The FCC has been pushing TV broadcasters toward digital television, in order to free up the analog TV spectrum for uses such as wireless home networki

FCC: Open up TV waves to wireless
By Richard Shim
Staff Writer, CNET News.com
January 16, 2003, 2:51 PM PT

The Federal Communications Commission is quietly considering opening the television broadcast spectrum for use by other wireless devices, including Wi-Fi products.

The proposal, revealed in a notice of inquiry adopted last month, would allow devices using unlicensed spectrum--bandwidth not licensed to broadcasters--to operate in the TV broadcast spectrum. However, they would tap into only those parts of the TV spectrum not being used and only be allowed to do this when they wouldn't interfere with authorized services.

The Dec. 20 notice will take effect when it is published later this month in the Federal Register, said an FCC representative. At that point, the agency will kick off a 75-day comment period.
The regulatory body is expecting a dogfight from TV broadcasters who in the past have been very protective of their territory--opposition that could derail the proposed changes or delay them.

"We're in for a bit of a bumpy ride," said Alan Scrime, chief of the policy and rules division in the FCC's office of engineering and technology. "TV broadcasters are an influential bunch. We're not expecting this to be a real quick one."

The FCC has been pushing TV broadcasters toward digital television, in order to free up the analog TV spectrum for uses such as wireless home networking technology.

The agency is looking at TV spectrum because it provides significant amounts of bandwidth per channel. In addition, the frequencies and amount of unused TV spectrum varies in different regions, leaving more opportunities for use, according to the notice.

Current 802.11b-based, or Wi-Fi, wireless home networking products operate in the 2.4GHz band and can interfere with other devices--such as cordless phones--in the same band. Expanding the spectrum of unlicensed devices would mitigate many interference issues, and could pave the way for new types of devices that can operate in other bands.

Scrime said that manufacturers have been developing products that can sense when they would interfere with other devices.

The FCC and specifically its chairman, Michael Powell, have promoted the adoption of broadband access by consumers. Wireless home networking technology has been viewed by the regulatory body as a significant complement to broadband, because it makes the service more valuable by allowing multiple consumers to share access wirelessly.

Others in Washington have been promoting the use of Wi-Fi technology. Late Tuesday, Sens. Barbara Boxer, D-Calif., and George Allen, R-Va. proposed the Jumpstart Broadband Act, which would allocate additional radio spectrum for unlicensed use by wireless broadband devices and add wireless technology as a third method of improving the establishment of broadband access.

The notice of inquiry to be published does not specifically identify Wi-Fi wireless home networking technology. However, as technology that uses unlicensed spectrum, Wi-Fi products would get a boost.

Wi-Fi products operate in the 2.4GHz and 5GHz bands, which are unlicensed parts of the radio spectrum. Analog TV stations operate in 6MHz channels and the FCC is targeting the 54MHz to 72MHz, 76MHz to 88MHz, 174MHz to 216MHz and 470MHz to 806MHz bands.
"Wi-Fi should benefit, if this comes to pass," Scrime said.

"We must be able and ready to conduct independent harmful-interference tests, and to act decisively when harmful interference has occurred," Commissioner Michael Copps said in a statement at the time. Other commissioners seemed inclined simply to wait until the digital-television transition is complete.

The politically powerful National Association of Broadcasters has voiced resistance to the idea for similar reasons, arguing that the devices would muddle the reception of over-the-air TV stations. The Consumer Electronics Association said in comments to the FCC last year that its member companies could not reach a consensus as to whether new devices could be introduced to the spectrum without posing interference risks to existing services.

Both new bills would instruct the FCC to move more quickly on concluding those rulemaking procedures. The agency would have to come up with technical rules and guidelines for those operating on the unlicensed spectrum, with an eye toward preventing "harmful interference" from the new devices.

But they differ slightly in their approaches. The American Broadband for Communities Act offered by Sen. Ted Stevens, the Alaska Republican who chairs the Senate Commerce Committee, would involve rewriting telecommunications law to free up only certain portions of the unused spectrum for wireless deployment.

Virginia Republican George Allen's two-page Wireless Innovation Act of 2006, co-sponsored by Democrats John Kerry and Barbara Boxer, and by Republican John Sununu, appears to call for unlicensed wireless activities on any unused piece of the analog TV band.

"At a time when the U.S. is lagging behind much of the world in broadband penetration--and more than 60 percent of the country does not subscribe to broadband service primarily because it is either unavailable or unaffordable--our legislation would put this country one step closer to closing the economic digital divide and achieving ubiquitous broadband Internet access throughout America," Allen said in a statement.

Thursday, April 6th, 2006 by Andy Beal


Google and Earthlink to Offer Free Wi-Fi to San Francisco
Unlike a lot of people I speak to, I’m not a big fan of San Francisco and so have never been compelled to be out in the “Bay”.

Google and Earthlink just came up with one reason worth the move, FREE Wi-Fi for the entire San Francisco area! The two companies won a joint bid to provide the city with free wireless.

According to ClickZ…

Under the companies’ plan, Google’s 300 Kbps “basic access” service will be free and ad-supported, while Earthlink will offer a paid 1 Mbps connection for around $20 a month.

Ads from Google will appear on the network’s capture portal, typically the first page users see when they log onto a third-party Wi-Fi network. In its proposal, the Mountain View company said it would market those placements to small Bay area businesses.

Google’s keeping quiet on exactly how they intend to display the ads (and how many), but I guess we’ll learn by the end of the year, when the project is scheduled for completion.

February 25, 2005
Speculator "Games" Low Power Television - Screws Up Potential For License-exempt Use Of TV Spectrum

I caution you to read the following, including the hyperlinked documents, carefully and critically. Not doing so will probably result (as was the case with me) in coming to a (mostly) incorrect conclusion that a Machiavellian plot is underway to blatantly, artificially restrict the amount of television broadcast spectrum potentially available for license-exempt use. While it appears that a plot is definitely underway to amass "paper" television station licenses... the purpose seems to be simple financial speculation - greed. This time, anyway.

In a February 24, 2005 email message (thoughtfully forwarded by Esme Vos of MuniWireless.com), Michael Calabrese, a Vice President of the New America Foundation (Spectrum Policy Project) writes:

Subject: Center Public Integrity Expose on spectrum speculators eating up white space in the TV bands

I'd like to call your attention to the Center for Public Integrity's expose, released today, revealing how spectrum speculators are accumulating Low Power TV licenses in a bid to "own" empty TV band channels ahead of the FCC's pending rule making to open TV "white space" (the wasted analog guard bands) to affordable community broadband on an unlicensed basis.
New America research associate Kartik Ramachandran identified the company, MS Communications, on which the Center for Public Integrity based its expose. This research, led by Jim Snider, is merely one example of a concerted broadcast industry effort to expropriate "white space" in the Channel 2-52 band -- a $6 billion grab (to date) described in the FCC Reply Comments we filed on behalf of a national coalition supporting the reallocation of unassigned TV channels for community broadband access.

You can view the expose at:
http://www.publicintegrity.org/telecom/printer-friendly.aspx?aid=602

You can view our Reply Comments describing the larger broadcast band spectrum grab at:
http://www.newamerica.net/Download_Docs/pdfs/Doc_File_2203_1.pdf (PDF download)
I hope this will lend credence to the argument that these TV band speculators should not be given more spectrum at the expense of unlicensed broadband and our economic future. Another question: why isn't the FCC stripping licenses away from these spectrum speculators?

Again, my conclusion of the aim of MS Communications is that they spotted the opportunity to "game" the FCC's arcane processes for licensing low-power television stations. This exchange is particularly enlightening:

When the Center queried the commission about MS Communications, an agency spokesperson replied in a written statement: "We can confirm that MS Communications is currently broadcasting over 201 LPTV licensed stations." In fact, Silberman is not broadcasting programming on any of those stations.

In Meridian, Miss., for instance, where MS Communications holds licenses for 12 low-power stations, the Center confirmed that nothing is currently being broadcast over any of the assigned channels. When asked about this, the FCC spokesperson replied that, as a matter of practice: "We trust that the licensee has indicated through filings that they are broadcasting and if they go off the air…they have to apply for the authority to [do so]. The responsibility is in the licensee's hands to notify the FCC when they are no longer broadcasting and the reasons for doing so."
This illustrates just how badly the FCC is out of touch with the real world. Their "reality" is defined by the paperwork that MS Communications files with them on a regular basis... not the "ground truth" that the spectrum that MS Communications has "locked up" has not seen any productive use since it was granted by the FCC.

The New America Foundation filing is troubling. The filing does an excellent job of documenting the "grab everything you can" mentality of the television broadcasters in the conversion to digital television broadcasting. (NAF's Jim Snider was the first to inform me that, in blatant contrast to the original plan for digital broadcasting, the television broadcasters will now be allowed to retain television channels 2-13.) Simply, the broadcasters are very effectively Gaming the FCC system; all but inevitable given the broadcaster's legal prowess and the FCC's "paperwork is reality" environment. Such in-depth research is commendable, and a demonstrable reason to support the work of the New America Foundation.

The conclusion that I reach from the MS Communications story and the NAF Filing (after a second, careful reading) is that the activities aren't a "smoking gun" of deliberately trying to sabotage the potential license-exempt use of television broadcast spectrum.

Sadly, the MS Communications story, in a microcosm, is the real story, writ large of the FCC's spectrum allocation policies over the last century. Overall, the radio frequency spectrum is vastly underutilized. Every Hertz per second per square mile that is not used is lost forever. Unlike the environment in the past century that the FCC was designed to administer, we now have technologies that can make efficient, shared, non-interfering use of all the available spectrum... but most companies are afraid to try to do so, at least in the US. Such innovation will inevitably be driven to developing countries where an "MS Communications, aided and abetted by the FCC" mentality doesn't (yet) exist.

My impressions of the current leanings of the FCC in permitting license-exempt use of television broadcast spectrum involves the use of an embedded GPS receiver and a centrally-maintained, accessed-by-every-device database of "don't transmit on "this" channel if you're located "here". The MS Communications example nicely illustrates why such a model ultimately unworkable, or at best, not the most efficient approach.

This is exactly why, in my in-person testimony (PDF, you'll have to search) to the FCC at the August 9, 2002 Spectrum Policy Task Force hearing, I recommended a "ground truth" technique for determining where there was available "white space" in a given area's actual use of television broadcast spectrum.

One of the things that Chairman Powell said this morning really struck me. He would really like to hear concrete proposals for how we get to the ideal of more of a spectrum commons model, flexible use and away from the private ownership model.

One thing that strikes me is that Mr. Tawil stated that they had gone down to using 288 megahertz of TV spectrum and what frustrates a lot of the techies and I've watched the 2.4 gigahertz thing band evolve very incredibly, long-range, very high bandwidth, many users, very dense deployments. They're making all that work in 83 megahertz of spectrum with some really onerous rules like very low power and they're making it work in that little chunk of spectrum in a very bad part of the spectrum for things like tree foliage.

The TV broadcasters have a total of 288 megahertz of spectrum available in the prime part of the spectrum and yet in any market, there's a handful of those channels that at most that are in use, 20. I'll be charitable and say 30. Why not evolve a model that lets a radio use the channels that are not being used for broadcasting and the radio has got to have a very specific limitation that it listens on a particular channel and if it hears TV broadcasting it just positively locks that up. There's no possibility of override. The radio just cannot go there if it hears a TV broadcast.
But the 75 percent of the other channels that aren't in use, that's legal, and it listens on a periodic basis every 10 minutes and that will encompass the ability to hear low powered TV stations, even somebody who's using one of these little rabbit transmitters that transmit on Channel 3 or 4 inside a house, it wouldn't interfere with 6 those. That's a way to get -- that's a way to at least start the transition into a more flexible use model. It's frustrating to hear the idea that that broadcast spectrum can't go there, no way, no how.

It seems to me to be a very simple equation - if the television broadcast spectrum is actually in use for the originally licensed purpose - television broadcasting, then license-exempt use of that channel isn't allowed. "In use" is easily determined by the embedding of the essential elements of a television tuner - if an analog or digital television transmission is decoded, that's "in use" as far as the license-exempt radio is concerned, which will then go on to use another channel that isn't in use.

Steve Stroh
This article is Copyright © 2005 by Steve Stroh


FCC Grants Aloha Partners 700 MHz Adjacent Channel Waiver

On February 18, 2005, buried in the typical minutiae of the FCC's daily output of announcements, was the approval (PDF link) of a long-sought waiver request by Aloha Partners LP that allows them to commence Broadband Wireless Internet Access services using their 700 MHz licensed spectrum in the Tucson, Arizona market. While Aloha Partners has been very public about the submission of the waiver request, it was not a certainty that the waiver would be granted.

In marked contrast to several previous developments with Aloha Partners (no, they don't have seem to have a web page - go figure), Aloha Partners has been silent about the granting of the FCC waiver. I was alerted to this development only through a mention in the February 24, 2005 issue of the Wireless Communications Association International's (WCA) Weekly Bulletin and License Exempt Alliance (LEA) Report (available only to WCAI members).
The waiver is necessary to conduct a proof-of-concept operational test that Aloha's operations in their 700 MHz allocations in Tucson (the former television channels 54 and 59) will not materially impact ongoing television broadcast operations on television channel 58 (which will eventually have to vacate the auctioned spectrum as part of the transition to digital television broadcasting.)

The waiver and proof-of-concept test is very significant. If Aloha Partners can operationally demonstrate a lack of interference to legacy television broadcast operations in auctioned 700 MHz spectrum, the various 700 MHz spectrum owners could commence new services such as (Fixed and mobile) Broadband Wireless Internet Access very soon rather than waiting indefinitely for legacy television broadcasting to cease operations in auctioned 700 MHz spectrum.

In a related development, on February 1, 2005, Aloha Partners LP announced that it will purchase Cavalier Group LLC and DataCom Wireless LLC, respectively the second and third largest owners of 700 MHz spectrum in the US. Aloha Partners now has spectrum sufficient for a (mostly) nationwide network, including spectrum in the top ten urban markets and "84% of the top forty urban markets".

In previous interviews, Aloha Partners has stated that they intend to use Flarion FLASH OFDM systems for their initial deployments. Flarion recently announced a significant advancement in its FLASH technology, which would seem to make it an even better fit for Aloha's operations.
An extended discussion of this development, based on previous interviews with Aloha, Flarion, and some well-informed extrapolation of what the Aloha waiver from the FCC means for "related" spectrum (potentially even a bigger deal than 700 MHz) will be a feature article in the next issue of FOCUS On Broadband Wireless Internet Access, available only to subscribers.

Steve Stroh
This article is Copyright © 2005 by Steve Stroh
Posted by Steve Stroh on February 25, 2005 at 07:30p

Catching Up - India and Canada To Develop New BWIA System
One of the projects at Canada's Communications Research Centre (CRC) is MILTON (Microwave-Light Organized Network); a system to economically and effectively distribute fiber bandwidth using license-exempt spectrum.

Now, India's Center For Development of Telematics (C-DoT) is interested in further development of MILTON for India's unique near-term telecommunications requirements - a rapidly "technologizing" society but relatively low incomes to pay for telecommunications services.

MILTON is pretty interesting - a MILTON "rosette" can consist of as many as 48 "pedals" - each pedal is an individual panel antenna that can support as many as 30 "hot spots". Each "hot spot" can be a individual user of bandwidth, or more likely a localized cluster of users that use Wi-Fi to connect.

It might help to think of MILTON as a 5 GHz "sprinkler head" on top of a fiber optic "hose".
Milton is primarily designed to use 5 GHz license-exempt spectrum. By using so many panels and aggressive frequency reuse, it's expected that a MILTON rosette can effectively distribute approximately 1 Gbps of bandwidth from a fiber connection- a reasonable, effective use of fiber bandwidth. MILTON implements cognitive radio techniques to deal with the interference that can be expected when using 5 GHz on specific pedals and channels.

One of the more interesting aspects of MILTON that I didn't see mentioned in my admittedly cursory look at the CRC's material on MILTON is how they deal with the potential for inter-antenna desense in the rosette. Then again, being outside the US, MILTON may simply use spectral diversity. Such an approach would be effective because Canada and India can make use of nearly 500 MHz of 5 GHz spectrum since they don't have to "protect" US DOD RADAR systems from "harmful interference". In the US, a long promised 255 MHz of spectrum at 5.470 - 5.725 GHz is still unavailable for communications use due to intransigence on the part of US DOD.

A recent and related development is that MILTON could be easily located up to 1 mile away from a fiber connection and still have the full benefit of 1 Gbps+ bandwidth with the use of 60 GHz radios. In the US, 60 GHz systems are license-exempt (the ~57-64 GHz has the same oxygen-absorption properties worldwide, so it's reasonable to expect that 57-64 GHz could be harmonized as license-exempt worldwide.) As an example, the BridgeWave GE60 achieves 1+ Gbps at a reasonable price of US$19,000/link. So if the fiber is in building A, but nearby building B is taller and is better situated for deploying a MILTON "rosette", a 60 GHz link could cost-effectively bridge that gap with no sacrifice in available bandwidth from the fiber.

More background:
Good overview by Sam Churchill of DailyWireless (and thanks for the initial tip for this story.)
Good summary article on CommsDesign
(From February 7, 2005. I'm catching up from when I was ill for most of three weeks.)

Steve Stroh
This article Copyright © 2005 by Steve Stroh

February 24, 2005
Seybold Disses License-exempt Spectrum and Systems... Again

Andrew Seybold is a well-respected advocate, critic, analyst, consultant, and writer on the subject of wireless data. He began writing about the field in its infancy, in the early 1980's when it was known as Packet Radio, and has chronicled and critiqued the rise, and fall, and progress of wireless telephony data services over the lifetime of the wireless telephony industry. Seybold has a large following through his training services and Seybold's past(?) affiliations with Forbes Magazine in doing a newsletter and a conference. In short, Seybold has earned his audience and his status as pundit.


Seybold is, and has been for his entire history, a severe critic of any use of license-exempt spectrum other than Wireless Local Area Networks (WLANs) - emphasis on local. He just can't see how it will work, especially given the potential for interference. Coming from a background of two-way radio, such a viewpoint is understandable. Seybold doesn't seem to have any exposure to advanced techniques of interference mitigation and management that are now extant in the most advanced systems designed to operate in license-exempt spectrum. In his prejudice against "serious" use of license-exempt spectrum, Seybold also prefers to ignore a number of very significant, very successful deployments of license-exempt systems such as the San Diego County Sheriff's Department (particularly notable because this is a public safety application.)
So it's no surprise whatsoever that he once again rails at license-exempt spectrum in this excerpt from a Seybold "talk" in Wireless Week:

Debi, Pleasanton CA:

What is your high-level take on using unlicensed spectrum for commercial purposes? Is it fair? And, more specifically, what do you think about developing commercial products that use unlicensed spectrum for short-range and then connects to GPS or cellular to extend the range of service?

Andy Seybold:

Debi--unlicensed spectrum is being used for commercial applications--I know of a number of 2.4 and 5 GHz systems that are being used for point-to-point, but I also know of a bunch that have crashed and burned because of interference--my real answer is that mission critical wireless applications should be used in licensed and coordinated spectrum only--it is too risky to rely on unlicensed spectrum. For example the city of Phila's new Wi-Fi system which I understand will be "shared" by both end-users and first responders is a real mistake in my view--we are going to see a lot of wide area systems that "connect" to unlicensed systems for in-building range extension and other things and perhaps that will work but the risk, to me, of interference, is too great--especially is you are charging for services and the customers expectations are for a solid, reliable wireless connection all of the time--there are a lot of issues with unlicensed systems and even if you have one that works today there is no guarantee that it will work tomorrow, if someone else decides to put up their own system either unknowingly or because they can and they say the hell with others who are already making use of the same spectrum.
"... expectations are for a solid, reliable wireless connection all the time..." Like cell phones, with their "saturation" coverage and "adequate" capacity? But I digress.

I think that what has happened with Seybold is that he's caught in a major paradigm shift in his industry - rapidly-evolving technology has made possible the effective, reliable use of license-exempt spectrum for commercial... and even critical systems. Seybold's simply not equipped to effectively analyze the trend.

One example of the type of system I'm talking about, and an example I cite often because I'm not aware of any other company or system that does as much to operate reliably in license-exempt spectrum is Aperto Networks' PacketWave, which iteratively tunes ten different parameters to optimize the link from base station to subscriber unit... including measures to automatically restore a reliable connection if interference is encountered.

Nancy Gohring, in her article in WiMAX Networking News (which alerted me to this particular Seybold utterance), stated For example, at one point he says that someone else might put up a network nearby that interferes, either on accident or because they say “the hell with the others.” The fact is, it’s pretty rare for someone to do that while saying “the hell with the others” because if you interfere with someone else, you’re also causing interference, and thus a reduced level of service, on your own network. That seems silly."

Unfortunately, the scenario that Seybold (who Gohring is quoting) describes is all too common - a license-exempt system starting up causes interference to an existing license-exempt system, with the new system suffering little or no interference from the existing system. By design, there is no remedy for such a situation in the FCC rules - license-exempt systems much accept any and and all interference. What's different in recent years is that systems now exist that can effectively deal with interference when it occurs. Or, simply be robust enough to not suffer interference from less-robust systems in the first place, as is generally the case with Motorola Canopy systems... but will cause less-robust license-exempt systems severe interference. Such is the Darwinian Effect of License-exempt Wireless that I have been trying to explain for many years now.

Steve Stroh
This article is Copyright © 2005 by Steve Stroh