I’m getting rather worried as I gear up for two major FCC proceedings that are supposed to be good proceedings for unlicensed spectrum access. Et Docket No. 04-151 proposes opening the 3650–3700 MHz band to unlicensed spectrum (proposed rules in pdf here). The other, ET Docket No. 04-186 proposes opening the broadcast bands to unlicensed spectrum access (proposed rules in pdf here). What could be wrong? See below. I sure hope someone other than me shows up to comment . . .
First is ET Docket No. 04-151. This proposes to allow unlicensed operation in the 3650-3700 MHz band, which is currently used for certain satellite uplink operations. There are a relatively few ground stations, and so it is proposed to open up the band to fixed unlicensed at higher power and mobile unlicensed devices at lower power.
The biggest problem I have is the proposal to limit instalation of high-power fixed units to “professional installers,” a class that does not yet exist and that the FCC must somehow create. The goal is to prevent interference with licensed systems or other fixed unlicensed systems by ensuring that those installing the system understand it and can set it up right.
I am very worried that creating such a class will create a significant barrier to deploying non-commercial community based networks. This depends on how hard it is to become a “professional installer.” If it is an objective exam administered by the FCC that requires only a basic understanding of the technology — something someone could read a pamphlet and fill out the exam questions in the back and mail it in with a $25 check for processing — that is one thing. But if it gets delegated to some professional organization that has an interest in creating barriers to entry to keep prices high, that is obviously another. The FCC has proposed the “professional installer” idea in other proceedings with higher power for unlicensed, such as 03-108, and I am concerned that it needs to be addressed.
But for this, I need feedback from people who are deploying in the field. Would some sort of professional certification be helpful? Is it worth it as the price of access to higher power? How should it be structured (either as a prefered alternative or as a worst case scenario)? The due date for comments is July 28, with replies a month later.
Far more worrisome is the proposal in Unlicensed Operation in the Broadcast Band, ET Docket No. 04-186. The FCC proposes to allow the broadcast licensees to decide when a band is “clear” for unlicensed access, and to allow broadcasters to charge for the privelege.
In other words, this is not unlicensed at all, it is allowing the broadcasters to charge for underlay rights under specific rules. It appears built on the pattern of the current rules that allow broadcasters to offer ancillary services by renting out the subcarrier channels or the vertical blanking interval (VBI). Theoretically, broadcasters would not be monitoring or interfering with content, so it does not give broadcasters a block in the way cable has on internet, but anyone who thinks this method will bring cheap broadband to urban and rural areas is smoking dope.
The problem for us is that this is _exactly_ the kind of compromise that MS or Intel will cut and we shouldn’t, because the big companies will pony up and then offer high-priced mobile services. But with this poison pill in place, I would rather scuttle the proceeding and wait a few years than lock up unlicensed in the broadcast bands as a revenue stream for News Corp. et al.
Due date on this is September 1, with replies a month later.
Stay tuned . . .
Back in the days of steam-powered color TV the FCC required a “first-class radiotelephone operator’s license” to run a broadcast (TV or radio station) transmitter. The test required either an understanding of basic electronics or a sharp memory — to memorize enough of the answers to the ~400 questions the test was drawn from. Presumably anyone who could pass the test the second way had enough wits to be trained to notice when Something Was Wrong and call the consulting engineer, who actually knew something.
It seems to me a test about this difficult would be just about right for a “professional installer” test — it would weed out the real dummies but not require a PhD for something that’s (mostly) grunt work.
The FCC has long-ago abandoned the 1st class license requirement so now the station’s Director of Human Resources can double as the chief transmitter operator. To be fair, transmitters are MUCH more stable now — unlikely to start broadcasting on someone elses frequency — and operating the transmitter is almost a case of “press the green button to turn it on, press the black button to turn it off, and if the red light comes on, call the factory.”