ArsTechnica notes that a pair of last-minute FCC filings from both Google and the Public Interest Spectrum Coalition (PISC) have just weighed in on whether the agency should support M2Z Networks’ plan for nationwide broadband access.
The Public Interest Spectrum Coalition filing to the FCC says:
If the Commission denies the M2Z Application, it should not let this valuable spectrum continue to lie fallow. Rather, the Commission should move immediately to a Notice of Proposed Rulemaking (NPRM) to establish service rules for the band.An NPRM should also explicitly seek comment on whether to open the band to “unlicensed” or “license-lite” use, such as that approved in the 3650-3700 MHz Band. The AWS-3 band lies between the existing 2.4 Ghz unlicensed bands and 900 MHz unlicensed bands. Existing Part 15 chipsets are capable of transmitting and receiving on the 2.155 GHz band although manufacturers suppress this capacity to comply with existing certification rules.
If the Commission modified Part 15 to permit operation of unlicensed devices in the band under rules similar to those for 2.4 Ghz devices, users could immediately take advantage of this new capacity by modifying existing equipment software. In a stroke, the Commission could exponentially increase the ability of community network operators, municipal operators, and commercial wireless ISPs (WISPs) to provide broadband services.
Cellular carriers oppose the M2Z plan. The CTIA called M2Z’s plan a “self-serving attempt to gain access to valuable spectrum outside of the auction process (pdf). The CTIA argued in an FCC filing (PDF) that the plan creates “a number of legal and public policy problems without serving the public interest” and that M2Z should have to bid on spectrum like everyone else.
M2Z wants the FCC to give them 20 Mhz of unpaired spectrum on top of the 2.1 GHz AWS band, at 2155-2175MHz. Without an auction. In exchange, M2Z would build a (free) nationwide wireless broadband network. M2Z would pay the Treasury 5% off the top from revenue generated from their faster subscription service. The limited speed (384 kbps), advertising-sponsored service would be “porn-free”, and available nationwide.
Google and PISC now see an opportunity to bring “open access” to the 2.1 GHz band.
Reportedly, FCC officials have indicated the agency plans to veto the proposal. That could leave an opening for Google and PISC to fill the void with an alternative proposal.
According to ArsTechnica, Google says that it “does not here take a substantive position on the relative merits of M2Z’s proposals,” and the PISC filing notes that the group “cannot support grant of the Application as filed.” But both groups are excited about possibilities for the band, especially the “open access” conditions that both groups wanted to see imposed on the 700MHz auction.
Currently, the 900MHz and 2.4GHz bands have grown crowded with cordless telephones and WiFi routers, while the higher 5.8GHz band has limited range and will shortly be filled with “ganged” channels using 802.11n.
Opening up another 20 MHz of unlicensed spectrum would help solve the problem. Another proposal, currently under FCC study, uses “white spaces” — unused television channels on the UHF band. That proposal would use “smart radios” to avoid interference with broadcasters.
There is also another option — 3.65 GHz for (lightly) licensed backhaul. It features a mid-range blend of power allotment (higher than unlicensed spectrum and lower than licensed spectrum) with 50 MHz available. A “Detect and Protect” contention protocol is designed to prevent interference in both the 25 MHz restricted and unrestricted spectrum blocks.
PISC thinks “smart radios” are a good solution for the 2155-2175MHz band, too. Instead of some kind of licensed mobile WiMAX-type approach, PISC belives that (unlicensed) community networks could be built using a “Detect and Protect” contention protocol to avoid congestion and interference.
If the FCC decides against M2Z’s proposal, it is expected to launch a new rulemaking procedure for the 2155-2175 MHz spectrum, complete with public comment periods and reply periods.
Related DailyWireless articles include; M2Z: Free Internet Now!, Broadband Wireless — Hello Goodbye, Statewide/Nationwide Wireless Broadband, National Broadband: Fee & Free, The AWS & 700MHz Dance, and FCC Rules on 700MHz: Limited Open Access, No Wholesale Requirement.









