Broadband Wireless Internet Access Weblog : Steve Stroh's commentary on significant developments in the BWIA industry
Updated: 8/6/2002; 9:46:18 AM.

 

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Saturday, July 06, 2002

On June 6, 2002, the FCC announced the formation of the Spectrum Policy Task Force, with the mission of:

  • Provide specific recommendations to the Commission for ways in which to evolve the current "command and control" approach to spectrum policy into a more integrated, market-oriented approach that provides greater regulatory certainty, while minimizing regulatory intervention.
  • Assist the Commission in addressing ubiquitous spectrum issues, including, interference protection, spectral efficiency, effective public safety communications, and implications of international spectrum policies.

As part of the SPTF's mission, it released a survey with a number of daunting questions about what the the public and the communications industry think FCC's spectrum policies should be - a golden opportunity to provide input directly to the heart of the FCC. To date, the number of comments has been surprisingly light, but the way the "game of initial comments to the FCC" is played is that the big industry players submit their comments at the very last moment so that other commenters don't have the chance to reference (and pre-emptively respond to) the comments of the big industry players.

A number of the survey questions deal with the possibility of allocating additional license-exempt spectrum and many other issues. Replies to the Survey are due by the end of Monday, July 8th (left unsaid is what constitutes the official "end of the day" for this filing - 00:00 UTC, midnight EDT, etc) - if you're going to reply, get it in by early evening on the 8th. Replies can be submitted via email using the FCC's Electronic Comment Filing System (ECFS). To get filing instructions for e-mail comments, commenters should send an e-mail to ecfs@fcc.gov, and should include the following words in the body of the message, "get form <your e-mail address>." A sample form and directions will be sent in reply.

Offering my insights to the FCC in response to this survey is how I'll be spending the majority of my holiday weekend. Thank goodness for laptops, comfortable outdoor chairs, and wireless LANs (for which we have to thank those who went to the effort long ago to goad the FCC into crafting the regulatory framework so that Wireless LANs, and all that flowed from them, could exist.)

Replies and followups to the initial comments are due by July 23, 2002.

Update 7/10/2002

To date, there have been 148 comments filed on FCC Proceeding 02-135. Mine is here, where I argue that spectrum allocation should be converted to a license-exempt model with radios that have "embedded spectrum allocation rules". On July 9th (the day after the due date) there were 142 - apparently the FCC is still permitting comments to be filed. A few of these errata and updates. One veteran of many such comment periods was a bit too much on autopilot and filed his comments with the cover page from a 2000 comment period :-) The comments are all over the map; I haven't had time yet to read more than a few. One company with extensive spectrum holding says everything's great, just let us use our spectrum however we want.

One of the very best comments I've read to date was Timothy J. Shepard Ph.D.'s four page comment. I've met Tim (I'm proud to say he's a fellow Amateur Radio Operator) and he's a very bright guy who can explain advanced communications ideas in ways that are relatively easy to understand. Tim's 02-135 comment is no exception - it begins "Imagine 100,000 people go to a football stadium" and goes on to explain that if we used the same logic as the FCC spectrum regulations, talking at football games would need to be tightly regulated to insure that everyone got an equal chance to use some of the scarce 3 KHz of audio spectrum that humans are equipped to use. Shepard's paper is highly recommended reading.

One thing I noted was that the comments that took the longest to download were from companines that seemed to have the most legal staff. When the FCC receives a comment on paper (and virtually the only ones that do so now are law practices; everyone else seems to file electronically), FCC staff immediately scan it and convert it to a .PDF file... a big .PDF file.


3:14:39 PM    


© Copyright 2002 Steve Stroh.



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