Re: [802SEC] ***SEC Five Day Review*** RR-TAG Comments on FCC WT Docket 06-49, Rule Changes for the Lower 900 MHz Frequency Band
Dear EC Colleagues,
I participated in the review of this document and voted to approve it in
.18. If this were an EC vote to approve it I would vote "approve" again.
802 (or 802.18, I don't recall which) has previously (successfully) opposed
the attempts by the M-LMS licensee to persuade the FCC to expand its
operations and I urge you all to allow this document to go forward in a
timely manner for the same reasons we opposed before.
The M-LMS operations at issue are controlled by essentially one individual
who has tried repeatedly to expand the nature and terms of the licenses he
and his various companies hold, to the detriment of the unlicensed devices
in the band that the FCC recognizes are important (that's why the FCC
established a "safe harbor" for unlicensed devices ... which states, in
effect, that if the unlicensed devices comply with Part 15 of the FCC rules,
*by definition* they may not be deemed to cause harmful interference to
M-LMS).
The M-LMS licensee knew the terms and restrictions on his licenses when he
bid on them quite a few years ago ... and has done little/nothing with the
spectrum, despite repeated attempts to persuade the FCC to change the terms
of the licenses to allow greatly expanded usage of the band that would
adversely affect pre-existing and new Part 15 uses, some of which involve
802 standards. The actions of the licensee are akin to buying a house
cheaply right at the end of the LAX runway, then turning around and seeking
to close the airport (that you knew darned well was there) because you don't
want to put up with the noise.
Regards,
Carl
> -----Original Message-----
> From: ***** IEEE 802 Executive Committee List *****
> [mailto:STDS-802-SEC@ieee.org] On Behalf Of Michael Lynch
> Sent: Wednesday, May 24, 2006 6:30 PM
> To: STDS-802-SEC@listserv.ieee.org
> Subject: [802SEC] ***SEC Five Day Review*** RR-TAG Comments
> on FCC WT Docket 06-49, Rule Changes for the Lower 900 MHz
> Frequency Band
>
> Dear SEC Members,
>
> Attached are comments that the RR-TAG proposes to file with
> the FCC. The subject of WT 06-49 is "Amendment of the
> Commission's Part 90 Rules in the 904-909.75 and 919.75-928
> MHz Bands". This band is shared between a variety of
> unlicensed and licensed services. The proposal would remove
> the restriction on M-LMS operators that currently prevent
> them from providing voice services and PSTN connectivity. The
> RR-TAG, in consultation with 802.15, is of the view that the
> changes will adversely impact unlicensed technologies that
> coexist under the current rules with the M-LMS service. The
> rules as they exist today are those that were taken into
> consideration by the M-LMS operators when they bid for their
> licenses in the 1990s. Similarly manufacturers have, based on
> those same rules, invested in developing unlicensed products
> for that frequency band that are widely used today by
> consumers. The FCC created a "safe harbor" in this band for
> unlicensed devices which should be maintained.
>
> The RR-TAG developed these comments during its May interim in
> Jacksonville. A quorum was present and these comments were
> approved by a vote of 9 Yes, 0 No, 0 Abstain.
>
> The comment period for 06-49 closes 30 May. I propose that
> the EC review begins today (24 May) and closes at midnight CDT 29 May.
>
> Regards,
>
> Mike
>
> +1 972 684 7518 (ESN 444 7518) Voice
> +1 972 684 3774 (ESN 444 3775) FAX
> +1 972 814 4901 (ESN 450 9401) Mobile
>
> <<18-06-0040-00-0000.doc>>
>
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