[Cu-wireless] FCC call to action re: wireless spectrum.

Tue Oct 21 14:10:45 CDT 2003

FYI: please comment (directions below):

Date: Tue, 21 Oct 2003 13:15:51 -0400
From: denis <denis at riseup.net>
Subject: [Imc-wireless] FCC - NYCw call to action
To: imc-wireless at lists.indymedia.org
Message-ID: <3F9569C7.3080500 at riseup.net>
Content-Type: text/plain; charset=windows-1252; format=flowed

------------------------------------------------------------------------

Subject:
Fwd: FCC - NYCw call to action
From:
Anthony Townsend <anthony.townsend at nyu.edu>
Date:
Tue, 21 Oct 2003 11:52:27 -0400

To:
"Urban Technology & Telecommunications" <telecom-cities at forums.nyu.edu>

Begin forwarded message:

> From: dgoody <nospam-nycw at voipexperts.com>
> Date: Mon Oct 20, 2003 6:46:24 pm America/New_York
> To: nycwireless at freenetworks.org
> Subject: [nycwireless] FCC - NYCw call to action
>
> As you may recall NYCwireless took it's first major policy action by
> signing onto FCC comments authored by the New America Foundation and
> the Media Access Project that support making more unlicensed spectrum
> available. Specifically these comments oppose action by the FCC to
> give away spectrum within the ITFS band that was originally allocated
> for educational broadcast to the cellular industry.
> (http://lists.nycwireless.net/pipermail/nycwireless/2003-September/
> 007608.html)
>
> Remember the wireless revolution would not be possible without the
> existing unlicensed band where 802.11b technology operates.
> Unfortunately this band is getting more and more crowded with
> applications and users. Additional spectrum will be required in the
> near future to keep the wifi revolution going. Individuals should have
> equal access to the airwaves not just huge corporations. The frequency
> spectrum is a common good that belongs to all Americans and should not
> be given away to rich telecommunication companies. Giant corporations
> already control access to television networks, don't let this happen
> to the rest of the spectrum. If the coalition of private interests
> behind the proposed changes to the ITFS/MDS band get their way it will
> result in huge give away of valuable spectrum to the cellular industry
> and a historic opportunity to provide more unlicensed spectrum will be
> missed.
>
> Individuals within NYCw need to take action to make all of our voices
> heard by the FCC. The best way for the NYCw community to make a
> difference is for everyone to file comments individually on the FCC
> website. The following is the short form of the instructions, read the
> directions written up by the Media Access Project below to find out
> more about the process. It's is best if your write a paragraph or two
> explaining how unlicensed spectrum (the spectrum used by Wifi) has had
> a positive impact on your life, your business or your community.
>
> The process (short form)
> 1. Surf to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
> 2. Fill in the relevant info and the Docket No. is 03-66. This is
> important you MUST list the docket no.
> 3. Let the FCC know that you feel the best use of the ITFS/MDS
> spectrum if for unlicensed usage. Anecdotal stories about the benefits
> of unlicense spectrum/wifi has had on your life will make your
> comments stand out.
>
> - Dustin -
>
> 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.
>

---
You are currently subscribed to telecom-cities as:
chuck.sherwood at verizon.net
To unsubscribe send a blank email to
leave-telecom-cities-149811M at forums.nyu.edu

To set DIGEST mode and only receive one list message per day with all
the daily traffic, please visit the list website at
http://www.informationcity.org/telecom-citie

------------------------------

_______________________________________________
Imc-wireless mailing list
Imc-wireless at lists.indymedia.org
http://lists.indymedia.org/mailman/listinfo/imc-wireless

End of Imc-wireless Digest, Vol 5, Issue 3
******************************************