ALERT! Apple trying to steal Amateur Frequencies!

[California Wireless Incorporated <cwi@rahul.net>]

I well-connected friend of mine forwarded me the following paper from Apple.

I had always thought of Apple as "the good guys" when it came to Amateur
spectrum, but with their proposal to grab 2390-2400 away from hams, I no
longer consider them "on our side." 

The guy at Apple's email address is at the end of this article.

-Mike K3MC

p.s. "...band is not occupied" ... Indeed!
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                Unlicensed Wireless Data Communication
              "Will All the Public Beaches Be Auctioned?"

The FCC will make three frequency allocation decisions that will
either enhance or severely limit the ways computers are used in
libraries, schools and other institutions. At stake is the
availability of frequencies for nonlicensed, no-charge wireless data
communications (Data-PCS) within buildings and on campuses, as well as
for low-cost wireless access to the Internet and other off-site
resources. If the FCC is to continue to provide, and even expand, the
bands for public nonlicensed communications, the education community
must express its interests and concerns. Otherwise, these bands are at
risk of being auctioning to fee-based commercial licensees.

     The FCC has been auctioning off a good deal of the available
spectrum; primarily, to voice services where the winning bidder
effectively purchases spectrum wholesale and resells it retail to the
public. Whether this is a good model for voice is not at issue here.
But, however, it is clearly a poor model for data, particularly local
area networks or mobile peer-to-peer computing. A school, library or
other nonprofit institution, could not use the low cost alternative of
wireless data if they had to pay $.35 a minute per device while the
network was in operation. Moreover, private, pay for service wireless
networks are built primarily for voice and can accommodate data at
only fairly low speeds. On the other hand, estimates to install wired
networks for all US public K-12 schools in the range from $18-20
billion. Unlicensed wireless data networks, in a nationwide clear 10
MHz band, could provide high speed (1 to 2 Megabits) transmission at
costs significantly lower than a wired network.

     We believe that unlicensed wireless can provide an important
alternative to wired networks for schools, libraries and other
institutions. Currently, a number of companies have been experimenting
and offering commercial products in the 900 and 2400 MHz bands.
Because these bands are also the home to industrial, scientific and
medical devices, they are interference laden causing the wireless data
devices to operate a lower speeds than a band dedicated to data
transmission. Accordingly, Apple and other computer companies have
been fighting for the past ten years to obtain a nation-wide clear
piece of spectrum for unlicensed data.

Priority One:  Fulfilling the Data-PCS band at 2390-2400 MHz.

     The most important task for the FCC is to provide
permanently-dedicated, exclusive spectrum for Data-PCS, in sufficient
quantity to allow modern computer communications. The FCC can do so;
it was recently given jurisdiction over several radio bands previously
used by the Federal government. Among those bands, the segment
2390-2400 MHz is particularly attractive for nonlicensed data
applications:

     * It is adjacent to the present 2400-2483.5 MHz "Part 15" band in
which the majority of industry development is now taking place;
therefore equipment can be readily extended to use it.

     * Because the band is not occupied, many measures required to
deal with interference in the traditional Part 15 bands will not be
required.  Data rates (bandwidths) can be increased and equipment
costs significantly reduced.

    The FCC is now seeking public comment about the best way to use
this band (2390-2400 MHz). Educators, librarians, public interest
groups and other information professionals should express support for
dedicating it to no-charge nonlicensed Data-PCS rather than to yet
more license-auctioned, fee-based services. Correspondence to the FCC
on this topic should refer to "ET Docket 94-32."

Priority Two: Retaining the Part 15 band at 2400 MHz.

     As noted above there are two public unlicensed bands available
for use without charged. While they are not optimal for wireless data,
the are very useful for experimentation and offering of lower speed
data transmission.  Of the two, the 2400 MHz Part 15 band is the more
important in that devices operating there are able to obtain higher
data transmission rates (although not as high as possible with a
dedicate 10 MHz of spectrum such as proposed above for Data-PCS). The
FCC has proposed auctioning off the lower 15 MHz (2402-2417 MHz), even
though acknowledging the severe impairment of the band. The FCC's
original inclination to retain this band for nonlicensed Part 15
operation should receive full support, expressed in letters to the
Commission on ET Docket 94-32.

Priority Three:  Preserving the "900 MHz" nonlicensed (Part 15) band.

The 900 MHz band has been the incubator for development of a wide
array of nonlicensed consumer and business products, including
cordless phones, utility meter readers and energy-saving control
systems, wireless earphones and speakers, handheld rental car check-in
and point-of-sale terminals, and first-generation wireless computer
networks. New networks offering low flat-rate wide-area data
communications are also being deployed nationwide in this band.
Millions of such unlicensed devices are in operation today and more
are being turned on daily. Obviously, retaining the 900 MHz band is
essential for low-cost products that consumers expect to continue
using.


The FCC has proposed to give a priority license -- meaning any
unlicensed device that interferes must leave the channel -- to a
vehicle location system. Unfortunately, the 20 year old technology
proposed is said to be very interference prone. Thus, most current 900
MHz unlicensed devices would be banned (subject to penalties of up to
$10,000 per day). We are not opposed to the service, which could be
quite valuable. The FCC should, however, require that effective
spectrum conservation technologies be applied as a condition for
permanently authorizing these stations. The monitoring services could
thrive in only a small segment (certainly no more than 4 MHz) of the
900 band and the millions of Part 15 products could continue to use
the remainder.

Public comment to the FCC on "Docket 93-61" is needed, calling for
restricting these preclusive monitoring stations to a small part of
the band, and for continuing to make the band available for
nonlicensed devices.

The Necessary Sum of the Parts.

Each frequency band being scrutinized by the FCC has important
characteristics that define nonlicensed wireless communications and
the ways we will or will not benefit from these technologies.  The FCC
also now has the opportunity to allocate additional dedicated,
exclusive nonlicensed spectrum to be available to all users. Each band
and each set of rules is part of an essential array of permanent
spectrum resources. If, however, the regulatory process continues as a
series of unconnected negative decisions as is possible without public
expressions of interest and concern, there will be no public spectrum
resources. All of the public beaches will be auctioned off.

Each of us can envision how we might use nonlicensed wireless communications.
Now we must convey our visions to the FCC. If we do so effectively,
the process will serve us well.

How to be heard:

The summary of the discussion above is that the FCC should be told
that there are compelling demands and values for nonlicensed wireless
bands, that cannot be met through licensed radio services. You should
ask the FCC to take every necessary step to fulfill these needs.

Your written comments to the FCC can be sent to:

Chairman Reed Hundt
Federal Communications Commission
Room 814
1919 M Street N.W.
Washington, DC 20554

You may also wish to describe your objectives to your elected
representatives in Washington and ask them to contact the FCC.

For further information: Jim Burger [burger@apple.com], Director of
Government Affairs, Apple Computer, Inc. (202) 466-7088