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To: Peter Ecclesine who wrote (35467)9/4/2010 4:10:40 PM
From: Charles Brown2 Recommendations  Read Replies (1) | Respond to of 46821
 
Hi Petere,

As long as we defend and support the regulatory status quo, like Part 74 -subpart H wireless microphones, we make a deliberate choice to compound error by adopting the meme of the 1920’s - slice, dice, splice, and finally, sell the electromagnetic spectrum.

If we consider an alternative approach we would have better receivers, and therefore, better sensing technologies because it would attract investment. I don’t think it is accidental that technical complexity is often used as a “MacGuffin”, or plot device in these discussions in the industry.

en.wikipedia.org

The FCC is also fond of Catch-22 arguments. “If you want this, show us that it works. If you can’t show us then go away.” It’s default bureaucracy to invoke a negative when an existence-proof doesn’t exist or when thinking and innovation are what is required. The person making the proposal is then in a position of proving a negative, with or without regulatory approval. The experimentation site issue and obtaining Part 5 Experimental License is less of an issue today since regulatory forbearance can be obtained in other sovereign countries at much less cost. This is an example of the "end run" strategy.

The status quo process is a costly, futile trap, complete with a hoary cast of telecom lawyers, lobbyist, committees espousing the views of vendor business models, and general DC-Beltway pandering and influence peddling. Among other things, it raises the cost of entry and “perceived risk”, which is also a myth depending upon the assumptions made. However, it is successful in blocking innovation. It’s not accidental that companies like Shared Spectrum Co. are resident and have found their funding in the Beltway.

While I understand the practical aspects of moving on the white spaces while the political timing was propitious, I wonder if it would exist at all if Microsoft, Dell, Google, et al, had not perceived the opportunity for a command and control model to leverage their data center investments and provide a pathway into portable devices. M2Z, the front-company for Google’s mobile/portable advertising ambitions, was mentioned in Message 26799997 passes for "creating thinking" in this crowd.

I’m not alone when I say that I will not share my medical records, browsing records, financial records, public safety, nor will I accede to their dishing-out community resources like radio spectrum for my “benefit.” I don’t want my communications access provisioned from the "cloud" or the “network.”

Specifically to the issue of Part 74 devices, wireless mics could have been “grandfathered”, which would have provided the industry with the opportunity to up-sell to HD and better devices in the new world of dynamic spectrum access. It could have been a catalyst instead of an inhibitor. The trade-off being made for wireless mics is a bad one by any socio-political-economic measure. If the broadcasters won’t be appeased, innovation demands a “end run" is intrinsically irresponsible, which is also a convenient myth. This can be done responsibly and I would argue that sometimes interests can be aligned; sometimes not. Just as Apple showed the music industry how to monetize their products in the world of digital distribution, the same is required in the wireless industry. IOW, the broadcasters need to be led, not fought. I would argue that that is also in their interest.

Regarding “sensing” in the “real world”, when we have commercial investment we will have better receivers and protocols. We won’t have commercial investment as long as we are caught in circular thinking about the problem. In the meantime, the only viable choice is to “end run” with what I call, “Renaissance Radio.” This concept avoids the regulatory maze and creates a new model which makes the old model obsolete. We will not have value creation by attacking the impregnable fortress of the status quo in wireless communications. Asking permission won’t work, not in this country anyway.

From my perspective, the WS proceeding is a lost opportunity on many levels, and a rather large one at that given wireless trends and how badly things could go wrong once this model is used as an “existence proof.”

On the topic of trials and existence-proofs of the WS architecture, perhaps you can point to some trials besides SpectrumBridge/SpecEx, which IMO, is short on details and long on “proprietary technology”, hyperbole, and “command and control” bedfellows. I perceive this company’s role as a sort of “point man” for WS interests, and Wally too, for the purpose of creating a trading market in spectrum. And therefore, it has attracted investment for all of the wrong reasons.



To: Peter Ecclesine who wrote (35467)9/5/2010 9:59:43 AM
From: Peter Ecclesine  Read Replies (1) | Respond to of 46821
 
Hi All,

On the difficulty of sensing all the equipment that License holders are allowed to use:

FCC Part 74 are mostly video services

gpo.gov

Part 74 Subpart H Low Power Auxiliary Stations

74.870 Wireless Video Assist Devices, which allow radio links of unspecified modulation between TV cameras and recording consoles.

(d) Wireless video assist devices are
limited to a maximum of 250 milliwatts
ERP and must limit power to that necessary
to reliably receive a signal at a
distance of 300 meters. Wireless video
assist devices must comply with the
emission limitations of § 74.637 [which are power limits] .

No particular modulation waveform is required. . .

How can anyone reliably sense whether the devices are being used by valid license holders, (about half of the Part 74 licenses are lapsed ;-) ), or the responsible parties do not enjoy protection?