What is the real motivation behind the reluctance of the Federal Communications Commission to make a decision about what to do with the specialized mobile radio industry? Is it greed? Power? Or are they just caught in a quandary as to how to protect and serve everyone?
The freeze that has been in place for the past two years has caused irrevocable damage to many small and large SMR operators across the country. Our businesses have been stifled by this government control.
They have required us to sit on the bench for more than two years. And, if they expect us to compete with digital enhanced SMR, cellular and personal communications services, then they should change the rules to give us a handicap for making us sit on the bench for two years. It’s time to let us back in the game, so that we can continue to compete in our own industry for our share of the business. If they want us to have at least a fair chance to survive, then they must give us a handicap.
One way would be to allow us to be exempt from commercial mobile radio service rules as long as we are analog. There is no way that we can be expected to meet the CMRS requirements with our present equipment technology and financial resources. There is also no way that analog SMRs are any kind of threat to digital ESMR, cellular or personal communications services when it comes to interconnect.
Now, we come to the big issue of auctions. If the FCC’s intent is to foster big business and put all the small SMR operators out of business, then continue the freeze, auction both blocks, require analog SMRs that are interconnected to comply with CMRS rules and don’t allow basic trading areas. There is no way that any small SMR operator has the financial resources or knowledge to participate in this arena.
However, if the FCC really wants to level the playing field, then show us some good faith for the damage already inflicted upon us over the past two years by making SMR operators sit on the bench while the other players like cellular and PCS and ESMRs have been allowed to continue playing the game, scoring touchdown after touchdown by gobbling up the marketplace.
John R. Guzzo
Hudson Valley Communications
Paper contributes to policy overview
I am writing to correct two misimpressions created by an article in the Jan. 27 edition of RCR titled, “FCC’s proposed spectrum policy downgraded to staff paper.” Specifically, this article suggests that key Federal Communications Commission bureaus and offices were intentionally excluded from participating in the development of the paper. Second, the article implies that because the paper is not a commission policy statement, its value is greatly diminished.
First of all, much hard work, careful thought and staff cooperation went into this piece. From the start, it was a collaborative effort of many commission staff including engineers, lawyers and economists from the Office of Engineering & Technology, the International Bureau, the Mass Media Bureau, the Office of General Counsel, the Office of Plans and Policy and the Wireless Telecommunications Bureau. The drafting of the paper was, of course, spearheaded by Gregory Rosston and Jeffrey Steinberg, its co-authors.
Secondly, while it is not a commission policy document, the paper provides a much-needed overview of spectrum policy issues, particularly during this period of dynamic growth of the wireless industry. Not since 1945 has the commission set forth a comprehensive framework with respect to spectrum management. Among other things, the staff paper attempts to provide more certainty to the wireless marketplace by discussing ongoing and recommended spectrum management, allocation and assignment practices.
The paper was issued to help generate public comment on key spectrum management issues. Unfortunately, your article mischaracterizes both the process and the ultimate value of this effort. I hope that RCR will report in the future on the issues and ideas explored in this paper and that such articles will spur additional public comment and debate on spectrum policies.
Michele C. Farquhar, chief
Wireless Telecommunications Bureau
Federal Communications Commission
OET fully involved in drafting paper
I write to correct a misunderstanding reflected in a recent article in your usually accurate publication entitled “FCC’s proposed spectrum policy downgraded to staff paper.”
The article implies that the Office of Engineering & Technology was only made aware of the staff paper entitled “Using market-based spectrum policy to promote the public interest” at the last moment and had only limited input therein.
In fact, OET’s spectrum experts received the draft paper and had the opportunity to submit ideas and comments. The OET review was done, appropriately, well before the paper was sent to the commissioners.
I respectfully suggest that your readers might have been better served had the article discussed the conclusions and recommendations contained in the paper rather than suggesting that it did not reflect the consensus of those who participated in its formulation.
Richard M. Smith, chief
Office of Engineering & Technology
Federal Communications Commission
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