Open Letter to the FCC about CBRS

An open letter regarding:

GN Docket No. 12-354
RM-11788
RM-11789

I am writing on behalf of my Company MTIN.NET LLC in regard to the proposed changes to the CBRS band. We are primarily a consulting company for Wireless Internet Providers (WISPs). One of the biggest changes our customers face is the availability of spectrum to operate in.  These are companies who primarily are investing their own money into providing access in their own communities.  They help to support local businesses by giving them a choice in high-speed broadband access. Sometimes, these WISPs are the only option.

Please take into consideration how any changes will affect these Entrepreneurs and their mission to bring broadband into underserved areas of the country.   Without WISPs, many homes and businesses would not have high-speed access that works with Voice, or streaming services.  Satellite is unable to deliver low-latency connections to users.

The ability of a WISP to have access to more spectrum not only allows them to provider more speeds and better service, but it has other benefits as well. WISPs have usually been started to fill a broadband need in an area.  Having access to high-speed access allows schools to offer greater learning tools, allows businesses to generate new revenue streams as well as saving money.  Please don’t leave the companies who are investing their own money, not shareholder’s money, out in the cold.

We are opposed to both petitions by CTIA and T-mobile. Please consider the comments from the WISP community before making any decisions. It is estimated WISPs service over 3 Million subscribers across the country.  Give them tools they need to thrive.

DOL-OSHA and FCC release Communications tower best practices

The Occupational Safety and Health Administration and the Federal Communications Commission are concerned about the risks faced by employees in the communication tower industry. Employees climb communication towers to perform construction and maintenance activities and face numerous hazards, including fall hazards, hazards associated with structural collapses and improper rigging and hoisting practices, and “struck-by” hazards.

You can read the safety document here.

 

WISPA Call To Action 5725-5850 band

From Rick Harnish

Purpose: Call To Action to support WISPA’s Petition for Reconsideration

Subject: FCC First Report and Order in the Matter of Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII_ Devices in the 5 GHz Band (ET Docket No. 13-49)

ATTENTION: ALL WISPS THAT USE THE 5725-5850 MHz BAND

This email is a request to all WISPs and other entities that use the 5725-5850 MHz band.  On March 31st, the FCC adopted new rules for the 5 GHz bands.  While WISPA petitioned successfully to retain unlimited gain antennas, the FCC adopted more stringent out-of-band emission limits by eliminating Section 15.247 rules and placing all new equipment under Section 15.407.  Currently, most 5.725-5.850 MHz equipment operates under Section 15.247 rules. In two years, Section 15.247 equipment will no longer be legal to manufacture. Requiring all new equipment to be certified under Section 15.407  has SEVERE ramifications for the WISP Industry. Section 15.407 equipment will be much more expensive (will need expensive additional filters) and will operate on fewer channels (will have to stay away from the band edges). That’s why WISPA is putting out a CALL TO ACTION, to encourage all WISPs and others who use this band to file FCC comments supporting the Petitions of Reconsideration filed by WISPA, Cambium Networks, Mimosa Networks and JAB Wireless.  Below are links to the First Report and Order and all of the Petitions for Reconsideration. Please review the seven points that are listed below the links and choose the point (or points) that you feel are the most significant and that have the most impact your WISP operation. Discuss those points in your FCC Comments.

FCC First Report and Order in the Matter of Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII_ Devices in the 5 GHz Band (ET Docket No. 13-49)

Wireless Internet Service Providers Association Petition for Reconsideration
Cambium Networks, LTD. Petition for Reconsideration
Mimosa Networks, Inc. Petition for Reconsideration
JAB Wireless, Inc.

On July 21st, Steve Coran, telecommunications counsel for WISPA and Rick Harnish, Executive Director of WISPA met with key staff people for Commissioners Clyburn, Rosenworcel, O’Reilly and Chairman Wheeler.  We stressed the importance of reconsidering this change in the rules.  We followed these meetings with a meeting with the staff of the Office of Engineering and Technology (OET).  We emphasized the following points:

1.      We thanked the Commission for preserving unlimited gain antennas in this band
2.      We explained how the new restrictions on out-of-band emissions (Section 15.407) would cause severe consequences for the WISP Industry and for many other industries, including Oil/Gas, School Systems, Aggregate Processors, Food Processors, County Governments and many more.
3.      We explained how many rural communities only source of Broadband is fed by this “Workhorse” band and would possibly go dark and/or service levels (capacity) would be compromised by the this change in rules, which would affect link distance, useable frequencies and capacity.

4.      We also explained how the new rules would cause manufacturers to add filtering to the radios, which would not only cost much more to produce, but would decrease the available spectrum from 125 MHz to 45 MHz due to a 40 MHz filter needed on both ends of the band.
5.      We explained that this decrease in useable spectrum would limit the ability for Wisps to use more than two sectors for Point to Multi-Point use and would cause a decrease in potential capacity to the consumers.
6.      We explained that the lower power/smaller antenna option to comply with the rules would cause some consumers to entirely lose their service due to distance limitations.  We also explained that consumers who have had service for many years, would not understand why they would either lose service or would now have to pay for a new installation (new more expensive radio) which would have less capacity and speed.
7.      We explained that many rural communities are fed by long distance PTP links in this band, which would not be possible with these new rules or would cause operators to have to build more towers at approximately $50,000 per tower, in order to retain service to these communities.  This would cause undue hardship on the operators and the consumers served by these links.  In some cases, the demographics of the communities would prevent the operator from investing in more towers and radios in order to retain service to these communities.

 We now encourage everyone to file comments supporting all of the above petitions for reconsideration.  The FCC and OET encouraged Steve and I to have operators file commentsexplaining the economic impact of these rule changes, examples of long distance links which would be impossible to make,given the rules changes, and other hardships the new rule will impose upon your business.  Please put your comments on your company letterhead.  Below are links to file your documents or comments.  You can read previous comments at http://apps.fcc.gov/ecfs/comment_search/paginate?pageSize=100