The Technical Reply Comments filed by NAF, et al. are below. NAF, et al. also filed a separate set of Economic/Legal Reply Comments, which you can find here.
FEDERAL COMMUNICATIONS COMMISSION
In the Matter of Unlicensed Operation
in the TV Broadcast Bands, ET Docket No. 04-186
Additional Spectrum for Unlicensed Devices
Below 900 MHZ and in the 3 GHz Band, ET Docket No. 02-380
TECHNICAL REPLY COMMENTS OF
NEW AMERICA FOUNDATION
Dr. Robert Broderson
Dr. Paul Kolodzy
Dr. Haiyun Tang
These Reply Comments are submitted to the Commission by New America Foundation and the expert parties listed on the first page (collectively "NAF, et al."). The Appendix gives a brief summary of each of the parties signing these comments. NAF, et al. has participated in this proceeding since its formal initiation and prior to that recommended reallocating the TV band "white space" for unlicensed access in dialogue with FCC staff and in workshop testimony before the FCC Spectrum Policy Task Force that preceded the initial NPRM.
A great deal of the material in the comments to the FNPRM recycles concepts that have already been discussed repeatedly in this proceeding. However, it is interesting to note that two issues raised by the opponents of this proceeding have disappeared from this round of comments, apparently because they have been thoroughly rebutted. These are the allegations of interference due to TV band device signal ingress into poor indoor CATV cabling and the allegation that there is minimal "white space." In this latter matter, Charles L. Jackson and Dorothy Robyn (in their comments for Qualcomm, hereinafter the "Brattle/Qualcomm" comments) have made an extensive effort to quantify the available white space under various assumptions. Motorola has demonstrated that there would be so much white space in channels 14-to-20 that it could be a valuable resource for public safety communications indeed, it should be a valuable resource for wireless communications and services more generally, even while protecting (during a reasonable transition period) the legacy public safety devices operating in 13 metro markets. While NAF, et al. disagrees with the policy conclusions of these last two pleadings, the arguments present show how bankrupt the initial pleadings of the opponents in this proceeding were.
In their filed comments, we note that the incumbent industry interests have mounted a concerted effort to exclude as many unused and under-utilized channels as possible from productive use by new services and devices. In aggregate, these incumbents would maintain the "vast wasteland" of spectrum inefficiency within the current TV band. It is imperative that the Commission consider the enormous social and economic opportunity costs of accommodating the unnecessarily restrictive (and spectrally inefficient) recommendations of NCTA, Motorola, Shure Inc., Qualcomm, and other self-interested spectrum incumbents. The general public interest in promoting wireless broadband ubiquity and other innovative uses of the airwaves is too great.
To view the full comments, please see the PDF document linked below.