WCAI - Advancing the Growth of Wireless Worldwide

Mission & Leaders
LEA's Vital Initiatives
News

MISSION

"To promote the interests of unlicensed spectrum providers, focusing especially on fixed wireless applications."

LEADERSHIP

LEA Chairman: Doug Campbell
AMA • TechTel Communications 4909 Canyon Drive Amarillo TX 79110	t: 888-797-1444 f: 502-583-8251

PR & Communication Committee: Charles Brown
WaveRider Communications 255 Consumers Road Toronto, ON M2J 1R4 Canada	t: 416-502-3205 f: 416-502-2968

LEA

WCA License Exempt Alliance - Fact Sheet
1333 H St., NW, Suite 700 West
Washington, DC 20005
t: 202-452-7823 f: 202-452-0041

Background

The License Exempt Alliance (LEA) is the primary advocate in Washington, D.C. for wireless Internet service providers (WISPs) and license-exempt vendors. Its mission is to foster the growth of wireless broadband access over license exempt spectrum in the U.S. and worldwide. The LEA was founded in 1999 as a separate unit of the Wireless Communications Association (WCA) (the world's trade association for the wireless broadband industry) as a way to obtain the advantages of scale and WCA's "brand name" before federal regulators. Led by prominent carriers and vendors operating in the 900 MHz, 2.4 GHz and 5 GHz license-exempt bands, the LEA has established itself with the Federal Communications Commission via ongoing government contacts and well-researched, founded formal filings in FCC proceedings. Below are some examples of how the LEA is working to obtain a regulatory environment that maximizes business opportunities for the license-exempt broadband industry.

Spectrum Policy Task Force

The FCC's Spectrum Policy Task Force has initiated a top-to-bottom review of the FCC's spectrum policies for both licensed and license-exempt providers. The Task Force chose two members of the LEA's Executive Committee to speak on license-exempt issues at industry meetings held by the Task Force in August 2002. Subsequently, the LEA submitted written comments to the FCC advocating several major regulatory goals to the FCC's Spectrum Policy Task Force:

Protect the spectrum the FCC has already allocated for license-exempt service, and thereby eliminate any uncertainty as to whether WISPs will continue to have full and fair access to those frequencies.
Find additional spectrum for license-exempt broadband service.
Revise the Part 15 rules to permit use of higher power in rural areas, and create separate technical rules for outdoor service
Update the Part 15 equipment certification rules and its policies for enforcement thereof, so that they are better suited for broadband service.
Provide more clarity in the Commission's existing Part 15 rules, which will be essential as license-exempt spectrum is more extensively deployed throughout the country.
Improve quality of communication between the license-exempt industry and FCC staff in critical legal and policy issues.

Interference Issues Raised by DARS Satellite Repeaters

The LEA successfully opposed an attempt by the satellite radio industry to impose operational restrictions on license-exempt service in the 2.4 GHz. The trade press and Wall Street Journal coverage of this dispute and the LEA's aggressive intervention had their desired effect -- in a couple of recent decisions, the Commission has taken a very dim view of the satellite radio industry's attack on WISPs.

New Spread Spectrum Rules

The LEA successfully lobbied the FCC for modifications of its spread spectrum rules that will spur innovation in the sector and make certain types of spread spectrum systems less likely to cause harmful interference. Specifically, the FCC (1) amended Part 15 to permit new digital systems to operate in the 2.4 GHz, 5.7 GHz and 902-928 MHz bands under the current spread spectrum systems, even though they may not strictly qualify as spread spectrum systems under the FCC's rules; (2) changed its rules for "frequency hopping" spread spectrum systems, allowing them to use as few as fifteen hopping channels with bandwidth up to 5 MHz and no minimum band occupancy requirements if output power is reduced to 125 mW; and (3) eliminated its "processing gain" requirement for direct sequence spread spectrum systems ("DHSS").

Protection of License-Exempt Operations at 902-928 MHz

The LEA is vigorously opposing an attempt by licensees in the Location and Monitoring Service (LMS) to expel or dramatically restrict WISP service in the 902-928 MHz band. Through filings and meetings with the FCC, the LEA is urging the FCC to reject the LMS attacks and preserve the progress WISPs are making in this spectrum. Thus far, the LEA has been successful in preventing any anti-WISP action in this proceeding, but it is expected that this fight will continue throughout 2003.

Major Initiatives Ahead

In addition to the ongoing matters discussed above, the LEA will be actively involved in current FCC proceedings to promote rural license-exempt broadband service and identify additional license-exempt spectrum below 900 MHz and at 3.6 GHz. The LEA also will be participating in upcoming proceedings on possible allocation of additional license-exempt spectrum in the 5 GHz band for license-exempt operation. The LEA will also continue to press for changes to the Commission's equipment certification and technical rules so that they are more suitable for broadband service.

In sum, the hard work and commitment of LEA members has been vital to the LEA's success. The LEA is poised to achieve even greater things in the near future- all that is required is continued support from the license-exempt industry. For more information on regulatory affairs, contact LEA counsel Robert D. Primosch at robert.primosch@wbklaw.com or 202-783-4141. For information on other member services, contact LEA Liaison Tim Sheetz at tim@wcai.com or 202.452.7823.

2008 NEWS

July 17

FCC Begins Field Testing Of Prototype ‘White Spaces’ Devices
FCC this week began field testing of prototype unlicensed TV “white spaces” devices in a month-long schedule that includes a dozen sites. As reported by TR Daily, the testing is designed to measure the performance of the prototype devices in bands used by both TV transmissions and wireless microphones. The four-week schedule includes a variety of suburban, urban, and rural locations – mostly in Maryland – including residences, the aircraft observation area at Baltimore-Washington International Thurgood Marshall Airport, parks, and the FCC’s headquarters. During the four-week period, the lab also plans to conduct wireless microphone testing at two sites – a sports venue and an entertainment venue. The Commission has said it plans to release a report on both its field testing and its earlier lab testing after the field testing is done. The testing is open to the public and information on specific dates and locations of tests is available here.

June 19

Google: Technology Could Protect Wireless Mics From Interference
Modern signal processing techniques could help wireless microphones operate more efficiently and protect them from interference, Google said in a white paper that argues the FCC should open up the TV “white spaces” to unlicensed personal/portable devices, according to TR Daily. “Through a very effective PR campaign by Shure and other wireless microphone manufacturers, the users of their wireless microphone products have been scared into believing that their ability to put on events will be irreparably harmed by the new rules currently being considered by the FCC, allowing the introduction of white space devices,” Google’s Phil Gossett wrote. “What they fail to mention is that these same proposed rules, rather than making things worse, offer the promise of making the coordination of hundreds of wireless microphones far easier, more reliable, and robust in the face of the introduction of additional wireless microphones (accidentally or maliciously) in the same or neighboring venues.” He said wireless mics would benefit by using CDMA technology utilized by mobile phone carriers instead of the antiquated FDMA technology.

May 30

FCC Conducting More ‘White Spaces’ Lab Testing
The FCC’s lab is conducting additional tests this week on a prototype unlicensed device submitted by Adaptrum in the agency’s TV “white spaces” proceeding, reported TR Daily. The lab, which had already conducted follow-up tests on a Motorola device, is expected to begin field testing soon.

May 1

U.K. Regulator Seeks Input On Unlicensed Device Plans
The United Kingdom’s Office of Communications (Ofcom) has launched a consultation on a framework for the regulation of license-exempt devices, specifically on the issue of determining which applications should share license-exempt bands and how they should “behave with respect to each other,” reported TR Daily. It continued: Ofcom has proposed dividing license-exempt applications into three classes based on their potential for interference. Comments are due July 15.

April 25

Opening Of ‘White Spaces’ To Portable Devices Sparks Lively Exchange At WCA 2008
A proposal to open the TV “white spaces” to personal/portable unlicensed devices sparked a lively exchange during a session at the WCA 2008 show this week, reported TR Daily. It continued: Advocates for such a move argued that it could be done without causing interference to incumbents, while a representative of TV broadcasters disputed that contention. Edmond Thomas, a senior technology policy adviser to the White Spaces Coalition, said the FCC has “more than sufficient” laboratory data to adopt rules now to protect incumbents in the spectrum such as TV stations and wireless microphone operators. He said the lab testing has been completed and agency officials are evaluating how to proceed with field testing. Thomas also said there’s a misconception that the devices being used for testing are the same ones that will be marketed to consumers. He said the devices being tested, several of which submitted by Microsoft have failed, are designed solely to gather data so the Commission can draft rules. Robert Kubik, director-telecom relations/global for Motorola, argued that spectrum sensing technology is able to ensure that unlicensed devices detect whether adjacent channels are being used or not. But Kelly Williams, senior director-engineering and technology policy for the National Association of Broadcasters, said it hasn’t been proven that sensing technology is effective. He maintained that the FCC’s tests have failed to show whether personal/portable devices will act appropriately even if they detect signals on adjacent spectrum. Meanwhile, FCC Chairman Kevin Martin said Thursday he hasn’t been briefed by the agency’s engineers about the outcome of its lab testing on prototype TV “white spaces” devices, and he seemed to leave open the possibility that the agency might not conduct field testing as it had planned, according to TR Daily.

April 17

TV White Spaces: Opportunity For Whom?
With regulatory and technical controversies escalating about the future of the business, WCA will present a high-level panel on the viability of broadcasters’ “white space” for interactive services on April 22 next week. Hosting the panel will be Medley Global Advisors Senior Policy Director Jessica Zufolo. Panelists will include representatives from FiberTower Corp., Motorola, the White Spaces Coalition and the National Association of Broadcasters (NAB). More specifically, they are FiberTower Senior Vice President for Government and Regulatory Joseph M. Sandri, Jr., Motorola Senior Director, Regulatory & Spectrum Policy Steve B. Sharkey, Harris Wilshire & Grannis Partner Edmond Thomas, who is also advisor to the White Spaces Coalition, and NAB Senior Director of Engineering and Technology Policy Kelly Williams.

April 3

Second Microsoft White Space Test Device Shuts Down
Proponents of opening up the TV “white spaces” to unlicensed devices suffered another blow when a second prototype Microsoft device shut down during FCC testing, according to TR Daily. It further stated: Microsoft said the device had “been delivering meaningful results over several weeks” before it unexpectedly stopped working. An identical device lost power last month and Microsoft said a device tested by the FCC last year was damaged. Meanwhile, Motorola has submitted recommended rules to the FCC on its multi-tiered approach for certifying devices permitted to operate in the broadcast white spaces, reported Communications Daily. Motorola recommended that the Commission permit two classes of devices – type A devices that use database techniques to make sure spectrum is clear before they operate, and type B devices, which rely on sensing techniques. Motorola said in October the FCC should set separate rules for high-power and low-power devices to operate in the band. WCA 2008 will feature a panel April 22 to examine opportunities in TV white spaces. Moderated by Jessica Zufolo, who is a senior policy director at Medley Global Advisors, this high-level panel will feature officials from FiberTower, Motorola, White Spaces Coalition and the National Association of Broadcasters (NAB).

March 27

Google Announces Plan To Open TV Band For Wireless Uses
Google announced a plan on Monday that may let wireless Internet devices use vacant television airwaves without interfering with current equipment. In a letter to the FCC, Google offered suggestions on how the airwaves, known as white spaces, could provide high-speed mobile access to consumers without disrupting televisions and wireless microphones. As reported by Bloomberg News: Google and Microsoft are part of a group called the White Spaces Coalition that wants the FCC to unlock the airwaves for unlicensed uses like mobile Web access after broadcasters convert to digital signals in 2009. Google said that its proposals could help ensure that consumers anywhere would be able to use devices on those airwaves by late next year. “Google is a strong believer in the potential of this spectrum to bring Internet access to more Americans,” commented Richard S. Whitt, a lawyer for the company and a WCA director. “The spectrum is way too valuable to be wasted,” he continued. Google plans to bolster revenue by creating more Internet services for mobile phones and devices. Details from Reuters
In related news, WCA 2008 will feature a panel on the topic on April 22 convening an array of top experts with diverse views. The 2 p.m. session “TV White Spaces: Opportunity For Whom?” will be moderated by Medley Global Advisors Senior Policy Director Jessica Zufolo. The panel will include FiberTower Solutions President Joseph M. Sandri, Jr., a longtime WCA director whose parent company FiberTower has proposed to the FCC in conjunction with Sprint Nextel a plan to use point-to-point licensing in White Spaces to maximize broadband use while limiting interference risks. Other panelists include Motorola Senior Director for Regulatory & Spectrum Policy Steve B. Sharkey, who is another WCA director whose company has a broadband plan for the spectrum band. Rounding out the session will be White Spaces Coalition Advisor Edmond Thomas, a partner at Harris Wilshire & Grannis who formerly served as chief of the FCC Office of Engineering & Technology. Representing broadcasters will be Kelly Williams, who is senior director of engineering and technology policy for the National Association of Broadcasters.

March 13

FCC Extends White Spaces Testing
The FCC announced last week that it will extend lab tests of wireless devices – which were to have ended – before it takes the devices out into the field, reported Broadcasting&Cable. It continued: The devices are intended to simulate laptops and “smart radios,” which are meant to sniff out available spectrum to broadcast on and which the FCC wants to be able to share the spectrum band with digital TV stations. Details.

March 7

FCC Releases Three Working Papers Regarding Unlicensed Spectrum Allocation
The FCC’s Office of Strategic Planning and Policy Analysis released three working papers regarding the allocation of spectrum for unlicensed use. Working Paper #41, “Enhancing Spectrum’s Value Via Market-informed Congestion Etiquettes” and Working Paper #42, “Modeling the Efficiency of Spectrum Designated to License Use and Unlicensed Operations,” examine ways in which spectrum designated to licensed and unlicensed use can be more efficiently used. Working Paper #43, “A Market-based Approach to Establishing Licensing Rules: Licensed Versus Unlicensed Use of Spectrum,” examines the feasibility of employing a market mechanism to determine whether spectrum should be designated to either licensed or unlicensed use. Details.

Jan. 31

FCC's McDowell Against Hard Date For White-Space Devices
FCC Commissioner Robert McDowell said Wednesday that he did not think there should be a hard date for allowing unlicensed devices to use the so-called white spaces between digital-TV channels, according to Broadcasting&Cable, which further reported: The FCC is in a second round of testing on the devices, and McDowell pointed out that the first round didn’t go very well. He said he wants science to drive the decision, adding that the FCC was hoping to move testing out of the lab and into people’s homes in the next few weeks and months. Details.

Jan. 24

Google Asks FCC To Reject ‘White Spaces’ Proposal By Sprint Nextel, T-Mobile
Google submitted an ex parte to the FCC, asking the agency to reject a recent filing by Sprint Nextel and T-Mobile USA in support of a proposal by FiberTower and the Rural Telecommunications Group to license the TV “white spaces” for fixed use, calling the submission “an unsupported and ultimately counterproductive proposal.” Google said it was sympathetic to the complaints of Sprint Nextel and T-Mobile about the lack of competition in the special access market, but said: “Nonetheless, for a host of reasons, the notion of licensing the TV white spaces as a substitute for wireline backhaul simply is no answer to the wireless carriers’ special access problem.”

Jan. 17

FCC Announces Plans For Additional ‘White Spaces’ Testing
The FCC issued a public notice, announcing that it will begin a second phase of laboratory bench testing on the performance of prototype TV white space devices on Jan. 24. The testing is part of a proceeding to consider authorizing the operation of new, low power devices in the TV broadcast spectrum where channels are not being used for authorized services. The FCC said it has received several prototype devices for Phase II testing, including four devices submitted by Adaptrum, Microsoft, Motorola and Philips, respectively. To help ensure the testing process is open and transparent, FCC has developed a Phase II test plan. Under the plan, Phase II testing will include both laboratory (bench) tests and field tests. The laboratory tests will measure the performance capabilities of the prototype devices under controlled conditions. The field tests will be conducted at a variety of locations to provide information on the performance of the devices under real world conditions. The test report is expected to be completed within four to six weeks of completion of the tests. Bench testing at the FCC laboratory will commence on Jan. 24 and is expected to continue for four to six weeks. Field testing will immediately follow the bench testing and is expected to conclude at the end of an additional period of four to six weeks. The testing will be open to observation by any interested parties. In a related development, a group that includes Google and Microsoft accused broadcast-industry lobbyists of interfering with FCC “white spaces” tests, reported Bloomberg News. A “public misinformation campaign” by the National Association of Broadcasters has “confused the testing process” and misled policymakers, the Wireless Innovation Alliance said in a letter to NAB President David Rehr. Details.

Jan. 10

Sprint Nextel, T-Mobile Support Licensing TV ‘White Spaces’
Sprint Nextel and T-Mobile USA expressed support for a proposal submitted by FiberTower and the Rural Telecommunications Group to license the TV “white spaces” for fixed use, saying such an approach would provide access to much-needed backhaul offerings, reported TR Daily. FiberTower and RTG submitted a white paper to the FCC in October proposing fixed licensed use of the spectrum.

2006 News

Jun. 27

Ofcom Proposes Raising Power Limits For License Exempt Devices In Rural Areas
The U.K. Office of Communications (Ofcom) is considering increasing the allowable power levels for certain license exempt devices in certain geographical areas to foster new services, improve spectrum efficiency and bring higher speed broadband to rural communities. Specifically, Ofcom is considering a power increase to 10 Watts at 2.4 GHz and to between four and 25 Watts at 5.x GHz. Details.

Jun. 1

EarthLink Wins Approval To Build Out New Orleans Network
The New Orleans City Council approved an ordinance to enable EarthLink to build a Wi-Fi broadband network in the city. EarthLink will offer free service for a limited time during the city's rebuilding efforts at speeds up to 300kbs, enabling users to access the Internet without having to view advertising. It will also offer a higher speed paid service that will be a symmetrical, 1 mbps solution for customers that want more bandwidth, customer support and products and services. Details.

Apr. 20

CEA Submits Tests Of Unlicensed Operations In TV Bands To FCC
Building attenuation is a critical factor in both determining whether an unlicensed wireless device can interfere with television reception and the ability of that device to autonomously detect vacant TV channels, Consumer Electronics Association told the FCC in an ex parte filing accompanied by a summary of analysis of field test data for unlicensed device operation in the television band. Higher building attenuation reduces the chance that an unlicensed device in one home interferes with a neighbor's home, CEA said. But higher attenuation also makes it more difficult for an unlicensed device inside a home to detect vacant channels, it said.

Feb. 16

WCA Extends Sympathy Over The Passing Of CommSpeed General Manager Mark Davis
Virginia Communications, Inc. sadly announced the passing away of Mark Davis, General Manager of their CommSpeed operation in Northern Arizona. Steve Merrill, Virginia Communications President said, "Mark was an enthusiastic and tireless champion of the wireless broadband industry, an excellent manager and very instrumental in the successful development of our 9,000-customer business in Arizona. He is sorely missed by all of us who worked with him. His passing was completely unexpected and has left a stunning void in our lives and the lives of his wife and children and the community in which he played such an active part."

Mark's family has requested that condolences be expressed through donations to the Friends of the Prescott Library, 215 E. Goodwin, Prescott, AZ 86303.

FCC Extends Compliance Deadlines For License-Exempt Equipment At 5 GHz
The FCC extended for 180 days the deadlines by which equipment for the license-exempt 5.250-5.350 MHz band must meet the new Dynamic Frequency Selection and Transmit Power Control requirements adopted for the license-exempt allocation at 5.475-5.725 GHz. As a result, Unlicensed National Information Infrastructure (U-NII) equipment operating at 5.250-5.350 GHz must demonstrate compliance with the new rules in any application for equipment certification filed on or after July 20, 2006. Any such equipment imported or marketed on or after July 20, 2007 must also comply with the new rules. Details.