[CWN-Summit] Recent Washington Developments

[Harold Feld]

Time for me to call in some five minutes. :-)

Reply comments were due in the 365-3700 proceeding last Friday.  To refresh 
your memory, this proceeding offers to open the 3650-3700 MHz band to 
unlicensed access.  The FCC proposes 20-watt "high power" devices that 
would require professional installation (how to certify a "professional 
installer" is one of the questions in the proceeding). It also proposes 
mobile devies of 1-watt.  Both sets of devices will be required to have 
dynamic power and frequency modulation to avoid interference with licensees.

So far, only two sets of replies have been filed -- that of Intel and that 
of the Satellite Industry Association (SIA).  I suspect more will be posted 
and that these two represent those who filed electronically (hard copy 
filings take a few days to get scanned and posted).  Others (like MAP) may 
not have had a chance to get stuff on paper yet owing to summer vacations.

Both Intel and SIA promote use of this space for licensed, rather than 
unlicensed, access.  Notably, Both point to the lack of response b y the 
unlicensed access community and the number of parties who filed in favor of 
licensing the band.

Now this is something of a crock, since we had NYC Wireless, CUWIN and 
Dandin Group (Dewayn Hendricks shop) on our comments, along with Consumer 
Fed. of America (50 million members through their individual organizations) 
and a host of others.

But this is what I was talking about in CU.  Our silence has impact as well 
as our speech.  How can we tell Congress that people really want this stuff 
when there is basically one set of comments?

I would urge everyone to take five minutes and file now in this 
proceeding.  Go to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi.

Then fill out the form.  The docket number is 04-151.  In the space marked 
"file brief comment," please say who you are and that access to this space 
for both high power and low power mobile devices would be very useful.  If 
you feel like it, please explicitly endorse the issues raised in by 
NYCWireless, et al.  We objected to the professional installer requirement 
and the inclusion of identity beacons in mobile devices.  The NYCWireless 
comments should be at the MAP and NAF websites.

Because the IEEE 802.18 Committee has submitted comments suggesting that 
this band be reserved exclusively for high-power point-to-point links, I 
would urge those who feel strongly about low power mesh networks to discuss 
the importance of low power as well as high power.

If you have some pre-existing materials in Word or PDF or WordPerfect, you 
can include them as an attachment.   If you want to write lengthy comments 
and submit them, write them in one of these formats, then submit as an 
attachment.

If you want to see what else has been filed in the proceeding, so you can 
reply to these comments, follow this link.
http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi  and plug in the docket 
number (04-151).

Technical comments explaining the value of unlicensed and rebutting 
licensees would be enormously helpful.

In other news, the unlicensed access in the broadcast bands proceeding 
(04-186) has been delayed 90 days.  The new deadline for filing is November 
30.  An analysis of this is at my blog, Tales of the Sausage Factory, 
hosted at http://www.wetmachine.com
If you are interested in helping us get comments ready for this proceeding, 
please let me know.

On money: I may have some deployment money through the Dept. of Housing and 
Urban Development (HUD) program on university and community 
partnerships.  This is only available to organizations that are partnered 
with any institute of higher education (community colleges, 4 years 
colleges, and universities) partnered with community groups.  But it can be 
worth a few hundred grand over several years.  I have some connections 
inside the program.  Contact me if interested.

On IP Address Space:  Let me know if you are willing to join an ARIN 
policymaking process on this issue.  I can make some introductions, but 
people involved in deployment need to make the case.  Please be advised 
that my experience with open policy processes in the Name/Numbering space 
is that they require a significant investment of time to make work.

That's it from D.C. for now.

Harold