Subject: [NEXTEL-1] Commentary by Laura Smith, ITA: Chaos Happens

From: [email-masked]
Date: Wed, 23 Jul 2003 19:17:48 -0400

Chaos Happens…

By Laura Smith
President, CEO
Industrial Telecommunications Association

July, 2003

It takes a true baseball fan to study the precision and drama of the battle
between the pitcher and the batter. But let’s face it, everybody loves the
free-for-all that occurs when that brush back pitch bounces off the batter’s
shoulder and the benches clear. Come to think of it, aren’t we all at least a
little bit thrilled when the players commence to beat one other to a pulp on the
ice during a hockey game? Mayhem? Bloodshed? Or, just your typical hockey game? My
favorite example of chaos, though, has to be the demolition derby. Cars furiously
bashing into one together with no single direction . . . no lanes . . . no
precision . . . and sometime no survivors. Just complete and utter chaos! 

It was chaos on the airwaves that Congress sought to avoid when it created the FCC
in 1931. They understood that spectrum was valuable and, unless properly
regulated, would end up useless. We’ve certainly undergone quite a few changes
since then. Not the least of which are the changes in what used to be the
Telegraph Division, which began regulating wireline, cable and radiotelegraph
services in the early 30’s. But one thing has not changed in all these years;
interference and the problems it causes to organized communications. As a
frequency coordinator, ITA fights the battle against the chaos of interference
every day, searching for the clearest frequencies possible for each private
wireless user.

When the Spectrum Policy Task Force released its findings late in 2002, I could
sense that the Commission had jumped on yet another bandwagon. Similar to what
happened in a previous administration where spectrum auctions were seen as the
be-all end-all, the FCC now is on a course to transition existing spectrum subject
to command-and-control regulation (you know . . .private wireless) to the “more
flexible exclusive use and commons models to the greatest extent possible.”

What is most disturbing about the report is that, while the FCC supports an
“integrated” approach, the Task Force only exempts public safety and the
broadcasters from its regulatory transition. No mention is made of private
wireless. 

One of the follow-ups to this report is the Commission’s proceeding to facilitate
the provision of fixed and mobile broadband access, educational and other advanced
wireless services in the 2500-2690 MHz bands. Now, I want to emphasize that we
believe unlicensed spectrum provides valuable opportunities for both our end user
and radio dealer members. And we will support this measure to increase fixed and
mobile broadband access. Just look at last month’s Private Wireless cover story! 

The problem that I see is the tendency for the FCC to choose a new spectrum policy
and charge in that direction. It’s like they are searching for a “killer-app”
policy that will solve all of their regulatory policy woes. Before this, spectrum
auctions were the silver bullet, and I think we all agree (even FCC officials
quietly concur) that spectrum auctions work fine in certain circumstances but were
implemented too broadly, culminating in the Nextwave debacle. Today, the buzz at
the FCC is allocating more spectrum for unlicensed use, opening up current
allocations for unlicensed, secondary users and in the future eliminating all
licensing in favor of technologies that “grab” unused frequencies in any band on
the spectrum.

What I am asking the Commission officials to do is to take their time on this
issue and think very carefully through all the possible repercussions and
ramifications of this policy direction. If they take this approach, I believe they
will see many potential pitfalls in a whole sale unlicensed use approach. From a
frequency coordinator’s standpoint, I have to ask the question, how do you
regulate in an unlicensed environment? Can anyone do whatever they want with the
spectrum? What if you have three organizations, each with applications that are
equally critical and important but are not compatible for sharing the same
channels? (Did we learn nothing from the 800 MHz debacle?)

My message to the FCC – unless proper regulation is maintained on America’s
airwaves, you will have a potentially explosive interference situation on your
hands. You will have people being thrown off the air, disrupting the operations of
corporations and public safety agencies. Law enforcement, emergency personnel and
firefighters use radios for their lifeline. There are also lives at stake when an
airliner comes in for a landing, when an oil barge docks, when a chemical plant
has an incident. If an unlicensed user overruns the radio system, how do these
public safety agencies or the private wireless users keep their people safe? More
importantly, how do they keep the public safe? 

What happens when you mix licensed and unlicensed services and don’t control the
possibility of interference? I’ll tell you what happens; absolute chaos happens!

Laura can be reached via telephone at (703) 528-5115 or email LSmith @
ita-relay.com

http://www.ita-relay.com/

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