New America et al./MAP

Petition Asking FCC to Declare Text Messaging Subject to Non-Discrimination Rules

adminn — Tue, 11 Dec 2007 11:32:00 -0500

The New America Foundation's Wireless Future Program, as part of a broader public interest coalition, on Dec. 11 filed a petition urging the Federal Communications Commission to issue a declaratory ruling stating that "Text Messaging and Short Codes are Title II Services or are Title I Services Subject to Section 202 Nondiscrimination Rules."

For the full document, please see the PDF attached below.

Reply Comments on Digital Radio Public Interest Obligations

Wireless Future — Thu, 15 Nov 2007 16:16:00 -0500

These Reply Comments were submitted on behalf of Benton Foundation, Campaign Legal Center, Center for Governmental Studies, Common Cause, Office of Communication of the United Church of Christ, Inc., and Prometheus Radio Project (collectively “Public Interest Coalition” or “PIC”) in the Commission’s Second Further Notice of Proposed Rulemaking on Digital Audio Broadcasting Systems and Their Impact on the Terrestrial Radio Broadcast Service, MM Docket No. 99-325, 22 FCCRcd 10344 (2007) (“Second FNPRM”).

For the complete document, please see the attached PDF below.

Comments to FCC on Digital Radio Public Interest Obligations

Wireless Future — Mon, 15 Oct 2007 05:11:00 -0400

With the transition to digital radio, the Commission has a rare opportunity to address documented failures in providing listeners with diverse and local programming. The transition to digital will provide broadcasters with additional programming capacity, and the Commission must use this opportunity to promote its goals of diversity, localism, and competition. The Public Interest Coalition supports the Commission’s efforts to ensure that with the additional programming capacity, broadcasters, in return for the exclusive use of the public airwaves, provide meaningful service to the public. Thus, the Public Interest Coalition urges the Commission to adopt rules and policies in which the public will gain substantial benefits from the new technology.

First, the Commission must limit the number of subscription-based services a station can offer. Free over-the-air radio continues to play a vital role in people’s lives. Limiting subscription-based services will protect and preserve free over-the-air radio.

Second, the Commission must impose spectrum fees on subscription-based services. Broadcasters will essentially be using additional spectrum to generate revenue. In return, to avoid unjust enrichment, it is appropriate for broadcasters to pay a fee for use of the spectrum to generate revenue. In addition, the Commission should seek to assign those spectrum fees in a manner that will directly benefit the public.

Third, the Public Interest Coalition supports the Commission’s conclusion that it has the authority to adopt public interest obligations for subscription-based services. Under Title III, subscription-based services are required to serve the public interest. Thus, the Commission must adopt broadcast type public interest obligations, including the political broadcasting and payment disclosure rules, for subscription-based services.

Fourth, in addition to the broadcast type public interest obligations, the Commission must adopt additional minimum public interest obligations for both free and subscription-based services. These public interest requirements must further the Commission’s goals of localism, diversity, and public safety. The Public Interest Coalition proposes that the Commission require all digital transmis- sions to air a minimum level of local civic or electoral affairs programming and independently produced programming. The Commission must also adopt rules and policies that will provide opportunities for minorities and women. Finally, the Commission must assure that all emergency related and public information is provided free of charge to the public.

Fifth, in addition to the above, the Commission must adopt rules in which subscription-based services fulfill additional public interest requirements for their free use of the spectrum. The Public Interest Coalition proposes a flexible plan from which radio stations will have the choice as to how they fulfill the additional public interest requirements. This flexible menu is based on a community’s needs for certain services.

Sixth, as the radio industry adopts digital technology, the Commission must have a means for understanding how broadcasters are using the technology to serve the public. To do so, the Commission must adopt meaningful reporting requirements. These reports must be easily accessible to the public over the Internet and the public must be made aware as to where these filings can be accessed.

Finally, the Commission must ensure that automated broadcast operations are relevant during emergencies. Automated broadcast operations must be automatically overridden in an emergency.

For the complete document, please see the PDF attached below.

DTV Receiver Desensitization Interference Study: Preliminary Results

Wireless Future — Tue, 05 Dec 2006 13:19:00 -0500

To view preliminary results from New America's testing of DTV receiver desesitization interference, conducted at the University of Kansas under the supervision of Kolodzy Consulting, LLC, and Marcus Spectrum Solutions, please see the PDF document linked below.

Comments Supporting Expanded Public Interest Obligations for Satellite Broadcasting

Wireless Future — Mon, 16 Oct 2006 15:53:00 -0400

COMMENTS OF
THE NATIONAL HISPANIC MEDIA COALITION
THE NEW AMERICA FOUNDATION
HAWAII CONSUMERS
PROMETHEUS RADIO PROJECT
MEDIA ALLIANCE
THE BENTON FOUNDATION
U.S. PIRG

Media Access Project, on behalf of The National Hispanic Media Coalition, The New America Foundation, Hawaii Consumers, Prometheus Radio Project, Media Alliance, the Benton Foundation and U.S. PIRG (collectively “NHMC, et al.”) respectfully submit these comments. NHMC, et al. support the Commission’s preliminary conclusion to apply the existing public interest obligations mandated by Section 335 of the Communications Act (47 USC §335) to spectrum authorized for DBS services in the above captioned proceeding (“the NPRM”).

But the Commission’s proposal does not go far enough; because this proceeding will dramatically expand the available spectrum for DBS providers, the Commission should also expand the current spectrum capacity set aside pursuant to Section 335 (“public interest set aside”), and revisit its previous conclusions that DBS operators cannot use their capacity to serve the interests of localism.

To read the full comments, please see the PDF file linked below.

Comments on DTV Converter Box Coupon Program

Wireless Future — Tue, 26 Sep 2006 06:48:00 -0400

COMMENTS OF
NEW AMERICA FOUNDATION
MEDIA ACCESS PROJECT
CONSUMER FEDERATION OF AMERICA
WIRELESS INTERNET SERVICE PROVIDERS ASSOCIATION (WISPA)
ACORN ACTIVE MEDIA FOUNDATION
COMMUNITY TECHNOLOGY CENTERS’ NETWORK
CHAMPAIGN URBANA COMMUNITY WIRELESS NETWORK (CUWiN)
THE ETHOS GROUP
FREENETWORKS.ORG

Introduction & Summary

For close to a generation, telecom policy analysts have argued that the TV broadcast band was extremely inefficiently utilized and that parts of it should be reallocated for more efficient uses. In recent years, Congress and the FCC have taken steps on two fronts to minimize the opportunity cost of this inefficient use by: (1) proposing to allow the use of unused spectrum (white spaces) between channels 2 and 51 by unlicensed devices, and (2) attempting to accelerate the DTV transition and return by broadcasters of channels 52 to 69. With respect to (1), in 2004, the FCC introduced a Notice of Proposed Rulemaking to open up the white spaces between TV channels 2 and 51 for unlicensed use. Earlier this month, the FCC released a Public Notice which lays out a one-year timeline to complete the proceeding. This comes in response to possibility of congressional action encouraging the opening of TV band white space to unlicensed use, and requiring the FCC to complete its Rulemaking (the Senate Commerce Committee recently approved such legislation, which is now awaiting a vote before the full Senate). With respect to (2), in late 2005, Congress passed a “hard deadline” for the DTV transition, requiring that TV broadcasters return 108 MHz of spectrum (TV channels 52 to 69) by February 18, 2009.

This NPRM has a direct bearing on both of these goals. First, the quality of the converter boxes NTIA mandates will affect the utility of the white spaces within TV channels 2-51. The stakes in enabling use of TV band white spaces by unlicensed devices are critical. The desirable propagation characteristics of TV band spectrum make the white spaces ideal for the deployment of high-quality, affordable fixed and mobile wireless broadband services, particularly in rural areas where such services are vitally needed and where the most TV band white space exists. Fostering the deployment of affordable and ubiquitous wireless broadband services will allow more households and businesses to access the Internet, and will carry enormous benefits for small business productivity, as well as for government efficiency, public safety, and education. Opening up more unlicensed spectrum will provide a new hotbed for innovation in wireless services.

Second, the design of the of the converter box subsidy NTIA mandates will affect whether those currently dependent on analog TV sets can transition to digital TV with minimal disruption, the raison d'etre for the converter box subsidy and a goal Congress has deemed essential for completing the return of TV channels 52 to 69.

In accordance with these two considerations, NAF, et al. recommends the following:

The minimum technical capabilities for the converter boxes should maximize the utility of the TV white spaces within channels 2-51 for broadband and wireless innovation.
The primary goal in designing the converter box subsidy should be to ensure that the return of TV Channels 52-69 is not endangered as a result of inadequate distribution of converter boxes to eligible households.

To view the full comments, see the attached PDF file below.

Technical Reply Comments on Unlicensed Access to TV Band

Wireless Future — Mon, 31 Jan 2005 17:00:00 -0500

INTRODUCTION

These reply comments are being filed by a coalition of the New America Foundation and other entities (NAF et al.) listed on the cover page. These entities include nonprofits, corporations, and professors of engineering, and they have joined in urging the Commission to complete positive action in its proposals in this proceeding. These entities have explicitly reserved the right to file reply comments individually. These coalition comments only concern issues on which the above entities were able to reach consensus.

Increasing use of TV broadcast spectrum in a way that protects existing users will also further the Commission’s goal of using spectrum more efficiently. The spectrum is an exceedingly valuable resource and increasing its utilization will contribute to economic growth in both FCC-regulated industries and throughout the rest of the economy. The proposals in the Notice basically are valid as will be shown below. Some legitimate concerns about the specific proposals have been raised in the comments and New America et al. address those concerns in these Reply Comments and show how modifications of the original proposals could eliminate concerns about interference.

While some would like to portray this Notice as an unprecedented step to use unproven technology, it actually builds on precedents in FCC action, commercial products, and military R&D. Cordless telephones have used dynamic frequency selection for about a decade to improve spectrum use and minimize interference. The Commission has already authorized software-defined radio and in an ongoing rulemaking is considering improving the security of the software. The Commission has already authorized a software-defined radio developed by one of the members of this coalition. The Commission proposed in its Notice three different techniques that could be used to enable unlicensed use in TV band “white space”: geolocation/GPS with comparison to database of licensed facilities, listen-before-talk systems that look TV signals before selecting a free channel, and systems using local beacons that identify free channels.

Geolocation technology using GPS is already widespread and has been recognized by the Commission in the E-911 context. Other geolocation technologies with better indoor coverage are under development. Fail-safe applications of such geolocation technology can be implemented in a straightforward way that would allow unlicensed transmitters to turn on only if they are in “white space” where they cannot cause interference. Ironically, the limiting factor of such systems may be the present accuracy and timeliness of the Commission’s publicly available databases. This problem can and should be resolved independent of this proceeding.

The Notice proposes that portable unlicensed devices could detect and avoid TV signals by having a detection system much more sensitive than normal receivers.¹ It is a basic technical fact that it is much easier to detect a signal than to demodulate. A detection system can accumulate signals for a long time before it makes a decision about whether a specific type of signal is present. By contrast, a normal receiver must decide what signal is present very quickly, which in the case of DTV is about 20,000,000 decisions/second.² Several commentors have said that it is possible to have a TV signal detector that is more sensitive than a TV receiver by simply using a very narrow bandwidth. Other commentors have pointed to “cyclostationary” or “feature” detector technology, featured at a Commission Tutorial on February 12, 2003, which is even more sensitive than the narrow filter approach. Thus technology is available to reliably detect weak TV signals and prevent interference.

The final enabling mechanism in the notice was the use of a beacon signal to signal what TV channels are available. The proposal in the Notice did not specify adequately that the range of the beacon signal had to be comparable to the validity of its contents since “white space” is location dependent. New America et al. suggest below a clarification that eliminates this concern.

NAF et al. are organizing these reply comments to focus initially on the points raised in the Joint Comments of The Association for Maximum Service Television, Inc. and the National Association of Broadcasters (MSTV/NAB) filed November 30, 2004. MSTV/NAB represent a large number of entities concerned about the proposals in this proceeding and their comments cover more issues than other commentors who were opposed to the proposals. After the points raised by MSTV/NAB are discussed, NAF et al. will address points raised in other comments. In each case the Commission can adequately address each raised issue with either the proposed rules in the Notice or straightforward modifications of the proposed rules in the Notice.

The coalition members all agree that making additional unlicensed spectrum available in lower bands is very important to the development of the information society in the US and in removing barriers to broadband in rural areas. Additional alternatives to broadband service, such as proposed in this docket, will also spur competition, innovation, and decreased costs in the provision of broadband services.

To view the full comments, please see the PDF file linked below.