 Welcome to the Unlicensed Podcast. As always, I'm Caleb. We've got Tasos over here. Hello! And this week we are excited to be hosting Richard Bernhardt from WISPA and a bunch of other things. He's a very busy man, so we really appreciate you taking the time today to talk to us. Before we hop into this real quick and do our introductions and such, Tasos give the good people out there their call to action and then we'll hear our catchy little team. Absolutely. Don't forget to like, listen, or subscribe to our channel right here on YouTube or anywhere you download your audio podcasts like Apple, Google, or Spotify. All right Richard, I really appreciate you again taking the time to talk to us today. For those of you who don't know Richard, he's been at this a little bit, knows a few things, so probably best to just let him kind of kick into an intro, tell a little bit about your history, how we've gotten where we are. Yeah, thanks guys. I'm Richard Bernhardt. I'm the Senior Vice President, I'm the Vice President of Spectrum and Industry for WISPA. I've been around WISPA a little over 15 years and WISPA is coming up on its 20th year, so you know that there's a lot of history there. I also sit on the Board of Directors and on the management of the Wireless Innovation Forum. That forum has brought you both CBRS and 6 GHz baseline standards, so the reason that those things work and the reason that they are out there in the wild today is because standards and regulatory work together and we protected fixed wireless in the process. I'm also the Chair of the Fixed Wireless Access for Ongo Alliance. Some of you may have known that as the CBRS Alliance. They changed their name to be Clever, but it is the same organization, so I try and keep a fair and even perspective on the non-mobile approaches to things in that group, although some mobile carries over into fixed wireless. WISPA and Ongo have an alliance and so we spend a lot of time talking about topics fixed wireless. All right, all right, so as everyone can see, you've got a lot on your plate, you've been around and there's a lot of hot topics, especially as we roll out of WISPA America. We just finished that show up a few weeks ago. Great show as always. Great venue. Great venue, yeah, fantastic venue. I gotta say, a beautiful place. Yeah, I was really impressed and loved it. I hope we can do it there again sometime. Yeah, for sure. Walked outside and I'm like, wow, this is really slick. But good show. No tumbleweeds. So there's a lot of these topics that are covered at the show, but it's good. We like to review things for folks that weren't able to make it, different reasons and stuff like that. Honestly, I think the hottest topic obviously right now is 6GIG, the AFC. Where are we? Really, really, why is this so gosh darn confusing? Like, are we ready? Are we not? So if you could shed your light of knowledge and experience on this topic a bit and kind of give us a status update, granted that could change entirely by the time this thing goes out in a couple of days. Well, like all bands, especially shared bands, everything is in flux all the time. But it's not as complicated as it seems. It's actually far less complicated than CBRS. So let me start at the beginning and I'll talk a little bit about where we came from was 6 GHz and where we are today. 6 GHz is an experiment, much like CBRS was an experiment in sharing spectrum with other incumbent operators. In CBRS, we shared that with us. We were the incumbent 965 nationwide license holder for March 90. We shared it with satellite ground devices and we shared it with the all-popular United States government in its radar systems. It's been 43 in other radar systems that need to be protected, especially on the coastlines of the United States. So those were all incumbents in CBRS. In 6 GHz, we don't have as much of the government influence, but many of the fixed wireless providers and ISPs and many of the Wisps out there do hold licenses for point-to-point 6 GHz backhaul. And not just Wisps, AT&T and many other large entities also use that band for its backhaul as to critical utility operators and many, many others. So in this case, instead of sharing with spin 43 radar systems, we're sharing it with critical backhaul systems, nuclear plants, railroads, that sort of stuff. And so you have to protect them and you have to protect us because we're also the license holders. So what was derived was a thing called the AFC system and that sounds scary because it's a system and it's attached to your radio and it's not something that you're used to doing because we're used to just putting up radios and making them go. So the AFC system like the SAS system is a coordinating device. It's there for the purpose of making information available so that you avoid colliding with the incumbents and we have a happy existence. Unlike CBRS, this AFC systems or automatic frequency control systems do not talk with the other ones. So SAS is talk amongst each other. AFC systems do not talk amongst each other. In CBRS, there's an aggregate interference level that's looked at. All the radios are taken into account when we're figuring interference in six gigahertz, not so much. In fact, there is no aggregate interference. All that the AFC does is reaches out to databases that give them information about where incumbents are living and where they propagate to so you can avoid them. And that's what you're doing when you're aligned with an AFC. Your radio reaches out to make sure that the time that you're going to be broadcasting, the power and direction that you're going to use with your six gigahertz standard power outdoor radio will not collide or create problem or havoc with the shared user who is mostly point-to-point systems. There are a few other users in the band that are not terribly going to get in the way of any particular uses but they are protected as well by the AFC system. So when you buy a tested and certified device, a device that's compliant with the ecosystem, it already takes into account that AFC and that your radio will reach out to the AFC and say, hey, where can I broadcast? Now, when we first started CBRS, there's a very tight connection between the operator and the SAS. So tight that if the SAS goes off the air or does not respond in four minutes and 59 seconds, boom, you are required to go off the air. So tight that if an EFC system even makes a peep, you must at a minimum go off the air for two hours to avoid colliding with incumbents. Shift back to six gigahertz, it's 24-hour heartbeat check-in, not four minutes and 59 seconds or every minute. You can check in once a day to make sure that you're not going to collide with an incumbent operator. So it's much easier and it's much more flexible. And six gigahertz sits in the band just above where Wi-Fi on the five gigahertz band looks at five eight. And it's 1250 megahertz of spectrum across the entire band. It's 850 megahertz of usable frequency in standard power frequencies. And guess what? After two and a half years of work, and that seems like nothing compared to what we did with CBRS, which took us eight years, in two and a half years of work, the band's open. The standards are complete, both on the AFC side and on the product side, on the device side. The wireless innovation forum and the Wi-Fi Alliance collaborated a tremendous amount along with the multi-stakeholder group. And as of today, the FCC, or not, it's actually as of a few weeks ago, the FCC put out a public notice indicating that the AFC operators are no longer in a holding pattern, but rather have been certified to operate. And since then, 11 devices have now been tested and certified in the ecosystem. So you have a pretty broad group of things coming into line. That's still pretty narrow on the amount of equipment and on the AFC season operation, but they are live and watch for many more to come in short order. Yeah, the FCC certifications were the final. The equipment cert part was always the part that kind of terrified me, right? Because it was like, all right, AFC seems pretty straightforward, but there were no certs coming out for equipment yet. I've done a lot of part 15 stuff back in the day. So you'd think it's pretty straightforward, but this is a whole new thing. So luckily, when that first one came through, I guess sometime in February or so, it was like, okay, they actually have a process and a way to sign off on this, which was extremely relieving, I guess would be the word for it for sure. So, unlike CVRS, which, you know, it falls into the 3.5 to 3.5 to 3.7 band only in the United States because it's an American band, the six gigahertz band is as close to a harmonized band as one can possibly get, and I say as close to because there really are no harmonized bands, and nor are there likely to be in the future because we just don't get along with other countries when it comes to spectrum or there's things that get in the way of us agreeing. WRC 23 just took place in Dubai. It happens every four years. It's a big collaboration, especially of European providers, and they look at bands that are out there and which ones we should try and harmonize. Well, if you look at six gigahertz, a good part of the world is actually using some portion of that 1200 megahertz for this purpose, and a lot of them are going to be using AFC systems, and a lot of them are using it for unlicensed or licensed by rule uses, or they're sharing them with mobile or licensed uses. So, you are seeing a lot of countries around the world quasi-harmonize with the United States on the use and the approach. Yeah, it was funny when Canada came out first, and I was like, well, that was spicy, not expecting that one, but it was good to see. It may have been a little bit of a kick in the shortest of somebody to hopefully get this order wrapped up, but just kind of talking. Well, we have a very good working relationship with Canada, and in fact, at Winforum at the Wireless Innovation Forum, we've been working with Canada for several years. So, while we probably would have been happier if we were the first ones out the gate, but Canada is using a lot of what we derived to make it theirs work, and that's what I mean by harmonize, that there is discussion going on here while it may not be legal plateau to say that Canada and the United States or any other country is following lockstep what they have to follow. They are following a lot of the same methodologies and approaches, and that's good. Okay. Yeah. And then just to be clear, if a manufacturer has an AP and a CPE that are type certified by the FCC to operate in this band, they've got all the firmware stuff to talk to the FCC, it is now completely legit to do commercial deployments with those. Is that the proper assumption? There is one more roadblock that so far only one of the companies that is certified has surmounted, and that's geolocation. There is a form of geolocation that the FCC is requiring so that they can understand where the radios are, and it's perfectly understandable why they want to know this. If we take a look back at the TV wide space area, there were databases just like there are databases being used by the AFCs. There were radios that had a sort of nationwide approach to things. They had to reach out to those databases to determine which of the formerly analog TV stations were available for radio communications, and lo and behold, people weren't entirely honest about where they were with their devices. So we had some devices that were showing up in New York when they were really in Los Angeles. So geolocation is one of those things that the FCC is paying greater attention to because if you want to protect incumbents, you have to protect incumbents on the ground in which you stand, not on the ground in which you wish you stood. That was kind of a thing that popped up recently. People were a little bit surprised that it was requiring an active GPS plug like in the CPE device, right? Because everyone is used to, it made sense originally with doing your AP device, and I'm speaking in general terms with space that we typically operate in, but the CPE side was relatively new. So I think, but people are getting that figured out, Sam. Yeah. I mean, in CBRS, the CPE is actually a CBSD. That's a lot of letters to say all in one mouthful, but a CBSD is the radio entity that fits into a CBRS, and there's either category A, which are lower power or lower power, and there's category B, which can be used outdoor. But the fact of the matter is that even though it's called a client, it is a CBSD and it has the impact and ability to interfere with a incumbent. So you have to consider it a radio just like you consider anything else. It may be a lower power radio, sometimes it is, sometimes it's not. Sometimes you use a category B device as your CPE, but if you are using a CBSD as your CPE, or you are using a type and a certified approved radio as a CPE in six gigahertz, they do radiate. And we are trying to make sure that both CPE, AP, wherever there's a radio that radiates and transmits, it is safe to protect the incumbent. Interesting. So I have some questions on the interference side. So you had mentioned with the AFC, it simply checks in once a day and says, hey, am I safe to operate on this frequency in this area, let's say, right? The AFC says, yes, it's fine. Okay. Let's say you start creating noise. What's the kind of mechanism or how does anything, if anything can shut down your system because it's been deemed as an interfere? How does that work? Yeah. So unlike a SAS, who has the power to actually tell you to shut down. We were going to get there. In the six gigahertz world, it's more of, if you're causing interference and you know it, then you're an intentional and fairer interferer and you need to get out of that band. This is not a black and white area. I mean, it's not a gray area, black and white. However, the mechanism for reporting interference by someone who is being interfered with is still a bit of a mystery. And the AFC systems have till middle or end of April, which is coming up very fast, to come up with a, and this will sound strange, collaborative method of reporting interactive or interference problem so that they can be resolved. The FCC has not gotten into detail about how they'll resolve interference claims or recordations, whether they will use their enforcement bureau or whether they'll leave it to industry to do something about it or whether they'll let the AFCs do something about it. At the moment, there is no mechanism of an AFC shutting down a six gigahertz radio because they don't have the methodology or knowledge of doing that. We also don't know what radio frequency you are actually broadcasting on. That's not recorded. So they're giving you information on where you can broadcast and what power or perhaps the AFC looks at it as they're giving you information on where you can't broadcast and how to protect the incumbent. They don't know what you actually did. And I don't want that to be a platitude for, oh, they don't know what I'm doing. Let's go do whatever we want to do because I will destroy the band very, very quickly. But the object here is that the AFC is not a policing radio. It is or device or algorithm. It is a informational device. Right. So if it deems you are able to operate in this area, or let's say it says you cannot, it's not saying you cannot on this particular frequency slice, you can use these other frequencies. It's binary. It's either there's somebody kind of there and it doesn't matter what frequency you might still have available or not, you cannot operate basically. So it's not going to protect you from other, just like CBRS, it's not going to protect you from other operators who are operating on license part 15, 6 gigahertz standard power outdoor, but it will protect the the right. So if there is, it doesn't matter what frequency the incumbent is on. And even though there might be spectrum available outside of where the incumbent is operating, you can't operate there at all if it says that path or whatever is used. Yeah. It is not, it is opportunistic in a way, but if there's a protected frequency, you're given that information. Okay. Just curious. Yeah. Yeah. When the the AFC approval notice from the ACC came out, you know, February, it did have that conflict resolution nugget in there that was like April 27th or whatever the date was. And it was like, yeah, if you guys haven't figured this out by then, then we're going to take back your good boy points and then shut it down until you figure out what's going on. So it's definitely a, I don't know. It was definitely a less gentle push, but I think them realistically, the AFC providers are financially driven to get this done, right? So, you know, I was nervous about it when I first read this. As you say, their business depends upon protecting those incumbents and protecting them well, because what's the point in having AFCs if you don't do that? And one of the other hats I wear, and because I have all this, you need lots of hats, the other hat that I wear is that I'm one of the co-chairs of the multi-stakeholder group for six gigahertz, which was created by the FCC and has both incumbents and non-encomments, and it's a very big group. They didn't give us a whole lot of authority, and they made it rather difficult to come to consensus. But we dealt with that issue of how do we deal with interferers who learn, who claim, how do we deal with incumbents that claim that there's an interferer, how do you do the triangulation, figure out who it is, and even if you find out who it is, how do you deal with it? And that's always been an issue in shared spectrum. It's always been in an issue in shared spectrum where there's no incumbents. And even in five gigahertz, you know, that's the preeminent band used by, unlicensed band used by Wisps today. We conflict, right? So, how do we do it? We call up the guy next door and say, you use channel A, I'll use channel B or use out of a bitch, don't do that, that kind of thing. There is human contact, there's usually a method for getting off the channel, and I suspect a routine will fall into place for six gigahertz as well. Yeah, they'll have to, and there's some pretty, not opponents, but I guess the stakeholders, like your AT&T's and stuff, right? You know, I think they've been one of the more vocal ones saying, hey guys, this is okay, but we need to be very careful. And it's actually, I was kind of not surprised, but it was good to see their notices and stuff. You know, you read through it at first, you're like, they don't want us to succeed. But when you read through what they're saying, you're like, no, this is actually kind of reasonable, right? I mean, because, you know, it's not just them from a business perspective. There are so many of these links that run six gig, these long links. I've put a lot of them up for state agencies, 911 systems, the government and stuff like that. So, you know, I think everyone seems to be pretty, pretty much on board as to, you know, what this should be, seems like the mechanisms are going to operate smoother. So, you know, maybe, maybe not quite the bumpy start that SAS had in the beginning with CBRS. Yeah, I wouldn't. It wouldn't bother me if there's some bumps. The bumps themselves give us the information we need to better protect. And I agree with you. I work with AT&T on a daily basis. And, you know, them Southern Company and utilities and all kinds of users who use the point-to-point, and these silly, crazy people called Wisps, who also have these licenses. The fact of the matter is, everyone wants to protect that use. That use is, we don't have so much backhaul, right? Protected backhaul. In fact, Wisps was trying to get more protected backhaul. And so, if you look at six and five and 11, those are basically your prime channels for backhaul. If one of them goes away, that's a big deal. So, our objective here is both protect those, those point-to-point links and make it good for the rest of the man's use. That's what shared spectrum is all about. What 100%? So, the AFC mechanism, like one of the things that you see people get a little bit nervous about is that the SaaS system was a little bumpy, you know, when it first began. Way, way better now than it used to be for sure, right? But, you know, like any big convoluted system, you got to work the kinks out. You know, people are worried about, we're going to see sort of similar bumps with AFC. But the AFC is a whole, the mechanisms and stuff, how often it checks in, what it looks for and stuff, seems to be much more, not simplified is probably not the right word, but there's a lot less to it, because basically it's giving you, hey, these channels are open, you know, you can use these channels and these channel widths, because you're not dealing with a mobile aspect or, like, I don't know, a battle cruiser coming in on six gig and wiping out the whole band, right? Most of these are ULS links that are fixed. So, maybe you could speak to that a little bit, you know, from a stability perspective or maybe why this mechanism is a lot sort of simpler than what we've seen before. And maybe folks shouldn't really be too concerned about it. Yeah, back in the day, the FCC considered that five gigahertz, five, eight gigahertz and two, four and nine hundred were garbage spectrum, because no one would ever be able to get along on those bands. And those were bands that no one really cared anything about. And there would be no way to protect them. And look, here we are, what, 20-something years later, and Wi-Fi certainly occupies more use than any other frequencies probably combined. And my guess is if you took all the licensed bands, you still don't have the billions of devices that you have in Wi-Fi. So, is it more Wi-Fi-ish or is it more license-ish? I think it's more Wi-Fi-ish. It's Wi-Fi-ish on steroids, because you have better equipment, you have equipment that can do more. It has some internal protections in it, the equipment itself, it's better with noise, it's out of band emissions issues are not as much as early Wi-Fi was or and not as strict as the OBE is in CBRS. So, you've got a band that has one more step that has to take place over what you do in Wi-Fi. It's not licensed. Okay, so this is part 15. So you're not going out and buying a license, you're not registering the FCC for a license. That doesn't mean you can do anything the heck you want to do, but it means that the opportunity is there for a lot of devices to operate in the same space. We know that frequency reuse is something that's very viable and can happen. We know that these are lower power devices. These are not 50 watts. These are more in line with what standard 5 gigahertz radio is using. And so, you know, will it work and will there be bumps in the road in the beginning? I think, excuse me, as long as the standard power radios listen to the direction of the AFC and not intentionally put devices which point their directional antennas directly at the beam or the Fresnel zone of the of the point-to-point, then it's going to work. We're going to have some bumps. There is no question about it. And there's going to be a whole lot of equipment in this band. That's my prediction. With a whole lot of equipment, there will be some bumps and bounces. But the other thing is, is that people will get used to those bumps and bounces in the same way that they do on 5.8 and the same way that they do on 900 or 2.4 or any other band where anyone can come in anytime that they want. And you're not protected from the other guys. So, you're forced to get along because the other guys are going to have the same problem as you are. That's the nice thing about physics. It's pretty fair. Yeah. Yeah. And I think with the output power that's there for the incumbent links, I think in a Wisp operator would be pretty silly if he looked at a spectrum scan, you know, and was actually in the path of one of these licensed links and said, hey, this looks clean. Let me operate here. I mean, it would just, it would shut them down instantly because it overpowered everything. And as you know, if it was harming another Wisp, that gets around the community pretty quickly. If you're harming someone like AT&T, they're going to come to you pretty quickly. So, and I think they should. I don't have any issue with this. This is not a fairness issue. This is not a, oh, Wisp should be ahead on this. This is an issue where if we stay in our right places, we get a benefit that hasn't been there. It's quite a bit of spectrum and it's wonderful for use. And we don't know what's happening totally with 5.9 gigahertz at the moment. You know, we're in line to continue the use that's being used. We've been using these special temporary authorities in 5.9 during COVID and doing an excellent job of providing broadband services to people who needed it. So, think about that. You got 5.8, 5.9, and 6. All in a row. Think about how much spectrum that is. That's a lot of spectrum. Yeah. And you know, with new technologies on beam forming and null forming and the ability to squash out much noise to detect when there's cross, when there's cross interference, crossing a degradation in the power, directional antennas, better focused radios, better focused masks. You take all of that together. You can live in the same environment. It is totally possible. We've been doing it for years. You've been doing it for years, decades actually. So, yeah. And even with those fancy antennas I've heard about. There's some pretty cool ones out there, I've heard. It is kind of funny too. People are like, I want to be the first to employ on this tower. I'm going to use up all the 6 gig spectrum and won't let anyone else use it, you know, like a land grab scenario. And I'm like, that's one approach, but like, there is no ownership just because you're the first one there. You see that kind of bumble up a lot. You're still going to have to apply the same principles in your network designed in 6 as you are in 5 or literally in the other band, right? So. Right. But one of the advantages of 6 gigahertz is you can use larger channels. When we get to the next generation of these things, you may be able to use 360 meg channels, which God knows why you want to use a 320 or 260 megahertz channel. But it has the possibilities. I mean, most of us are using like 40 to 80 and 80 is rare, you know, where most of us use 20 megahertz to double. So A and B. So you've got, you're very conservative on what you're using. And I don't anticipate that people are going to jump up to these massive power, massive amounts of spectrum just because it happens to be sitting there. That's management issue. You will run into interference that you're going to have to deal with. It's not pretty and it costs you to do that. So using the right or appropriate amount of bandwidth and the right or appropriate amount of power is what will sustain the industry well. That's exactly right. And I think people are learning that and they will learn it quick, right? Because of the SNR requirements of radios at those extremely wide channels make the operating distances extremely short. And like you said, I think the pre some reports still show that 20 megahertz is the most popular channel size that people are using these days up to 40. I predict that in six gigahertz, 80 megahertz will be pretty much the average. Even though radio has been able to do it now, they haven't been very successful. So yeah, I mean, people will start with the wide channel, but I think they'll end up falling between 40 and 80 megahertz on average. It's much cleaner and it works. The cable industry went out and put modems and switches all over the place and they opened up these 80 megahertz channels just for the public to use. And creating noise for the purpose of creating noise is just not a good thing. And that conversation has been had. In this band, I don't see that happening, but the potential for using wide, for specialty purposes, depending upon if you're trying to, for example, in a stadium or in a mine, if you want a wider channel and there's a reason for it, you have the option to do it. And if you're in an area, a rural area or underground or whatever, you're not likely to be causing interference to anyone else. So go ahead and do it, but don't do it just to do the land grab thing. Probably not a great idea. My biggest worry there, again, is I see Wisps trying to offer gigabits or beyond gigabits and they want to offer these 300 meg channels or 120 meg channels, whatever it is, to get this maximum bandwidth. And they start selling the service and offering the service. And yeah, it starts working great at first, but then other people come around. And then what happens when you're forced to go down to a more narrow channel and now you can't offer the speeds you were initially offering because you don't have the spectrum available, right? That's what I worry about overselling things based on that. This is kind of a segue into CBRS, right? And what I see now, I do see a lot of throughput being pushed on CBRS equipment that's out there, and it's incredible what's being done. But I'm worried about when more and more CBRS operators start firing up their stations, when GAA starts dropping down and all of a sudden you're being allotted less of that, operators may not be able to offer the speeds they started offering because the spectrum starts adjusting on them. And it's just a word of caution after so many years of doing this that people should be maybe a little bit more conservative with their offering and not assume that the spectrum they're using today is going to be there in this shared system in the future. Yeah, I mean, there's a limited amount of spectrum. That's why we're using shared spectrum. If we had all the spectrum we possibly wanted, we didn't need to share it with anyone. We just say you can have that much, you can have that much, no problem. But the problem is we've run out of you can use that much. And spectrum isn't all built equally. Low-frequency band spectrum is good for getting around some pine needles and trees and obstacles, but it doesn't carry a lot of data. High band, millimeter wave frequencies are fantastic for carrying lots of data, but they go very, very short distances. In most cases, they'll go less than a kilometer and their purpose is mostly for bridging, but they can carry in an immense amount of data. If you're going rooftop to rooftop, perfect solution because you can carry gigs of data. But the natural place for most of our operators is in the mid band. And the mid band is very limited in the available frequencies because three gigahertz is the prime real estate. CBRS takes up a portion of that. C-band now takes up the upper portion of that. The 3.45 to 3.55 takes down the lower portion of that. We have one more band sitting out there in the national spectrum strategy called the 3.1 to 3.45 band, which everyone wants to claim and everyone wants except the United States military who says, oh, it will cost $108 billion to move these things out of that band. So if you've got 3.1 to 3.45, 3.45 to 3.55, 3.55 to 3.7, 3.7 to 3.98, how much is left of three gigahertz? Now you say move into four. Well, in four, there are a few gaps, but mostly they're used by government entities, satellite devices. And otherwise, there is not as much four as you think. Five, we all use. So we know what the unis are in five. And there's some protected areas in five as well. We just talked about pretty much all of six up to seven, right? We're getting up with the upper portion of that middle band that's got a lot of room. Between seven and nine, there are some open bands or some potentially reassigned bands that could be used for sharing. And above that, you're getting into fairly high frequencies. So you see the problem. There's not a whole lot of frequency left. And you can head south, you know, 2.5 licensed band, very popular with with the carrier. And you start looking at that band and you go, oh, that band's already taken. And right beneath that are most of the cellular bands and scientific bands and the old TV white space bands. And we're now down to 400 kilohertz. And we've already talked all the way up to 10 gigahertz, which is already being used for point to point and satellite. That's 10 gigahertz of bandwidth that's already occupied, including all of the mid band. Yeah, that's why this matters. It's really, really important. And while people should be able to do new things, that's exactly what we want. That's why we go into the, the, the the specifications for these bands and we try and make them technology neutral. Because we want it, we want radio manufacturers to come out with new things and new approaches that will not interfere, but provide greater efficiencies. It's why we want antenna manufacturers to take a look at the process and say, how can I stay super focused and provide the best amount of, of gain and output that I can on my antennas? We want the, the filters of people and the receiver people to say, keep your masks as tight as possible. So you're not overlapping into other bands. If we make the equipment on all portions of it as good as it can be, then we can share it and we double triple even many, many times the amount of usability that it has had in the past. And that is why we're, why at Whisper, we strive for sharing spectrum. Definitely. I don't know. My radio knob channel width thing goes, has a knob that goes to 11. So if I got it, there's 11 and on there, I'm going to use it. Wide channels. Yep. But it's already got point to point licensed and unlicensed as well. And 10 to 10.5 is a band that Whisper was seeking for backhaul. So you're losing between 10 and 11 pretty soon quickly. You know, and, and there's uses in 12, those little flying satellites up there. They lied 12 and, you know, 13. Yeah. 14 and 15, but you can keep going on. It, it, it, it is really heavily used. Yep. Yep. All right. One last question about six, and then I want to talk a little bit about more CBRS stuff. So in the ASC, so we know geolocation is the thing and your output powers cap, 30, 60, B, M, ERP and the standard power stuff that we're doing. Is there a directionality in sort of coverage area or like antenna specs that fall into the ASC and these calculations as to what channels are open? Or is it a purely point source isotropic 36 dbi and bubble they draw around it and figure out where it could be interfering? Because we don't record at this point. And this could change because it changed the CBRS at, because we don't record the, the directionality and the down tilt and the gain of the antenna. We, we have to assume an isotropic approach. And so the AFC is looking from, you know, if my user who I have to protect is anywhere in the scope or range of that device and that device is using either a sweep type antenna or, or a NAMI directional type antenna, then they have the potential to interfere. So it does assume a more conservative stance at the moment. WSPA has sought in an NPRM or in a further notice to provide additional information and more characteristics on approaching it from allowing the AFCs to at least consider enhanced antenna patterns and also to consider directionality. Directionality should always be one of the considerations any shared mechanism uses. We haven't convinced them of that completely yet. It's still on the radar to do that. But for now, most of the calculations, they taking to affect some aspect of that, but it's, it's not a specific aspect. Okay. So now channel availability and the grand scheme of things is probably the most conservative, not worst case, but suppose conservative, eventually we, if we add in some directionality and antenna sizing and things like that, then we could start potentially seeing a lot more channels open up that were previously blocked. Now that said, you know, everything I've seen, I've been actually quite surprised in most locations, the number in sizes of the channels that are available. Because, you know, first I'm like, we're never going to be able to get a channel anywhere rural where you've got these six gig lengths in a lot of cases. But I mean, from everything I've seen, it looks way better than I originally thought. Well, think about it this way. Now, six gigahertz is not a millimeter wave. So it can go great distances. So as a backhaul, it's an ideal backhaul. It is a fairly good size beam width. So that means that it is susceptible to some interference. But it's also six gigahertz, not 900 megahertz. And so you can look at the Fresnel zone and you can look at the power that's being used in the distances between those links and you can do some avoidance techniques. You know, if you know you're going like this and another one's going like this, you point the laser over there, you know, and it is perfectly capable, you are perfectly capable of doing those kind of measurements to say, this is how I avoid having a problem. The way I like to do it, especially up in the millimeter range, millimeter wave range is say, take out your red or green laser, actually take out your red laser in a gymnasium because we do not want point these at airplanes, point it at the wall. Okay. And you get this nice little dot sitting on the wall. And now we smoke up the room and we see that nice narrow beam that goes in there. Now close your eyes, put on a blindfold, spin you around six times and the other person has a green one. Turn it on. What's the likelihood you're going to cross beams with that red beam that's sitting there? Pretty slim, right? Because there's a lot of room in that room and there's a lot of space in that space and the statistical likelihood that your narrow directional beam is going to cross that narrow directional beam is pretty low. And in six gigahertz, it's a little more because the beams are wider, the Fresnel zone is wider, but it's not infinite. And you can calculate ways to use the space that's not being used. Yeah. And like I said, there are a lot of channels and it looks like hopefully there'll be a lot more sort of open up as they refine these calculation methods and stuff over time and it'll be an iterative process for sure. Yeah. You don't open the gate on a new frequency and expect it to work perfectly out the door. No, no, for sure. So well, hopefully we'll start seeing a lot of gear going up soon. We'll have stuff pretty soon. We're really excited. Real kind of quick thinking about CBRS. So there's a couple of things. CBRS is still plugging and chugging. Actually, I think it's got a lot more traction than it has over the last couple of years. And I think there's two sort of things driving that at least, yeah, from my perspective is one, you know, in our space, a lot of people started deploying a CBRS because it was better at foliage penetration. I mean, clear spectrum, obviously, right? Yeah. But from a physics perspective, everyone's like, hey, I'll be able to shoot through more foliage, just a lower frequency and get through more stuff. And that was the main. More power too. Yeah. And more power, exactly. And those were the driving things. But now ever since beads come out, and there's been this whole conversation about, you know, what is reliable, unlicensed versus licensed and stuff, we see a lot of people who are using CBRS now and deploying because it is licensed by rule. I believe is the proper thing that I always mess up, right? That's GAA. GAA is licensed by rule and palace priority access license, right? So, you know, to those out there that are doing that, I mean, you know, a lot of us say, hey, we have reliable, you know, 100 meg or above service and this licensed by rule service to sort of block out bead overbuilding is where a lot of this is going and stuff. I mean, you know, what do you think? What are your thoughts on that? Or, you know, where do you see this going? What are some pitfalls that you may run into with this sort of thing? Because it's got to be a really popular topic lately. And then you're as well-qualified to speak about this as anyone is for sure. So, bead and Ardolf and CAF 1 and CAF 2 and the AG funds, our US AG funds and the Treasury funds and so on and so on and so forth, all have strings attached in case you didn't know that. Yeah. And they are big strings, they're yarn, they're big to speak. And you need to be aware of what the strings are attached to. And you need to be aware of those even if you're not going to use those funds or even if you're not going to apply for those funds. And in many cases, the window for applying for those funds may not be even open anymore. Understand that bead is a, I think there was good intent behind it. And I think that the Congress and the White House, when they passed the infrastructure bill, they wanted to see ubiquitous broadband across the United States and that's a fair and reasonable thing to want. They want to do away with the digital divide. They want to provide for digital equity and they want to provide reasonable and fair service to every household and business in America. There's a reason why we don't have it in every household in America today. I get told about the parallels with the electrification of the United States using things like the example of TVA. Believe it or not, we have not electrified all of the United States even 50 or 80 years later. There are portions of the United States that literally do not have good sources or even access to commercial electrical services. I'm not expecting us to take 80 years. But in fact, in order to achieve the purpose that the government wants, it has to pay attention to more than simply a few specific factors. Fiber is very nice. It's glassy. You can see it. You get all kinds of pretty colors. It can be buried underground. It can be put up on poles. It also can cost you hundreds of thousands of dollars to go past one single home. Now that isn't the norm. You know, when you do a unified project across urban areas in particular, fiber may be a fantastic role. But the fact of the matter is, in these areas that aren't covered or don't have good service or unserved or underserved, underserved means they have no competition, there's a reason that they're underserved. It's very expensive to serve them. And in CAF I and in CAF II and in ARDOF, we spent millions of dollars at the FCC level saying fill in those gaps. It's time. Fill in those gaps. Here's this money. And they took that money and went to New York. And they went to San Francisco and they went to Chicago. But they did not go to Little Town USA. Why? It's too darn expensive to go into Little Town USA. So if the mandate today is take funds, give the rural areas and the underserved areas the service that they so desire and so need and so should get, how do you get it there? Well, you can throw money at it. That's number one. You take B, this 42.5, 42.8, I forget the exact number, billion with a B dollars put into that. Okay, that's more dollars than our industry has ever seen. And you do that across all 50 states in tribal territories and our territories. And you say, go states, go tell us how you're going to do this. Because of course, the federal government has a clue. So they're going to give it to the states to say, hey, you know your area, go do it. And the states go, we don't even have a broadband office. We don't have anything except this old economic development. We better hire people quickly. So the federal government said, let's throw $100 million at every state to do planning. That'll take care of the problem. They'll build broadband offices who will solve all of these problems. So we got these wonderful new, very green broadband offices in every state who said, maybe $42.5 billion isn't going to be enough money for this. And they looked at and the federal government looked at unless it's that's more money we ever given you this 25% contributions is $50 billion. How can you not cover all of the states? Well, if you go out there and tell me I have to use fiber, it can cost me $20,000 to go buy Bill's farm. And then John's farm, the next farm over might be $40,000 and so on and so forth. And if I spend all the bead money on there, then I don't have money to do digital equity. And I can't cover the other areas that I have. How am I supposed to do this? Oh, and by the way, we just got done with this silly little health issue called COVID and there's no labor around. And the supply chain comes mostly from China and you put in the in the bead, you got to buy American and you got to use American labor standards and you have to do it by this schedule. And I can't do it because I don't have those products, those products are made in China. And by the way, they cost more because there's now a huge competitive market for them. Those areas that you want to cover, maybe we'll cover them last. Oh, doesn't that sound like art off and calf and so forth. So the object here is, is there RF solutions, which we all know are reliable, which we all know it can be comparable to license, which we all know can be comparable to fiber and complement each other because the Wisp community and the FWA community have nothing against the fiber community. We love the fiber community. Most of us use them for backhaul, even fiber to the home, but we do not have the ability to do that in every location. So CBRS, right? You knew I'd get back to it at some point. CBRS is a band that is in the middle. It's licensed by rule. It has that little licensed word on it. And in the NTIA, they placed a very big emphasis on the ability to use license frequency if you're not using fiber because license is quote, unquote in ear quotes, reliable. Great. At first, we thought that was the giveaway that CBRS was, of course, licensed. It's licensed by rule. The FCC said it's licensed. Panels are clearly licensed. And then the BDC came around. And we changed the way we report to the FCC on what's covered and not covered. And at first, no problem. 70 and 71 are two categories which said, you know, you're either unlicensed or licensed. We jump a little, which category should it be in? But, of course, they should be in 71. It wasn't that entirely clear. So we called up the FCC and said, hey, FCC, where should this license, where should CBRS go? And they said, well, CBRS is like unlicensed. So we're going to put it into the unlicensed sphere. What? You're going to put it unlicensed. It's not unlicensed. It's licensed by rule. And we had this big to do FCC to its credit back down on that issue and said, yeah, you're right. Report it a 71. Report it like it's a licensed frequency. And that was great for two rounds of BDC until the BDC group itself at the FCC said, hmm, we want to get more granular. Let's get more granular. Let's add category 72, which is for GAA. Okay. So if you use GAA, you just reported under 72, and we're good. What does 72 mean? Is 72 licensed? Is 72 meet the NTIA requirements? Because the NTIA and the FCC are not talking to one another on this subject. So we had a big period of time where we're going, you just changed BDC and you threw all these things which we thought was settled into another category. What do we do now? And again, to their credit, the FCC said, go talk to the NTIA. And so we went to go talk to the NTIA and the NTIA finally through Alan Davidson, the chair of this process said, yes, GAA is licensed by rule. It is reliable. It is within the factoring for BD. How many other licensed frequencies do Wisps have that qualify for that? You might have a little 2.5. You might have a little bit of 11 back all. But for the most part, even if you got some secondary market stuff here and there, maybe a power to, you're not going to go out and buy licensed frequency, especially if it's not for your whole network. So this is the only one that you've got that actually is licensed by the politics of the day and works for doing deployments which in fact will protect you from being overbuilt. Because if you deploy CVRS and you meet the 100 by 20 category, 100 up or down and 20 up, you have the ability to provide a network with RF that meets their requirements. We all know that 5.8 and all of the others, especially in rural environments, is providing a 100% reliable product. There's no interference. It's a directed signal. It's in that little midden band area we talked about before. It's pretty and it works. They're not engineers at NTIA, not for the most part. And they take political direction. And when politics collides with policy in Spectrum, you get a nuclear explosion. And that's what we had. So we quashed the nuclear explosion at least with regard to CVRS. And thankfully, you can now deploy CVRS in order to avoid the bead overbuild requirements and participate in bead if you want to. You can go after the funds. That is one method. There are other methods, but that is a really good one for CVRS. And they've codified this or written it down somewhere. So they're probably not apt to change their mind on this six months down the road. There was an opinion by Mr. Davidson's office that was written and provided. So it has been clarified as far as we know. Fantastic. Absolutely fantastic. So, yeah, we've seen a lot of that sort of stuff happening. I think we're going to see a ton more. I think it is important to note people are like, well, SixKig has a system. It's got letters on this AFC thing. So that applies as well. And I think it's important that people understand that, no, that is not the case in SixKig with the AFC. It is not covered by this license by role. It's popped up more than you would think or hope, for sure. It hits me at least once a week and at very high levels. You have to go through an AFC. Therefore, it must be licensed, right? No, it's part 15. It works like license. Therefore, it must be licensed, right? No, it's part 15. Can we change it? No, you can't change it. It's part 15. And so there's the advantages of having an unlicensed spectrum that lets you do things very flexibly the way you want. And there's the disadvantages that it is not a license frequency that can be used with beat. That is not saying it can not be used with beat. 5.8, 6, maybe 5.9, 2.4, 4 gigahertz, 60 gigahertz and all the rest of them can be used if there's an ultra high cost area for which the states plead and say it's too expensive for us to put fiber in everywhere or licensed in everywhere. You can go ahead and make the state make up lead to say allow RF in our mix. Great. 100% dare it. I think there's been a lot of hesitation. There's been a lot of hesitation in the market, not knowing what beat was going to look like, not knowing what the AFC was going to do and what the real world results are when it was going to happen. And honestly, I think a lot of the, you know, AFC has happened in six gigs, a real thing. SAS with CBRS has gotten way cooler than it used to be. Now, especially they're doing these like strength or widening out the heart beats and stuff. So that makes the whole SAS process a lot less onerous. So like really in terms of tools in the toolbox, there's so many options available now. And the bead monster that everyone was terrified of for a long time is not nearly as scary now that there's been a lot more light just shined upon it. So I think, you know, if you're in that hesitation or, you know, bummed out or not sure what to do, honestly, you know, I think there's never been as many tools in the toolbox between the policies, the physics, the spectrum availability and the tech. There's a lot of really cool tech that's coming out that, you know, manufacturers of radio platforms, antennas, so on and so forth have been able to adapt and change and, you know, change some ways, the core ways we're used to doing stuff. So there's been no better time to say, Hey, let's build these networks, let's continue to grow and, you know, get it down the road. Yeah. I mean, and at the end of the day, you know, just because you have coverage with the technology that's licensed by rule or whatever, whatever I mean, doesn't mean that somebody's not going to come in and try and overbuild you anyway. They may not be able to use the beat funds to do that, but there's people with their own money and private equity and, you know, big guys with lots of money in the bank that if they want to come in the area, they're going to come in the area. They just can't use the free government money, you know, to do it, you know, so. Let's be real about something. Wisps have never had to compete against anyone ever, right? Yeah, exactly. There's no competition. No, no, no. Yeah. And some of that non-competition has included AT&T, Verizon, Timo, you know, Comcast, Charter, Cox, Spectrum. We've been doing it for years. All right, systems and 100 other co-ops and 100 other things, right? So the truth is that, yes, this is an obstacle, but, you know, you're fighters, you always have been fighters and it's a big country. And 1990, 2000, 2010, 2015, 2006, it's still not covered. There's still lots of places that are not covered and there's still lots of places that Wisps have been covering for many years where nobody else comes in. Do we fear that Comcast, Charter, Cox, AT&T, Verizon, Timo, whoever it is, even Dish come in? You may come in? Sure. We'll compete. Maybe we'll collaborate. That's what I really love to see. I'd love to see a collaboration between fixed wireless providers and maybe a cable industry who puts down strands and then doesn't do anything beyond a few meters beyond that. You have all this capacity to cover America in much better forms to provide lots of competition. And we are experts at fixed wireless. Why not combine those two? That's my dream. That's Richard's dream. It's been Richard's dream for 10 years. I think it's a viable one. And when I approach the large providers about these things, they always go, oh, that's a good idea. We need to find some way to actually do that. The same way we are sharing spectrum with them now to say, look, you're not covering these clients or maybe your competition is covering those clients. Why not have an inroad into those clients? And at the same time, we want the bands that we argue for, you know, we've talked a lot about six gigahertz in CBRS, but there are lots of other bands. And in those other bands, we want to make sure that there's a competitive play for fixed wireless and that it encourages a robust and efficient ecosystem with lots of tools that come from the manufacturers, including better and better equipment that can give you more and more available space. Amen, amen. We always talk about the private public partnerships with Wisps going to talk to their local governments and stuff like that. As far as this funding, really, you shed some light on that private partnership where Wisps should look at working with some of these larger operators. And like you said, I mean, a lot can be done there. We just have to look at different ways and diversify our business models, not just, you know, what equipment we use and what frequencies we use. So interesting point of view. I like that. One last thought on that. So now that we have six gigahertz and we have CBRS, we have the ability to do more than just to deliver signal to the point of demarcation. The point of demarcation at a home or in a business is a great place. It's where you drop the line from the CPE and you say, I've done my job. You know, a broadband go off and multiply. There's a whole world inside that building. Go do some indoor wireless work. Understand that Wi-Fi is not the only solution. CBRS is now becoming one of the best options for indoor. WAN has existed for years. Go do managed Wi-Fi if you want to indoor, do something inside and beyond the point of demarcation. There are viruses and predators and so forth. Come in and help them with that. Help them with managing the signal in their house or office. If they're an industrial or a commercial group, don't just drop it at the edge of the line. Work with John Deere and understand that their equipment now has Wi-Fi on board. It geofences. It does moisture sensing in the ground. It monitors dairy flow. The geofencing part stops that equipment from leaving or being stolen or changed. It monitors their engine and the oil levels. There are a thousand vertical markets that wisps could be involved with with the types of tools they have today. Think beyond the box. Yeah, exactly. I had somebody in the industry a long time ago, a friend of mine I haven't talked to in a while, but he had mentioned that once and it wasn't on the technical side. He's like, but when I, you know, I do my wisp business, he goes, when I walk into one of my customers' offices, he goes, I look around. I'm like, man, I want to sell them the toilet paper and their thing. I want to sell them the papers for their printers, their toner. He's like, there's so much business that you have access to once you have a foot in the door for a business that you can do. You know, so especially in MDUs and MTEs. You know, you've got these multiple dwelling units, multiple family units, condos, even, even multiple tenant enterprises that are businesses. They're all right there and there's all this opportunity. And maybe selling them toilet paper and printer paper is not the idea because that's probably going a little beyond the scope of what makes your business flow correctly. But selling of the allied services, absolutely. We'll monitor your building. There's security and surveillance that we can do. There's, you know, your toilets are flooding when you're not there. We can monitor that. There's 100,000 things that will relate to the delivery of broadband signal that make the possibilities endless and with more spectrum and with more tools and the ability to use fiber and the ability to get even into the mobile world if you want to provides you with this all-source approach that can make your business more than one-dimensional. Yep. For sure, for sure. Well, guys, we've got a lot of ground on the day. You know, we could, all of us are apt to get on Slopebox and then start going for a bit. We could probably keep on this for hours, but Richard probably got some work to do. Get back banging those drums and getting things done here. So is there anything in closing, you know, closing statement or, you know, other than what you've done? Although I think, you know, I think we summed things up really well. Couple, couple, couple of brief points. One, the tools are out there using. Don't be afraid of them. One of them, yes, you have to use a CPI and CBRS. All that means is that either you get someone certified or you hire somebody who is certified so that they can sign off on the information that's necessary to protect the band. It's not that hard. It's not that expensive. Sousses, for what you need to know, it's not that complicated. And if you have a really bad experience with a sauce, go to another one. You're allowed to change sauces. You're allowed to change equipment. And there's some very exciting things. I can't talk a lot about it, but there's some very exciting things coming in CBRS in the next couple of months that will reduce the impacts of some of the negative things in CBRS. Very, very significantly. Remember I said, do things indoors. Watch for this. CBRS, even in DPA zones indoors, likely going to be a big deal. And 6 gigahertz, I can't say more about how the opportunity you have there. It's like opening or doubling or tripling the spectrum you have. It's using, you know, the new Wi-Fi 7 and Wi-Fi 6E. You have the ability to use these tools, which you never had before. You've got really specialized antennas. You have reasonably priced equipment when you compare it to the carrier's equipment. Go for it. Use it the way you can. Use it and help us at WISPA get more for what you need. If you need backhaul, support us in 10 to 10.5. If you need information on how to use IoT or how to connect yourself in an area, we have resources for that. Avail yourself. A lot of people like to sit around and complain, I do it myself. And there's a lot to complain about. But there's also a lot to be very, very thankful for and a lot to be used. A lot of opportunity. So I beckon upon you, as they did in the old day, go forth and multiply, do something wonderful, do some of this stuff. And I'm fired up. I'm ready to go out and smash. I know, I'm excited. I want to go do something now too. And then anyone looking to get in touch with you, Richard, what's the best way for them to find you? Yeah. Of course, WISPA.org has all of the contacts for WISPA. We have a robust staff that deals with everything from the shows. Join us at WISPA America. Join us at WISPA Losa. Join us on our lobbying days in Washington, DC. Join us with our state effort to try and deal with things at each of the state levels. We have state coordinators for all 50 states. Join us on our technical side. So you can join a group that is involved with the technical matters that you need to learn, or you want to share your information. That's the greatest thing about this industry. Why stay in this industry? We share. We have a collegiality. We compete, but we share. And that is really, really wonderful. Website number one, come to the webinars, number two, come to the events, number three. I'm available. You can reach out to me. People do it every single day. My phone number, I'll give you my phone number. It's not a secret. It's 408-472-0881. You can reach me at R. Bernhardt at B-E-R-N-H-A-R-D-T-C, right there on the bottom. R. Bernhardt at WISPA.org. And I'm happy to talk to you. All right. Toss out a scene. I'm looking for us. Where can they find us? Yeah. You can find us all over on social media, on Facebook, and a lot of the WISPA groups, of course. There's always our website, rfelements.com. You can email us tossos at rfelements.com or Caleb at rfelements.com. And until next time, everyone, go out there, multiply, smash something. Do whatever you got to do. Just do it. Just do something. Get excited. Get motivated. Let's go. Bye, everybody. Use the tools. Yeah. Bye. Bye. See you.