Subject: [NEXTEL-1] FCC - NYCw call to action

From: [email-masked]
Date: Fri, 17 Oct 2003 16:40:59 -0400

-------- Original Message --------
From: dgoody <[email-masked]>
Subject: FCC - NYCw call to action

As you may recall NYCwireless took there first major policy action by 
signing onto FCC comments that support making more unlicensed spectrum 
available. 
(http://lists.nycwireless.net/pipermail/nycwireless/2003-September/007608.html)

This is fantastic first step, but now individuals within NYCw need to 
take the next step on this important piece of FCC regulation. If the 
coalition of private interests get their way it result in huge give away 
of valuable spectrum to the cellular industry and a historic opportunity 
to provide more unlicensed spectrum will be missed.

The best way for the NYCw community make difference is for everyone to 
file comments individually on the FCC website. Here is the short form of 
the instructions read the directs written up by the Media Access Project 
below to find out how to do it properly. It's is best if your right a 
paragraph or two about how unlicensed spectrum (the spectrum used by 
Wifi) has had positive impact on your life, your business or your community

1. Surf to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
2. Fill in the relavent info and the Docket No. is 03-66.
3. Let the FCC know that you feel the best use of the spectrum under 
consideration is for it to be used for unlicensed application. Good to 
give story as to positive impact of unlicensed spectrum.

Increasing Public Access to Unlicensed Spectrum
By Harold Feld, Associate Director, Media Access Project
Copyright 2003 to Media Access Project.
Released under the Creative Commons BY License

	An obscure proceeding at the Federal Communications Commission (FCC) 
may hold the key to the next evolution in unlicensed wireless services. 
  For the first time, the FCC has proposed dedicating a significant 
amount of spectrum to unlicensed access on a primary basis.  This means 
that users within the new unlicensed band would not have to worry about 
whether they interfered with a protected service.  Even better, the 
proposed band includes spectrum immediately adjacent to the existing 2.4 
GHz underlay.  The existing unlicensed underlay in the 2.4 GHz band has 
spurred vast amounts of telecommunication innovation and investment; 
increasing the available bandwidth will reward those who have developed 
this technology and spur further growth and wider deployment.  If the 
FCC approves the proposal, the benefits to unlicensed wireless 
technologies would be enormous.

	At the same time, however, the FCC has also proposed auctioning the 
rights to an unlicensed underlay.  This proposal, if accepted, would 
entirely defeat the purpose of unlicensed access.  Worse, it would set a 
negative precedent that could severely limit the expansion of unlicensed 
wireless access.

	The FCC needs to hear from all users and supporters of unlicensed 
wireless access in support of allocating the relevant band for primary 
unlicensed access.  This document provides background, general 
guidelines, and instructions for how to file at the FCC.  It is not 
intended as a form letter or sign on petition.  The FCC needs to hear 
the stories of people using unlicensed access and who are eager to take 
this technology to the next level of deployment and innovation. 
However, as described below, anyone with Internet access can file 
comments at the FCC.

Background

On April 2, 2003, the FCC released a “Notice of Proposed Rulemaking,” or 
NPRM.  A NPRM is an agency proposal to change existing rules.  By law, a 
federal agency must give the public a chance to see proposed rule 
changes and to file comments on these changes.  The FCC usually has a 
deadline to file comments and a deadline to file replies to these 
comments.  In addition, however, members of the public can continue to 
file comments even after these deadlines.
This NPRM goes by the rather lengthy name “Amendment of Parts 1, 21, 73, 
74 and 101 of the Commission’s Rules to Facilitate the Provision of 
Fixed and Mobile Broadband Access, Educational and Other Advanced 
Services in the 2150-2162 and 2500-2690 MHz Bands.”  It’s Docket Number 
is WT 03-66.  This information will be important later.  The NPRM 
discusses a proposal by certainly licensees to restructure the 
Multipoint Distribution Service (MDS) and Instructional Fixed Television 
Service (ITFS).
While this sounds extremely boring and technical – and in many ways is – 
the essence of the NPRM is a question: What do we do with a huge band of 
spectrum covering from 2500 MHz to 2690 MHz.  Those familiar with 
spectrum will recognize this as prime spectrum with excellent 
propagation characteristics.  Furthermore, importantly for unlicensed 
access aficionados, it sits practically adjacent to one of the existing 
unlicensed bands (2400 MHz).  At the moment, this spectrum is parceled 
into exclusive licenses that are required to offer fixed point-to-point 
two way communication on either a commercial basis (MDS service) or 
non-commercial educational basis (ITFS).
Under the current rules, none of the licensees can really exploit the 
potential of the band.  The original rules for the service date back to 
the 1970s, and the efforts by the FCC to fix these rules over the years 
to make the spectrum productive have created a confusing patchwork of 
licenses rights.
So the FCC wants to reorganize the band to make better use of the 
spectrum.  The current MDS and ITFS licensees have proposed a 
restructuring plan which would, unsurprisingly, benefit the existing 
licensees.  The existing licensees would enjoy total flexibility and 
would be allowed to reorganize themselves to offer mobile as well as 
fixed services.
To its credit, the FCC has asked whether others could benefit from this 
reorganization.  Specifically, the FCC has proposed creating a band 
dedicated exclusively to unlicensed use. NPRM  79-81. The FCC also 
proposed extending the existing unlicensed rules (also known as “Part 
15” rules, for their location in the FCC’s rules) to include the 
2500-2690 range.  143-148.
The effect of either proposal on unlicensed access would be enormously 
beneficial.  Even if the FCC merely extended the Part 15 rules, it would 
help overcome many congestion issues and help avoid interference with 
other devices.  Creating a significant band devoted exclusively for 
unlicensed without the fear of interfering with a licensed “primary” 
service would open the door to a whole new range of products and services.
At the same time, the FCC also proposed allocating the spectrum to 
exclusive licensees.  Worse, it proposed “auctioning” the right to a 
Part 15-style underlay.  Such an auction would defeat the value of 
unlicensed and would set a bad precedent for future spectrum restructuring.

The New America Foundation/Media Access Project Comments
The New America Foundation (NAF) and the Media Access Project (MAP) 
drafted and submitted comments that supported both the creation of a 
primary unlicensed band and the extension of the Part 15 rules.  The 
NAF/MAP comments also contained other material relating to auctions and 
other issues raised in the NPRM.  Copies of the NAF/MAP comments are 
available from both the NAF website (www.spectrumpolicy.org) or on the 
MAP website (www.mediaaccess.org).
A number of parties joined the comments.  Most importantly, the comments 
were joined by wireless ISPs eager to see expansion of wireless access.
No other party in this proceeding filed in favor of expanding unlicensed 
access.  Many parties filed against the proposal.
While the FCC does not decide policies solely by counting noses, it does 
look to see if there is interest in expanding unlicensed access in the 
relevant band.  At the moment, the record does not reflect support for 
expanding unlicensed wireless access.
How You Can Help
Anyone can file comments at the FCC.  Reply comments are due on October 
23, 2003.  But 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.  Most important are comments filed that 
provide either technical information or real world experiences that 
underscore the value of unlicensed wireless access.  In particular, if 
you are a WISP, a WISP subscriber, or some other business user of 
unlicensed access, the FCC will be very interested in your comments.

A Style Guide For Posting 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 you have to.  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.

Be personal-  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 wi-fi, try to make the comments personal.
	In particular, if you are a business, discuss the economic impact of 
unlicensed access and how you would benefit from expanding unlicensed 
access.

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 File Comments
	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.  In other words, 
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).

	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 03-66 (ignore the “WT”).  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  Again, the relevant 
docket Number is 03-66.

How To Stay Involved
	NAF and MAP will continue to update their websites with new 
information.  The NAF website is http://www.spectrumpolicy.org.  The MAP 
website is http://www.mediaaccess.org.  In addition, the Washington 
Internet Project (http://www.cybertelecom.org) is a good resource for 
FCC proceedings that relate to unlicensed access.

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