Fwd: [Imc-wireless] FCC - NYCw call to action

Forwarded material follows.  Response deadline Thurs. Oct. 23d.

Seattle area activists also should attend the CPSR meeting at
Discovery Park, this saturday Oct 25th from 8:30am-7:00 pm
having many nationally recognized experts on telecom. policy.
http://www.cpsr.org/conferences/annmtg2003/index.html

Todd Boyle CPA  9745-128th Ave NE Kirkland WA 98033
425-827-3107 - http://www.ledgerism.net/
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Date: Tue, 21 Oct 2003 13:15:51 -0400
From: denis <denis@xxxxxxxxxx>
To: imc-wireless@xxxxxxxxxxxxxxxxxxx
List-Subscribe: <http://lists.indymedia.org/mailman/listinfo/imc-wireless>

Subject: Fwd: FCC - NYCw call to action
From: Anthony Townsend <anthony.townsend@xxxxxxx>
Date: Tue, 21 Oct 2003 11:52:27 -0400
To: "Urban Technology & Telecommunications" <telecom-cities@xxxxxxxxxxxxxx>

Begin forwarded message:

From: dgoody <nospam-nycw@xxxxxxxxxxxxxxx>
Date: Mon Oct 20, 2003 6:46:24 pm America/New_York
To: nycwireless@xxxxxxxxxxxxxxxx
Subject: [nycwireless] FCC - NYCw call to action

As you may recall NYCwireless took it's first major policy action
by signing onto FCC comments authored by the New America
Foundation and the Media Access Project that support making more
unlicensed spectrum available. Specifically these comments oppose
action by the FCC to give away spectrum within the ITFS band that
was originally allocated for educational broadcast to the cellular
industry.

http://lists.nycwireless.net/pipermail/nycwireless/2003-September/007608.html

Remember the wireless revolution would not be possible without the
existing unlicensed band where 802.11b technology operates.
Unfortunately this band is getting more and more crowded with
applications and users. Additional spectrum will be required in
the near future to keep the wifi revolution going. Individuals
should have equal access to the airwaves not just huge
corporations. The frequency spectrum is a common good that belongs
to all Americans and should not be given away to rich
telecommunication companies. Giant corporations already control
access to television networks, don't let this happen to the rest
of the spectrum. If the coalition of private interests behind the
proposed changes to the ITFS/MDS band get their way it will result
in huge give away of valuable spectrum to the cellular industry
and a historic opportunity to provide more unlicensed spectrum
will be missed.

Individuals within NYCw need to take action to make all of our
voices heard by the FCC. The best way for the NYCw community to
make a difference is for everyone to file comments individually on
the FCC website. The following is the short form of the
instructions, read the directions written up by the Media Access
Project below to find out more about the process. It's is best if
your write a paragraph or two explaining how unlicensed spectrum
(the spectrum used by Wifi) has had a positive impact on your
life, your business or your community.

The process (short form)

1. Surf to http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

2. Fill in the relevant info and the Docket No. is 03-66. This is
important you MUST list the docket no.

3. Let the FCC know that you feel the best use of the ITFS/MDS
spectrum if for unlicensed usage. Anecdotal stories about the
benefits of unlicense spectrum/wifi has had on your life will make
your comments stand out.

- Dustin -

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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