Politics

Action Item for WISPs: File With the FCC for More Unlicensed Spectrum

WISPs need more unlicensed spectrum, but so far barely a dozen have filed comments with the FCC arguing in favor of it. If WISPs fail to act, the usual monopolies will set the rules, again.

by Alex Goldman ISP-Planet Managing Editor [February 23, 2007]

When the government has spectrum available, there's billions of dollars in special interests arguing for special consideration. How can the WISP industry compete to be heard when its entire annual revenues are likely less than the salaries at any major telco or equipment maker?

The WISP industry's arguments in favor of more open spectrum will be heard when the WISP industry learns to work with those advocating open spectrum as a matter of principle (the New America Foundation), free speech (the EFF and others), and the one group represented more in rhetoric than in fact: consumers.

Skimming through the 751 comments appended to FCC proceeding 04-186 ("In the Matter of Unlicensed Operation in the TV Broadcast Bands: Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band") we find submissions from Matsushita, Panasonic, Motorola, Dell, Comcast—all the usual telecom industry suspects. Associations like the NCTA (one of many voices of the monopolies) and the Consumer Electronics Association (representing a massive number of manufacturers) have submitted comments.

Others have also submitted comments. You'll find familiar people, like Dave Hughes and WISPA, filed comments in support of the WISP position.

Nevertheless, the balance of comments, especially in terms of dollars donated to politicians, remains overwhelmingly in favor of the monopoly position.

Furthermore, the public is not engaged on this issue. In the conclusion of his policy paper, Spectrum Policy Wonderland: A Critique of Convention Property Rights and Commons Theory in a World of Low Power Wireless Devices (.pdf), the New America Foundation's J.H. Snider writes, "The combination of special interest zeal and public apathy is an explosive political combination that, as long as it lasts, will inevitably result in special interest spectrum politics that unduly favors the licensed over the unlicensed property rights model. To the extent that law and economics are not on the side of licensed property rights holders, there may be hope that these political dynamics will one day change."

Act now
This is where WISPs come into the picture. If you're a member of the ISP-Wireless list or a member of WISPA, you've already received a note from Marlon Schafer telling you how to file comments.

It's easy.

1. Write your comments in a word processor and sign them with your own name and the name of your company (city and state are useful too).
2. Go to the FCC's comments page.
3. Type the proceeding number, 04-186, into the first box and fill out the rest of the form.
4. Attach the file or cut and paste it into the space on the form.

Before you do this, you might want to read what others have filed. WISPA's filing can also be read here on the WISPA website.

You may also want to read the FCC's initial Notice of Proposed Rulemaking (NPRM) and recent NPRM, but both are very long .pdf documents.

We fear that those opposed to change and new technology will win this one. It's up to WISPs to act. The deadline for filing comments is midnight on Friday, March 2, 2007.

—End