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Comments on Cognitive Radio Policies
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posted by mpawlo
on Friday May 07, @02:56AM
from the stanford dept.
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Lauren Gelman writes "The Center for Internet and Society at Stanford Law School helped a group of technology companies file comments with the FCC on their cognitive radio rulemaking. We're going to be filing reply comments as well, so please contact Public Knowledge if your company is interested in signing on.
We argued:
A. The Commission fails to articulate an overarching vision for how cognitive radio capabilities will transform spectrum policy and use.
B. The Commission treats cognitive radio as deterministic rather than heuristic, ignoring the defining capacity of software defined radios-that they can adapt to their environment.
C. The Commission limits opportunities for innovation by choosing technology winners.
D. The Commission should not presupposes any additional rents from optimization of interference will accrue to current bandwidth licensees.
E. The Commission fails to address how a diminishing (if not disappeared) interference effect might alter the categorization of spectrum as a ÃÂlimited resourceÃÂ.
And offered these specific proposals:
A. The Commission must confirm that its long-term goal is to eliminate the old interference and property- based system that currently impedes innovation in cognitive radio devices, and that the proposals in the NPRM are first steps towards achievement of that policy .
B. The Commission must develop a timeline for this transformation .
C. The Commission must adopt the "Intelligent Device Bill of Rights" proposed by the Commission's Technical Advisory Council that states that that any wireless device may use any bandwidth to perform its function as long as it does not interfere with others, and that all users of the spectrum shall have the right to operate without harmful interference from others.
D. The Commission must reaffirm its commitment to continue releasing spectrum for unlicensed common use."
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