Subject: [NEXTEL-1] Intel's View On Spectrum

From: [email-masked]
Date: Wed, 15 Oct 2003 00:56:39 -0400

Before the FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of  Amendment of Parts 1, 21, 73, 74 and 101 of the  WT Docket No.
03-66 Commission.s Rules to Facilitate the Provision  ) RM-10586 Fixed and Mobile
Broadband Access, Educational  and Other Advanced Services in the 2150-2162 ) and
2500-2690 MHz Bands

Part 1 of the Commission.s Rules . Further   WT Docket No. 03-67 Competitive
Bidding Procedures
Amendment of Parts 21 and 74 to Enable  MM Docket No. 97-217
Multipoint Distribution Service and the
Instructional Television Fixed Service
Amendment of Parts 21 and 74 to Engage in Fixed
Two-way Transmissions

Amendment of Parts 21 and 74 of the ) WT Docket No. 02-68 Commission.s  Rules with
Regard to Licensing in  ) RM-9718 the Multipoint Distribution Service and in the
Instructional Television Fixed Service for the Gulf
of Mexico

COMMENTS OF INTEL CORPORATION

I. INTRODUCTION AND SUMMARY
Intel Corporation hereby submits this comment in response to the above referenced
Notice of Proposed Rulemaking. Intel is the world.s largest semiconductor
manufacturer and a leader in technical innovation. Intel is also a leading
manufacturer of communications and networking chips and equipment.

Intel believes that the current regulatory regime for Multichannel Multipoint
Distribution Service (MMDS) and the Instructional Fixed Service (ITFS) in the 2500
to 2690 MHz band is impeding the deployment of efficient new technology that could
enable valuable new uses such as wireless broadband access.  The impetus behind
this rulemaking is the .Coalition. proposal of the Wireless Communications
Association International, Inc. (WCA), the National ITFS Association (NIA) and the
Catholic Television Network (CTN) to revise the MMDS and ITFS rules. Intel
recommends the Commission adopt a two-step approach that implements many of the
reforms proposed by the Coalition, but complement them with a 2-sided auction or
.simultaneous exchange..

a.  Current Problems

This band is currently used for one-way video services, even though its use for
two-way broadband services would likely be far more valuable.  As discussed below,
the development and success of Wi-Fi and other wireless broadband technologies
suggest that such uses could be highly valuable. But, as the Coalition stated in
its original proposal, the current licensing regime is precluding MMDS and ITFS
licensees from taking advantage of next generation broadband technology.1 It
maintained the existing regulatory regime creates several obstacles to such
innovation including:

 Adoption of new broadband technology would require numerous applications that
would create substantial administrative burdens and delays.  ?  Professional
installation and notice requirements and other restrictions impede the retail
distribution of MMDS/ITFS services.
 Overly preclusive interference protection rules effectively prevent operators
from offering ubiquitous coverage for non-stationary devices such as laptops.

1 WCA, NIA & CTN, A Proposal For Revising the MDS and ITFS Regulatory Regime,
October 7, 2002, p.7
The current interleaved band plan precludes broadband service unless the adjacent
interleaved channel licensee agrees.2 Additionally, private efforts to move the
spectrum to new more highly valued uses are made difficult by the site licensing
of the ITFS spectrum which has left unassigned areas or .white spaces. and by
ill-defined interference rights that frustrate the ability of parties to reach
negotiated settlements.

b.  Proposed Reforms

In this rulemaking the Commission proposes a wide range of reforms that would:
Modify rules to facilitate deployment of next generation, low power systems that
can serve non-stationary devices such as laptops,

Establish a new band for isolating high power, one-way systems from low power,
two-way systems, Propose the use of a simultaneous exchange as a mechanism for
transitioning
from the old to the new band plan, and Remove regulatory underbrush.

In its original comment on the Coalition proposal, Intel supported the proposed
reforms, but recommended that the Commission consider complementing them with
staff analysis and recommendations contained in the Spectrum Policy Task Force and
OPP Working Paper No. 38. 4 In this comment, Intel recommends that the Commission
adopt a two-step approach. First, it should implement the Coalition.s (or a
similar) deinterleaved band plan. Then it should hold an auction of the white
space areas in the ITFS spectrum. The white space areas should be licensed on a
national overlay basis. There should be no limits on eligibility. If an incumbent
ITFS licensee turns in its license that license area should become part of the
overlay license.

Intel also believes that Commission should consider structuring the ITFS auction
as a simultaneous exchange along the lines discussed in the NPRM. A simultaneous
exchange could serve as non-coercive way of moving spectrum to higher valued uses
by a date certain and in a way that would substantially reduce the transaction
costs of aggregating and disaggregating spectrum by frequency and area.

II. BENEFITS OF WIRELESS SERVICES AND BROADBAND ACCESS
Reforming the 2500 to 2690 MHz band of spectrum could generate enormous consumer
benefits.  As noted above, the Coalition has stated that current regulatory regime
is impeding the use of this band for potentially valuable wireless broadband
service.  As demonstrated by the rapid growth of Wi-Fi, such wireless services are
highly valued in the marketplace and if this spectrum is reformed, it is uniquely
situated to meet valuable longer distance wireless broadband needs.

The marketplace and technical success of Wi-Fi illustrate the benefits from
wireless broadband service.  Wi-Fi is the name that the Wireless Ethernet
Compatibility
Alliance (now the Wi-Fi Alliance) gave to the wireless standards collectively
known as
802.11 . defined by the Institute for Electrical and Electronic Engineers (IEEE).
Wi-Fi
devices operate today in the 2.4 and 5 GHz unlicensed bands.

The pace of Wi-Fideployment and the expansion of Wi-Fi product lines have been
impressive. Although
802.11 products did not begin shipping in significant volume until 1999, the
growth has
been staggering.  Sales have increased from 7.9 million wireless LAN chipsets in
2001 to
a projected 23-25 million chipsets in 2002, according to Allied Business
Intelligence.5
The 2500 to 2690 band could be used to provide additional wireless broadband
services that could both compete with and complement Wi-Fi and other broadband
services. A group similar to the Wi-Fi Alliance has formed Wi-MAX (Worldwide
Interoperability for Microwave Access Forum), a non-profit organization of leading

equipment and component manufacturers who are promoting wide-scale deployments of
point to multipoint wireless networks.  The leading Wi-MAX technology (known as
802.16) can serve subscribers up to 30 miles away, thus benefiting customers who
cannot
gain access to broadband connectivity due to topographical limitations. Wi-MAX
could
also complement 802.11 by providing .backhaul. to hot spots, especially those not
served by cable or DSL.  Wi-Fi and Wi-MAX technologies could work together to
deliver seamless wireless service to all locations, including remote/rural areas
and in
developing countries.  802.16 wireless broadband technology could provide shared
rates
up to 70 Mbps, which could serve several business and home subscribers using a
single
sector in a base station. This band could also be used for other new wireless
broadband
technologies

In sum, the success of Wi-Fi technology demonstrates that there is considerable
demand for wireless broadband technology and the promise of WiMax technology on
the
this spectrum band for use as a longer distance wireless broadband access service

5 http://www.alliedworld.com/prhtml/wlic03pr.pdf.html

 For example, in December 2002 the IEEE established the 802.20 Mobile Wireless
Access (MBWA)
Working Group.  This goal of this new standard would aim to .enable worldwide
deployment of
affordable, ubiquitous, always-on and interoperable multi-vendor mobile broadband
wireless access
networks that meet the needs of business and residential end user markets..
http://grouper.ieee.org/groups/802/20/  Applications of this type of service would
include: mobile and
suggests that reforming this spectrum could generate enormous consumer benefits
particularly in underserved areas.

III. ANALYSIS AND RECOMMENDATIONS
Intel believes that this rulemaking can achieve significant reform that would
promote efficient use of this spectrum so that the industry may deploy innovative
technology.  Intel recommends the Commission adopt the reforms proposed by the
Coalition, but consider complementary reforms. As discussed below, we believe the
Commission should consider a two-step approach that would keep the efficiency and
voluntary advantages of the Coalition proposal but which would provide more
marketplace certainty and reduce the transactions costs of moving this spectrum to
higher valued uses.

a.  The Coalition Proposal.s Strengths

The Coalition proposal has several strengths. First, it .de-interleaves. both the
MMDS and ITFS licenses. By separating the low and high power bands, it will
facilitate the deployment of portable and mobile two-way data services. Second, it
proposes a mechanism for transitioning to the restructured band plan, albeit on a
market by market basis. Third, it proposes the assignment of geographic overlay
licenses, thus providing for greater technical flexibility and the assignment of
.white spaces..

b.  The Coalition Proposal.s Weaknesses

The proposal also has important weaknesses. The proposed market-by-market
transition does not establish a firm deadline for restructuring this band and it
entails
ubiquitous Internet access, transparent support of Internet applications and
access to enterprise intranet
services. http://grouper.ieee.org/groups/802/20/P_Docs/IEEE%20802.20%20PD-04.pdf,
p. 5
7 substantial transaction costs that could discourage aggregation and
disaggregation of spectrum by frequency and area. Indeed, this approach could lead
to a prolonged uncertain transition. Such marketplace uncertainty could increase
the risk of investments that require a substantial upfront commitment and whose
success requires national reach.  The evolution of the cellular market structure
to six national carriers has demonstrated that there can be enormous benefits in
achieving a national scope. As we have discussed, Wi-MAX (802.16) is a promising
two-way data service technology, but it could be much more useful if is reliably
available nationwide so that users may roam freely from location to location
without losing connectivity. Also, long lead times exist for research and
development of new technologies. Greater certainty on how much and when this
spectrum will become available for new uses would create a more attractive
environment for innovation and investment.

c.  The Commission Should Implement A Two-step Approach

Intel recommends the Commission adopt a two-step approach that implements many of
the reforms proposed by the Coalition, but complements them with a simultaneous
exchange as discussed in OPP Working Paper No. 38 and proposed in the NPRM.
First, the Commission should adopt the Coalition.s (or a similar) deinterleaved
band plan. The market by market transition plan proposed by the Coalition should
be kept as a default.

Second, and before the actual change in licenses in accordance with the new band
plan, the FCC should hold an auction of the white space areas in the ITFS
spectrum. The white space areas should be licensed on a national overlay basis.
There should be no 8 limits on eligibility. Excluding non ITFS eligibles would
unnecessarily limit the benefits to be achieved from new uses of this spectrum.
If an incumbent ITFS licensee turns in its license that license area should become
part of the overlay license.  The Commission should consider structuring the ITFS
auction as simultaneous exchange along the lines discussed in the NPRM. A
simultaneous exchange could serve as non-coercive way of moving spectrum to higher
valued uses by a date certain and in a way that would substantially reduce
transaction costs of aggregating and disaggregating spectrum by frequency and
area. It would also help establish a more certain marketplace which would be more
conducive to investment in longer distance, wireless broadband services such as
Wi-MAX.
IV. CONCLUSION
For the reasons and in the manner stated above, Intel supports reforming the MMDS
and ITFS regulatory regime, because it would serve the larger public interest by
fostering more highly valued use of this spectrum.

Respectfully submitted,

INTEL CORPORATION
By: /s/ Peter Pitsch
Peter K. Pitsch
Jamie P. Estrada
Intel Government Affairs
1634 I ST, N.W. Suite 300
Washington, DC 20006
(202) 628-3838

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514882287

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