for those following such stuff.
marlon
----- Original Message -----
From: New America Foundation
To: undisclosed-recipients:
Sent: Thursday, February 01, 2007 4:28 PM
Subject: New America and Allies Submit FCC Comments Proving Case for Unlicensed
Access to Unused TV Channels
New America and Allies Submit Comments to FCC Proving Case for Unlicensed
Access to Unused TV Channels
Yesterday, New America with Media Access Project and allies (NAF, et al.) filed
comments in the FCC's proceeding to open up the unused channels ("white space")
in the prime frequencies of the TV band to unlicensed use for broadband and
wireless innovation (Docket 04-186). NAF, et al., have filed numerous sets of
comments in this proceeding since it was initiated in 2004. The proceeding,
stalled at the FCC for almost two years, was re-activated in October after the
Senate Commerce Committee unanimously adopted a bill (reintroduced this month
by Sens. John Kerry and Gordon Smith) to require the FCC complete the
rulemaking and open the "vast wasteland" of TV white space for unlicensed,
wireless broadband and innovation.
Our new comments authoritatively address two overriding issues: First, claims
made by the TV broadcast industry that unlicensed devices operating in unused
TV channels would interfere with TV reception and other licensed uses of the TV
band; and second, whether the TV white space spectrum should be exclusively
licensed instead of unlicensed.
NAF, et al. filed three sets of comments yesterday:
Economic/Legal Comments
We challenge the FCC's re-opening of the issue of whether or not to license the
TV white space, given its prior decision and an indisputable record in favor of
an unlicensed approach. The comments summarize the tremendous and still
rapidly increasing social and economic benefits of unlicensed spectrum,
including more affordable and ubiquitous broadband - particularly in rural
areas - home and enterprise networking, wireless device and service innovation,
and more. The comments explain why licensing is both impractical and
inadvisable in this band. We argue that the interference-avoidance mechanisms
proposed in the FCC's original 2004 rulemaking are sufficient-along with
specific technical parameters to be developed by the FCC-to protect licensed TV
band users. Full comments available at:
http://www.newamerica.net/publications/resources/2007/economic_legal_comments_on_further_notice_of_proposed_rulemaking_for_unlicensed_access_to_tv_white_s
Technical Comments
Our Technical Comments, drafted by NAF technical advisor and prominent former
FCC engineer Michael Marcus, address further technical issues that have arisen
since the original 2004 comment period. These technical comments address the
specific concerns and confusion propagated by the broadcast lobby with respect
to the interference potential of unlicensed devices. They summarize the
results of two engineering studies commissioned by NAF making an irrefutable
empirical case for why unlicensed devices can both sense TV broadcast signals
AND avoid causing interference. One of these studies, examining the potential
for unlicensed devices to use cognitive radio sensing to detect and avoid
occupied TV channels, was filed as an appendix to the Technical Comments. This
White Space Sensing Study is available on our website here. Full comments
available at:
http://www.newamerica.net/publications/resources/2007/technical_comments_on_further_notice_of_proposed_rulemaking_for_unlicensed_access_to_tv_white_spaces
Final Results of University of Kansas TV White Space Interference Study
NAF, et al. also filed the results of an unlicensed device interference study,
commissioned by NAF and conducted at the University of Kansas IT labs, proving
irrefutably that portable and low-power unlicensed devices can operate in empty
TV channels without causing interference with television viewing on other
channels. Full comments and study available at:
http://www.newamerica.net/publications/resources/2007/final_results_of_university_of_kansas_tv_white_space_interference_study
Thanks as always for your time and attention to these important issues.
Best wishes,
Michael Calabrese
Vice President and Director, Wireless Future Program
New America Foundation
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