roundtable: GovAccess.171.wireless: FCC EMAIL addrs; why free wireless NII
roundtable: GovAccess.171.wireless: FCC EMAIL addrs; why free wireless NII
GovAccess.171.wireless: FCC EMAIL addrs; why free wireless NII
W. Curtiss Priest (BMSLIB@mitvma.mit.edu)
Wed, 19 Jul 95 13:36:34 EDT
Message-Id: <9507191739.AA03168@a.cni.org>
Date: Wed, 19 Jul 95 13:36:34 EDT
From: "W. Curtiss Priest" <BMSLIB@mitvma.mit.edu>
To: Telecommunications Policy Roundtable <ROUNDTABLE@CNI.ORG>,
Subject: GovAccess.171.wireless: FCC EMAIL addrs; why free wireless NII
FCC taking comments on petitions via Internet! FYI, Curt
Curtiss Priest
<bmslib@mitvma.mit.edu>
----------------------------Original message----------------------------
Date: Tue, 18 Jul 1995 13:23:59 -0700
To: GovAccess@well.com
From: jwarren@well.com (Jim Warren)
Subject: GovAccess.171.wireless: FCC EMAIL addrs; why free wireless NII
[Apologies to those who have send GovAccess subscription changes for me
to process manually. Will get to 'em as soon as I can. Or you can make
the changes you desire, as noted in the footer of each issue of
GovAccess. --jim]
&&&&&&&&&&&&&&&&&&&&
FCC May Take Next Step - *IF* Public Shows Enough Interest
Reading between the political lines, it seems likely that - since at least
one FCC Commissioner has shown interest in a possible public-domain
spectrum allocation, and the FCC has now implemented public comments by
email - *IF* there is extensive public interest expressed in the proposals,
then the FCC well might actually move to the next step in formal
consideration (pursue a rule-making).
However, the FCC doesn't have to even consider a possible rule-making on
this matter.
If the public cares, the FCC probably will. If the public can't be
bothered ... why should the FCC bother?
For metropolitan-region free-spectrum public-domain communications
alternatives, speak up NOW!
&&&&&&&&&&&&&&&&&&&&
FCC Announcement and FCC EMAIL ADDRESSES for Public-Spectrum Public Comments
Date: 18 Jul 95 19:22 GMT
From: LOVETTE@AppleLink.Apple.COM (Lovette, James)
Jim, here's this morning's announcement from the FCC about accepting direct
E-mail on the two Petitions. This is a real breakthrough and undoubtedly
stems from your actions, buttressed by our suggesting it to Commissioner
Ness, who followed through immediately. She deserves a lot of credit not
only for this but for her enlightened awareness of the way the world now
works and communicates.
(Jim, you should be aware of the fact that the WINForum proposal has little
if anything to do with a "wireless NII" and in fact concentrates explicitly
on "SuperNet," that essentially just extends a common carrier's "broadband
backbone" inside buildings. There's not a mention of "community" or
"universal access" networks. I'm sorry the FCC characterizes the AT&T-based
proposal as being for "wireless NII" because it's at the opposite pole from
our objectives for "wireless Internet--and more!)
BRAVO to Commissioner Ness!!!! (BRAVA, I think it should be.)
===
>From David Sidall
7/18/95, 9:25 a.m.
Subject: Wireless NII
Good morning.
The FCC now is accepting comments through the Internet on the wireless NII
proposals filed by WINForum and Apple. The WINForum petition is RM-8648 and
the Apple petition is RM-8653. Deadline for reply comments is July 25. Each
petition has its own separate address because some parties may address
aspects that relate only to one or the other petition. However, the
Commission has announced that it will consider both petitions together in a
single proceeding, and therefore all comments filed in either file will be
considered in the broader context. The addresses are:
RM-8648@fcc.gov
RM-8653@fcc.gov
(These addresses are not case-sensitive.)
&&&&&&&&&&&&&&&&&&&&
Inventor of Packet Networking (and much more!) Notes Some Values of Pub-Spectrum
[Paul Baran is an internationally-renown, elder statesman of computer
communications. He has been a frontiersman and innovator in datacomm since
at least the 1960s - and *continues* to innovate ... when permitted by law.
--jim]
Date: 11 Jul 95 21:56:23 EDT
From: Paul Baran <73507.2223@compuserve.com>
This is written in response to [a request from] Jim Warren for reasons that
the FCC Commissioners or others should want to learn more about the Apple
NII Communications Commons proposal:
1. The Apple NII proposal raises the opportunity to consider a major new
concept: how new technology can allow many more users to share the common
radio spectrum at lower cost and regulatory burden.
2. This is a wake up call from the technical community to the FCC to draw
attention to the implications of the new digital signal processing
communications technology.
3. With success the amount of available spectrum space could be greatly
increased to improve our ability to apply electronic communications to
societal sectors not cost effective today, nor likely to be feasible with
the present regulatory trajectory.
4. Public shared access by all comers without complex licensing is both
technically and economically superior to the present concept of auctioning
off the public spectrum to the highest bidder.
5. While the funds received from the one time auction appear to be
significant, they are economically counterproductive. The high front end
costs of spectrum licensing is a major disincentive to new technology risk
investments in new radio technology. (Initial venture capital investments
can rarely be justified if greater than a few million dollars, an amount
far less than the bid price of national frequencies.) Only very large
companies seeking monopoly positions can afford the front end costs of the
bidding game.
6. The one time funds received by government for selling off he public's
spectrum is small compared to the long term revenue potential over time. It
is a public policy of selling the goose that lays the golden eggs rather
than the eggs over time.
7. To ignore this new input information means continuing to keep a range of
new services from becoming cost feasible.
8. We believe the new technology alternatives are so compelling that it
will be just a matter of time whether it is adopted or not. When the new
technology is adopted, either earlier or later, the world will look back
and credit the FCC Commissioners for their vision, or view them in
retrospect with the same attitude as we view the old East Germany
leadership for trying to maintain the status quo.
&&&&&&&&&&&&&&&&&&&&
Center for Democracy and Technology's Comments on a Public Wireless NII Band
[This provides extensive details about the value of a public-domain
wireless spectrum allocation, and also an example of a possible format for
comments, although comments from the lay public are acceptable in almost
any <civil> form. --jim]
Date: Mon, 10 Jul 1995 17:38:09 -0400
From: djw@cdt.org (Daniel J. Weitzner)
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
) RM-8653
Allocation of Spectrum in the 5 GHz Band to )
Establish a Wireless Component of the National )
Information Infrastructure )
Comments of the Center for Democracy and Technology
I. Summary and Overview
The Center for Democracy and Technology (CDT) is a non-profit,
public interest research organization whose mission is to promote civil
liberties and democratic values in new computer and communications
technologies. CDT believes that Commission's consideration unlicensed
radio spectrum for high-speed data and voice communications will have a
major impact on the growth of the National Information Infrastructure and
the degree to which all citizens have access to new interactive media.
CDT is concerned about the development of the NII Band from a
public policy perspective inasmuch as it can advance First Amendment values
in new interactive media, but we are also concerned about the development
of new NII access services as a user. Our work is heavily dependent on
affordable access to the NII in order to fulfill our public education and
political advocacy mission. Unless we and our constituents around the
country have affordable access to the NII, our ability to achieve our
organizational goals will be severly limited.
II. A Gateway-free Component of the National Information
Infrastructure, as proposed in Apple Computer's NII Band Petition, is in
the Public Interest
New interactive media, commonly know as cyberspace, has tremendous
potential to stimulate improvements in the economic, cultural, educational
and political life of our country. However, its progress is stymied in
part because access to the NII is limited by access bottlenecks. The world
of cyberspace is flourishing with new services and a diversity of
information, but gaining full participation in these services is often
limited for individuals, schools, libraries, and other community and
nonprofit institutions because high-bandwidth access to the NII remains
expensive and scarce. In most cases, high-capacity access to the NII is
available only through monopoly service providers who offer limited options
at high prices. Where competitive options are available, they are often
priced beyond the reach of individuals and local institutions.
An unlicensed NII Band can help elliviate this access bottleneck by
creating a new competitive access option which operates without any single
gatekeeper. Such a service will stimulate competition with existing access
providers and offer consumers, especially schools, libraries, community
institutions, and individuals, a more flexible and affordable method of
connecting to the NII. The unlicensed wireless service as proposed in
Apple Computer's NII Band Petition is in the public interest inasmuch as
it: 1) promotes ubiquitous, affordable access to the NII for citizens all
around the country, 2) increases the diversity of information sources
available on the NII, and 3) forms a platform for a vibrant new public
forum for political discourse at a local and national level.
A. Unlicensed, high bandwidth wireless service is an innovative
approach to the still-unbroken "last mile" access bottleneck and will
promote ubiquitous access to the NII
Despite all of the excitment surround developments in interactive
communications media such as the Internet and commercial online services,
access to these services remain limited by a dearth of high-capacity
network access options and uneven geographic availability such high-speed
access technologies that do exist. A new means of providing high
bandwidth, "last mile" connectivity. Unlicensed wireless service as
proposed by the Apple NII Band Petition is an option that should be
aggressively promoted by the Commission in order to enable an alternative
access path to the NII.
Experience from the rapid and unregulated development of the
Internet suggests that gateway-free, packet-based transport technologies
can be a fertile platform for the development of new information and
communication services, and promote easy access to a large number of users.
The NII Band proposal should be pursued a communications access option
that will promote a true First Amendment diversity of information sources
and be the basis of vibrant public forum in cyberspace.
1. Cyberspace is booming but end-user access options are limited by
monopolistic pricing and regulatory delays
The last few years have seen explosive growth in the development of
the new interactive media including the Internet, commercial online
services, as well as smal computer bulletin board services, Freenets, and
other interactive technology. Taken together, these developments hold out
the promise of a true information revolution that will alter the way that
our society does politics, business, education, and healthcare. However,
the potential of these new technologies for our democracy, our economy, and
our culture will only be realized if all Americans have easy and affordable
access to the growing information infrastructure. Without the opportunity
for full participation, the interactive media will not grow, and our
society will suffer from continued social alienation, failures in our
democratic process, and increased economic stratification.
Over the last ten years, telecommunications policy makers have been
debating various statutory and regulatory policy steps that could be taken
to make high bandwidth access to the NII more widespread and more
affordable. Regretably, policy changes have been slow and actual advances
in access options have been virtually nonexistent. Indeed, the vast
majority of individuals and small institutions still are limited to access
through analog telephone lines. Prices remain reasonable, but bandwidth
limitations keep multimedia services beyond the reach of those tethered to
the NII by POTS lines. The only bandwidth increases have come as a result
of innovations in modem technology, which have push effective access speed
up from 1200 bits per second to 28,800 bits per second.
High bandwidth services in the wireline infrastructure has been
slow in coming because of high capital costs for full broadband upgrades,
as well as slow marketing practices and regulatory delays for wideband
services such as ISDN.[1] In many cases these delays arise out of
legitimate questions as to the wisdom of high-cost upgrades, as well as
genuine difficulties in adapting old regulatory structures to new services.
However, the net result is delay in end user access to cyberspace.
2. Unlicenced wireless services such as the NII Band can break the
access bottleneck
Clearly, a new approach to "last mile" bandwidth is needed. The
Internet is a useful case study in successful stimulation of the
development of a range of new information and communications services. By
creating an alternative communicaitons platform, the Internet was able to
stimulate the development of a a number of new services and, in fact, a
whole new communications medium. As developed by the Advanced Research
Projects Agency and then the National Science Foundaton, the Internet as
conceived as a "test bed" for the development of NII services. On a
platform of packet-switching technologies, basic addressing schemes, and
other technical standards, the Internet did indeed service as a seedbed for
the development of numerous services such as electronic mail, the World
Wide Web, and Usenet newsgroups.
By providing an alternative path for access to the NII, the
unlicensed wireless services can help elliviate the current access
bottleneck that hampers participation in the NII by individuals, schools,
libraries, and other small institutions.
B. Unlicensed wireless service with sufficient bandwidth will increase
the diversity of information sources accessible to all Americans
Since its inception, the Commission has sought to increase the
diversity of information sources available to the American public. In the
case of the broadcast media, diversity enhancing policies have included the
fairness doctrine, equal time rules, and children's programming rules.
These policies were necessary to assure that the scarce radio and
television spectrum was used in way that reflected the broad needs of all
Americans.
The potential abundance of new interactive, digital communications
media such as the Internet and commercial online services require a new
approach to achieving the First Amendment diversity goal. Unlike broadcast
media which are characterized by a scarcity of communications channels, new
interactive media have an inherent abundance of communications
opportunities which enable all users to be information providers as well as
information receivers. However, the First Amendment diversity goal will
only be achieved if individual users from a diversity of institutions and
geographical settings have access to the NII. There is no channel scarcity
in interactive media to pose the kind of diversity barriers that exist in
the mass media. However, the potential abundance of interactive media will
be squandered if access to the NII is limited because of access bottlenecks
such as now exist to the NII from lack of high-capacity, widely available
access options. Unlicensed wireless services which offer high capacity,
bi-directional access withe the interference of gatekeepers can play a
critical role in promoting a diversity of information sources in the
growing NII.
C. Unlicensed wireless service can be the platform for a vibrant
"public forum" in cyberspace
For some time policy makers [2] have struggled with the question of
how to promote affordable and widely available access to new interactive
media for the nonprofit sector, including schools, libraries, and community
groups. These groups often cannot afford the high cost of currently
available access services, but their participation in the NII is vital both
for their own institutional missions and in order to assure a lively public
forum for the healthly functioning of our democracy. Policy proposals
currently under consideration seeks regulatory means to provide low cost
access to the NII for eligible groups in the nonprofit section. An NII
Band that provides gateway-free, no cost access to the NII could become an
important part of the solution to difficult public access issues that face
communications policy makers as our society comes to rely more and more on
new interactive media.
III. Rules Implementing the NII Band Proposal Should Emphasize Equal
Access, Bi-directional Communications, and an Open Standards-Setting
Process
The Center for Democracy and Technology endorses the major
functional specifications for the NII Band as outlined in Apple Computer's
Petition. We believe that the Commission should work to implement these
goals. In these comments, we would place special emphasis on the equal
access goal cited in Apple Computer's Petition and would also add an
explicit requirement that NII Band services incorporate bi-directional
communication for all users as a part of the basic service available to
individual users.
A. Equal access, decentralized network architecture is a critical
component of any NII service
CDT endorses the equal access goal set out in the Apple Petition
and here notes that an equal access, open network is a critical
architectural component of the NII as it develops. The architectural
characteristics of the NII will have a critical impact on the diversity of
information sources available, as well as the ease of access for
individuals and communities around the country.[3] The analog public
switched telephone network enables 'many-to-many' communication but
suffers from bandwidth constraints which limit most Americans' access to
mulitmedia network services.
A true diversity of information in new interactive media will
require that all Americans have access to network services that enable
communications from any point to any other point, without the interference
of information gatekeepers such as are found in the mass media today. As
such, the network architectures available to individuals and institutions
will have a determinative impact on the First Amendment free flow of
information in the information age. The Commission should promote network
services based on architectures that enable individuals and institutions to
communicate with anyone around the country or the world, without the
barriers to diversity that may be imposed by communications gatekeepers.
An open access[4] network, such as the NII Band would enable
point-to-point communications around a local area, as well as easy access
to global, open networks such the Internet. Therefore, in the interest in
the First Amendment diversity and free flow of information, the Commission
should seek policies which, to the greatest extent possible, promote open,
many-to-many communications services.
B. NII Band must support bi-directional communications as a basic
feature for all users
Full participation in the communication an information exchange
that is the NII requires that individuals have bi-directional access to NII
elements such as the Internet and other interactive media. In order to
promote the full economic, cultural, educational, and political uses of
interactive media, access must be bi-directional. This is not to say that
every application will require fully symmetrical communcations, but such
options should exist and be available to all users on demand. While it may
be implicit in the Apple Petition, CDT suggests that the Commission include
bi-directional communications as a basic criterion for NII Band Services.
C. Technical standards should be developed by the private sector, with
opportunity for Commission review in the event that basic functional
service goals are not met
CDT concurs with Apple Computer's suggestion that technical
standards for NII Band services should be developed by the private sector,
according to broad functional requirements set out by the Commission. We
do believe, however, that the Commission should reserve the option to
review standards as they are developed and implemented in the event that
such standards do not meet the goals established by the Commission's
decisions.
IV. Conclusion
In order to promote the development of the NII as an open access,
decentralized, gatekeeper-free network of networks, the Center for
Democracy and Technologies encourages the Commission to take whatever steps
are necessary to enable the implementation of NII Band services.
Respectfully Submitted,
The Center for Democracy and Technology
Daniel J. Weitzner
Deputy Director
1001 G St., NW
Suite 700 East
Washington, DC 20001
tel: 202-637-9800
email: <djw@cdt.org>
July 10, 1995
====NOTES====
1 The marketing of ISDN Basic Rate and Primary Rate services is delayed as
a result of an ongoing proceeding before this Commission on the applicaiton
of subsciber line charges to ISDN services. In comments, CDT has commended
the Commission for its aggressive efforts to resolve this question, but the
service is nevertheless in a state of uncertainty until the issue is
resolved.
2 See S. 2195, the "National Public Telecommunications Infrastructure Act
of 1995", sponsored by Sen Inouye and the Snowe/Rockefeller public access
Amendment to S. 652
3 For a more detailed exposition of this point, see Berman & Weitzner,
Abundance and User Control: Renewing the Democratic Heart of the First
Amendment in the Age of Interactive Media, 104 Yale L.J. 1619 (1995)
4 See Clinton Administration White Paper on Communications Act Reform, 18
Daily Rep. for Execs. (BNA) M-1, M-4 (Jan 27, 1994)
&&&&&&&&&&&&&&&&&&&&
"Everyone can be great, because everyone can serve."
--Martin Luther King [From: clint@clint.com]
Mo' as it Is.
--jim
Jim Warren, GovAccess list-owner/editor (jwarren@well.com)
Advocate & columnist, MicroTimes, Government Technology, BoardWatch, etc.
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