WISPs – Technically, Operationally Competent Purveyors of Reliable Broadband

By Richard Bernhardt, WISPA National Spectrum Adviser?

Mr. Dawson’s commentary on NTIA’s exclusion of unlicensed spectrum in BEAD all but suggested that WISP operations, competency, and the science underlying radio propagation might be among the factors.?During a meeting among WISPA and NTIA staff earlier this month, however, NTIA expressed no such misgivings, and indicated that it is more concerned about the future availability of unlicensed spectrum than other factors such as resiliency, or the questionable suitability of aging, included technologies such as DSL.?Although NTIA may have coordinated with FCC to some degree on the NOFO, it is not aligned with the actions of the FCC.

Two initial observations.?First, the FCC considered the same types of technical concerns during at least two proceedings related to the allocation of billions for funding for broadband deployment:??the 2018 Connect America Fund (CAF) Phase II and 2020 Rural Digital Opportunity Fund Phase I.?In both proceedings, the FCC rejected arguments against unlicensed spectrum, and permitted winning bidders to use entirely unlicensed spectrum to meet their buildout and performance obligations.?The FCC reached those decisions because applicants would have to demonstrate, through long form applications, sufficient networks and operational expertise to meet their performance obligations by using only unlicensed spectrum.?Those performance obligations include, for example, that 80 percent of a provider’s download and upload measurements must be at or above 80 percent of the required speed (i.e., an 80/80 standard).

Second, Mr. Dawson’s commentary relied heavily on third party references to “some WISPs” and unattributed anecdotal stories.?That is hardly sufficient to support a decision from a federal agency that has the responsibility to allocate over $42 billion in the most efficient manner possible, to connect as many unserved and underserved Americans to broadband as soon as possible, and available evidence clearly shows this is not the path the NTIA followed.

While a more desirable approach would have been for NTIA to follow the FCC’s long form application procedure to allow States to determine when a company using entirely unlicensed spectrum has the network capacity and operational experience to provide reliable broadband service, NTIA did not do so.?Instead, the criteria NTIA adopted for defining reliable broadband service were that the service must be (1) a fixed broadband service; (2) that is available at a high degree of certainty; (3) both at present and for the foreseeable future.?

As Mr. Zumwalt, CEO of WISPA, pointed out in his reply to Mr. Dawson, networks using only unlicensed spectrum clearly meet those three criteria because millions of Americans currently receive their broadband service from wireless networks using unlicensed spectrum and have been for decades.?There are also evolving technologies in several spectrum bands including the 57-71 GHz band (FCC allocated 14,000 megahertz of unlicensed spectrum for present and future use of that band) that enables 1 Gigabit download speeds and 6 GHz band (FCC allocated 850 megahertz of unlicensed spectrum for future outdoor use) that enable speeds that easily exceed 100 Mbps download speeds.

Turning now to specific technical and operational criticisms raised by Mr. Dawson:

Received Interference as an Interrupter...WISPs are the Highest and Most Experienced in Getting the Signal Where It Needs to Go:?WISPs are in the business of making sure their signal is not materially interrupted.?To that end, they utilize frequency agile directional antennas who are generally focused on both ends utilizing either internal spectrum analyzers or using external tuning methods.?Without accurate aiming, signals diminish.?Since the beams are tuned and directional, they are far less susceptible to interference.?That is the nature of Point-to-Point and Point-to-Multipoint radio communication.?WISPs always get their signal to the client for reliable service.?

Causing Interference - Doesn't Happen when Professional Operations are Deployed.?WISPs are Professionals:?WISPs work with minimal allocated unlicensed spectrum and are professionals at making sure that they efficiently and appropriately use the spectrum allocated.?Hence, they use the right and allowed power with very specific end-to-end objectives.?They canot afford waste.?Unlike many carriers, they do not generally utilize omnidirectional or over-encompassing broadcast antennas because it is inefficient.?Further, WISPs regularly coordinate with those around them to assure they do not interfere in-band or out of band.?

Interference as a Limiting Service Issue Yet Overcome by WISPs in Even the Most Difficult Deployments:?Every WISP is both aware and adaptive to interference.?In radio, especially unlicensed radio, others can use the same frequencies.?But, since operators are frequency agile, meaning they can move to another channel, even another band if necessary (back-up) and most radios these days are software defined (SDR) they are able to find the areas that are not over-burdened with a noise floor (meaning interference enough to affect performance).?Again, WISPs also coordinate.?The laws of physics apply equally to licensed and unlicensed.?In unlicensed however, you may have more potential operators and uses, but the use of directional antennas, coordination, back-up/failover, and other techniques does away with any material issues.

How WISPs Operate and Do things Differently, Respectfully, and Get the Job Done Consistently and Reliably:?Many WISPs are different from carriers in that they use the "tools" that they need to get the job done.?The reason many large ISP providers, carriers, and other entities (even those with licensed frequencies) do not go into rural areas is they are often diverse in topology and clutter (the objects which can interfere with radio signals).?That topology and clutter also interferes with licensed operation (and can interfere with fiber).?But for more than two-decades WISPs have been the companies who figured out the way to get the signal to those with none.?They use different radio frequencies in different areas, even to different client locations; they opt for the available choice that works well.?They use tactical placement of APs and clients to attain line of sight away from outside interference, and they consistently adjust their network operations to assure consistent delivery of broadband services even where it’s hard to do.

?WISPs use the Appropriate Level of Bandwidth to Achieve the Result Without Waste:?WISPs are not wasteful of frequencies.?That means in some areas, generally rural, they may use larger channels to achieve the speeds and feeds they offer.?However, the location and the type of delivery, specific to their clients, does not over-utilize bandwidth/spectrum.?While that has often been leveled as an excuse, look at the small amount of unlicensed spectrum allocated versus the amount of licensed spectrum, and you will see that WISPs have to be very efficient and well thought out in their use of spectrum.?

WISPs are Organized and Experienced in Delivery of Broadband Services:?Mr. Dawson seems to think WISPs are the wild west.?Yet, if you conduct a poll of customer service on almost any WISP in America, is there the level of disharmony you will find in any call to a commercial carrier or cable provider??WISPs are the local providers who actually listen to their clients (and potential clients); who respond in person to fix issues; who are diligent in assuring consistent network performance.?Often WISP clients hold their WISPs for years if not decades.?As Mr. Dawson indicated he had himself.?The reason is good, effective, personal, reactive service. There is nothing chaotic about that.?

You Cannot Exceed Physics in Delivery:?WISPs consistently monitor and adjust their networks, so their customers get or exceed the performance of their contracted service.?Just as with any provider, fiber, cable, mobile cellular or fixed wireless, the delivery of services is not perfect.?Remember the laws of physics apply to all of these.?None of them can exceed the laws of physics.?WISPs are experts at using the resources allocated even in the worst of conditions.

?WISPS Use the Right Equipment for Each Situation and Client:?While other providers use subsidies, grants, or simply charge higher and higher rates, most WISPs deploy their own networks without outside assistance.?They use equipment designed to deliver high quality, reliable, sustainable, and consistent broadband to their clients.?The cost of the equipment is less because it serves a different purpose than mobile or satellite.?The quality and performance however are not lessened by the cost.?In both backhaul (moving the signal to the place where it can be deployed to clients) and last mile (delivery to the client), the right equipment is always deployed.?Equipment in unlicensed bands can travel great distances without much degradation.?It is then delivered, even in the most rural areas with the same level of confidence.??

Finally, WISPs use appropriate methods to deliver consistent and reliable broadband which may employ some of each of the above's techniques or none of the above to get the job done where, in most cases, for decades, nobody has chosen to do the job at all.