Greetings. Today, with the
approval of the Executive Committee, I have edited and filed the attached
comments with both FCC and NTIA.
FCC and NTIA jointly propose in
this proceeding to establish, via a public/private partnership, a "model
city" (i.e. an urban environment) that is considered a test bed for spectrum
sharing and technology development and initial rollout and evaluation. The
original idea came from the President's Council of Advisors on Science and
Technology in 2012.
These comments were prepared
initially by Brennan Price and reviewed by me when I first saw them yesterday
afternoon. The basic premise of our comments is that there can't be a model city
for technological development and spectrum sharing without integrating Amateur
Radio in it. There is also an important segment at the end about the inherent
inequity and failure of the concept of a Model City for technological rollout
and testing if some of the services in the model city are saddled with
public,private or environmental antenna regulations which preclude the creation
of a realistic environment.
The EC has directed that
we monitor this proceeding because, absent our meaningful participation in Model
City technological investigation, we could be very much out in the cold. Today
is the comment date so we will know soon what others have said. There is not a
reply comment period permitted by the public notice, but we can get in some
rebuttal if we need to do so.
This was prepared at the very
last minute for various reasons so thanks to the Executive Committee for a quick
review and turnaround on this and for their patience. We will try to prevent a
recurrence of the timing of this.
Let me or Brennan know any
questions you have about this filing.
73, Chris W3KD
Christopher D. Imlay
Booth, Freret & Imlay, LLC
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile