[comp.dcom.telecom] Apple Data-PCS Petition for Rulemaking

sjl@world.std.com (Scott J Loftesness) (02/23/91)

Patrick, I will be sending you a file with the complete text of
Apple's recent petition for rulemaking to the FCC for a new
Data-Personal Communications Service.  It's about 60K in size so
probably should end up in the Archives!


Best, 

Scott


[Moderator's Note: And that is where readers will find this latest
addition to the Telecom Archives, filed as 'apple.data.pcs.petition'. 
My thanks for sending it along.   PAT]

"Donald E. Kimberlin" <0004133373@mcimail.com> (04/11/91)

Continuing a thread about Apple Computer applying to operate a radio
LAN product with the FCC [last commented in Digest v11, iss153], there
was rather expectable news reported in this week's trade press.

The following is from {CommunicationsWEEK} for April 10:

                       "TELCOS OPPOSE APPLE SPECTRUM"

                           "By Kathleen Killette"

"WASHINGTON - In comments submitted to the FCC, telcos, utilities and
others have said Apple Computer, Inc. has not justified a separate
spectrum allocation in its petition for personal communications
services."

        "In addition, Apple's critics say the company's petition
should be folded into the FCC's broader PCS inquiry, which has been
under way since June." (1990, of course.)

        "This week, the agency will receive more comments on a
petition submitted in January by Apple" ... "for data-only PCS. The
computer industry's growing interest in wireless technologies is
pressuring the FCC to carve out spectrum fpr over-the-air local area
data networks."

   ..........

        "Apple asked the FCC to allocate 40 megahertz of spectrum in
the 1,850-MHz to 1,990-MHz radiofrequency band for `Data-PCS.'
Data-PCS would let PC users `access files, peripherals and the
gateways of wired and wireless data networks,' within a local area of
between 50 and 150 meters, Apple stated."

        "Data-PCS would use a maximum of 1 Watt of output power and
directional antennae, which would let different antennae use the same
frequency simultaneously for transmitting and receiving packetized
data."

        "But AT&T opposed Apple's petition, stating that PCS spectrum
allocations should not be limited to data-only applications."

        "Southwestern Bell Corp., St. Louis, agreed, and added that,
`Apple's request should be considered, if at all, solely within the
context of' the FCC's current PCS inquiry.  Apple also wants too much
spectrum for Data-PCS and has not proposed and compensation for the
existing users of the 1,850-1,990 MHz band, stated Southwestern."

        "That spectrum currently is allocated to commercial, fixed
microwave users that operate private network, such as utiliteis and
large corporations.  Many of these users are licensed as Operational
Fixed Service users and providers."

        "The Utilities Telecommunications Council" <what part of the
woodwork DO all these outfits come out of?> "also objected to Apple's
petition, noting that water, gas and electric utilities have invested
more than $360 million in radio equipment to operate in the
1,850-1,990 MHz band." <Sounds to me like no more than ONE electric
company'a annual rate ...>

        "That investment - which supports roughly 2,000 licenses"
<aha!  let's see - $360 million/2,000 comes to ... $180,000 per EACH
license.  WOW!  That's some AWFULLY expensive 2 Gigahertz microwave,
folks!> "-could be stranded if private microwave users are relocated
to other frequencies, resulting severe economic hardships, according
to the council."

        (end quote)

        So, it looks like Apple is getting the typical treatment:
Overstated tales of woe from the poor, beleagured utility companies --
who for the most part still enjoy just sticking more capital in their
rate bases the way Telcos did for decades.  If any argument makes more
sense, that put forward by AT&T does...simply to say that PCS should
be for both voice and data.  But to cry the blues about what is a
rather insignificant portion of the total investment of the utility
industry just doesn't seem to fit. What could possibly motivate the
utilities, who want all the excuses they can find to stick more
capital in their rate bases, to jump into this fray?

"Fred R. Goldstein" <goldstein@delni.enet.dec.com> (04/11/91)

In article <telecom11.280.3@eecs.nwu.edu>, 0004133373@mcimail.com
(Donald E. Kimberlin) writes...

>        "The Utilities Telecommunications Council" <what part of the
> woodwork DO all these outfits come out of?> "also objected to Apple's
> petition, noting that water, gas and electric utilities have invested
> more than $360 million in radio equipment to operate in the
> 1,850-1,990 MHz band." <Sounds to me like no more than ONE electric
> company'a annual rate ...>

The utilities are among the major users of the 2 GHz fixed microwave
band.  Back before cheap fiber optics, a lot of companies had private
radio systems there.  Many still do.  Utilities and railroads are the
major users, since they have rights-of-way and lots of data to send.

>        "That investment - which supports roughly 2,000 licenses"
> <aha!  let's see - $360 million/2,000 comes to ... $180,000 per EACH
> license.  WOW!  That's some AWFULLY expensive 2 Gigahertz microwave,
> folks!> "-could be stranded if private microwave users are relocated
> to other frequencies, resulting severe economic hardships, according
> to the council."

It's not cheap stuff.  To build a microwave network, you need radios,
towers, antennas, etc.  The 2 GHz band has a longer hop range than the
alternatives (higher frequencies).  So a utility might stick one 2 GHz
dish on a tower every 40-50 miles or so.  If they were displaced to
the 6 or 12 or 18 GHz ranges (and I'm not sure 12 is still available),
then they'd need towers every 20-30 miles (at 6 GHz) or even closer.
These don't come cheap!  I don't think Apple really apreciates that.

Voice and data PCNs are both neat ideas.  But the private microwave
users have a good case.  You can't replace all radios with glass;
glass is only suitable to high-density routes, and much private
microwave crosses inhospitable terrain, mountain peak to peak.  A huge
amount of spectrum is reserved for government use, and the FCC
currently only gets to divvy up the rest.  It's not an easy business.


Fred R. Goldstein              Digital Equipment Corp., Littleton MA
goldstein@delni.enet.dec.com   voice: +1 508 952 3274
 Do you think anyone else on the planet would share my opinions, let
 alone a multi-billion dollar corporation?