Debating unlicensed spectrum rights
WINForum weighs in against IA columnist Bill Frezza, but another defends his position

Source: Interactive Age

On July 3, Interactive Age published a column titled "Where the I-Way Meets the Skyway," by Bill Frezza, that supported Apple Computer Inc. and argued against WINForum in Apple's petition to obtain radio spectrum for unlicensed devices in the 5-GHz band.

Taking issue with Frezza, WINforum president J. Ron Cross wrote a response to IA, printed below.

Also printed below is a response to the WINForum reply by Benn Kobb, co-founder and past president at WINForum.

And just to round out the debate, Frezza adds his final comments, as well, at the bottom of the page.

WINForum's J. Ron Cross writes:

Perhaps because Mr. Frezza did not contact any of the principals involved in WINForum's 2-gigahertz or 5-GHz efforts, he has perpetuated a number of factual inaccuracies in his column that reflect an overall misunderstanding of the Wireless Information Networks Forum and its projects. We would like to correct these inaccuracies and move forward to pursue what we perceive as common goals.

As an initial matter, Mr. Frezza portrays WINForum as a "lobbyist-loaded coterie" of "telephony interests." WINForum is an open organization that has and continues to strive for diversity in membership, and it welcomes participation by any entity interested in pursuing wireless information networking. Indeed, WINForum and Apple Computer Inc. have discussed the commonalities between the two petitions and are attempting to work out a strategy for meeting the overall goal of both petitions - providing additional unlicensed spectrum for wireless multimedia computer applications - while deferring the definition of technical etiquette issues to a representative industry consensus body.

WINForum also takes issue with Mr. Frezza's characterization of the history of the unlicensed PCS allocation at 2 GHz as having been "shanghaied" by telephony interests. Apple was not the first, nor the only, company to seek spectrum for unlicensed devices in the desirable 1910- to 1930-MHz band. While all of these companies originally believed that all unlicensed uses were compatible, it was only in the context of setting industry consensus etiquette that it was determined separate allocations may be more efficient for asynchronous (usually, but not always, data) and isochronous (usually, but not always, voice) communications. Ultimately, the FCC determined that the public interest would best be served with a 10-megahertz isochronous allocation and a 10-MHz asynchronous allocation.

Because of Mr. Frezza's preconceptions regarding WINForum, his view of current events is more than slightly skewed. Nowhere in WINForum's petition is the "primacy of circuit-switched voice" asserted. In fact, WINForum's petition was largely devoid of technical details because it is WINForum's position that such matters should be worked out in the context of an industry standards group once the allocation is under way.

WINForum has advanced some concepts in its petition as illustrative of the kinds of applications that could be supported using an additional allocation for high speed data in the 5-GHz band. Apple, for its part, has advanced other applications that it views as desirable. That does not mean these visions must be contradictory.

Had Apple participated in the development of the WINForum petition, as it was explicitly invited to do, the petition may have been different. Unfortunately, Apple elected not to participate in the development of WINForum's petition and WINForum's petition was filed before Apple's petition and could not benefit from Apple's insights.

WINForum encourages all interested parties to express their views at the FCC and invites all interested parties to join in its efforts to facilitate wireless information networking. Instead of fostering division in the industry, Mr. Frezza might find that his interests, and the interests of the "Washington-adverse PC industry," will best be served by uniting to achieve larger ends - the allocation of spectrum in the 5-GHz band for wireless multimedia applications.

J. Ron Cross

Bennett Z. Kobb writes:

To me, the larger point of Bill Frezza's column was that a valuable communications opportunity could be compromised if left exclusively up to the usual trade associations and political forces of the day.

NII Band and SUPERNet do not fit the traditional model of wireless communications. In Apple Computer Inc.'s NII Band proposal, users will be able to provide local and metro-area wireless data service to themselves, without mandatory subscriptions to service providers that paid billions at FCC license auctions. WINForum's SUPERNet aims only at short-range, indoor applications, but otherwise shares much of this unlicensed wireless vision with Apple.

Proposals for new uses of the radio spectrum must confront a gauntlet of stakeholders. The Federal Aviation Administration is concerned that this new wireless data service will endanger aviation electronics. The advocates of spectrum auctions grimace at the thought of "free" spectrum for the general public to use, regardless of the economic benefits it can stimulate.

WINForum's letter refers to a more obscure conflict between the telephone manufacturers that today principally make up the association and the computer hardware and software firms interested in wireless local and metropolitan area networks.

WINForum claims that it has deferred the definition of technical issues, and that differences between voice and data proponents of this new wireless technology may not arise in practice. Nevertheless, WINForum's stated technical positions are not all amorphous or undeveloped. Suggestions for a phone-like, connection-oriented architecture for this new service decorate its proposal like electronic freckles.

Europeans are engaged in a similar discussion over the structure of HIPERLAN, the High Performance Radio Local Area Network. In HIPERLAN, WINForum criticizes, a local file transfer can commence even though an expensive long distance phone call may be waiting. WINForum's proposal portrays this as a defect of HIPERLAN, which conveys much about its members' business interests.

Look for the minimum data rate and communications range to be allowed in the service to emerge as issues. Some companies are asking that low- and medium-speed uses be precluded from the new service. If made a part of the regulations, this could limit consumer choices only to high-end products that can communicate only at very short range. On the other hand, a scalable solution would permit various price points and data rates for community networks, as well as indoor applications.

Certainly, corporate delegations will spend enormous time and energy developing technical rules for the new service. But in the real world, technical merit has never been the sole consideration when allocating spectrum. Of the five presidentially nominated FCC commissioners, not one is an engineer. They are attuned to public demand, Congressional power, the agendas of career staff, and the ceaseless requests of industry lobbyists.

The FCC uses a paper-intensive process intended to ventilate all sides, but with compressed time windows in which to participate. This jungle is familiar territory to telephone makers. They are ensuring that their spin is on record. The Internet community should get in gear to do the same.

Bennett Z. Kobb ( served as co-founder and the first president at WINForum. He is the publisher of Spectrum Guide, a handbook of radio frequency allocations.

Bill Frezza replies:

Of all the specious claims in WINForum's letter, the most infuriating is the claim that they do not seek primacy for voice communications over data. Intentionally obscuring this issue so it can push its agenda within the orbit of its so-called open trade association rather than airing it as a defining characteristic of their approach is grossly dishonest.

There are two ways to handle congestion control in overloaded networks: blocking (busy signals) or flow control (uniform degradation of throughput and latency). Choosing one or the other is key to defining the use of this precious spectrum. Let WINForum show its sincerity in working with the PC industry by renouncing the former and it will find that agreement can quickly be reached.

[Interactive Age -- 08-14-95, p. 34]

[Copyright 1995, CMP Publications, Inc.]