[CWN-Summit] Action Alert on Upcoming FCC Proceeding
Harold Feld
hfeld at mediaaccess.org
Mon Nov 8 15:21:41 CST 2004
Feel free to redistribute. I've tried to come up with a basic summary of
issues for the unlicensed in the broadcast bands proceeding. Although the
deadline is Nov. 30, feel free to file comments earlier if you wish.
Harold
MEDIA ACCESS PROJECT ACTION ALERT
FCC PROCEEDING: UNLICENSED UNDERLAY IN BROADCAST BANDS PROPOSAL TERRIBLY
FLAWED. COMMENTS NEEDED TO SUPPORT CHANGES TO PROPOSED RULES.
Contact: Harold Feld, Associate Director, Media Access Project
hfeld at mediaaccess.org
The FCC has proposed allowing low power unlicensed use in the broadcast
bands. Specifically, the FCC proposes a scheme to allow use of vacant
channels (as defined in the official Notice of Proposed Rulemaking (NPRM))
for low-power unlicensed transmitters.
If done correctly, this could provide a tremendous boost to efforts to
create both commercial and non-commercial wireless networks. The relevant
frequency bands have physical characteristics that make them particularly
valuable for unlicensed access. It takes much less power to send a signal
at these frequencies, and the transmitted signal can penetrate obstacles
that signals at 2.4 GHz or higher will not penetrate. Even very low power
signals in these bands can provide important coverage in urban, suburban,
and rural environments.
But the FCC has not proposed a viable set of rules. The proposed rules
allow television broadcasters, all of whom received their broadcast
licenses for free, to charge fees for access to broadcast spectrum. The
FCC further hobbles the potential for networking through its refusal to
trust the reliability of already proven technologies for interference
control. It therefore requires mitigation measures that will make it
practically impossible for community wireless networks (CWNs) and low-cost
commercial wireless internet service providers (WISPs) to use of the
frequencies.
The proposed FCC rules would:
* Require all devices to accept a command signal from broadcasters,
allowing broadcasters to dictate the ability of any wireless network or
device to access broadcast spectrum. Broadcasters may receive
compensation for this service. This will essentially foreclose community
networks, small ISPs, and transmission of content that competes with
broadcast television. While pilot beacons that signal when spectrum is
or isnt available may become a valuable tool for allowing greater access
to public spectrum, the FCC proposal places all the power in the hands of
the broadcasters.
* Require all devices using broadcast spectrum to transmit an ID
beacon containing the owners personal contact information. While
intended to allow broadcasters to find sources of interference, this would
also allows any thief or hacker access into your laptop, PDA, or other wifi
enabled device. Again, while ID beacons may help foster increased public
access in some circumstances, the FCCs proposal as written raises serious
concerns.
* Require professional installation for any non-portable device used
for networking. This requirement would impose a heavy burden on volunteer
community wireless networks, particularly those communities for which
English is not a first language.
* Mandate GPS location technology, an expensive form of location
technology, rather than permit cheaper alternatives.
The flaws in the FCCs proposal derive from a combination of timid vision
by the agency and a failure to understand the realities driving unlicensed
networking. Public comment on relevant issues can persuade the agency to
correct the problems in the proposal.
MAP asks on all individuals and organizations interested in the deployment
wireless networks to file comments with the FCC. MAP urges interested
parties to tell the FCC:
* Broadcasters, who have received their spectrum licenses for free on
condition that they serve the public interest, should not have the power to
tax wireless networks by imposing access fees.
* Broadcasters should have no ability to control access to public
spectrum, particularly where broadcasters have an interest in controlling
the nature of public access.
* The FCC does not create access rules to benefit broadcasters, but to
protect the viewing public from harmful interference with free, over the
air television. The FCC should rely on technologies that place control in
the hands of users such as reliance on dynamic power and frequency
controls rather than protect broadcasters from competition.
* The FCC should not mandate ID beacons for portable devices. This is
an invitation to identity theft, security breaches or worse. Nor does it
address any interference issues. No single laptop or PDA is going to
interfere with a licensee.
* The FCC should not require professional installation of unlicensed
devices. This imposes an unfair burden on community wireless networks,
small WISPs, and non-English speakers.
* The FCC should not mandate specific technologies. For example, it
should not require GPS, but should instead require that all devices
demonstrate an ability to know its precise location and change its
behavior accordingly.
Anyone can file comments at the FCC. Even if the comment and reply comment
deadlines have passed, 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. At the same time, the FCC does not just count
noses. A comment that just reads AI like unlicensed@ or Adon=t just give
spectrum to greedy broadcasters, give it to the people@ doesnt help as
much as something more detailed. Most important are comments that provide
either technical information or real world experiences that underscore the
value of unlicensed wireless access.
A copy (PDF) of the FCCs Notice of Proposed Rulemaking is
available at:
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-113A1.pdf>http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-113A1.pdf
The docket number for the proceeding is ET 04-186.
How To File Comments
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). 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.
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
04-186 (ignore the letters that designate which bureau has
jurisdiction). 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
A Style Guide For Drafting Comments 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
can. 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.
Give details- 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 wifi, try to put details in the comments that relate the
particular proceeding to your experience. For example, if you are a
business, discuss the economic impact of unlicensed access and how you
would benefit from expanding unlicensed access. If you are an community
volunteer, discuss how community wireless networks have improved your
community.
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 Stay Involved
You can always check how a docket is going by clicking to the FCC=s ECFS
search page: http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi. As with
filing a comment, enter the docket numbers as 04-186. Comments will appear
in chronological order, with the most recently filed comment at the top.
Media Access Project, New America Foundation, Free Press, and the Champaign
Urbana Wireless Internet Network will continue to update their websites
with new information on this issue. The relevant websites are:
MAP: http://ww.mediaaccess.org
NAF: http://www.spectrumpolicy.org.
Free Press: http://www.freepress.net/wifi/
CUWIN: <http://www.cuwireless.net/>http://www.cuwireless.net
In addition, the Washington Internet Project (http://www.cybertelecom.org)
is a good resource for FCC proceedings that relate to internet issues
before the FCC, including unlicensed access.
Harold Feld writes a blog about wireless issues (among other things)
called Tales of the Sausage Factory hosted at www.wetmachine.com.
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