Cognitive Radio

I drafted and filed comments on the FCC’s Cognitive Radio Notice of Proposed Rulemaking on behalf of interested technology companies. The effort was organized by Public Knowledge.

Cognitive radio sounds super-techie, but this is really all about speech. If new technologies make it possible to get more use out of the same spectrum, that means more voices can be heard. Scarcity is no longer a legitimate reason for the government to grant exclusive monopolies to certain speakers. We argued that the FCC proposals benefit entrenced majorities instead of paving the way for future innovators to enter the market.

Our specific arguments:
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 “limited resource”

Our 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.

We will be filing reply comments so please contact us if your company is interested in joining us.