Public Knowledge - FCC Filings

Joint Filing of Technology Sector Organizations and Public Interest Organizations Concerning Open Access

Webmaster — Wed, 18 Jul 2007 12:50:06 -0400

This document is also available in PDF Format.

July 18, 2007

The Honorable Kevin J. Martin

Chairman
Federal Communications Commission
445 12th St., SW
Washington, DC 20554

Re: Joint Filing of Technology Sector Organizations and Public Interest Organizations Concerning Open Access;
WT Docket Nos. 96-86 and 06-150; PS Docket No. 06-229.

Dear Chairman Martin:

Reply Comments of Public Knowledge, et al. on Broadband Industry Practices, FCC Docket #07-52

Webmaster — Mon, 16 Jul 2007 18:05:52 -0400

This filing is also available in PDF Format.

Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of
Broadband Industry Practices
WC Docket No. 07-52

To: The Commission

Reply Comments of Public Knowledge, et al.

Public Knowledge Comments to the FCC In the Matter of the XM/Sirius Merger

Webmaster — Mon, 09 Jul 2007 18:50:30 -0400

Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of:

Sirius Satellite Radio Inc. and
XM Satellite Radio Holdings
Seek Approval to Transfer Control of
FCC Authorizations and Licenses

MB Docket No. 07-57

To: The Commission

COMMENTS OF PUBLIC KNOWLEDGE

Public Knowledge submits these comments in response to the Public Notice¹ in the above docketed proceedings. If the proposed merger withstands antitrust analysis, Public Knowledge supports the merger subject to conditions that will result in greater program diversity, increase consumer choice and keep prices in check.

Full comments also available in PDF format.

Comments Of The Ad Hoc Public Interest Spectrum Coalition to the FCC on 700MHz Spectrum Reform

Webmaster — Thu, 24 May 2007 00:01:39 -0400

The full filing is available in PDF format.

In the matter of:

Service Rules for the 698-746, 747-762, and 777-792 MHz Bands:
WT Docket No. 06-150

Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band:
PS Docket No. 06-229

Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures:
WT Docket No. 05-211

Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010:
WT Docket No. 96-86

SUMMARY

The Ad Hoc Public Interest Spectrum Coalition (PISC) applauds the Commission for including issues raised by PISC in the initial comment period.

The United States continues to fall further behind the rest of the world in broadband Internet access — our markets lack the competition necessary to serve consumers with lower prices, faster speeds and universal access. Even as the broadband market has further consolidated — leaving 96% of the market in the hands of two technologies — our policy framework has only served to diminish opportunities for competition. The auction of the 700 MHz spectrum creates a new possibility for competitive broadband provision. It is imperative that we learn the lessons of the wireline market and make the appropriate policy corrections in the launch of the most promising wireless broadband markets.

The Commission simply cannot choose to let current market conditions and participants control the outcome of the upcoming auctions. To date, existing wireless broadband providers do not offer a useful “third pipe” for American consumers. Perhaps most importantly, this market for broadband capable mobile devices is dominated by the same incumbent firms that control the wireline broadband market. These incumbents make clear that they have no intention of offering broadband with the freedom to attach any device and run any application.

To foster real wireless broadband — the fast, ubiquitous, and dynamic third pipe everyone agrees our country desperately needs — PISC recommends that the Commission take the following steps both to ensure that new spectrum is offered on an open and nondiscriminatory basis and to bring in new entrants interested in challenging the current cozy wireless oligopoly and broadband duopoly:

Ad Hoc PISC Comments In Support of Skype Communications Petition to Apply Carterfone Principles to Wireless Services

Webmaster — Mon, 30 Apr 2007 17:14:41 -0400

The full comments are available in PDF format.

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of
Skype Communications S.A.R.L.
Petition to Confirm a Consumer’s
Right to Use Internet Communications
Software and Attach Devices
To Wireless Networks

Docket: RM-11361

The Ad Hoc Public Interest Spectrum Coalition (PISC) file these comments in support of the Petition filed by Skype Communications to apply the Carterfone principles to wireless services. The undersigned concur in Skype’s finding that carriers are harming consumers with restrictive practices. Carriers are leveraging their dominant position in wireless service and retail handset markets to engage in unsavory and anticompetitive practices that maximize their profits at the cost of reducing consumer welfare.

Ex Parte Comments Of The Ad Hoc Public Interest Spectrum Coalition -- Open Access

Webmaster — Thu, 05 Apr 2007 11:48:52 -0400

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)
Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)
Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)
Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission:

Consumer Federation of America, Consumers Union, Free Press, Media Access Project, New America Foundation and Public Knowledge (collectively referred to here as the “Public Interest Spectrum Coalition” or “PISC”), file these ex parte comments urging the Federal Communications Commission (“FCC” or “Commission”) to condition the award of licenses for at least half of the 700 MHz band on the licensees’ compliance with open access principles. The auction of licenses in the 700 MHz band is a unique and critical opportunity to bring broadband to American consumers and open an avenue for competitive broadband providers. It is without question the best opportunity to open a legitimate “third pipe” for consumer broadband connectivity—long a goal of the Commission. Given the state of the market failure in US broadband and our unenviable position relative to international performance in broadband connections, a pro-competitive policy in the 700 MHz auction is imperative. The undersigned public interest groups urge the FCC to adopt our recommendations in order to maximize the opportunities for new, competitive entrants and promote greater broadband access in the United States. We recommend that the FCC require that a portion of the auctioned licenses be subject to a service condition of open access. This will create a competitive retail market for wireless broadband services in a national marketplace. It will bring innovative, competitive providers into the market that would otherwise never appear.

Ex Parte Comments Of The Ad Hoc Public Interest Spectrum Coalition -- Network Neutrality

Webmaster — Thu, 05 Apr 2007 11:39:36 -0400

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)
Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)
Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)
Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission:

Ex Parte Comments of The Ad Hoc Public Interest Spectrum Coalition -- Auction Rules

Webmaster — Wed, 04 Apr 2007 17:42:45 -0400

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)
Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)
Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)
Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission

Media Access Project, on behalf of Consumers Union, Consumer Federation of America, Free Press, New America Foundation and Public Knowledge (collectively referred to here as the “Public Interest Spectrum Coalition” or “PISC”), files these ex parte comments addressing the proposal submitted by Frontline, the proposed Band Optimization Plan, and auction and service rules needed to ensure that this auction of unique and highly valuable spectrum will maximize the likelihood of competitive entry in broadband wireless that protects public safety, increases opportunities for minority and women owned businesses, and promotes broadband access by all Americans.

Filing: MAP and PK Support of M2Z Application; FCC Docket WT 07-16

Scott Burns — Sat, 03 Mar 2007 09:45:10 -0500

This letter is also available in PDF format.

March 2, 2007

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

RE: Docket WT 07-16

Dear Ms. Dortch:

We are writing to express qualified support for the application of M2Z Networks, Inc. for license and authority to operate a broadband wireless service in the 2155-2175 MHz band.

Letter to FCC in Opposition to Delaying Implementation of The Set-top Box Integration Ban

Scott Burns — Wed, 15 Nov 2006 15:02:40 -0500

This letter is also available in PDF format.

November 15, 2006

By Hand and ECFS
Chairman Kevin J. Martin
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re: CS Docket 97-80

Dear Chairman Martin:

The undersigned consumer and public interest groups are writing to express our opposition to petitions to further delay implementation of the set-top box integration ban. We believe that such a ban is critical to ensuring competition in the set-top box market, which will relieve consumers from the onerous costs of the cable monopoly over set-top boxes by increasing retail choice, lowering prices and creating market-based incentives for functional innovation. Moreover, the trend toward migration of popular and premium channels to the digital tier leaves consumers ever more vulnerable to excessive monthly rental costs for cable distributor boxes. Consumers are already hostage to the costly programming packages offered by cable. Migration of some of those channels to the digital tier piles yet more burdensome costs on consumers already suffering from exorbitant cable price hikes.