Subject: [NEXTEL-1] Microsoft On- Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band

From: [email-masked]
Date: Tue, 10 Jun 2003 04:24:14 -0400

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C.
In the Matter of
Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band

ET Docket No. 02-380

REPLY COMMENTS OF MICROSOFT CORPORATION

Microsoft believes that robust, reasonably priced broadband networks are essential
to the development of new software, applications, and services that improve
productivity, enrich personal lives, and deliver benefits to every sector of
society. We have often argued that innovative wireless technologies operating in
“unlicensed” bands1 can help make this happen. We have also said that “underlay”
operations could be an important component of tomorrow’s unlicensed broadband
networks – particularly in lower-band spectrum (such as the television broadcast
bands) where longer-distance and through-the-wall transmissions better enable
rural service and the development of mesh networks. Microsoft believes that
examining the technical feasibility of unlicensed operations in the broadcast and
3650 MHz bands is a critical part of theCommission’s broader review of the
nation’s spectrum policy, and therefore supports the Commission’s call for a
robust and expeditious technical analysis of the issue.

A wide range of commenters, including Intel, AT&T, Bluetooth, ITIC, Intersil, the
New America Foundation et al., Shared Spectrum Company, the SDR Forum, and the
Wi-Fi Alliance, all share Microsoft’s views on the potential of unlicensed
wireless technologies. And many share Microsoft’s hope that unlicensed devices may
over time provide an additional broadband choice to some consumers.4 Others have
pointed out that the broadcast and 3650 MHz bands are particularly suitable for
unlicensed use, and that unlicensed devices can coexist with incumbents in those
bands.

Admittedly, not all commenters were so enthusiastic. Some raised concerns that
unlicensed devices might interfere with their operations. Microsoft recognizes
these concerns, and anticipates that a robust and thorough technical analysis will
help address them. It is our expectation that the engineering record will
demonstrate that unlicensed devices can share spectrum with broadcasters, public
safety operations, and other users of the bands.

A handful of other commenters, however, do not raise interference issues; they
just argue that allowing unlicensed underlay operations would be either unlawful
or bad public policy. These commenters are mistaken as a matter of law. And the
market has already demonstrated that they are wrong as a matter of policy.

More:
http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514088183

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