Bill Stevens <bsteven@apple.com> (05/03/91)
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,
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
------------
A SUMMARY of Apple's Data-PCS Petition to the FCC
(FCC RM 7618)
Apple Computer, Inc. ("Apple") proposes that the FCC initiate
a rulemaking to allocate 40 MHz in the 1850-1990 MHz band to a new
radio service to be used for high-speed, local area data
communications services ("Data- PCS") between and among people using
personal computers. FCC action is urgently needed because the
computer industry is rapidly developing technologies to meet the
requirements of computer users, and to bring the power of computing to
people who, for a variety of reasons, have been beyond its reach.
The development of computer technology over the past decade has been
characterized by three trends:
1) computers are increasingly being networked, using cabling and
common carrier facilities, to give users access to information from a
variety of sources;
2) the media of computing are changing from simple text and numbers to
new, information-rich data types: sound, speech, graphics and complex
imagery; and
3) technology improvements are allowing computers to be made smaller
and much more mobile than ever before.
As personal computer technology now moves from the desk-top to
the briefcase, the networking and portability features will become
mutually inconsistent unless the networking capability becomes as
personal and portable as the computer itself. With such a networking
capability, a person could communicate with his or her peers and could
access files, peripherals, and the gateways of wired and wireless data
networks, all within a "local area" of 50 meters. The development of
Data-PCS, therefore, will facilitate spontaneous, collaborative
computing in the work-place and in educational settings, thereby
increasing the productivity and efficiency of people in these
environments.
There are, however, presently no technologies and no radio
services that can be used to create the shared electronic space
necessary for collaborative computing, principally because no existing
technology or service can assure consistent, high-quality, high-
capacity data communications in a spectrum-efficient manner.
Apple, therefore, is proposing the creation of a new radio
service to be devoted primarily and exclusively to local area, high
speed data communications to support collaborative computing and
spontaneous networking. As conceived by Apple, a Data-PCS radio
service would:
* be accessible to users of personal computers without imposition of
licensing obligations, network connection fees, or air-time charges;
* be open to any computer manufacturer's products and any network
access and usage scheme that complies with the regulatory
requirements;
* be regulated in a manner that assures non-discriminatory access to
assigned frequencies by compatible devices for like purposes; and
* have flexibility built into the initial regulatory scheme to
encourage innovation in and the evolution of Data-PCS technologies and
services.
In particular, Apple urges the Commission to allocate 40 MHz
between 1850 MHz and 1990 MHz for Data-PCS, preferably 1850-1890 MHz,
because these frequencies have optimum propagation characteristics for
local area, in-building use. Such an allocation will allow several
networks with data rates of, for example, 10 Mbps (rates comparable to
EtherNet or other highspeed wired LAN technologies of today), to
coexist in the same location.
The Commission should model the basic regulatory structure for
Data-PCSon Part 15 of the FCC Rules, relying on manufacturers and the
equipment authorization process rather than on individual licensing,
to assure compliance with regulatory requirements. These regulatory
requirements would:
* confine Data-PCS transmissions to a maximum power limit of one watt
of output power;
* permit the use of antenna directionality, to take full advantage of
re-use of frequencies;
* require all users to transmit data in packetized form, with a
required minimum period of "listening" for traffic before transmitting
and a maximum permitted duration of continuous channel occupancy;
* require manufacturers to disclose the channel usage and access
schemes employed by all Data-PCS equipment, with the exception of
encryption schemes, and not authorize systems using schemes intended
to exclude fair access to the frequencies by others;
* require manufacturers to assign each transmitter a universal ID to
be transmitted in each transmission sequence; and
* along with all PCS equipment and similar devices, protect the health
and safety of users by including such devices under the general
guidelines of GEN Docket No. 79-144.
Finally, Apple requests that the FCC expedite consideration of
this proposal and not defer action awaiting resolution of the many
complex questions associated with establishment of a regulatory
framework for voice PCS. There is an immediate and critical need for
Data-PCS, which cannot be met using any other frequencies or radio
services. Unlike voice PCS, Data-PCS is not simply a more efficient,
or a less expensive, means of providing an existing service. The
Data-PCS capability does not exist at present. It will require
substantial investments to create Data-PCS, let alone to develop it to
its full potential. Those investments cannot be made until the FCC
allocates sufficient bandwidth and establishes the operating
conditions that will enable Data-PCS to flourish.
The urgent need for Data-PCS is underscored by international
considerations facing the U.S. computer industry. At present the U.S.
industry leads the world in personal computer technology, but it is
being strongly challenged by Japanese companies. The U.S. industry,
if it is to remain competitive, must be in the forefront of developing
a wireless capability for personal computers. It can do so if the FCC
creates an environment for Data-PCS now, in advance of WARC-92.
Initiative by the FCC will encourage the spread of Data-PCS with a de
facto U.S. standard and thus will substantially enhance the
competitive posture of U.S. computer manufacturers in the world
market.
Filed January 28, 1991 with the Federal Communications Commission.
Placed on Public Notice by the Commission February 8, 1991. Initial
"Comments" were due April 10 and "Reply Comments" are due by May 10.
Any party may offer comments or reply comments. Please call (408)
974-4674 for a copy of the complete Petition as filed.