MSS Comments in Wireless Innovation NOI
Your blogger has filed comments in the Wireless Innovation NOI, Docket 09-157. Here is a convenient link to all the filed comments using an undocumented feature of the FCC web site.
The MSS comments reviewed the following issues:
II. Lessons of Pioneer’s Preference
III. Section 7 Issues
IV. “Receivers use spectrum not transmitters”
V. Innovative Wireless Systems Need Both Spectrum and Antennas
VI. “Green” Wireless Technologies
VII. Enforcement and Spectrum Options
VIII. More Effective G/NG Sharing
IX. Are the FCC and NTIA “Test-Beds” real or an Illusion?
X. Decision Making Issues
XI. The Role of Wireless Standards
Among the issues discussed is the question the Commission raised about "green" wireless technologies. In particular the MSS comments raise the question about why broadcasters must use hundreds of kilowatts of AC power to broadcast signals few watch in order to be eligible for "must carry" rights. This is a followup and modification to the pioneering proposals in OPP Working Paper 38 by Evan Kwerel and John Williams.
An observation: The NYTimes has a website that has more viewers than the printed edition. Does anyone require them to cut down trees and process wood pulp in order to get access to the Internet? Why must broadcasters both use large amounts of electric power and deny others the use of spectrum just to get the must carry rights that get them the overwhelming majority of their viewers? Under current law this is most likely necessary and there might even be some constitutional issues involving the rights of cable operators - but shouldn't FCC at least consider the issue?
The comments also urge FCC to work with NTIA to explore the possibility of future federal government systems that are designed from the beginning to share unused spectrum with FCC licensees. Such system need not be as conservative as cognitive radio systems in order to guarantee high confidence radio communications for the primary federal users. I had previously discussed this issue in a New American Foundation paper and at an IRAC meeting.