[comp.dcom.lans] Data-PCS Petition - Please Comment

bsteven@Apple.COM (Bill Stevens) (05/05/91)

Dear Reader,


On January 28, 1991, Apple Computer filed a petition with the Federal 
Communications Commission, requesting the creation of a new radio
band, which we call "Data-PCS".

May 10, 1991 is the FCC's deadline for comments from the public on this
important issue.  If created, Data-PCS will enable all computer
manufacturers to produce high performance wireless communications products
for the United States.

Please review the following information, and consider what benefits
YOU might gain from the creation of this new communications capability.
Instructions are included for writing directly to the FCC.  Alternately,
you may simply "reply" to this posting, which will return your electronic
comments to Apple Computer.  We will forward all such replies to the FCC.
The preferable approach, of course, is to mail a personal letter to the 
Chairman of the FCC, as described below.


Thank you,
William M. Stevens
manager, Wireless Communications Research
Apple Computer


P.S.  A "text" version of Apple's "Data-PCS" petition may be obtained 
via anonymous FTP from:

     ftp.apple.com
	 /pub/fcc/datapcs.txt
	 
If you desire a copy of the petition but are unable to obtain it via
this method, please reply to this posting (at data.pcs@applelink.apple.com),
and indicate that you are requesting a copy of the petition.
----------------------------------------------------------------------------




										April 24, 1991


An Open Letter from David Nagel, 
Vice President for Advanced Technologies, Apple Computer, Inc.
 
Apple recently asked the Federal Communications Commission (FCC) to allow 
radio frequencies to be used for wireless data communications.  We call this 
new technology "Data-PCS," for Data Personal Communications Service.  It will 
permit high-capacity computer information to be communicated among people 
using personal computers, throughout a radius of about 50 meters indoors.  
Today there is no provision in the law assuring this function- and we need 
your help to make Data-PCS possible.
 
Apple is asking that computers be able to communicate wirelessly the way they 
do on wired networks (at high speeds and sharing the network equitably).  We 
are asking that a small part of the airwaves be made available to all computer 
manufacturers and users, without requiring radio licenses or having to pay for 
using the airwaves.  Apple's vision of Data-PCS particularly focuses on 
"spontaneous" computer communications, whenever and wherever you want to 
access resources or collaborate with others having similarly equipped PC's or 
other compatible equipment. 

The convergence of wireless communications and computers, particularly 
portable computers, will dramatically change the nature of computing.  People 
in business, scientists, engineers - those in all walks of life - will be 
liberated from the constraints of physical networks.  Creativity and personal 
productivity will be enhanced.  Students and teachers will no longer be 
confined to a rigid classroom set-up.  Instead, computing, communications, and 
therefore learning, will take place everywhere.  

John Sculley, Apple's CEO, recently said: "The key strength of twenty-first 
century organizations will be not their size or structure, but their ability 
to simultaneously unleash and coordinate the creative contributions of many 
individuals."  Data-PCS is one of the tools that will enable individuals to 
realize this vision. 

Data-PCS is being featured in numerous newspapers, magazines and professional 
journals.  Recently IBM, NCR, Tandy, Grid and other computer companies have 
told the FCC that they strongly endorse the need for radio spectrum for Data-
PCS.  
 
But Data-PCS is now a vision, not yet a reality.  It will not happen unless 
the FCC adopts new Federal regulations.  Radio spectrum is a scarce and 
valuable commodity, sought for many functions.  Apple is asking the FCC to 
give Data-PCS "equitable" consideration when viewing needs for spectrum.  When 
the FCC passes new regulations, Apple and a host of other companies can make 
Data-PCS real.

The most powerful voices in support of Data-PCS will be those of users like 
yourself.  I ask you to write to the FCC, not only stating your support but, 
to the extent you are willing, explaining how you might find Data-PCS of value 
to you and your organization.  Suggestions on how to direct your comments are 
attached.  The FCC's formal review process on Data-PCS has a next major 
milestone May 10;  I hope you'll write by then.  

Thank you for considering this issue.  The true value of Data-PCS will only be 
realized when it is available to all of us.  I hope you share our vision and 
will help make it come true. 

          Very truly yours, 
          David Nagel
          Vice President, Advanced Technology Group
          Apple Computer, Inc.








Supporting Data-PCS:

Please write a letter using the reference number the FCC assigned our petition 
for Data-PCS:  "RM-7618."  You should address and send your letter as follows:


(On your institution's letterhead if possible.)

(Date)
Hon. Alfred C. Sikes, Chairman
Federal Communications Commission
Washington, D.C.  20554
 
Reference: Rulemaking  7618
 
Dear Mr. Chairman:
 
We (I) understand that Apple Computer, Inc. ("Apple") has asked 
the FCC to allocate spectrum to establish a new radio service 
("Data-PCS") for local area high speed communications among 
personal computing devices.  We are writing to urge you to grant 
Apple's request (RM-7618).
 
(Please describe in the text your views on how Data-PCS could be 
important to you.)
 
Respectfully submitted,
 
Your name and title or function
 

If you would like a copy of Apple's Petition to the FCC for Data-PCS, or if 
you have questions, please call (408) 974-4674 or email to:


     internet:   data.pcs@applelink.apple.com
	 applelink:  data.pcs

henry@zoo.toronto.edu (Henry Spencer) (05/05/91)

In article <52465@apple.Apple.COM> bsteven@Apple.COM (Bill Stevens) writes:
>... I ask you to write to the FCC, not only stating your support but, 
>to the extent you are willing, explaining how you might find Data-PCS of value 
>to you and your organization...
>Please write a letter using the reference number the FCC assigned our petition 
>for Data-PCS:  "RM-7618." ...
>"...We are writing to urge you to grant Apple's request (RM-7618)..."

A note of caution:  there are two separate issues here, and Apple is
(deliberately or accidentally) confusing them.  One is whether spectrum
provision for radio local networks is desirable.  The other is whether
Apple's specific proposal should be adopted as the means to that end.

I would suggest that you should not write to the FCC saying "please do
it Apple's way" unless you have studied the details of Apple's proposal
and understand the tradeoffs involved.  If your position is "radio
networking would be very useful to us, although we don't understand the
specifics of Apple's proposal and its implications", say exactly that.

I have *not* studied the specifics of Apple's proposal, and am not up
on the complex tradeoffs involved in spectrum allocation, so I cannot
comment one way or another on the technical merits of their proposal.
But I will say that this public appeal, and its wording, make me very
suspicious that somebody's trying to pull a fast one.  "Don't worry
about what the fine print says, you wouldn't understand it anyway, just
hurry up and sign it."
-- 
And the bean-counter replied,           | Henry Spencer @ U of Toronto Zoology
"beans are more important".             |  henry@zoo.toronto.edu  utzoo!henry

nelson@sun.soe.clarkson.edu (Russ Nelson) (05/05/91)

In article <1991May5.051210.23293@zoo.toronto.edu> henry@zoo.toronto.edu (Henry Spencer) writes:

   I have *not* studied the specifics of Apple's proposal, and am not up
   on the complex tradeoffs involved in spectrum allocation, so I cannot
   comment one way or another on the technical merits of their proposal.
   But I will say that this public appeal, and its wording, make me very
   suspicious that somebody's trying to pull a fast one.  "Don't worry
   about what the fine print says, you wouldn't understand it anyway, just
   hurry up and sign it."

Not to mention the fact that their petition doesn't specify who's going to
*lose* spectrum.  I also couldn't find a copy of the petition posted to
rec.radio.amateur.misc, where there are a number of people qualified to
discuss the specifics of it.  I also noticed a separate copy of the article
posted to comp.sys.ibm.pc.misc.

--
--russ <nelson@clutx.clarkson.edu> I'm proud to be a humble Quaker.
It's better to get mugged than to live a life of fear -- Freeman Dyson
I joined the League for Programming Freedom, and I hope you'll join too.

woody@ucscb.UCSC.EDU (Bill Woodcock) (05/07/91)

    
        > henry@zoo.toronto.edu (Henry Spencer) writes:
        > This public appeal, and its wording, make me
        > very suspicious that somebody's trying to
        > pull a fast one.  "Don't worry about what the
        > fine print says, you wouldn't understand it
        > anyway, just hurry up and sign it."
         
        > nelson@sun.soe.clarkson.edu (Russ Nelson) writes:
        > Not to mention the fact that their petition
        > doesn't specify who's going to *lose*
        > spectrum.  I also couldn't find a copy of the
        > petition posted to rec.radio.amateur.misc,
        > where there are a number of people qualified
        > to discuss the specifics of it.  I also
        > noticed a separate copy of the article posted
        > to comp.sys.ibm.pc.misc.
    
    Insofar as I know, there are two groups concertedly opposed to Apple's
    proposition:  Telcos,  (primarily  BellSouth  and AT&T) and utilities.
    (Local public utilities, and railroads.)
    
    The FCC has, at the behest  of  a  group  of  Telcos,  been  making  a
    long-term inquiry into the possibility of PCS (Personal Communications
    Services) and PCN (Personal Communications  Networks)  since  June  of
    1990.  Since  the  beginning  of  this year, Apple has "subverted" the
    Telco's proposal, which included provision for _both voice and  data_,
    and was moving ahead at a leisurely pace, changed it to suit their own
    needs, accelerated the pace, and refused to answer any questions about
    their intentions.
    
    Basically, this mean  that  they  dropped  all  provisions  for  voice
    communications,  which  I  consider  vital,  since currently allocated
    cellular bandwidth won't last  us  forever,  and  have  been  avoiding
    dealing  with issues like security, what to do with the people who are
    currently using the bandwidth, and where to expand cellular to.
    
    So, this brings us to the utilities, who are the current licensees  of
    the  bandwidth.  So  far,  the primary users of the "Operational Fixed
    Service Licenses" in   this   area  of  the  spectrum    are    public
    utilities, like  your  gas,  water, electric, and possibly  even  your
    local  telco.  They've been using the bandwidth to communicate between
    offices,  and to  communicate  with  service  vehicles. Railroads have
    also invested heavily in transmitter towers located every 40-50  miles
    along  their rights-of-way.  Currently, most estimates show that about
    a third of a billion  dollars  worth    of    capital   investment  in
    frequency-specific equipment  would  be  rendered useless, if  Apple's
    version of  the  bill  passes  unmodified.    There  is  currently  no
    provision  in  Apple's  bill for  compensation,  and I find this to be
    a rather remote prospect, in  any  case,   since  Apple  has  proposed
    that  the  bandwidth  be  made available to all computer vendors.
    
    I suggest two possible compromises:
    
    1)  Apple  could  just  use the bandwidth that the FCC has already set
    aside for the purpose of unlicensed microwave  transmission  in  Parts
    15.247 and  15.249.    Several  vendors  have  already  started making
    networking components which utilize this area of the spectrum, and are
    having notable success.  This area is significantly more hospitable to
    high-bitrate communications than the  even  shorter  frequencies  that
    Apple has asked for, but Apple couldn't monopolize it.
    
    2) Apple could, as Motorola has done, just buy an expanse of spectrum,
    up where there's little demand, and do whatever they  feel  like  with
    it.   They   wouldn't  need  to  worry  about  displacing  anyone,  or
    commandeering anyone  elses'  planned  expansion,  and  they  wouldn't
    have any competition within that spread.
                             
                            -Bill Woodcock
                             BMUG NetAdmin

________________________________________________________________________________
bill.woodcock.iv..woody@ucscb.ucsc.edu..2355.virginia.st..berkeley.ca.94709.1315