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It's Time to Log on to the FCC

A wireless industry veteran and pioneer calls on fellow WISPs to file comments with the FCC. "You don't have to hire a lawyer, or go to Washington. Just e-file!" If you're in the office this weekend, now's the perfect time.

by Dave Hughes [July 2, 2004]

On the ISP-Wireless list in June, Dave Hughes posted a call to arms to Wireless ISPs (WISPs):

Reference why WISPers should Electronically File Comments with the FCC

There is a perfect example, in play right now. Jim Taylor on this list (the Motorola vs. WISP thread) named four Docket Numbers WISPs should file on. He said "It's important for all of us to file comments on ET Docket Nos. 04-186, 02-380 & 04-151."

[ed. note: you can also view the comments that have already been filed on 04-186 (14 comments as of this morning), 02-380 (155 comments as of this morning), and 04-151 (17 comments as of this morning).]

I looked at and grabbed 04-151 this afternoon, and saw that only 10 comments had been filed on it—8 of them just the legally required 'notice' that company personnel had met with FCC staffers while this action is live (called Ex Parte comments), and only two with substance (one objecting from the 'Coalition of C-Band Constituents' who do not want the NPRM making 3650-3700Mhz 'unlicensed' because they say it will interfere with the licensed specialized satellite services.)

Then Item #11 was posted there (with two 'Views' (photo reproduction of the original documents) by the FCC itself, which, in 43 pages in the first 'View' (you click on) spells out the complete NPRM. Everything you want to know about this item is there for the reading. And in the second 'View' summarizes the rule in about one page.

And what is the 'Proposed Rule?' No less than making the 3.65-3.7Ghz band (between the 2.4 GHz and 5.2 GHz bands) UNLICENSED and with a permitted EIRP of TWENTY FIVE WATTS!!!!! (where the max for 900 and 2.4 is 4 watts EIRP) Thats 25,000 milliwatts, friends, or 44 dbm permitted! (Only time I have ever read wireless permitted power expressed as '14 dbW' or Watts, not Milliwatts! And in the lengthy elaboration of the language of the NPRM, it specifically cites the value this *could* have for RURAL WISPS by permitting MUCH greater range in rural areas!!! 44 dbm gets you 101 miles of range with an 18 db antenna.

The FCC is actually asking whether anyone 'wants' this rule made? Not one WISP has filed a single comment, for or against that proposed rule over the 60 days this has been in play and on line for anyone with a browser to see, inviting public comments!

Now do you want radios in 1 to 2 years after this rule is adopted, and manufacturers jump on it and get their 3.7 GHz radios certified, that can give you that range, unlicensed? Then say so, for cripes sake! Those who, for various reasons don't want the rule adopted will sure sound off!

So get on the FCC site, go to the 04-151 Filed Comments, go to Item 11, and read the complete NPRM. Lots of bureaucratic babble in there, but if you read you will get what the proposed rule will say and why (there will be some restrictions on how close you can set up near a satellite system using the same bands, licensed, most of which are on the East or West Coasts) and make your case. Since the item was published in the Federal Register (when the clock starts ticking) on April 23rd, you can make comments for 75 days—or until about July 8th, 15 more days, and then post 'Reply' comments until about August 8th!

You can post short comments real time in ASCII, or prepare a Word document and upload it, or prepare a PDF and upload it or even an Excel document and upload it. And it will appear within a few days as an item everyone else can read, and comment on your comment—as well as the Staff and Commissioners will get it. Then the FCC Staff has to summarize the comments for the Commission, with such statements as '26 Comments were made, 16 in support of the item, 8 opposed, and 2 making further recommendations, which will be considered.' So the Commissioners, when the item is heard and decided upon, always know what the 'public' thinks about their rule, if they sound off online. Make your case and you will be heard. You don't have to hire a lawyer, or go to Washington. Just e-file!

You will see my comments in that item in a few days supporting the proposed rule. In fact I will post at least two statements, one as a WISP myself, but also representing the wireless interests of 1,200 Environmental scientists who, in 24 Long Term, NSF funded, Ecological Research projects from above the Arctic Circle to the jungles of Puerto Rico—all in remote areas—try to gather data from data loggers both long distances away, and those in forested areas, where the 25 watts of power can punch through trees better than WI-Fi radios using a max of 4 watts EIRP in areas where there is no interference with anything but the birds and the bees! Since I have been trying to help scientists gather their data wirelessly from remote areas, I know the value of this changed rule. And I will get some of them to support the rule.

And then if somebody says something stupid in the comment section, or some company tries to bullshit the FCC about how it will cause 'problems,' (aka for "I don't want the unlicensed competition") I will make, later, a reply comment to shoot them down, doing technical research if I have to.

Dave Hughes

We replied immediately, saying:

Dave: two questions:

1) Are you the Dave Hughes who brought broadband to Mt. Everest?

and

2) May we publish this note in ISP-Planet?

We received permission to publish, as well as a desciption of Hughes' latest projects (see Related articles, below).

—End