Broadband & Community Broadband

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

Why are America's municipalities -- from small town Corpus Christi and Granbury, Texas, to big cities such as Philadelphia -- building wireless broadband networks and fighting state legislatures that want to ban them? The networks rely on unlicensed public airwaves to extend the reach of WiFi-type broadband coverage to blanket business districts, towns and even entire cities.

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.

SUMMARY

For more than two years, in three different proceedings and a host of Commission sponsored workshops, the Commission has received reams of evidence on the public interest value of permitting direct access to the public to broadcast band spectrum via the Part 15 rules. While incumbents have railed against the Commission, promising dire consequences for the future of free over-the-air television and for the digital transition, these claims lack merit. As far back as 1989, the Commission recognized that it could permit low power transmitters to operate in the broadcast bands.

The rapid development of Internet applications and digital convergence has already rendered the Telecom Act of 1996 largely obsolete and a source of contentious regulatory uncertainty. Sen. Ted Stevens, the likely new Senate Commerce Committee Chairman, is expected to initiate a major debate on overhauling the Act next year. Voice over IP and the potential for wireless broadband as an alternative last-mile pipe further complicate the policy debate.

There is general agreement that traditional mechanisms for managing radio frequency (RF) spectrum are inefficient and in need of significant reform. Many, if not most, of the economists who have considered the issue appear to concur with the view that increased reliance on market forces would enhance efficiency, and support assigning spectrum via transferable, flexible licenses, especially when spectrum is perceived to be scarce.

Last August, Berlin completed its transition to terrestrial, over-the-air digital TV. From start to finish, Berlin's DTV transition took approximately 9 months. The most interesting feature of its transition plan was that instead of giving subsidies to complete the transition to broadcasters, they were given to consumers. Consumers dependent on broadcast TV were given a voucher so they could purchase digital-to-analog converter boxes allowing them to continue to watch broadcast TV on their analog TV sets.

There is a general consensus that accelerating the digital TV transition -- thereby freeing up the 108 MHz of “beachfront” spectrum corresponding to TV channels 52- to-69 -- is clearly in the public interest. Because transmissions at this frequency range pass easily through walls and trees, the 700 MHz band could jumpstart the deployment of more affordable wireless broadband connections, particularly in rural areas.

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