This is fantastic first step, but now individuals within NYCw need to take the next step on this important piece of FCC regulation. If the coalition of private interests get their way it result in huge give away of valuable spectrum to the cellular industry and a historic opportunity to provide more unlicensed spectrum will be missed.
The best way for the NYCw community make difference is for everyone to file comments individually on the FCC website. Here is the short form of the instructions read the directs written up by the Media Access Project below to find out how to do it properly. It's is best if your right a paragraph or two about how unlicensed spectrum (the spectrum used by Wifi) has had positive impact on your life, your business or your community
1. Surf to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
2. Fill in the relavent info and the Docket No. is 03-66.
3. Let the FCC know that you feel the best use of the spectrum under consideration is for it to be used for unlicensed application. Good to give story as to positive impact of unlicensed spectrum.
Increasing Public Access to Unlicensed Spectrum By Harold Feld, Associate Director, Media Access Project Copyright 2003 to Media Access Project. Released under the Creative Commons BY License
An obscure proceeding at the Federal Communications Commission (FCC) may hold the key to the next evolution in unlicensed wireless services. For the first time, the FCC has proposed dedicating a significant amount of spectrum to unlicensed access on a primary basis. This means that users within the new unlicensed band would not have to worry about whether they interfered with a protected service. Even better, the proposed band includes spectrum immediately adjacent to the existing 2.4 GHz underlay. The existing unlicensed underlay in the 2.4 GHz band has spurred vast amounts of telecommunication innovation and investment; increasing the available bandwidth will reward those who have developed this technology and spur further growth and wider deployment. If the FCC approves the proposal, the benefits to unlicensed wireless technologies would be enormous.
At the same time, however, the FCC has also proposed auctioning the rights to an unlicensed underlay. This proposal, if accepted, would entirely defeat the purpose of unlicensed access. Worse, it would set a negative precedent that could severely limit the expansion of unlicensed wireless access.
The FCC needs to hear from all users and supporters of unlicensed wireless access in support of allocating the relevant band for primary unlicensed access. This document provides background, general guidelines, and instructions for how to file at the FCC. It is not intended as a form letter or sign on petition. The FCC needs to hear the stories of people using unlicensed access and who are eager to take this technology to the next level of deployment and innovation. However, as described below, anyone with Internet access can file comments at the FCC.
Background
On April 2, 2003, the FCC released a “Notice of Proposed Rulemaking,” or NPRM. A NPRM is an agency proposal to change existing rules. By law, a federal agency must give the public a chance to see proposed rule changes and to file comments on these changes. The FCC usually has a deadline to file comments and a deadline to file replies to these comments. In addition, however, members of the public can continue to file comments even after these deadlines.
This NPRM goes by the rather lengthy name “Amendment of Parts 1, 21, 73, 74 and 101 of the Commission’s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Educational and Other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands.” It’s Docket Number is WT 03-66. This information will be important later. The NPRM discusses a proposal by certainly licensees to restructure the Multipoint Distribution Service (MDS) and Instructional Fixed Television Service (ITFS).
While this sounds extremely boring and technical – and in many ways is – the essence of the NPRM is a question: What do we do with a huge band of spectrum covering from 2500 MHz to 2690 MHz. Those familiar with spectrum will recognize this as prime spectrum with excellent propagation characteristics. Furthermore, importantly for unlicensed access aficionados, it sits practically adjacent to one of the existing unlicensed bands (2400 MHz). At the moment, this spectrum is parceled into exclusive licenses that are required to offer fixed point-to-point two way communication on either a commercial basis (MDS service) or non-commercial educational basis (ITFS).
Under the current rules, none of the licensees can really exploit the potential of the band. The original rules for the service date back to the 1970s, and the efforts by the FCC to fix these rules over the years to make the spectrum productive have created a confusing patchwork of licenses rights.
So the FCC wants to reorganize the band to make better use of the spectrum. The current MDS and ITFS licensees have proposed a restructuring plan which would, unsurprisingly, benefit the existing licensees. The existing licensees would enjoy total flexibility and would be allowed to reorganize themselves to offer mobile as well as fixed services.
To its credit, the FCC has asked whether others could benefit from this reorganization. Specifically, the FCC has proposed creating a band dedicated exclusively to unlicensed use. NPRM 79-81. The FCC also proposed extending the existing unlicensed rules (also known as “Part 15” rules, for their location in the FCC’s rules) to include the 2500-2690 range. 143-148.
The effect of either proposal on unlicensed access would be enormously beneficial. Even if the FCC merely extended the Part 15 rules, it would help overcome many congestion issues and help avoid interference with other devices. Creating a significant band devoted exclusively for unlicensed without the fear of interfering with a licensed “primary” service would open the door to a whole new range of products and services.
At the same time, the FCC also proposed allocating the spectrum to exclusive licensees. Worse, it proposed “auctioning” the right to a Part 15-style underlay. Such an auction would defeat the value of unlicensed and would set a bad precedent for future spectrum restructuring.
The New America Foundation/Media Access Project Comments
The New America Foundation (NAF) and the Media Access Project (MAP) drafted and submitted comments that supported both the creation of a primary unlicensed band and the extension of the Part 15 rules. The NAF/MAP comments also contained other material relating to auctions and other issues raised in the NPRM. Copies of the NAF/MAP comments are available from both the NAF website (www.spectrumpolicy.org) or on the MAP website (www.mediaaccess.org).
A number of parties joined the comments. Most importantly, the comments were joined by wireless ISPs eager to see expansion of wireless access.
No other party in this proceeding filed in favor of expanding unlicensed access. Many parties filed against the proposal.
While the FCC does not decide policies solely by counting noses, it does look to see if there is interest in expanding unlicensed access in the relevant band. At the moment, the record does not reflect support for expanding unlicensed wireless access.
How You Can Help
Anyone can file comments at the FCC. Reply comments are due on October 23, 2003. But interested parties can continue to file comments using the procedure outlined below.
Contrary to popular belief, the FCC really does read public comments and really does care about them. Most important are comments filed that provide either technical information or real world experiences that underscore the value of unlicensed wireless access. In particular, if you are a WISP, a WISP subscriber, or some other business user of unlicensed access, the FCC will be very interested in your comments.
A Style Guide For Posting To The FCC
Be polite- The staff at the FCC are real people with human feelings. They do not appreciate hearing that they are morons or losers or corrupt servants of special interests. If you abuse them, they will disregard your comments. That’s just human nature.
Explain yourself- Many of the people who will read your comments are not engineers or are engineers unfamiliar with the specific issues you describe. If you assume an audience generally familiar with the issues but with no technical training, you will probably hit the right level. At the same time, do include complex technical or economic information where you have to. This is important in building the record. If you have lengthy technical comments, try having a plain English summary at the beginning followed by technical comments. Make sure you explain all acronyms.
Be personal- The FCC needs to hear about real world experiences in the field. Even if you are just a general supporter of unlicensed access services such as wi-fi, try to make the comments personal.
In particular, if you are a business, discuss the economic impact of unlicensed access and how you would benefit from expanding unlicensed access.
While there is no page limit (some filings are hundreds of pages long), try to stick to essentials. A shorter document will be given preferential treatment by staffers than a longer one that says the same thing. This is simply human nature.
How To File Comments
The FCC will accept written comments in Word, WordPerfect, or PDF format. You can also type in short comments directly to the FCC on its comments webpage at:
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi. In other words, anyone with Internet access can file a comment just by going to the FCC’s webpage and typing in the window provided (scroll down to the bottom of the page).
If you write comments, you should include at the top the name of the proceeding and the Docket No. You must also include in the written comments the date of filing, your name, and an address where you can be reached. You do not need to be a lawyer, or even a U.S. citizen, to write or file comments before the FCC.
When you go to file your comments, the docket number should be entered as 03-66 (ignore the “WT”). The FCC’s webpage is relatively self-explanatory about what information is required and how to attach any files. At the end of the process, you will receive a confirmation from the FCC that your comments were filed. You may wish to print this out and save it for your files.
You may view other comments in this proceeding by using the FCC’s Electronic Comment Filing System (ECFS) search function available at:
http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi Again, the relevant docket Number is 03-66.
How To Stay Involved
NAF and MAP will continue to update their websites with new information. The NAF website is http://www.spectrumpolicy.org. The MAP website is http://www.mediaaccess.org. In addition, the Washington Internet Project (http://www.cybertelecom.org) is a good resource for FCC proceedings that relate to unlicensed access.
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