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The COOK Report on Internet
A Special Report on Shared Wireless Public Spectrum - by Dave Hughes
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(c) COOK Network Consultants and David R.  Hughes (This report, in its
totality, may be freely reproduced.)

FROM THE EDITOR:  We have known Dave Hughes well for 16 years -
during which time he has consistently and beneficially pushed the barriers
of grass roots, public interest telecommunications.  Because we agree with
his positions, we offered him the COOK Report as a general platform for the
publication of what we believe is an important policy piece that has now
been made even more significant because of the way in which Apple failed
to succede in its NII Band petition before the FCC..


THE CASE FOR SHARED WIRELESS PUBLIC SPECTRUM

AN EXAMINATION OF THE NEED FOR AND  TECHNOLOGY BEHIND WIRELESS
LOCAL LOOP ACCESS TO THE INTERNET & ITS APPLICATION TO THE FCC
NII/SUPERNET 1996 PROPOSALS - by David R. Hughes

"We are ordered under the law to make sure that advanced
telecommunications services are affordable to everyone in the country..."

Reed Hundt, Chairman, FCC
April 25th, 1996

Executive Summary

A significant portion of the electromagnetic spectrum, with appropriate
radio-design rules should be allocated by the FCC, without license, for
shared general public use. This is now technologically feasible, as
digital signal processing based on the dramatic gains in computing power
which have occurred over the past several decades have made radical
changes in radio design possible .

Spread spectrum technology is one example of the revolutionary new ways
radios can operate in digital, rather than analog modes, without
significan t interference.  Such radios can operate where there are a
myriad of public needs for lower cost data links to world nets than
commercial wired services can or will deliver, even in an unregulated
environment. These include rural areas, small towns, the 16,438 public
school districts, US public libraries, and other institutions.

There are many places where commercial data services above the level of
plain telephone modem service, simply don't, and is not likely to, exist at
affordable rates, even for corporate telecommuters, and in 'community
networking' environments. Yet the mandate of the FCC is to insure
affordable communications for all citizens.

Rules established in 1984, for no-license wireless in Part 15 'garbage'
bands are inadequate.  Nevertheless, they have shown what is possible
and, by projection, what dramatic economic difference they can make to
the taxpayer in such uses as school links to the Internet.  Recent
proposal s by Apple Computer and by WINForum, which held early promise,
are being processed now by the FCC.

Unfortunately what was put before the FCC that resulted in the April 25,
1996 decisions,  now out for public comment falls far short of what is
needed, and what is in the general public, not just industry, interest.
FC C rules must be changed to recognize the new possibilities, and give
manufacturers of no-license radios a strong incentive to invest what it
takes to develop new radios that use digital technologies and hence
minimize interference.

Such rules can, and should co-exist with licensed spectrum, commercial
services.  Adopting this policy will also open international third world
trade opportunities for companies who need strong incentives to spend
what is needed for R&D in these difficult technologies. The public needs
to get involved.  Why?  Because commercial communications service
corporations are already lobbying, and are bending the FCC processes to
fit their interests. The public must make its views known to the FCC
during the next few months or the 'commercialization' of all radio
services is likely to close the window on the potential for public for
no-license wireless forever, and stunt a promising new industry's
growth.

INTRODUCTION

Radio - wireless transmission and reception of data - is undergoing a
technological revolution. This revolution is fueled by the same
scientific research and development that led to the explosion of
innovation in the computer industry - the digital signal processing
power of tiny silicon chips. This revolution, in turn, can, for the
first time, make possible FCC regulatory policies that are much stronger
in their general public outcomes, than would have been possible under
earlier technologies.  Reed Hundt's goal -- We are ordered under the law
to make sure that advanced telecommunications services are affordable to
everyone in the country..." - is achievable.

This paper lays out the case for a publicly shared-spectrum by first
explaining just how technology has changed radio.  It then surveys some
of the public needs that only are partially, or not at all, met by
commercial data-radio service, when set against the criteria contained
in the FCC lega l mandate:

    "It shall be the policy of the United States to encourage the
 provision of new technologies and service to the public."

Next we shall summarize one crucial, current set of proposals before the
FCC - now called the NII/SUPERNET device rules, which were submitted by
Apple Computer , and WINForum, an organization representing only the
interests of some large communications companies.  We assert that the
outcome of these proposals can determine, forever, whether or not the
new technologies will be used primarily in the public's or only in the
corporate communications companiesD5 interests.

This paper will detail the principles that should underlie the rules
made b y the FCC in these - or other comparable proceedings.  It
concludes with admonitions as to what must be done by the public, public
policy activists, and the no-license wireless manufacturing companies
themselves to offset the lobbying by companies who only have an interest
in what benefits the segment of the industry which benefits most from
exclusive licensing of spectrum by the FCC.

Public Assumptions and Mindsets

The general public seems to assume that because almost all radio and
wireless communications has been regulated, by licensing  specific
frequency bands of the electromagnetic spectrum to various private
interests, that this is the way it must always be. And from that
licensing - most recently exemplified by the $20 billion in auction
proceeds by companies determined to offer commercial 'services' where
the revenue is generated from the use of the channels, rather than in
the sale of the access devices, most Americans also assume that all two
way wireless communications has to be commercial.  It does not.

Historically, the FCC has used the sovereign power of the United States
to regulate the use of the electromagnetic spectrum because of the fact
that early radios interfered with each other. These early radios had to
employ sufficient radiated power in narrow frequency bands in order to
get the 'range' to communicate with receivers. Unacceptable interference
with radios operating in similar frequencies by other entities in the
same geographical area covered by other radios was inevitable. This had
to be arbitrated 'in the public interest.' Thus government - the FCC -
licensing of spectrum was born.

The idea of no-license, no-cost two way communications is below the
public's radar screen - although in using cordless short range
telephones, they are doing exactly that. So the immense implications of
not paying for two way data communications - even at a local community
level with relatively short range devices - from a few hundred feet to
10 or so miles, where the business is in the sales of radios and
wireless devices, seems to escape public attention. That is so even when
it is in their pocketbook interest to have some segments of their
computer communications free - which is about as 'affordable' as you can
get. Yet it is precisely the revolution in digital signal processing
that makes no-license, no-cost - except for the radio devices - data
communications a practical reality today.  The allocation of public use,
wireless, no license spectrum will no t result in the complete bypass of
the public switched telephone network. Because data networks are
interconnected everywhere - as in the global Internet - where there is
still a need for local users of data communications to be connected to
long line providers of communications networks, where the kind of radios
I am talking about cannot reach - or compete.  This part of the link is,
and probably will remain 'commercial.'

So the effect of permitting no-license wireless radios, with ranges up
to 2 0 miles, to compete with local wired loop telephone or cable
commercial services, only serves to reduce, not entirely eliminate the
costs of data communications for the end users. And it is not completely
contrary to the interests of common carriers who provide data links. It
makes more business for them to carry the increased traffic that will be
generated by many more entities communicating digitally.  The use of no
cost local digital radio not only makes it  'more affordable' but it
also permits such wireless links to be extended to places, and at data
rates, which, especial ly in a de-regulated communications environment,
commercial carriers are not interested in going.

We contend that it is in the public interest for the FCC to support the
development and operation of new classes of no-license digital radios
(which, by their technological design, dramatically reduce the
historical problem of 'interference' with other radio traffic) just as
vigorously as t hey have the awarding of exclusive channels of spectrum
allocation in the past. Technology, in short, should be changing FCC
policy and rules far more than it has.

The growth of television and broadcast radio, as well as two way radio
communications, such as the unprecedented demand for such mobile
services as cellular telephones has put demands on the FCC to allocate
ever more finely. And the value to commercial interests of these bands
spawned the recent auctions - which lead some to believe, that the
spectrum is a 'scarce' commodity,  that all radio traffic is becoming
commercial services, and that the entire spectrum be auctioned off to
the highest bidder.  This is not necessary.

Spectrum 'Sharing,' Without Unacceptable Interference

But changing technology has a way of challenging the basic assumptions
upon which regulatory structures and historical precedence are built and
perpetuated. Several technological developments that have spread over
the past few decades have made it possible to promulgate rules that can
permit far wider, and affordable access, to telecommunications networks
than earlier wireless technologies and allocation of spectrum permitted.

Spectrum 'sharing,' without unacceptable interference, is now a
practical reality.  That statement is counter-intuitive, and challenges
the assumptions on which the entire edifice of FCC regulation has been
based. But it is crucial to understand the technological facts that
underlie this new reality.

Analog Versus Digital: What Is Changed and Why

The most fundamental of the changes that have made this situation
possible, have come from the dramatic increase in the processing power
of digital signal processors - computer chips - along with the equally
dramatic falling prices and the substantial miniaturization of devices
usin g such chips. This has permitted the digitalization of radio
transmissions, a nd a corresponding ability to detect such signals, and
sort them out from nois e - at ever lower levels of radiated power.
From mobile as well as fixed locations. By individuals and not just by
institutions.  Note that earlier radio, current general television, and
even most current cellular telephone signalling is 'analog' - not
digital at all.

There is no more convincing, engineer-qualified, spokesman for the
dramatic differences in the possible increase in usable spectrum brought
about by digital processing, than  Paul Baran, who in 1964 originated of
theory of 'packet switching' at RAND, and who today is still one of the
mos t visionary of radio engineers.

In recent presentations at technical conferences Baran points out, that

 "A pristine pure slice of spectrum to have error-free performance is
not required when using digital modulation."

Paul Baran's key technical explanation of the difference between the
comparative ability of traditional analog signals and newer digital
signalling to handle interference was expressed most clearly at the
Marconi Centennial celebrations in Italy in June 1995. (See sidebar for
the full quotation)

There he stated, that the reason analog signals - such as used in
television - needed to have exclusive slices of spectrum was because,
even if an 'interfering' signal was only 1/10,000 as strong as the TV
signal, there would be visible TV image disturbance. But, if the signal
is digitized, tha t interfering signals can be 1000 times stronger,
without visible interference. In other words many, many more radios,
televisions, cell phones, computer communications, can co-exist in the
same space without effective interference from digital signalling, than
was possible using old er analog signalling.

To make these technical characteristics even more significant in terms
of policy use of the spectrum, while it is counter-intuitive, it is
known from the work of Shannon, that transmitting data over a wide
number of channels, at low power, is in fact more efficient use of the
spectrum than sending the same data over a narrow band with higher
power!

The whole traditional 'spectrum utilization' schemes adopted by the FCC
in earlier eras, are being rendered obsolete by digitalization.  And, as
the phenonomon of 'convergence' between radio and digital processing
continues, radio itself is starting to show signs parallel to Moore's
Law - essentially doubling computer power every 18 months.  For it is
the computer manipulation of the data that is changing what is possible.

The heart of the reason there can be 'Public No-License Spectrum' at a
scale that makes a difference, is the emergence of this very powerful,
yet cheap, digital signal processing.  FCC rules can be different. We
shall illustrate how in the New Rules section of this paper. We can have
our communications cake and eat it too. Spread Spectrum

No radio technological development more clearly illustrates the changed
possibilities for wireless data communications than spread spectrum.

First of all, using digital signal processors, a radio can be made to
disassemble a stream of data fed into it from a source.  It can be made
to do this right down to the sub-byte level - bundle it into tiny
packets of data, and transmit those packets in short bursts in random
ways over a wide range of frequencies.  (Thus the 'spread' in spectrum)
This can be done at low levels of power, while a corresponding radio at
the other end, using the same proprietary algorithms used by the first
radio, can capture and analyze those packets, re-assemble them
perfectly, and feed them into a receiving system or network.

Secondly, error-correcting techniques possible for digital signalling
can even deal robustly with the interference that does occur.  If a
great deal of interference occurs, the usual effect is the slowing down
(from retrying to get the signal through perfectly) of the rate of data
exchange, not its complete failure.

Thirdly, the transmissions, being generated from proprietary systems,
can only be intercepted with the greatest difficulty.  Such interception
would require the monitoring of a large number of frequencies
simultaneously, and the capture of all the data.  It would then be
necessary to sort it out from all emanations issuing from other sources
in the same band of frequencies, to order it in the sequences sent, and
then to decode it by substantial processing power. i.e. such
transmissions are surprisingly secure, even without encryption.  This of
course, gives problems to certain intelligence agencies, who bring their
own legitimate interests to the FCC, which then has to balance the
public interest against agency interests.

After all, spread spectrum was developed by the US military in order to
permit clandestine battlefield communications, which could neither be
effectively intercepted, nor jammed. Commercial implementations of that
same technology can retain those characteristics, and even bring a level
of security to the transmissions that is adequate without extensive
encryption, for many general public uses.

In other words, spread spectrum, using frequency hopping techniques can
co-exist with other radios using the same frequencies or bands.  In fact
there can be 'spectrum sharing' to such a degree that it is no longer
necessary for the FCC to award licenses to just one transmitting entity
operating in an area. There still have to be rules, of course, but very
different rules, for this new era of digital radio.

What Should Be Done with the Regulatory Structure?

From a practical standpoint, given the enormous investment already made
in analog communications systems, together with the precedence of past
FCC licensing upon which entire industries depend, one cannot cavalierly
expect the whole regulatory structure to be changed overnight. across
all bands and frequencies  Some call for the abolishment of the FCC, on
the grounds that we have unlimited spectrum.  Others call for the
wholesale auctioning off of all spectrum, to the highest bidder. But
simply because radio is privatized does not automatically mean that
companies who control the spectrum will act beyond their narrow private
interest to include  the public interest as well. So the rules now must
accommodate a dual analog-digital world.  They must both enable the new
digital radio technologies which hold even greater promise of better
spectrum utilization  to thrive and grow, while permitting the older
technologies to continue to be used until replaced by the new by the
actions of the marketplace and further technical development.

Readers who wonder where this is leading should look at, one Colorado
Springs based company, Omnipoint.  After nine years of development of a
superior (to analog) digital cellular telephone service technology,
Omnipoint has been licensed to enter the marketplace in Manhattan, where
it can provide commercial cellular phone service at one tenth the cost
per customer ($200 - versus the $2,000 cost for analog services).

But while that may be occurring in areas where companies are choosing to
provide commercial services - where customers pay for the service, and
only secondarily for the equipment to access it, there is no reason why
there should not be a healthy industry that manufactures advanced,
consumer level, digital radios, where  services are not charged for and
where only the purchase of a radio is involved, and the spectrum where
the radios operate is 'shared' with. competing company radio products.
The core 'business' then becomes the manufacture of radios, which is
more comparable to the personal computer business, than the telephone
company, or cellular telephone service, business.  For in the no-license
shared spectrum arena, it is getting to the point that the computer is
the radio.

Since we are undergoing a massive swing away from tightly controlled,
government, regulations, toward as much privatization of communications
as possible, the new rules need to give as much incentive as possible to
encourage for developers and manufacturers of advanced digital radios to
invest what is needed to perfect their products.  Instead we are
restrictin g and herding them into poor corners of the spectrum, while
letting 'the highest bidders' for spectrum have - and absolutely control
- the cream. The  current situation is derived from the  FCC's first
efforts, in 1985, t o recognize the revolutionary power of spread
spectrum.

A little regulatory history is in order. For it illuminates just how the
FC C works, and may be working now, in considering current Apple and
WINForum proposals. Simply because technology is giving us a better
mousetrap does not mean all powerful interests are buying it. There is
now and has been for some time a vested interest in some companies, in
blocking or marginalizing the new potential for better serving the
public.

Spread Spectrum and Part 15

In 1981, the Defense Department declassified much of the government work
that had gone into the development of spread spectrum radio. This, in
turn, opens the possibility for the FCC to make new rules which could
permit the 'sharing of spectrum' by spread spectrum radios to a degree
unheard of before, even sharing them with analog uses that would not
effectively be interfered with.

The FCC's own engineers were behind the first issuance in 1981 of a NOI
- Notice of Inquiry - inviting comment on proposed new radio classes.
This was followed in 1984 by another circulation of an NOI, then a
Notice of Proposed Rule Making (NPRM) - which is the usual way new
initiatives or changes in FCC rules are put out for public comment.

That NPRM was remarkable for its vision For it asked whether or not,
permitting radios that operated in ANY frequency bands above 75mhz with
suitable digital processing control techniques, and of up to 100 watts
of power, would be acceptable.  This would permit radios to operate even
across spectrum set aside for television channels if the radios were
properly designed. Which they can be required to be by strigent FCC
rules. For the radios themselves have to be type certified - i.e.
licensed - by th e FCC.  An enormous wasteland of unused, but set-aside,
TV spectrum, could have been used on a shared basis by other, advanced
digital radios.

One would have thought the US government was suggesting  opening  the
Fort Knox gold treasury to a public give-away.  Skeptical comments came
back from two key sectors, both of which wield great - some would say
undue, influence over FCC policies.  Even some elements in the FCC's own
staff, less interested in the FCC's ultimate mission, than in the
politics of rulemaking, resisted the revolutionary, visionary, proposal.

Corporations such as Motorola, and Bell South, who have either a vested
interest in the traditional 'singular' (to one company) licensing of
spectr um, or at least the bending of the rules to their company's
benefit, objected. Also US Intelligence agencies, already beginning to
deal with the difficult y in monitoring and intercepting digital
communications traffic objected, on national security and law
enforcement grounds.

Faced with the double whammy of big government and big business
objecting to a proposal which, even if modified somewhat, would have
been very much in the public interest, the FCC had to back down. It
emerged, in 1985 with rules which neither contained the original vision,
nor were particularly of great incentive to risk-taking investors in new
technology radios.

The FCC first relegated the new Spread Spectrum radios to what is called
the Part 15, or ISM (Industrial, Scientific, Medical) bands - the
garbage bins of spectrum allocation - with uses such a microwave ovens,
automatic garage door openers, and short range portable phones.

In other words, not only were the new radios not to be permitted to
operate across existing licensed bands - vast stretches of which have,
in any particular location little or no use at all, but were relegated
to crowded, catch-all bands, in which there is no true equal 'sharing'
because the FCC still licenses other uses in these Part 15 bands and
they have higher priority than Spread Spectrum radios. i.e. if operators
of licensed equipment complain they are being interfered with by the
unlicensed radios, the unlicensed operators must shut down.

So the rules promulgated by the FCC for the use of new radios designed,
engineered, and manufactured by risk-taking companies restricted the
power to one watt, and even required the approval of the types, gain,
and location of antennas connected to the Part 15 Radios.  Spread
spectrum no license wireless was thereby marginalized.

Forty Companies Making Radios

However, in spite of these severe limitations, over 40 companies have
invested in efforts to make radios that, because the communications in
the US that used them could take place anywhere, required only that the
radios and antennas themselves be licensed before being sold.  These
radios could also communicate without forcing their users to sign up for
commercial wireless services.  They opened to thousands of companies,
schools and colleges, government and other public organizations, the
abilit y to link, internally, their offices, buildings, and personnel,
at ever highe r data rates paralleling the public demand for digital
bandwidth. For only the cost of the radios and the technical expertise
to install and maintain them.  This is an attractive alternative to
either being compelled to pay telephone companies' line charges for hard
wiring between their facilities, or paying for very costly wireless
services, such as by satellite.

For the radios that have already been produced, even under the severe
limitations of power and range  give buyers the opportunity to have no-
license digital operations extending from short range wireless 'LANs'
operating up to 5 megabits per second - half a wired ethernet speed,
without the wires, through wireless modems operating in the 56kbs range
for up to a few miles, and 115kbs radios that can operate to 20 miles.
Finally FCC approved radios have recently come to market that can
provide T-1 and higher (2mbs) rates at 25 miles, using only one watt of
power. The only real cost is the radios themselves, a site survey and
ultimate connection to the buyerD5s network. They can coexist with other
radios on the same frequency bands. Which, if the radios are properly
engineered, will cause little or no interference.  The principles that
shake out are: 'Shared spectrum.' Low cost. Public interest.

The cost of such radios is affected by the scale of manufacturing and
market penetration - which, in this earliest decade of the new Part 15
rules - is still higher that it would be if a Public Shared Spectrum
were s et aside exclusively for the use by such radios - and not all the
other contending uses as in Part 15, where, for example, microwave
ovens, not designed to use digital signalling, can interfere in close
quarters with T- 1 speed digital radios operating in the 2 gigahertz
range.  These radios are designed not to interfere with other similar
radios using spread spectrum.

The principles that shake out are:

The Right radios -> Shared spectrum -> Low cost -> Public interest.

And all this is being done in poor spectrum - Part 15 -bands, with
tertiary priority, not frequency bands that have been set up by the FCC
for the flowering of such technological radio advances with true 'shared
spectrum' where all radios are equal. And where the best performing
radio at the lowest cost will gain market share.

So a promising revolution was stunted at the birth of its first
technologic al child, and is now only a dwarf of an industry in
comparison with the communications giants, who themselves are now
getting - as evidenced by the demand for spectrum - into digital
wireless themselves.

If there were a compelling requirement that all two way digital
communications had to be in the form of commercial services - because of
the scarcity of frequency channels, rather than just the purchase of
radios , then there would be no argument that the public interest would
be best served by simply letting the marketplace for such commercial
wireless services run its course. But because it is already
demonstrable, as deregulation starts, that many of the large
communications companies - including telephone companies and cable - are
little interested in bringing affordable advanced technology data
communications to 'marginal' markets, rural areas, smaller towns, or
public agencies - where there is just as much 'need' to be connected as
the dense and upscale central urban city markets.  These needs must be
met.  Just what are they?

Demonstrable Needs

Now is there a compelling 'need' for such radios, and for the
connectivity to the Internet among other things which they afford?  The
question is, is it in the public interest to have a choice between
buying commercial telephone data services, or commercial wireless
services both of which carry recurring, monthly charges, and paying
one-time costs for radios and their installation, which will perform the
same tasks, without the recurrin g charges, and which can be set up and
used where commercial telephone or radio service providers do not
operate, or can only operate at very high cost.

There is definitely such a need in rural areas where, telephone
companies have historically been compelled, in the public policy
interest of 'univers al service' that was embedded in the 1934
Telecommunications Act, to provide telephone services, even at a loss.
But those telephone companies now, by reason of the updated 1996 Act are
now permitted to go where only they, in their business interest want to
provide services, including advanced digital services such as ISDN,
frame relay, dedicated data services.

One glance at the plans and practices of the largest telephone carriers
since the advent of the World Wide Web and the Internet, show they have
made a beeline for the largest, most affluent, urban areas, and are
interested in selling to corporate America first.  But this does not
always correspond to the need of public institutional sectors - such as
the 107,36 1 public and private schools in the US, not to mention the 8,
965 colleges - where the cost to connect up the 44,727,396 students to
the Internet, for example, is proving to be a new cost burden to
taxpayers.  The conventional wisdom is that 'eventually' all market
needs will be met.  But already, 20 years into the digital computer
revolution, 10 into the Interne t and 5 into the World Wide Web
explosion, there are still places and sectors that have barely achieved
the first step.  The recent 'Net Day' in high-tec h California,
hooplawed all the way to images of the President and Vice President
dragging cable through a school to wire it up, even missed, as reported
by NBC, thousands of schools which are still not connected.

At least one entire school generation has graduated into the world of
work since the digital revolution has been under way.  Those lucky
enough to attend Internet connected schools benefitted, those who
didn't did not. And what they learned or did not learn, will affect
their futures.

If the goal of the FCC as Reed Hundt states,  ". . . Make sure that
advanced telecommunications services are affordable to everyone in the
country. . ." is to be met then it follows that the providing of
no-license Public Spectrum can be a large gap filler right now.

In fact the notion of 'Community Networking' - where communities can be
entire small and rural towns, or neighborhoods within larger cities
matches up very well with the unique 'one to many' and 'many to one'
characteristics of two way, no-license, digital radios, and their
practical potential ranges, of several miles.

The Needs of Our Public Schools

Nowhere is that matchup more obvious than in the case of American public
schools, whose geographic location corresponds closely the communities
in which people live.

There are 84,175 public schools - in 16,438 public school districts - in
the US, and they have a counterpart in the location and distribution of
public libraries.  While schools are but one clear 'need for
connectivity' sector, Old Colorado City Communications has had plenty of
experience with what it takes to connect them up. It has been involved
with projects in Montana, Wyoming, Colorado, and from reports received,
in lots of other states.

Public schools, all of which are clamoring to get connected to the
 Internet - have four cost connectivity problems.

a.  Connecting a school district building to the nearest point of
presence. These connections - whether a commercial POP, a state wide
network, or even, to some local college which itself is linked to the
net, must be at h igh enough data rates and robustness to serve all of
its schools, whether or no t they are in a single complex of buildings,
such as in small and rural-small school districts.  For example - it has
been the choice of  Colorado Spring s School District 11 to route all
its Internet connections through its distri ct headquarters, through its
own firewalls, and from there to the net through an MCI commercial POP
3 miles away.  In tColorado's rural San Luis Valley the closest
commercial point of presence is from 15 to 40 road miles away from the
schools. What has been 'unaffordable' are the monthly telephone company
costs to extend 56kbs or higher data lines to each of the schools. Quite
apart, in the typical case of the Valley, from the additional cost of
the Internet service available at the end of the local loop lines.

b.  Connecting a single, separate, school building to either its
district headquarters, or the nearest POP, separately. In the case of
the large (32,000 student) district in Colorado Springs, that means 55
separate buildings linked to the central district system.  None of the
schools are more than 7 miles from the district headquarters.  This is
rather typical. Most of the large urban school districts in the nation
could be circumscribed by a 10 mile radius.  Currently the only apparent
solution for connecting all schools to the center, and then to the net,
is by local loop wired commercial services - which for a 55 building
district like 11, with a mix of 56kbs and fractional or full T-1 levels,
can cost from $12,000 to $20,000 a month in just local loop telco
charges, even with educational discounts. That is not a trivial amount -
from $144,000 to $240,000 a year - just to get the data signals from the
school buildings across town to Internet providers - before paying for
that service too. And who is paying that bill?  Taxpayers, in the case
of public schools.

Then in rural and small town districts where all the schools K-12 may be
in a single complex, but the distances are greater to the closest
larger-ci ty POP, the costs for a wired T-1, 25 miles can range from
$750 to $1,250 a month.  Again this figure covers just the local loop
charges, not Internet service charges. In the San Luis Valley of
Colorado, US West quotes $13,000 a month to extend T-1 wired services
from the central town to all 14 school districts, with many having as
few as 300 total students.

c.  Connecting classrooms to central school servers, in  single, very
short range (150 to 1,000 foot) areas.  Here wireless lans can
substitute for wired lans. But ironically that is far less a recurring
cost problem to sch ools - for once a wired lan is in place there are no
link-service costs, while linking buildings across cities always
involves commercial service costs.

d.  Connecting students and teachers pursuing studies from homes,
apartments, to 'their' school.  This can be either walking or busing
distan ce - again, with a very high proportion of student populations
living within district boundaries, which, except for very unusual rural
situations - will be in the 5 to 20 mile radius of the schools - the
'community' of household s served by the district.

Thus we have a connectivity-cost problem (1) within schools (2) between
school buildings (3) between school systems and a net point of presence
and (4) between school buildings and the residences - where students,
teachers, parents, and community members live.

Finally there is a little-remembered added premium to the costs of
public school connectivity. Most public schools in the US operate on a 9
month school-year basis. But dedicated data connections by local-loop
carriers ar e routinely 3 to 5 year continuous line contracts  So the
real cost to the school is at least effectively 25% higher per month
while the nets are bein g used.   No-license wireless does not incur a
cost for time unused.

Connectivity Issues Affecting Libaries

Public libraries (there are 15,679 of them), which also are in
'communities ' have three essential cost-connectivity problems.

a.  Links to the nearest POP with high enough bandwidth to permit at
least ONE PC-based workstation to handle web-level graphics and sound.
Which means 'faster than a POTS dial up telephone line' - 56kbs up.

b. In the case of library districts, links between the branch libraries
and the central library, which itself is linked to some POP. An example
is the Pikes Peak Library District.  While its central library is linked
to the AC LIN state wide system, by a T-1 going though a local
university, its 10 smaller branch libraries currently have only POTS
dial-up capacity lines.  These lines cannot handle web-level graphics --
certainly not for more than one patron at a time, even in a library with
several, or many terminals.  The total cost of ten 56kbs lines from US
West will average $1,000 a stiff pric e. And T-1 or fractional T-1 lines
cost over $500 a month - or $5,000 just to get data from a branch
library through the central library to the net. Wireless can eliminate
such branch library local-data-loop costs.

c.  Links between the library and school systems served by them. In this
era of inter-library services, almost all schools have their own small
libraries, but want to be linked to larger libraries, not only for
administrative purposes, but also so that students can use the online
resources of distant libraries.

Libraries are one of the only public institutions where all citizens can
ha ve net access, at general public expense.  If public libraries have
low enough cost connections to the Internet, then any citizen not in a
school, government office, or business with links, or who personally
owns a computer, modem, and has a commercial account on an Internet
provider's service - can get, within reasonable limits, net access.

It is the cost of the local loop, above the ordinary dial up connection
spe eds of 28.8 kilobits per second that is a taxpayer burden for public
schools an d public tax-district libraries. One which no-license
wireless capable of operating out to 10 miles urban, and perhaps 25
miles rural, can dramatically reduce the cost to taxpayers. If the
average cost for local-lo op data services is only $250 a month to
schools, the cost savings by using no - license wireless can be over
$250 million a year nationwide. While the capital costs for equipment
for both applications is nearly the same. For, while radios with the
ability, in the Part 15 bands to reach 5, 10, 20 mile s cost from $1,000
to $5,000 or so, an organization using commercial data links must also
purchase what are referred to as 'DSU/CSUs' necessary to interconnect
computer systems to the phone company data lines, and Routers. That is
also a comparable capital cost. So buying radios to connec t without
wires is comparable to buying the equipment necessary to connect by
commercial wires.

While commercial telephone companies certainly appreciate gathering $250
million a year from schools and libraries for data services, providing a
way to avoid such recurring costs is certainly in the public interest.
Rather than asking government to subsidize these networks, a different
and less costly approach can come from manufacturers, who through
selling their radios provide free user connectability to the Internet.
Thi s would also give local communities a real choice between
technologies and not just between differnt cable or telephone companies.
This could also stimulate the growth of a small wireless 'industry'
which, in a nation that proclaims 'competition' to be  desirable, may
actually provide some competition to the largest communications
companies, as well as each other.

While it is more obvious why the ability for schools and libraries to
substitute no-license wireless for commercial wiredservices in the local
areas is in the public interest, it is less obvious, but just as
advantageo us, for local 'communities' to be able to take advantage of
the unique capabilities, and economics, of wireless across
neighborhoods, small cities , and rural towns - or even between rural
towns.

RBOCs Are Failing to Make Adequate Service Available

There is no reason why small towns, or neighborhood entrepreneurs, or
public organizations, should be barred from offering no-license wireless
links across their 'communities' to give individuals accesss bypassing
commercial local loops, and giving them direct access to the Internet.
Problems already exist in cities throughout the country, where world
wide web bandwidthh demands  make it impossible to rely on 28.8 speed
modems for useful work  - particularly for professional multi-media
applications for people working from home.

Unfortunately, as soon as there is an individual requirement for
individual connectivity at greater than twisted pair, local dial up
telephone modem speeds, the choices are far more limited than public
opinion assumes. Either ISDN, dedicated 56kbs or higher speed lines, are
required.  But the fact is that in every Regional Bell Operating Company
(RBOC) area, ISDN availability varies and is non existent in small towns
and rural areas. Pricing fluctuates wildly as well. In fact several
RBOCs are discouraging o r refusing ISDN connections to individual
homes.  This is happening even where encouraging telecommuting is a part
of corporate strategy, and the telco has the necessary switches in place
at central offices.

Pacific Bell, in an internal memorandum, widely circulated online the
week of April 20th, informed its sales staff that zero per cent
commissions would be paid for residential ISDN.  Apparently that market
is not in their 'interest.'  And US West, rather than lower prices for
ISDN in the face of increaing residential demand in Colorado, and the
State of Washington, requested PUC approval to triple their rates for
the service.  As residenti al telecommunications users want ISDN to get
the data rates they now need for serious use of the Internet, they find
plain old telephone service (POT S) is no longer enough, and ISDN to be
a roll of the dice.

MCI, with 4,000 engineers in its software plant in Colorado Springs,
wanted to permit several hundred software engineers to work from home.
US West stated it could not supply ISDN compelling MCI to try to work
out an arrangement with TCI Cable, which is attempting to deliver
cable-modem data. that is not yet available.  So even in a city as
technologically advanced as Colorado Springs, the frustration level  of
data communications users is palpable. Furthermore the deregulatory
effects of the 1996 Telecommunications Act, show no promise of
satisfying demand. Since long distance and other carriers have  little
or no, in place wired 'infrastructure' to offer,  no-license wireless
can fill that gap provided FCC rules don't prohibit it.  There are no
compelling reasons why they should. Except for the issues of
'interference,' which, are being handled, already, in the Part 15 spread
spectrum bands.

For students accessing schools or colleges from home, the cost of
dedicated data circuits beyond their twisted pair telephone lines is
prohibitive. Whi le the pat solution is to 'get another phone line'
those who advocate that as a total solution are often the ones for whom
28.8 modem speeds are already insufficient. Distance learning requires
as much bandwidth for multi-media communications as does telecommuting.

In short: no-license wireless in local communities - essentially LII's
(Loc al Information Infrastructures) can fill a large gap in 'last mile
connectivit y' at data rates now required by most individuals.

It is not as if some large markets are being denied to telephone
companies by the use of no-cost wireless locally - there is no evidence
that the telephone companies are about to make the staggering
expenditures for local communications infrastructures to residences,
businesses and institutions. In fact, wireless permits such telephone
companies to sell to the growing bandwidth requirements as increasing
numbers of end users access the nets.  They will benefit economically
along with the radio manufacturers.

Benefits Are More Than Domestic

Reed Hundt, the Chairman of the FCC, cites the economic benefits to the
US from the burgeoning number and variety of wireless commercial
services coming online - all assured of their slice of spectrum by US
government guarantee.  But it will be  a long time before world  markets
will be ready for such advanced commercial services.  Yet there is a
market right now for no-license radios to connect educational,
government, and business facilities, even in capital cities of the third
world, to the world data networks.  I would hold that it is very much in
the public interest to encourage such industries to export US products
where US telephone based services have little chance of establishing
themselves.

So the need for dramatically increased levels of connectivity is not
only domestic, it is International. The clamor of third world countries
to get i nto the Information Age by connecting to the Internet in
countries with very poor or non-existent traditional telephone
infrastructures, creates a situation that is in the trade-interest of
the United States.  For FCC poli cies that truly serve the public
interest could enable US manufacturers to make and sell tens of millions
of radios which can go where no telephone company can, or is interested,
in going.  This would be comparable to the huge export business that US
production of personal computers triggered.

Even where distances between towns exceed 25 miles, the ability of well
designed radios to 'relay' and reach 50, 75, 100 miles without
unacceptable losses of bandwidth can solve many connectivity problems in
countries where the US would like to export, and reduce - again in the
public's interest - its trade deficit. (If auctions of spectrum, where
the money goe s to pay the deficit, is reason enough to use that unusual
way to award licenses, then expanding US manufacturing is a sufficient
reason to bring up this topic.)

But why should we, or the FCC, be interested while in making the case
for public spectrum, by makinf reference to what it could do for foreign
countries? Its a matter of engineering and development costs.  Unless
there is a substantial and growing market for radios so advanced that,
when engineered right, they can fully reach the potential indicated by
radio theory,   the developmental costs will be high. Onmipoint spent
over $100 million in engineering costs to get its new digital telephone
technology right. The potential for large sales in foreign, third world,
markets, can act as a big incentive for  further development.

What is needed to enable the very largest proportion of the US
population can use advanced radios without interference is that
manufacturer's spend what is necessary to make the best radios possible
and profit from their efforts. And while other countries may eventually
be able to design and sell radios as advanced as the US, this area of
radio engineering represent s a sector where US technological savvy can
give it an edge.

There is already some evidence, in the limited markets that Part 15
Rules have opened up, that some radio companies are 'cream skimming' by
building radios not adequately engineered for low interference, selling
int o markets until interference starts happening and then moving on. I
am aware of reports of some company radios being introduced into the
vast, untapped foreign markets, and then, as soon as a concentration of
radios begins to interfere with each other, the company moves on to
another city. Proper design would make that unnecessary. But there has
to be a powerful incentive for radio companies to do the hard
engineering in the first place - research and development costs must be
justified.

So what is the FCC doing about this?  It is standing pat on current
rules, which marginalized the potential of no-licensed advanced data
radios.  And it is even proposing to 'roll back' some Part 15 Rules,
especially those pertaining to antenna placement - both height off the
ground - and power gain from directional antennas.

One action known as the NII BAND is underway.  What has happened
illustrates what is wrong with FCC policy making in the nearly absolute
absence of public comment on the desirability and need for wireless
capabilities. The Uncertain 'NII Band' Trumpet

One current attempt to get such a 'Public National Information
Infrastructure' or 'NII Band' was made by Apple Computer  and WINForum
(a large company industry group) when they submitted a pair of Petitions
submitted to the FCC in May, 1995 asking them to set aside 300 mhz of
spectrum in two bands, for no-license wireless radios. The two petitions
arrived almost simultaneously, and the FCC chose to deal with them
together - though their differences are significant.

The Apple petition was originally much bolder, and wa specifically
targeted at 'community networking' through no-license wireless. Among
other things, it proposed rules to  permitted wireless communications
over a distance of at least 15km.  Though it had technical deficiencies,
and  di d not go far enough, it was a step in the right direction, as
originally proposed.

The WINForum petition reflected the 'wireless lan' commercial interests
of its sponsor companies.   It totally excluded any concept of
'community' networking. WINForum lobbyist and technicians from parent
companies had vigorously followed up with the FCC staff. In fact some
advocates of WINForum's position regard 'community networking' as
comparable to the babble of CB radio which it most certainly is not. (If
for no other reason than what goes on in wireless linking to the
Internet is, itself, not open babble, but point to point communications.
The babble happens, if anywhere, on the Internet itself, not in the
means of reaching it.)

These petitions, and the public comments following them made in June and
July of 1995 can be found on both the FCCs own web site
<http://www.fcc.gov> and on Warpspeed Imagineering, Inc's site at
<http://www.warpspeed.com>

Unfortunately, and depressingly, Apple failed to follow through with
sufficient technical information to answer just how 'community
networking' could work from a practical standpoint.  Instead, on
February 29, it and WINForum, sent a written agreement to the FCC that
supported in "principle" both wireless LANs and the longer range
community networking rules.  But Apple, which was the chief proponent of
community networking, failed to provide sufficient technical
implementation recommendations or adequately answer the technical
questions and concerns raised by the FCC engineering staff following the
submission.  All it  communicated  to the FCC on the issue, were
generalities.  There was never a joint WINForum Apple submission that
included detailed technical recommendations for the longer radio range
community networking -- originally known as Apple's NII Band.  What was
left was a set of wireless LAN rules of interest to companies which want
to sell to local institutiona l markets.

Actually all the public comments made in mid 1995 addressed AppleD5s
'community networking' topics - and none addressed the WINForum
proposal. But the Apple NII BAND petition sunk beneath the waves as soon
as big interests got involved. The FCC's own staff doesn't seem to be
able to think for itself, as to what is, or is not, in the broadest
public interest .  It only seems to react to what 'the industry'
proposes.  When Apple didn't follow through, it ignored the 'community
networking' concept for no- license wireless, and did not propose to the
Commissioners that the longer range radios be approved.

Apple Fails to Act

So the FCC, lacking technical proposals, and after waiting to no avail
for Apples' technical followup, and apparently ignoring the public call
for n o- license wireless 'community networking,D5  started proceedings
on April 25th, 1996 on what they called the NII/SUPERNET devices rulings
for no- license wireless communications in 350, instead of 300,
megahertz of bandwidth - from 5.15-5.35ghz and 5.725-5.875ghz which
hitherto has been occupied by some ISM bands, and Amateur radio
frequencies.

The FCC staff presented a request for formal comments by what is called
an NPRM - Notice of Proposed Rule Making, and asked the Commissioners to
approve these steps, which they did, with excessive praise, by all of
them, for the staff proposal.  The praise even confused the press, some
of whom reported on the 'Community Networking' proposal, referring back
to the original Apple proposal, though the term was never used in the
presentation or commissioner discussion.  Only Commissioner Ness
expressed interest in the original, longer range radio, proposal.

What is being formally proposed for public comment is a narrow, very low
power, use of wireless devices.  The use is to take place inside
buildings where the only thing such devices can do is power wireless
lans at one tenth of a watt, in the 5 giga hertz frequency range.

The term 'community networking' is not in the proposed rules. And in
response to a later press question  about longer range radios, the FCCs
Chief Engineer Richard Smith replied the FCC will probably hold an
auction for such radio uses.  The staff only left the public interest
door open a crack by agreeing to ask 'questions' about the longer range
proposals made, but then not backed up by Apple when the NPRM is
circulated for comment.  A complete report on  what was said at the
public FCC meeting approving the go-ahead of the rulemaking process is
at New Signals Publishing web site
<http://home.navisoft.com/nspi/n1.html>

The next step, in the rulemaking progress is to publish the NPRM, giving
the public 30, or perhaps 60 days to file comments - probably
electronically as well as in writing - and another 15 days to comment on
the comments.

There are some grievous shortcomings in what the FCC has proposed  to
date.  And unfortunately, the statements by Commissioners, the press
release announcing the NII/SUPERNET bands, and the FCC  followup press
conference appear to promise much more than it will deliver.

There is some irony in what the FCC did do, however. Wireless lans are
probably the least needed by schools or libraries, because wiredlans are
being installed at a  rapid rate  all across the country.  Once
installed t hese cost nothing to operatte. Furthermore, an even later
technology - infrared, not regulated by the FCC - is already maturing
into short range, in buildin g, wired LAN substitutes.   So with fanfare
rules that schools and communities don't need are being circulated,
while those they do need are being ignored.

There is even a darker suspicion as to why, with a large number of
companies already building wireless lans in the Part 15 spectrum,
companies such as AT&T and Northern Telecom are so interested - via
WINForum - in the short range, no-license proposal now pending. And that
possibility is because they really have no intention of giving schools
and offices 'free' access, but simply will use the new bands to give
them wireless voice telephone - like PBX's - or other data services.
Doing so by incidentally not having to bid on, or pay, for a license.

Perhaps the FCC does not even understand the real motives behind
WINForum's petition?

New Rules

Because there is a great deal of difference between electromagnetic
spectrum use in sparse rural areas, (where the need for no-cost longer
range data links is the greatest and the likelihood of interference the
least), and in urban areas, where distances are shorter, but the chances
of interference is greater, the need for different rules for different
areas presents itself.

We shall sum up what we, and others, believe to be some basic principles
which should be followed in the FCC rule making  for such 'NII Bands' -
or truly 'community networking' Public Spectrum.  These would include:

         a.  The Rules for the NII Bands should be market-centric.  Not
'on e size fits all.'  Rural, where spectrum interference is lowest, but
the need is for greater range, should be granted higher effective
radiated power, or lower interference-limiting rules, than dense urban
areas where distances are shorter, and congestion greater. And
'relaying' from one radio to another, to extend range, should not be
prohibited where reaching the total population is the important object.

         b.  The Technical rules for the radio performance in the
spectrum - the frequency hopping rules - should be raised to the  point
that local interference between like radios is minimized. The original
rules had a low bar for entry into the Part 15 bands, in order to
encourage experimentation  but led to interference between radios not
engineered to a higher spread spectrum standard. Now that processing
power is greater, and developers have the benefit of over 10 years
experience with frequency hopping radios, the bar can, and should, be
raised.

         c. In fact, the rules should take 'product-life' factors for
 radio design into account. With the rapidity of change in processing
 power - therefore potential signal processing power - reflecting far
 more the dynamics of microcomputer design, the rules should make
 provisions for changes based upon greater capabilities - less
 interference with higher throughput and robustness of operations.

It may even be desirable to award licenses to the radio manufacturers
for a fixed period before re-certification of the same radios - such as
2, 3, o r 5 years.  This policy would have the goal of constantly
raising the technological 'floor' of acceptable radio performance,
thereby being an incentive for designers to build ever better radios,
tapping the still rush ing frontier of component capabilities and
falling costs. Currently radio desig ns are certified forever. And
poorer performing radios pollute the spectrum, relative to better
radios. In other words, technological 'change' needs to be built into
the rulemaking in ways as never before.  Though this rule would impose
some hardship on some companies,  if technological progress is the only
way the 'interference' problem can be solved, then this must be a firs t
priority to the goal of giving the public affordable access to the
Internet .

        d.  The rules should be more oriented toward looking both toward
'complete systems' and 'how they will be operated' - rather than just
looking discretely at the radio specifications, and then separately
antenna designs.  How the radios are designed to be, operated can make a
large difference in interference. A case in point is one current
manufacturer,D5 s radios are designed to be 'on,' or transmitting, all
the time, rather than just 'listening' before transmitting. This
increases interference unnecessarily.

        e. There should be encouragement in the rules for designers to
crea te radios which 'search' wide spectrum bands, sensing whether there
is traffic at the instant, and only communicating where there is none.
This would mark a trend away from the historical allocation of discrete,
and narrower 'bands' or channels  of operation.

        f. Wattage and antenna that permit communications to reach at
least 15 km (and preferably 40 km should be permitted in rural areas).
Permitted antenna design should be such that relaying between radios is
feasible, extending that distance, with directional antennas to at least
80 km.  This would come closer to meeting the needs - and legal mandate
stated by Chairman Reed Hundt at the beginning of this article, more
than any other thing the FCC could do in the public interest.  It would
effectively reduce the cost of the 'last mile' (which in practical
communit y- school networking terms means 10 to 20 miles) of data
communications to zero, with one time costs for the radios.

What Needs To Be Done?

Readers must speak out by letter, email, fax, telephone when the
NII/SUPERNET NPRM is circulated for comment.  It will be necessary for
far more individuals, public interest communications organizations, and
technically savvy observers, to comment, formally, on the NII Band
proposals. To offset the well funded efforts expected from large
communications companies lobbying in their own self-interest, it will be
necessary for:

       a. Civic networking organizations, power users of
telecommunications , educators, and librarians, can assist in strongly
stressing to the FCC duri ng the comment period, that there is a public
need for adequate, no-license wireless communications. Comments do not
have to be limited to the specific technologies or frequencies being
considered in the NIISUPERNET proposals.  Why?  Because it is clear that
the FCC has yet to hear from a broad constituency of end users,
individual and institutional - the 'Public ' - on behalf of community
networking.

       b. Those who understand and can comment on the technical issues
involved should file comments making the case for longer range, higher
power, higher performing, no-license wireless radio rules. According to
press conference comments made by FCC staff on April 25th, the
'question' will be asked in the NPRM, about 'longer range' radio rules.
Answer them.

       c. It is important for the public to learn about the
technological advances coming in wireless communications. One would
appeal to that special breed of journalist who can translate
technological babble into layman's language, and point out the economic,
as well as policy, implications. The public needs to understand the
value of having appropriately made government rules.  Journalists need
to help bring the little understood, but revolutionary developments of
radio, out of the shadows.

Conclusion

The window of opportunity foir using the public spectrum to provide high
performance, affordable wireless links to world networks for EverymanD5s
benefit may not stay open for long. The giant communications
corporations have shown how much they value wireless by their $20
billion in auction bids for exclusive rights to spectrum slices. The
pressure to privatize all the spectrum not reserved by government itself
is getting intense. So unless the public acts now, to convince the FCC,
and Congress, that it shou ld have Public Spectrum reserved for its use,
the window may close forever.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Side Bar 1 Spread Spectrum in the Words of Paul Baran

"To the modern communications engineer, a lack of strong signals
anywhere, no matter how distributed, represents a theoretically unused
capacity that is available to be utilized with the proper signal
processing . With advanced signal processing techniques, transmission of
signals on top of undesired signals received at lower levels represents
a potential source of usable transmission capacity.  There is a caveat
here.  We are assuming digital signals that are able to operate with
lower signal to noise ratios than  analog signals. That means if the
desired signal is but slightly stronger than an interfering signal, it
can theoretically be received witho ut error. This game doesn't work
with old fashioned analog modulated signals, such as analog broadcast TV
signals where even weak interference 40 dB below the picture is visible.
40 dB is a power ratio of 10,000 to 1. That means if an interfering
signal is 1/10,000 as strong as the analog TV signa l it will be visible
in the received TV image.

Compare this situation relative to the case of a digitally modulated
signal able to operate at a 20 dB signal to noise ratio. 20dB is a power
ratio of 1 to 100, or a tolerance 100 times as great as in the analog TV
case.   With the addition of error correction codes, some digital
systems can operate at a 10 dB level or a noise tolerance 1000 times as
great as our analog TV example."

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
What Is To Be Done?

1. Comment vociferously on the NII/Supernet NPRM

2. Technically knowledgable people must help make the technical case to
the FCC

3. Journalists must educate the public on what is at stake

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Web Resources

For more information point your browser at: www.fcc.gov
www.warpspeed.com wireless.oldcolo.com home.navisoft.com

Author Contact Information

Dave Hughes
Old Colorado City Communications
dave@oldcolo.com
voice 719-636-2040
fax 719-528-5869