The FCC wants you!!!

Michael Dillon michael at
Sat Jun 15 07:12:58 UTC 1996

If you know American ISP's who don't normally hang out on ISP mailing
lists or if you have any contacts in the educational system who are
concerned with the cost of technology, then please forward this message to
them. Here is the opportunity for direct political action that really can
make a difference without requiring well-funded intermediaries and

Michael Dillon                                   ISP & Internet Consulting
Memra Software Inc.                                 Fax: +1-604-546-3049                             E-mail: michael at

---------- Forwarded message ----------
Date: Fri, 14 Jun 1996 22:13:01 -0600 (MDT)
From: Dave Hughes <dave at>
Reply-To: inet-access at
To: inet-access at
Subject: Re: Accuracies of My Own
Resent-Date: Fri, 14 Jun 1996 23:14:53 -0500 (CDT)
Resent-From: inet-access at

Jack Rickard says:
> In any event, my perception is that Dave is always early to the table, and 
> by the time the world is ready to buy something, he's already moved on.  I 
> was vaguely aware of his wireless activities, and somewhat more interested 
> in them with the recent NIIBand proposals.  There ARE some issues and I do 
> hope Dave is successful in steering this toward the 15 km version as 
> opposed to the limited range Wireless LAN version some of the big guys seem 
> to be determined to push through.
> In fact, this is actually a rather key issue specifically for Internet 
> Service Providers and more specifically for those in rural areas.  As a 
> newbie to the mailing list, I may be reintroducing something that has 
> already been done to death.  But this NIIBand could be a huge advantage for 
> small ISP's in rural areas (not JUST academia and K-12 Dave) if done right, 
> and another fiasco if done wrong.  The FCC has this open for comment now. 
>  If Mr. Hughes would provide info on docket numbers and where to write, you 
> all could have a significant impact.  On the one hand, you can offer 24 
> Mbps links by radio at 10-15 km.  On the other, 3COM can do wireless LAN 
> inside a building for about 1000 feet.  All from a stroke of the FCC pen.
Yes, this is a far more significant issue than most ISPs realize - whether
the FCC, in both responding to the Apple-WINForum proposal to allocate
350Mhz of spectrum in the 5Ghz bands for what the FCC dubbed the 
"NII/SUPERNET" Band for 'no licence' wireless - will do that in BOTH
the 'wireless lan' segment AS WELL AS the requested '15 km' segments
and thus permit anyone, including ISPs to have no-comm cost bandwidth
up to 2Mbps between two points, or, with relay, 1Mbps (above and
below T-1) for the cost of the radios. Spread spectrum technology which
is a revolution in radio communications (wide band, digital processor
controlled low power - with no practical interference versus traditional
narrow frequency band high power - with so much interferecne, the 
frquencies have to be licenced and highly controlled).

And yes I, and a too-small handful of others are deep into the issues
at the FCC level as the decision hangs in the balance. Because I
am the Principal Investigator on the $375,700 'Wireless Field Test
for Education Project' I was invited to a roundtable with FCC
Commissioners nominally debating 'wireless for education' two weeks
ago, and, using our real-world wireless project going on in the
San Luis Valley (one school being relaibaly connected now 15 miles
at 115kbs, bypassing US West, from NT-Lan router to Cisco Router
at the POP. Zero local loop cost) and reporting on the other
projects we have examined (8 Belen, New Mexico Schools, conected
T-1 between each other in a WAN - up to 10 miles across the district.
Zero local loop cost (which would normally run $84,000 a year wiht
telco T-1 between schools).

We made an impression, but know what giant forces we are up against.
Some FCC staffers want to 'auction' the longer range (even 15km)
stuff. Some big communications companies, led by the Cellular 
Telecommunications Industry Assn - CTIA, would like all 'no-licence'
that can compete with them to be killed. 

Our arguements, that got a few thinking anyway, was that IF the FCC
rules permit radios to be made which go 15-45 miles, no licence,
no interference, and solve the problem of the 16,000 school
districts whose biggest problem is the cost of bandwidth *between*
school building of a district first, then the cost from the main
hub to the POP, second, then between the student and/or teacher
at home to the school, at 56kbs or above, THEN the problem of
'community' networking will also be solved. For school districts
are coincident where people live and log on from. (ditto ISPs)

We turned a few heads when I showed my calcuations that, if
the 14 School Districts of the SanLuis Valley are connected to
the one central POP at T-1 by US West, it will cost $1.2 million
over 10 years. If by T-1 25mile radios (yeas they exist now)
it will cost $173,000 for the same 10 years. 

Now if ISPs want to strike a blow for economic telecom freedom, 
you can start by accessing our NSF Wireless Field Test web site,  and go into the Regulatory section
where you will find direct documents, links to the FCC, the
Belen Paper, and my long but piercing piece 'The Case for 
Public Spectrum' (and if you are a skeptic about the technology,
read the Paul Baran short papers - the invetor of packet switching)

Then all you have to do to sumbit public comments o the NIIBand
matter is to email:

            96-102 at

and that is the email address for the Docket Item. You *must* comment
before July 15th, or yours will not be considered. (but under the law
and regulation, if you *do* comment, your comments must be summarized
by the staff and presented to the COmmissioners with the staff 

You do NOT have to comment on all the heavy duty technical issues.
Right from the chief FCC Engineer who drafts the rules, and was
the father of the original Spread Spectrum rules in 1985 he
says that your statemnt of what you NEED, and why, would be
much appreciated. As simple as 'I am an ISP who needs T-1 from
my site, 8 miles to the nearest POP, no licence/cost wirless,
with a radio I can afford' is to the point. (of course the more
you show your technical economic need in sophisticated terms
the better it will be received. The FCC engineers are no dummies
and political handwaving doesn't impress them (it only impresses
the COmmissioners whenthe handwavers are called AT&T or Congress)

I can just about assure you the FCC staff doesn't even know you
exist, as a class, (small ISPs) or what function you serve in the
food chain, or why you shouldn't just pay $650 a month for your
local loop T-1 like anybody else. And unless you email them
(and they now have a policy that email must be taken as seriously
as formal paper mail filings), your colective case won't even
be mentioned when the likes of Motorola, AT&T, CTIA, the NSA
(who gets gas pains when secure wireless is mentioned) are

All will not be totally lost if this NPRM does not fly (new
spectrum) for we still have the more congested Part 15, 1 watt
bands. And the 4 NSF types who attended the FCC rountable
were impressed enough with our case that we spent a day with them
and they are about to fund a 'developmental' project that will
be done by TAPR, that may bring you that $500 T-1 plug and play
radio, with range. (by licencing the guts to mfgrs).

Matter of fact I will be in Washington DC at the NSF Monday
on this (being carrie dby my sidekick in radio engineering
matters) and two other matters. One of which will (their idea,
not ours) see part of our team in Ulaanbaatar, Mongolia in
August, linking 8 sites to the satellite Spintlink downlink
site run by Mongolian engineers in an old Soviet lab. (web
page at already - but they can't get the signal
across town, so crappy is their phone system). So by September
you willbe pinging systems in Mongolia, the last 10km of
which will be wireless.

I always wanted to help set up the Ghengis Khan BBS in a Mongolian
yurt, running OS2 (cause IBM is everywhere), with NAPLPS character
sets (Chinese, Cyrilli Russian, and Mongolian - none of which
are ascii), solar powered, and with spread spectrum radios
linking China to Russia. With nary a Telco in a hundred miles.
And I got a hunch I will have that done before ISPs in NYC
do it.

Dave Hughes
dave at

Oh yeah, if you  you will reach, by wireless,
the OS2 system in my home. Not blazingly fast beacause I
am trying out a different set of radios. And teh wired 56kbs
frame relay to which it is attached is actuallythe slowest link
in the chain. But its been running 160kbs for almost a year now,
for $0 cost from me to my own Internet service.  

More information about the NANOG mailing list