Excellent points Marlon. I support your view.
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message -----
Sent: Monday, September 25, 2006 2:14 PM
Subject: [WISPA] Fw: NAF comments on NTIA converter box subsidy program

Hi All,
I got this right before walking out of the office today.  And it's due by 5 pm eastern.
I talked to Jim S. on the phone and told him that he can put WISPA down as a supporter.  I'll try to file some reply comments tomorrow.
Here's the Reader's Digest version I got from Jim on the phone.  The DTV transition has to happen by 2009.  There's 1 BILLION $ out there for set top converters for people that still have analog TVs.  The issue is, how good do the receivers in the converters have to be?  The New America Foundation has written up a case for good receivers as a requirement rather than ones that would, by default, screw up the white spaces issue.
So WISPA is officially onboard with the attached doc from New America.
If anyone has any additional thoughts they need to be talked out today so I can file something for us tomorrow.  Unless someone else wants to take this ball and run with it....
Here are MY thoughts.  For those that remember the Cirrus radio debate, I see this as the same thing.  For those that don't remember, the short version is that Cirrus wanted the FCC to shut down about half of the 2.4 gig band due to interference with their 2.3 gig sat radio service.  The FCC told them that it was their own fault that they build such crappy receivers.
I think we should file comments reminding the people of this and extol the virtue of taking this opportunity to free up some currently wasted spectrum for the greater public good.
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----- Original Message -----
From: Jim Snider
Sent: Monday, September 25, 2006 10:38 AM
Subject: NAF comments on NTIA converter box subsidy program

Dear colleagues:


I am asking you to sign on to the attached NAF et al. comments in the NTIA’s DTV converter box NPRM.  Comments are due at 5pm today.  New America's Naveen Lakshmipathy is coordinating the sign on effort.


For close to a generation telecom policy analysts have argued that the TV broadcast band was extremely inefficiently utilized and that parts of it should be reallocated for more efficient uses.  Congress and the FCC have engaged in two sets of activities to minimize the opportunity cost of this inefficient use.  First, the FCC has introduced a Notice of Proposed Rulemaking—and the Senate Commerce Committee has passed legislation to require the FCC to complete this Rulemaking—opening up the white spaces between TV channels 2 and 51 for unlicensed use.  Second, Congress has required that TV broadcasters return 108 MHz of spectrum, TV channels 52 to 69, at the end of the digital TV transition, which must be complete by February 18, 2009.


This NPRM has a direct bearing on both of these goals.  First, the quality of the converter boxes it mandates affects the utility of the whites spaces within TV channels 2-51.  Second, the design of the of the converter box subsidy it mandates will affect whether those currently dependent on analog TV sets can transition to digital
TV with minimal disruption, the raison d'etre for the converter box subsidy and a goal Congress has deemed essential for completing the return of TV channels 52-69. 


This set of comments argues that 1) the NTIA should ensure that the converter boxes have high quality receivers so white space spectrum is not wasted, and 2) the NTIA should make it as easy as possible for consumers to acquire and redeem the converter box coupons.


--Jim Snider


J.H. Snider, Ph.D.
Research Director, Wireless Future Program
New America Foundation
1630 Connecticut Ave., NW
Washington, DC 20009
Phone: 202/986-2700
Fax: 202/986-3696
Web: www.newamerica.net
My Book Website: speaksoftly.jhsnider.net
My Personal Blogs: jhsnider.net/telecompolicy jhsnider.net/citizensassembly


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