Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
ET Docket Nos. 04-186, 02-380
Dear Ms. Dortch:
The nonprofit Mountain Area Information Network (MAIN) in western North Carolina and the nonprofit Access Humboldt network in northern California are established community-based rural broadband providers. MAIN has provided Internet access services to the rural mountain region of North Carolina since 1996 and is one of the longest-surviving, community-based ISPs in the United States. Access Humboldt provides broadband media services for public safety, health, education and government in rural North Coast communities, including tribal lands.
Community-based ISPs provide service in the most sparsely populated rural areas and in some of the poorest urban areas. We can provide this service because unlicensed access requires no fees and uses equipment that, because of economies of scale, costs a fraction of what equipment for licensed spectrum costs.
We are joined by the undersigned rural development and advocacy organizations in voicing our strong opposition to a proposal by FiberTower Corporation (“FiberTower”), Sprint Nextel Corporation (“Sprint Nextel”), the Rural Telecommunications Group, Inc. (“RTG”), and the Wireless Communications Association International (“WCAI”) requesting that the Commission “take immediate action to authorize limited fixed licensed use of a limited portion of the vacant TV Bands White Spaces (“White Spaces”) channels in rural and tribal areas.”
While this proposal may be in the best interest of these companies and their respective trade organizations, it is unequivocally not in the best interest of rural and tribal communities. Indeed, this proposal to license portions of the vacant “white spaces” TV bands will do lasting harm to the vacant TV channels’ potential, as unlicensed spectrum, to boost local innovation, local network investment, local economic development and job-creation, and community self-help in rural and tribal communities.
As the Commission’s own engineering studies have documented, and a voluminous public-comment record has affirmed, cognitive radios now exist – and will continue to evolve – which can co-habit the White Spaces without interference, both for backhaul links and last-mile broadband services. This technology will allow non-profits and small companies to strengthen existing community networks and deploy new ones. But this will only happen if the Commission ensures enough spectrum for manufacturers to see a viable market in which to invest.
If the Commission were to accede to the Fiber Tower Coalition’s proposal, manufacturers’ incentives for further innovation and refinement of long-distance backhaul radios would be greatly eroded. The proposal would take more than the 6 channels requested, as it would destroy the usefulness of adjacent channels due to out-of-band emissions. It is our understanding that while TV white spaces devices would be required to protect the new licensed backhaul service, the TVWS devices would also be required to accept interference from the licensed service. It should be self-evident that such a major reduction in unlicensed spectrum would likewise result in a major reduction of investment and innovation.
In addition, the need to create new rules for this licensed backhaul service will create new uncertainty and delay. Although the FiberTower coalition claims that they can use “off the shelf” technology to deploy immediately, the Commission would still need to propose new rules to resolve complex questions such as appropriate power limits, what constitutes “rural,” and other matters on which the Commission has not previously sought public notice. The delays inherent in this proposal, therefore, are very likely to discourage manufacturers from moving forward with the kind of full-bore development of white spaces technologies which our rural and tribal areas so desperately need.
It is our understanding that the FCC has already opened two proceedings to help with the problem of licensed backhaul: the NOI on reforming Part 101 and the effort to make FSS/MSS spectrum available. Rather than jeopardize the advance of unlicensed wireless broadband by reducing its potential spectrum and by introducing further delays and uncertainties, the FCC should look to these new proceedings to provide more spectrum for licensed wireless backhaul.
We greatly appreciate the Commission moving to expedite the deployment of unlicensed white spaces technologies. After working so hard in 2008 to support the Commission’s unanimous vote on the white spaces, our constituents have become very discouraged by the delays of the last two years. We look forward to the September 23 meeting and vote.
Mountain Area Information Network
34 Wall Street, Suite 407
Asheville, N.C. 28801
1915 J Street
Eureka, CA 95502
|Center for Rural Strategies
Media Working Group Inc.
|Tribal Digital Village Network
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