FCC Comments

Comments on FCC Spectrum Policy Task Force Recommendations

January 27, 2003 |

These comments are intended to highlight the recommendations NAF, et al., consider to be among the most laudable or among the most lamentable. In general, Commenters embrace the "major findings" and "common elements of spectrum policy" set forth in the Report (pp. 3-4). In particular, the Report's enthusiasm for expanding the "commons" model by designating additional bands for unlicensed spectrum use on a shared basis represents a major recognition that emerging wireless technologies will change the way Americans access and use the airwaves. Yet, at the same time, NAF, et al. observe that the Report implicitly endorses methods of making the transition from legacy command-and-control licensing to more flexible, market-oriented models that would in practice both abandon a number of the traditional policy goals enumerated by 9 Congress in the Communications Act and serve to undermine other important policy goals endorsed by the Task Force itself. Even putting aside the thorny question of whether most incumbent licensees should continue to receive exclusive use of frequencies at no cost, an additional grant of new, more flexible and marketable license rights must, in the view of NAF, et al., continue to be for short and limited license periods and reserve any residual "ownership" rights for the public, as under current law.

For more from this document, see the PDF linked below.

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