Subject: [NEXTEL-1] Addition Info On- Coalition Urges FCC to Open More Spectrum for Unlicensed PublicAccess]

From: [email-masked]
Date: Mon, 15 Sep 2003 12:05:01 -0400

Addition Info On- Coalition Urges FCC to Open More Spectrum for Unlicensed
PublicAccess

-------- Original Message --------
From: dgoody <[email-masked]>
Subject: Coalition Urges FCC to Open More Spectrum for Unlicensed PublicAccess

NYCwireless is proud to support this effort to provide additional 
spectrum for unlicensed use. Many thanks to the New America Foundation 
and the Media Access Project for drafting these comments. Below I have 
included the press release from New America and a summary of the 
recommendations contained in the comments.

Dustin Goodwin
Broadband Policy
NYCwireless

--

Press release from New America 9/9/2003:

Coalition Urges FCC to Open More Spectrum for Unlicensed Public Access

On Monday a coalition of public interest groups and wireless community
networks filed formal Comments to the FCC urging the Commission to open
underused spectrum for unlicensed citizen access -- an action that would
provide rural and underserved communities with more affordable access to
wireless broadband Internet connections.  The coalition responded to
FCC-proposed changes to the large band originally allocated to nonprofit
institutions for Instructional Television Fixed Service (ITFS) and to
private firms for commercial video services (MMDS).  Although ITFS
licensees originally were awarded license rights in exchange for
providing educational services, the band has been vastly underused and
the FCC has allowed licensees to lease out most of the spectrum to
private firms.  The FCC-proposed rule changes would reduce the spectrum
available for education and encourage educational licensees to sell
their licenses to private companies, effectively ending the educational
obligations associated with the band.

In order to preserve and expand the noncommercial benefits of the ITFS
band, the coalition urged the Commission to reallocate one half of the
entire ITFS/MDS band (90 MHz) for unlicensed public access on a primary
basis.  This portion of the band would be located at 2.5 GHz, directly
adjacent to the 2.4 GHz band currently used by WiFi services. Current
educational applications that need to relocate would be reimbursed by
spectrum revenue or by fees manufacturers would collect on WiFi-type
equipment.   Alternatively, the coalition recommends that a band
equivalent to the current ITFS allocation (120 MHz) be preserved for
educational uses on a primary basis, but opened for unlicensed sharing
to maximize unlicensed citizen access. The coalition also opposed
allowing licensees to sell spectrum they never paid for, urging instead
that any auctions return revenue to the public.

The full Comments are located at
http://www.newamerica.net/Download_Docs/pdfs/Pub_File_1350_1.pdf. Other
groups signing the comments include Consumers Union, Consumer Federation
of America, the New America Foundation, Media Access Project, the Benton
Foundation, Center for Digital Democracy, and Public Knowledge.  Also
joining the coalition are wireless community access networks
NYCwireless.org, Seattlewireless.net, and the Bay Area Wireless User
Group (BAWUG.org) and wireless ISPs Roadstar Internet Services, of
Northern Virginia, and Emenity, Inc., of New York City.

--

Summary of recommendations found in the comments:

• The proposed re-banding and grant of new flexibility rights to ITFS
and MDS licenses should include a reallocation of approximately half the
total band (90 MHz) for unlicensed public access on a primary basis;
this can be done while protecting licensee’s reasonable expectations to
the services and transmission capacity under their license, and any
relocation to the upper portion of the band can be funded by makers of
unlicensed equipment and/or from auction proceeds by asking Congress to
extend the pending Spectrum Relocation Trust for relocating federal users.

• Alternatively, a band equivalent to the current ITFS allocation (120
MHz) should be preserved for education on a primary basis, but opened to
maximize unlicensed citizen access as an underlay, subject to
non-interference with existing ITFS applications; this underlay should
include both unlicensed access to the unassigned “white space” on a
primary basis, but also opportunistic access of unlicensed communication
using unused or underutilized capacity within licensed geographic
service areas across the entire ITFS/MDS band.

• If the Commission decides to reallocate or reassign license rights on
the band, any auction mechanism must comply with the statutory goals and
restrictions of the Communications Act, which the proposed “two-sided”
giveaway auction decidedly does not, as it diverts federal revenue from
the Treasury to private parties; a genuine auction where potential
licensees bid in terms of the annual user fee would best optimize the
various policy goals of the Act.

• The ITFS allocation should be maintained as noncommercial public
service spectrum; the Commission should retain the ITFS eligibility
requirements and should require increased noncommercial public service
requirements in return for the free use of spectrum and increased
flexibility to provide valuable data networking services.

• If the Commission determines that unlicensed public access to the band
– on an underlay or primary basis – is feasible and desirable, it should
refrain from imposing a private intermediary between citizens and
license exempt spectrum; a retreat from the open access Part 15 model
that is characteristic of the WiFi band (2.4GHz), as suggested by the
NPRM, would undermine First Amendment values, as well as the goals of
innovation and competition favored by the Communications Act.

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