this message to them. Here is the opportunity for direct political action that really can make a difference without requiring well-funded intermediaries and lobbiests... Michael Dillon ISP & Internet Consulting Memra Software Inc. Fax: +1-604-546-3049 http://www.memra.com E-mail: [email protected] ---------- Forwarded message ---------- Date: Fri, 14 Jun 1996 22:13:01 -0600 (MDT) From: Dave Hughes <[email protected]> Reply-To: [email protected] To: [email protected] Subject: Re: Accuracies of My Own Resent-Date: Fri, 14 Jun 1996 23:14:53 -0500 (CDT) Resent-From: [email protected] Jack Rickard says: > > In any event, my perception is that Dave is always early to the table, and > by the time the world is ready to buy something, he's already moved on. I > was vaguely aware of his wireless activities, and somewhat more interested > in them with the recent NIIBand proposals. There ARE some issues and I do > hope Dave is successful in steering this toward the 15 km version as > opposed to the limited range Wireless LAN version some of the big guys seem > to be determined to push through. > > In fact, this is actually a rather key issue specifically for Internet > Service Providers and more specifically for those in rural areas. As a > newbie to the mailing list, I may be reintroducing something that has > already been done to death. But this NIIBand could be a huge advantage for > small ISP's in rural areas (not JUST academia and K-12 Dave) if done right, > and another fiasco if done wrong. The FCC has this open for comment now. > If Mr. Hughes would provide info on docket numbers and where to write, you > all could have a significant impact. On the one hand, you can offer 24 > Mbps links by radio at 10-15 km. On the other, 3COM can do wireless LAN > inside a building for about 1000 feet. All from a stroke of the FCC pen. > > Yes, this is a far more significant issue than most ISPs realize - whether the FCC, in both responding to the Apple-WINForum proposal to allocate 350Mhz of spectrum in the 5Ghz bands for what the FCC dubbed the "NII/SUPERNET" Band for 'no licence' wireless - will do that in BOTH the 'wireless lan' segment AS WELL AS the requested '15 km' segments and thus permit anyone, including ISPs to have no-comm cost bandwidth up to 2Mbps between two points, or, with relay, 1Mbps (above and below T-1) for the cost of the radios. Spread spectrum technology which is a revolution in radio communications (wide band, digital processor controlled low power - with no practical interference versus traditional narrow frequency band high power - with so much interferecne, the frquencies have to be licenced and highly controlled). And yes I, and a too-small handful of others are deep into the issues at the FCC level as the decision hangs in the balance. Because I am the Principal Investigator on the $375,700 'Wireless Field Test for Education Project' I was invited to a roundtable with FCC Commissioners nominally debating 'wireless for education' two weeks ago, and, using our real-world wireless project going on in the San Luis Valley (one school being relaibaly connected now 15 miles at 115kbs, bypassing US West, from NT-Lan router to Cisco Router at the POP. Zero local loop cost) and reporting on the other projects we have examined (8 Belen, New Mexico Schools, conected T-1 between each other in a WAN - up to 10 miles across the district. Zero local loop cost (which would normally run $84,000 a year wiht telco T-1 between schools). We made an impression, but know what giant forces we are up against. Some FCC staffers want to 'auction' the longer range (even 15km) stuff. Some big communications companies, led by the Cellular Telecommunications Industry Assn - CTIA, would like all 'no-licence' that can compete with them to be killed. Our arguements, that got a few thinking anyway, was that IF the FCC rules permit radios to be made which go 15-45 miles, no licence, no interference, and solve the problem of the 16,000 school districts whose biggest problem is the cost of bandwidth *between* school building of a district first, then the cost from the main hub to the POP, second, then between the student and/or teacher at home to the school, at 56kbs or above, THEN the problem of 'community' networking will also be solved. For school districts are coincident where people live and log on from. (ditto ISPs) We turned a few heads when I showed my calcuations that, if the 14 School Districts of the SanLuis Valley are connected to the one central POP at T-1 by US West, it will cost $1.2 million over 10 years. If by T-1 25mile radios (yeas they exist now) it will cost $173,000 for the same 10 years. Now if ISPs want to strike a blow for economic telecom freedom, you can start by accessing our NSF Wireless Field Test web site, http://wireless.oldcolo.com and go into the Regulatory section where you will find direct documents, links to the FCC, the Belen Paper, and my long but piercing piece 'The Case for Public Spectrum' (and if you are a skeptic about the technology, read the Paul Baran short papers - the invetor of packet switching) Then all you have to do to sumbit public comments o the NIIBand matter is to email: [email protected] and that is the email address for the Docket Item. You *must* comment before July 15th, or yours will not be considered. (but under the law and regulation, if you *do* comment, your comments must be summarized by the staff and presented to the COmmissioners with the staff views. You do NOT have to comment on all the heavy duty technical issues. Right from the chief FCC Engineer who drafts the rules, and was the father of the original Spread Spectrum rules in 1985 he says that your statemnt of what you NEED, and why, would be much appreciated. As simple as 'I am an ISP who needs T-1 from my site, 8 miles to the nearest POP, no licence/cost wirless, with a radio I can afford' is to the point. (of course the more you show your technical economic need in sophisticated terms the better it will be received. The FCC engineers are no dummies and political handwaving doesn't impress them (it only impresses the COmmissioners whenthe handwavers are called AT&T or Congress) I can just about assure you the FCC staff doesn't even know you exist, as a class, (small ISPs) or what function you serve in the food chain, or why you shouldn't just pay $650 a month for your local loop T-1 like anybody else. And unless you email them (and they now have a policy that email must be taken as seriously as formal paper mail filings), your colective case won't even be mentioned when the likes of Motorola, AT&T, CTIA, the NSA (who gets gas pains when secure wireless is mentioned) are testifying. All will not be totally lost if this NPRM does not fly (new spectrum) for we still have the more congested Part 15, 1 watt bands. And the 4 NSF types who attended the FCC rountable were impressed enough with our case that we spent a day with them and they are about to fund a 'developmental' project that will be done by TAPR, that may bring you that $500 T-1 plug and play radio, with range. (by licencing the guts to mfgrs). Matter of fact I will be in Washington DC at the NSF Monday on this (being carrie dby my sidekick in radio engineering matters) and two other matters. One of which will (their idea, not ours) see part of our team in Ulaanbaatar, Mongolia in August, linking 8 sites to the satellite Spintlink downlink site run by Mongolian engineers in an old Soviet lab. (web page at www.magic.mn already - but they can't get the signal across town, so crappy is their phone system). So by September you willbe pinging systems in Mongolia, the last 10km of which will be wireless. I always wanted to help set up the Ghengis Khan BBS in a Mongolian yurt, running OS2 (cause IBM is everywhere), with NAPLPS character sets (Chinese, Cyrilli Russian, and Mongolian - none of which are ascii), solar powered, and with spread spectrum radios linking China to Russia. With nary a Telco in a hundred miles. And I got a hunch I will have that done before ISPs in NYC do it. Dave Hughes [email protected] Oh yeah, if you http://220.127.116.11 you will reach, by wireless, the OS2 system in my home. Not blazingly fast beacause I am trying out a different set of radios. And teh wired 56kbs frame relay to which it is attached is actuallythe slowest link in the chain. But its been running 160kbs for almost a year now, for $0 cost from me to my own Internet service. - - - - - - - - - - - - - - - - -