A few updates in a posting by Harold Feld on [CWN-Summit]: http://lists.chambana.net/mailman/archive/cwn-summit/2005-March/000124.html --- 1) you _must_ file your comments with the FCC through ECFS (step three) or they don't count. (hk: Harold is refering to this link: http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi ) 2) Jennifer Manner is no longer at the Commission. (hk: her email has an autoreply saying to send FCC related messages to john.branscome at fcc.gov) Relevant information is also available on my blog, Tales of the Sausage Factory, at http://www.wetmachine.com/index.php/item/227 Harold --- --- http://lists.chambana.net/mailman/archive/cwn-summit/2005-March/000125.html I have been making calls today. The situation is moving in a more favorable direction. The relevant decision makers are getting our emails and see broad popular support for mesh as well as high-power. Key issues on which decisions have not yet been made and where comments may prove helpful: 1) Allowing low power mobile devices in the band is critical to expanding mesh. 2) Low power mesh requires non-exclusivity and cheap equipment. The Commission should not impose overly conservative interference protection criteria that drive up price. Flexibility has been critical to the success of unlicensed as a networking solution. 3) Mesh devices must be allowed to communicate with each other in a peer-to-peer fashion, rather than requiring mesh devices to communicate with a high power base station. 4) Any system of licensing or registration must be non-exclusive; the Commission must not create a "first in time, first in right" licensing systems. Remember, things are turning our way. Be polite, be informative, and BE PERSISTENT. Harold Feld --- and some related comments in Harold's blog: --- http://www.wetmachine.com/index.php/item/227 : Last Gasp on Unlicensed Order As those who follow unlicensed proceedings at the FCC here know, the FCC has been considering opening up the 2650-3700 MHz band to unlicensed use. The rumor is that the FCC will vote on the item at its March 10 meeting. I have also heard that the item is not particularly friendly to mesh networks. We have until Wed. March 2, 2005, 5 p.m. Eastern Time to turn this around. Wanna help? The 3650-3700 MHz band is relatively open and is under consideration by the FCC for expanded unlicensed use. The FCC proposed to allow fixed “high power” (25 watts EIRP) unlicensed operation and more standard mobile “low power” (1 watt EIRP) operation-- as long as certain incumbent operations are proetcted. I have heard that the FCC instead is likely to authorize high power as a “licensed lite” regime in which the first operator is protected against interference and all subsequent operators must seek permission of the first operator to activate their systems. This is known as a “first in time, first in right” scheme. I have heard from the good folks at CUWIN that this would be a disaster for low power mesh networks in urban areas. Basically, the party that gets to the tallest building first will be able to blanket the entire area and prevent other systems from going live. Under federal law, parties may file comments with the FCC until Wed., March 2, 5 p.m. Eastern time. I am urging anyone who cares about the future of mesh networks to file at the FCC and emphasize the following points: 1) Open spectrum/open source is a volunteer community. Barriers to entry must be low, and the FCC must recognize that investment happens without big corporations or well-funded start ups. Rules that prohibit or limit the ability of multiple entrants will make it next to impossible for open source mesh systems to deploy. 2) Low power is more important in many communities than high-power. The FCC must not sacrifice the possibility of low power mesh in the 3650-3700 MHz band for the sake of high-power in the band. Ideally, the FCC should have rules that permit both, as high power is necessary for backhaul and can be useful in point to point. But if the FCC insists on chosing, it should keep the low power option and implement high power when cognative radio technology has improved. 3) Above all, the FCC must not establish exclusive licensing or “first in time, first in right” site licensing that will make it impossible for communities to deploy numerous open source solutions. Intel's filing opposing us on this can be found here. While Intel supports open source and open spectrum in some bands, it supports closed proprietary systems in others. This is why open source/open spectrum supporters cannot rely on our “friends” in private industry. In any given proceeding, they will file in accordance with their interests of the moment. To file a comment, go to the FCC's ECFS comment upload page. In the “proceeding” field, type 04-151. The rest is self-explanatory. You do not need to be a U.S. citizen to file a comment. Anyone can do so. You should, however, explain your interest in the proceeding (e.g., “I am an open source developer and I wish to take advantage of new opportunities for open source-based wireless networking”). Then reiterate from the key points in your own words. Remember, if the FCC does not hear from smart people, it will only make dumb rules. Stay tuned . . . ---