Interesting People mailing list archives
Apple's comments to Markey Committee re HR3636
From: David Farber <farber () central cis upenn edu>
Date: Wed, 16 Mar 1994 19:44:41 -0500
Honorable Edward Markey March 16, 1994 Page 1 March 16, 1994 Honorable Congressman Edward J. Markey United States House of Representatives 2133 Rayburn House Office Building Washington, DC 20515-2107 Dear Congressman Markey: You have raised a number of important issues with regard to the substitute amendment to H.R. 3636, SEC. 203, Broadcast Spectrum Flexibility. On behalf of Apple Computer, I would like to make the following observations. As you are well aware, the interests of computer companies, information providers, telecommunications entities, and broadcasters are converging. Legislative and regulatory decisions will determine both the role of industry participants and the path of technological development. Some of the most important of those decisions relate to the uses to which the radio spectrum will be put, the role of radio-based technologies in the national information infrastructure, and the terms under which industries and users needing spectrum will gain access to that spectrum. Consideration of alternative uses of broadcast-TV spectrum is, in this regard, a timely inquiry. The inquiry could result in the rededication of some of broadcastingUs vast spectrum resources to new and emerging technologies, while retaining the balance for the valuable purposes for which broadcast spectrum allocations were first made. You, the Congress, the Administration, and the FCC have made spectrum allocation for new technologies a high-priority issue. For example: % 200 MHz will be reallocated from the public sector to the private sector, over the next decade, in compliance with the Omnibus Budget Reconciliation Act of 1993, Title VI. The NTIA has identified possible frequencies, and release of the first 50 MHz appears imminent. % The FCC has reallocated 220 MHz from existing fixed microwave uses to Remerging technologiesS and 120 MHz of that will soon be auctioned to enable implementation of new families of PCS. % Of the 220 MHz referred to above, 40 MHz has been allocated for unlicensed PCS, including, with your support, for the Data-PCS capability so eagerly sought by the computer industry. (The obstacles involved in making that band available, however, remain of great concern.) Simultaneously, technical advances in modulation schemes, geographic frequency reuse and data compression are endowing each megahertz of spectrum with more information-carrying capacity. Taken together, the prospects of more spectrum, and better ways of using it, are rich indeed. The present issue regarding the future of the broadcast TV spectrum, therefore, should be viewed in the broader context of the critical, albeit sometimes painful, effort to assure a distribution of spectrum resources that best reflects societal needs and takes account of new technologies. In this regard, development of the broadcast TV spectrum or other spectrum from the growing pool of bandwidth should include a generous provision for unlicensed applications such as Data-PCS, which involves wireless local area high-speed communications among people using computing devices, without the burdens of usage-sensitive airtime charges. Spectrum for such technologies is the sine qua non for universal access to the NII gateways that will be provided by carriers, as well as for in-premises communications in businesses, schools, and health-care facilities. Unfortunately, the spectrum allocated to Data-PCS in the FCCUs PCS proceeding is encumbered with existing microwave operations and, therefore, does not fully meet the computer industryUs needs. Similarly, several of the directions now being taken in HDTV in the present FCC ACATS process merit review. For example, transition from NTSC to HDTV could be made more rapid and painless if embedded NTSC hierarchical encoding technology were added to the currently proposed HDTV system. Likewise, there are great disadvantages for making HDTV compatibility with computers merely an RoptionS for broadcasters, as could result from the present FCC ACATS process. The ability of HDTV to deliver legible text, maps, diagrams and other graphics will, in itself, represent an epochal improvement over todayUs NTSC television, but its value will be limited unless HDTV and computers speak the same technical dialect. Finally, the selection of the ATV system should be re-oriented to take into account the potential usefulness of ATV for the NII applications such as health care, education, library access, support of government, and enhanced electronic commerce. We believe the computer industryUs spectrum needs and its concerns about HDTV should be addressed within a comprehensive examination of new spectrum usage and opportunities. Issues regarding the convergence of the spectrum needs of broadcasters, the computer industry, and other proponents of new, spectrum-based technologies would be an appropriate topic of separate hearings before your sub-committee in which Apple would pleased to participate. Sincerely yours, James M. Burger, Esquire Director, Government Law
Current thread:
- Apple's comments to Markey Committee re HR3636 David Farber (Mar 16)