[arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies
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 W3KD@ARRL.ORG
Nicely played Chris and Brennan! 73, Doug K4AC From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Friday, August 29, 2014 12:38 PM To: arrl-odv Subject: [arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies 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 W3KD@ARRL.ORG
I thank the Executive Committee for its quick review and Chris for his edits and filing. I recommended filing favorable comments in large part because our allies in the DoD (at least at the senior executive level) are committed to real-world testing of spectrum sharing arrangements going forward. They justifiably view it as an improvement over some scattershot approaches that have been taken in the past. DOD's main concern was that real-world testing in a Model City should come at the proof-of-concept stage, only after joint, public-private negotiation and analysis of a sharing protocol and testing in a controlled environment. They also didn't want a permanent Model City named, as there is no one city that will be ideal for each analysis. Their positions on both these issues were also in our interest, so I worked them into our main argument, which Chris accurately described. This was a good exercise in keeping our sharing partners close. The chance to take a dig at CC&Rs was gravy. And very tasty gravy. 73 de Brennan N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079 ________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of Imlay, Chris, W3KD Sent: Friday, August 29, 2014 12:38 To: arrl-odv Subject: [arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies 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 W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG>
Brennan, It seems to me that the past few filings have come to us at the proverbial “last minute.” I have to wonder why that is, as the FCC gives ample time for notification and response. There is no reason for us to have to scramble to get things in the proper shape for approval. Could you explain to me why this is? Tnx es 73, Mike - - - - - - - - - - - - - - - Mike Lisenco, N2YBB Director, Hudson Division ARRL - The national association for Amateur Radio™ 917-865-3538 n2ybb@arrl.org From: Price, Brennan, N4QX Sent: Friday, August 29, 2014 1:48 PM To: arrl-odv Subject: [arrl-odv:23253] Re: FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies I thank the Executive Committee for its quick review and Chris for his edits and filing. I recommended filing favorable comments in large part because our allies in the DoD (at least at the senior executive level) are committed to real-world testing of spectrum sharing arrangements going forward. They justifiably view it as an improvement over some scattershot approaches that have been taken in the past. DOD's main concern was that real-world testing in a Model City should come at the proof-of-concept stage, only after joint, public-private negotiation and analysis of a sharing protocol and testing in a controlled environment. They also didn't want a permanent Model City named, as there is no one city that will be ideal for each analysis. Their positions on both these issues were also in our interest, so I worked them into our main argument, which Chris accurately described. This was a good exercise in keeping our sharing partners close. The chance to take a dig at CC&Rs was gravy. And very tasty gravy. 73 de Brennan N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079 -------------------------------------------------------------------------------- From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of Imlay, Chris, W3KD Sent: Friday, August 29, 2014 12:38 To: arrl-odv Subject: [arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies 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 W3KD@ARRL.ORG -------------------------------------------------------------------------------- _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv
Mike (and all), The timeliness of this particular draft fell well short of the standards I set for myself and that CEO Sumner and the board ought to expect from me. The desirability of coordinating a response with the DoD and an unexpected but necessary trip to visit my parents this past weekend delayed the work somewhat, but not to the extent that lack of timeliness is excusable. I take some exception to the perception that the "past few filings" have come at the last minute. Over the last year, there have been six additional filings to which I have substantially contributed, and my records reflect the following dates for initiation of EC review and for filing (I am not on the EC reflector, so it may be possible that my review initiation dates are incorrect in some instances): * Response to Mimosa 10 GHz Petition for Rulemaking: EC Review 4/8, filing 4/10 * FCC Process Reform: EC Review 3/27, filing 3/31 * WRC-15 Advisory Committee Comments on January 2014 Proposals: EC Review 2/14, filing 2/18 * RM-11708 Reply Comments: EC Review 1/5, filing 1/7 * WRC Advisory Committee Comments on September 2013 Proposals: EC Review 10/3/13, original filing deadline 10/11/13, actual filing 10/17/13 after government shutdown * RF Exposure Limits: EC Review 8/29/13, filing 9/3 The two-day windows on Mimosa and the RM-11708 reply comments were not ideal, but there were some moving parts at play and necessary review by multiple people on both of these, particularly RM-11708. The remaining windows reflect the lead time that I strive to provide and that I think the EC can reasonably expect. The next round of WRC Advisory Committee comments was solicited yesterday and has a short fuse reply date of September 12. I have an imminent opportunity to do better, and I will take it. 73, Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079 ________________________________ From: Lisenco, Mike (DIR, Hudson) Sent: Friday, August 29, 2014 16:07 To: Price, Brennan, N4QX; arrl-odv Subject: Re: [arrl-odv:23253] Re: FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies Brennan, It seems to me that the past few filings have come to us at the proverbial “last minute.” I have to wonder why that is, as the FCC gives ample time for notification and response. There is no reason for us to have to scramble to get things in the proper shape for approval. Could you explain to me why this is? Tnx es 73, Mike - - - - - - - - - - - - - - - Mike Lisenco, N2YBB Director, Hudson Division ARRL - The national association for Amateur Radio™ 917-865-3538 n2ybb@arrl.org From: Price, Brennan, N4QX<mailto:bprice@arrl.org> Sent: Friday, August 29, 2014 1:48 PM To: arrl-odv<mailto:arrl-odv@arrl.org> Subject: [arrl-odv:23253] Re: FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies I thank the Executive Committee for its quick review and Chris for his edits and filing. I recommended filing favorable comments in large part because our allies in the DoD (at least at the senior executive level) are committed to real-world testing of spectrum sharing arrangements going forward. They justifiably view it as an improvement over some scattershot approaches that have been taken in the past. DOD's main concern was that real-world testing in a Model City should come at the proof-of-concept stage, only after joint, public-private negotiation and analysis of a sharing protocol and testing in a controlled environment. They also didn't want a permanent Model City named, as there is no one city that will be ideal for each analysis. Their positions on both these issues were also in our interest, so I worked them into our main argument, which Chris accurately described. This was a good exercise in keeping our sharing partners close. The chance to take a dig at CC&Rs was gravy. And very tasty gravy. 73 de Brennan N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079 ________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of Imlay, Chris, W3KD Sent: Friday, August 29, 2014 12:38 To: arrl-odv Subject: [arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies 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 W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG> ________________________________ _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv
participants (4)
-
Christopher Imlay -
Doug Rehman -
Mike Lisenco N2YBB -
Price, Brennan, N4QX