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Apple filed numerous documents with the FCC, regarding NII Band and Spread Spectrum. They are a matter of public record with the FCC (Federal Communication Commission), but we have provided many of them on this website for your convenience.
 
Apple filed numerous documents with the FCC, regarding NII Band and Spread Spectrum. They are a matter of public record with the FCC (Federal Communication Commission), but we have provided many of them on this website for your convenience.
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=Summary=
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Apple's May 24, 1995, NII Band Petition for Rulemaking described the company's vision for creation of an unlicensed "NII Band" in the 5 GHz range. Along with a petition submitted by WINForum, Apple's Petition formed the basis for the proposals set forth in the NPRM.
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Apple welcomes the Commission's decision to embrace the concept of an NII Band and its prompt action to implement the proposals outlined by Apple and WINForum. It strongly supports the Commission's proposal to make available 350 MHz of spectrum for use by "NII/SUPERNet" devices.
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Apple, however, believes that the Commission took an overly conservative approach on the maximum power level permitted for all NII/SUPERNet devices. Apple recommends a transmitter power of 0.1 watt (+ 20 dBm) and 0.316 watts (+ 25 dBm) for personal/portable and fixed equipment, respectively, with, of course, the proviso that antenna gain not be restricted for point-to-point, fixed outdoor links.
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With respect specifically to longer reach "community networks," the Commission has overemphasized the risk of harmful interference and understated the public need for a low cost, flexible, easily implemented means of meeting the communications needs of those who are underserved by alternative technologies and services. As a result, the Commission proposed certain restrictions on the operation of longer-distance NII/SUPERNet devices that would prevent the development of community networks at 5 GHz and limit the full utility of wireless NII/SUPERNet local area networks.
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Community networks must be provided for adequately if the Commission is to satisfy the core goals underlying its NII/SUPERNet proposal. Longer- distance links are an integral part of solving the communications needs of individuals: local area networks, while important, will not provide full value unless they can be connected with the broader information infrastructure. Yet for far too many users, longer distance connections linking them to the broader information infrastructure are unavailable or prohibitively expensive. While universal service requirements can help to alleviate the problem of differential access to the NII, they alone cannot solve it. The Commission must seize this opportunity to create a low-cost, flexible means for creating longer distance connections.
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In its NII Band Petition, Apple proposed that community network links operate with a transmitter output power of up to 1 watt -- the same power now permitted under Part 15 spread spectrum rules for use of the 5800 MHz ISM frequencies, whose frequencies match the upper portion of the proposed NII/SUPERNet Band, and for HIPERLAN transmitters in Europe, whose allocated frequencies match the lower portion of the proposed NII/SUPERNet Band. Yet community networks have been tarred with the false and misleading label of "high power" and somehow differentiated from other applications allowed the same power. This has caused the Commission and some other parties to overestimate the possibility that community network links could threaten the reliable operation of other services.
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Although one watt ordinarily would not be described as "high power," Apple believes that community network technologies would not be adversely affected if they were restricted, as Apple has proposed for all NII/SUPERNet devices, to transmitter power of 0.1 watt (+ 20 dBm) and 0.316 watts (+ 25 dBm) for personal/portable and fixed equipment, respectively, with, of course, the proviso that antenna gain not be restricted for point-to-point, fixed outdoor links. These power levels, combined with the use of narrow beam directional antennas, would support the essential requirements of community networking while addressing the concerns that have been raised about operation at a 1 watt output power.
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In a further response to concerns about interference, Apple proposes that the Commission adopt a simple over-arching "band plan" that divides the NII/SUPERNet Band into two sub-bands: one optimized for the operation of very high rate ("VHR") systems, and the other open to all devices meeting the more general NII/SUPERNet technical rules. The VHR-only sub-bands should be located at 5150-5250 MHz and at 5825-5875 MHz, which would provide a total of 150 MHz of spectrum devoted exclusively to VHR-type systems. These sub- bands would be governed by rules addressing solely VHR operations, and technical standards could be designed specifically to meet the unique requirements of very high rate operation. All non-VHR operations, including community networks, would be excluded from this portion of the NII/SUPERNet Band.
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The remainder of the NII/SUPERNet Band -- 5250-5350 MHz and 5725- 5825 MHz -- would be open to all NII/SUPERNet devices, including VHR systems, community network links, and other devices whose users will make a host of tradeoffs between power, bandwidth, and distance. The rules governing these "open access" sub-bands would be more flexible and accommodating than the VHR-only technical rules, and would not be optimized for any particular technology or service.
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In adopting rules to govern the operation of NII/SUPERNet community network devices, the Commission should not mandate licensing. Fears of a "tragedy of the commons" are based on questionable assumptions and must not be overstated and invoked to prohibit a much-needed technology. In particular, proposals to license NII/SUPERNet community network links ignore the fundamental nature of this type of operation -- shared use of the spectrum resource -- and would force those who would prefer an unlicensed solution to use a licensed alternative, undermining, perhaps fatally, the development of community networking.
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Moreover, there is no reason for the Commission to destroy the promise of community networking by forcing it into a licensed model. Given Apple's proposed band plan, community networks do not present an unreasonable threat of interference to others using the NII/SUPERNet Band. Licensing also will not lead to more efficient spectrum use. In fact, licensing community network users may lead to decreased spectrum and economic efficiency.
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Because the Commission should reject any suggestion of licensing community networks, Apple comments only briefly on the statement in the NPRM regarding potential auctioning of NII/SUPERNet community networking links. The entire premise of a potential is misguided, both because the Commission's auction authority would not extend to community networks and because any approach based upon licensing by geographic area, such as BTA or MTA, rather than on a link-by-link basis would recreate many of the problems community networks were designed to overcome. For the same reasons that licensing of 5 GHz community network links would be unwise and detrimental to the interests of those who would be served by these networks, it would be inappropriate to rely solely on other licensed providers to satisfy the appetite for community networking.
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While licensing should not be employed, several non-intrusive "hooks" can be used to promote opportunities for cooperation among community network users and, thereby, minimize any theoretical risk of a "tragedy of the commons." These could include the use of an imbedded unique transmitter ID, a publicly available, on-line data base containing information about users' equipment, and an informal system for coordination. Prior to adopting any frequency registration and coordination system, however, the Commission should solicit the views of those who would be affected by the system, in particular potential users of unlicensed community network links.
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Just as the concept of licensing should be abandoned, so too should the notion of imposing unique regulatory requirements on community networks that are interconnected to the PSTN. While the regulatory status of services provided using unlicensed devices may require Commission consideration, this question is not unique to community networks and need not be resolved in this proceeding.
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With respect to technical rules, Apple strongly supports the Commission's decision to adopt only minimal technical regulations governing operation in the NII/SUPERNet band and to leave the development of additional sharing rules to a more flexible industry process. This approach will maximize the diversity of devices that can operate within the NII/SUPERNet band, while providing adequate "ground rules" to promote efficient spectrum use and prevent interference to other services.
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The "interim rules" proposed by the Commission and derived from the rules in Subpart D, however, are not appropriate for use even on an interim basis. Rather than adopting interim rules, the Commission should set strict timeframes within which industry must develop sharing rules -- one year from the NPRM date for rules governing operation within the VHR-only bands, and six months from the date on which a Report & Order is released in this proceeding for the general use bands -- and should prohibit the introduction of NII/SUPERNet devices prior to these dates.
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Finally, while the Commission should endorse the principles underlying Apple's proposed "Part 16" approach, it need not create a new "Part 16" in its regulations. Specifically, the Commission should adopt an approach similar to that used for the Data-PCS bands at 1910-1930 MHz and 2390-2400 MHz and the millimeter wave bands at 59-64 GHz, including a reference to NII/SUPERNet use in the Table of Frequency Allocations, providing the spectrum certainty required for reliable operations, and promoting the development by industry of sharing rules and assure that any such rules provide fair and equitable access to the spectrum for all NII/SUPERNet devices. This approach is fully consistent with both the Communications Act and Commission precedent, and addresses the Commission's obligation under Sections 303(g) of the Communications Act and Section 706 of the Telecommunications Act of 1996.
    
=The NII Band: Suggested Technical Rules=
 
=The NII Band: Suggested Technical Rules=

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