[CWN-Summit] Now at Risk: FCC Decision Freeing 3650-3700 MHz Spectrum

[Stephen Ronan]

As most of you know, back in March, the FCC made an innovative
and helpful decision to open up a new band of spectrum for
community wireless folks and others to use: the 3650 to 3700 MHz
band. The plan was for there to be an unlimited number of
licensees throughout the country, with an easy online application
process, no eligibility restrictions to speak of, and with all  
licensees having a mutual obligation to cooperate and avoid
harmful interference to each other. That band is currently used
for Fixed Satellite Stations and they would continue to use it in
and near their facilities which are mostly on the East and West  
Coasts, and exclusion zones around those facilities would prevent
much of any usage nearby. For that reason, some coastal cities,  
such as New York, Philadelphia and the Bay Area would not benefit
much if at all from the new rules, but the great majority of the
geographic area of the country including rural areas would
benefit and many major metropolitan areas such as Albuquerque,
Atlanta, Austin, Boston, Chicago, Cleveland, Columbus, Detroit,
Houston, Kansas City, Las Vegas, Milwaukee, New Orleans, Oklahoma
CIty, Phoenix, San Antonio, and Tucson.

A map on page 66 of the FCC's Order clarifies the areas that are
outside of the FSS exclusion areas.

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-56A1.pdf>

The power limits and other aspects of that FCC decision would
make it much easier for free and low-cost networks to be deployed
that could reach greater distances, with radio signals carrying
broadband Internet access through walls and ceilings and other
obstacles more effectively than low-power WiFi devices. More
detail here:

<http://makeashorterlink.com/?N13563D8B>

Unfortunately, after the decision was issued, there was a time
period for those opposing the decision to file a Request for
Reconsideration and nine parties have done so including some,
such as Intel and Motorola, who are asking for there to be severe
restrictions on who can use the spectrum. Rather than opening it
up for anyone to use, Motorola is requesting that the 50 MHz of
spectrum be divided into two 25 MHz blocks with each auctioned
off to the highest bidder. Intel and a couple of others signed
another petition calling for all that spectrum also to be divided
among two exclusive licensees in most major metropolitan areas
such as the ones listed in the first paragraph above. And the
Wireless Communications Association called for half the 50 MHz of
spectrum to be made available to just one exclusive licensee in
each rural and urban area that isn't already excluded by the
presence of Fixed Satellite Stations.

The filing of the Petitions for Reconsideration and their
availability for review was published in the Federal Register
July 27, setting off a fifteen day period for opposition to the
Petitions for Reconsideration to be filed. Those comments are due
by August 11 (there still may be an opportunity to file comments
"ex parte" after that but it's better for them to arrive before
the deadline if possible).

I hope you will consider filing at least a brief comment
thanking the FCC for their original decision to open up
the spectrum for nonprofit community groups and all
others to share while committing to not interfere with each
other's networks, and in your comment opposing the attempt to
instead have much or all of the spectrum auctioned off to the
highest bidder.

You can review previous comments that have been filed, including
the Petitions for Reconsideration at the FCC web site by entering
04-151 in the search bar in the top left corner at www.fcc.gov.

See how easy it is to file a comment...
just enter 04-151 in the proceeding number here:

<http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi>

complete the brief form, selecting Reply to Petition for
Reconsideration in the drop down box at the bottom, and then
either upload your comment or type it into the text entry box...

Just a couple of paragraphs identifying your and/or your
organization's interest in equitable access to technology,
thanking the FCC for opening up the spectrum for uses that can
bridge the digital divide, and then opposing the idea that the
rights to the spectrum would instead be auctioned to the highest
bidder would be a huge help.

            - Steve Ronan