Fwd: Airwaves Update: NAF et al. Coalition FCC Reply Comments on Proposed Giveaway of Educational Spectrum

Begin forwarded message:

> From: "Michael Calabrese" <Calabrese@xxxxxxxxxxxxxx>
> Date: October 26, 2003 1:07:49 PM PST
> To: "Michael Calabrese" <Calabrese@xxxxxxxxxxxxxx>
> Subject: Airwaves Update: NAF et al. Coalition FCC Reply Comments on Proposed Giveaway of Educational Spectrum
>
> We thought you would be interested in the FCC Reply Comments in the high-stakes ITFS/MDS proceeding that we filed Thursday on behalf of an increasingly diverse coalition of WISPs (e.g., AMA TechTel, Roadstar), community access networks (e.g., NYCwireless, BAWUG, Rockwood PA school district) and national consumer/user groups (e.g., Consumers Union, Consumer Federation of America).  The list of groups signing on is below, just after the 5 key summary points.  
>
> Our proposal is that 90 of the total 190 MHz now allocated to ITFS/MDS should be reallocated (as part of the band's reorg) to create a new, dedicated unlicensed band at 2.5 GHz -- immediately adjacent to the 2.4 band where WiFi thrives. Although we defended the concept of the spectrum set-aside for education (ITFS - which has 120 of the band), it is clear the FCC is disposed to reallocate much of it -- but likely to auction licenses for "flexible" advanced (3G/4G) wireless services.
>
> Unfortunately, we are still outnumbered by incumbent licencees claiming (falsely) that ANY unlicensed access creates intolerable interference and even that it is ILLEGAL for the FCC to allow unlicensed access to spectrum! (e.g., the comments of Stanford and Northeastern Universities repeat this extreme claim that previously had been made only by Cingular).
>
> It is not too late to add comments to the docket; they might not have court standing, but could influence the Commission. Please do!
>
> Michael Calabrese
> --------------------------------------------------------------------------------------------------------------------------
> Reply Comments (filed 10/23/03):
> http://www.newamerica.net/Download_Docs/pdfs/Pub_File_1390_1.pdf
>
> Comments (9/8/03):
> http://www.newamerica.net/Download_Docs/pdfs/Pub_File_1350_1.pdf
>
>
> NAF et al.'s Comments emphasize the following general points:
>
> * 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.
>
> -----------------------------------------------------------------------------------------------------------------
> Commentors in this proceeding fall into three broad categories: commercial providers of
> wireless services using unlicensed spectrum access; non-profit users of unlicensed spectrum
> access using unlicensed access to promote education, broadband deployment, free expression, and
> narrow the digital divide; and users of licensed and unlicensed wireless services.
>
> AMA*TechTel Communications is a large regional provider of unlicensed wireless
> broadband Internet, serving more than 4,000 residential and business customers in West Texas.
> In addition to wireless Internet service, AMATechTel also provides Dial-up, ISDN, DSL, T1, and
> VPN services, as well as long distance and phone and messaging systems.
> http://www.amatechtel.com/
>
> Rockwood Area School District, Somerset County, Pennsylvania is a rural school district
> in southern Pennsylvania that has built an unlicensed wireless infrastructure for their elementary
> and high schools that also supports broadband connections for residences and businesses in the
> community.
>
> NYCwireless: NYCwireless serves as an advocacy group for wireless community networks
> providing free, public wireless Internet service to mobile users in public spaces throughout the
> New York City metro area. These public spaces include parks, coffee shops, and building lobbies.
> NYCwireless also works with public and nonprofit organizations to bring broadband wireless
> Internet to underserved communities. http://www.nycwireless.net
>
> Emenity, Inc.: Eminity builds custom-designed, fully outsourced local wireless networks for
> private and public organizations. Emenity is based in New York City and has field offices in San
> Francisco, Los Angeles, Boston, and Washington, DC. Emenity designed the Lower Manhattan
> Wireless Network, a public wireless network built for the Alliance for Downtown New York.
> http://www.emenity.com
>
> Roadstar Internet, Inc.: Roadstar is a wireless Internet service provider serving Loudoun
> County, Virginia. Roadstar has over 100 business and residential subscribers to their wireless
> broadband Internet network, relying solely on license-exempt spectrum.
> http://www.roadstarinternet.com
>
> Bay Area Wireless User Group: BAWUG was founded to promote broadband wireless
> Internet within the greater San Francisco Bay Area. BAWUG was started by radio engineers and
> enthusiasts to provide technical and organizational support for wireless users and developers of
> access points. http://www.bawug.org
>
> The Bay Area Research Wireless Network: BARWN.org has built free public wireless
> networks in the San Francisco Bay Area with the goal of researching and developing the most
> cost efficient technologies and network designs to provide under-served communities with
> wireless broadband Internet. http://www.barwn.org
>
> SeattleWireless.net: SeattleWireless is a not-for-profit effort to develop a wireless
> broadband community network. SeattleWireless uses widely available, standards-based RF
> technology operating in license free frequency, to create a free, locally owned wireless Internet
> backbone. http://www.seattlewireless.net
>
> NewburyOpen.net is an open WI-FI network that provides high-speed Internet services, in
> the form of free wireless and for-pay workstations, to Boston residents, workers, and travelers.
> NewburyOpen.net is a testbed for new business models, technologies, and applications-all
> revolving around the idea of the ubiquitous Internet. http://www.newburyopen.net
>
> NoCat is a nonprofit community-supported 802.11b wireless network in Sonoma County, CA. They
> provide software, information and technical support to unlicensed wireless users and network and
> access point developers at their web site: http://nocat.net/
>
> New America Foundation: NAF is a nonpartisan, non-profit public policy institute based in
> Washington, D.C., which, through its Spectrum Policy Program, studies and advocates reforms to
> improve our nation's management of publicly-owned assets, particularly the electromagnetic
> spectrum. http://www.newamerica.net
>
> Media Access Project: MAP is a 30 year-old non-profit, public interest telecommunications
> law firm which represents civil rights, civil liberties, consumer, religious and other citizens
> groups before the FCC, other federal agencies and the Courts. http://www.mediaaccess.org/
>
> Consumers Union: CU, publisher of Consumer Reports, is an independent, nonprofit testing
> and information organization serving only consumers. http://www.consumersunion.org
>
> Consumer Federation of America: CFA is the nation's largest consumer advocacy group,
> composed of two hundred and eighty state and local affiliates representing consumer, senior,
> citizen, low-income, labor, farm, public power and cooperative organizations, with more than
> fifty million individual members. http://www.consumerfed.org/
>
> The Center for Digital Democracy: CDD is a nonprofit public interest organization
> committed to preserving the openness and diversity of the Internet in the broadband era, and to
> realizing the full potential of digital communications through the development and
> encouragement of noncommercial, public interest content and services.
> http://www.democraticmedia.org/
>
> Public Knowledge: PK is a public interest advocacy organization dedicated to fortifying and
> defending a vibrant information commons. PK works with wide spectrum of stakeholders to
> promote the core conviction that some fundamental democratic principles and cultural values -
> openness, access, and the capacity to create and compete - must be given new embodiment in the
> digital age. http://www.publicknowledge.org
>
> The Benton Foundation: The Benton Foundation's mission is to articulate a public interest
> vision for the digital age and to demonstrate the value of communications for solving social
> problems. http://www.benton.org
>
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