<?xml version="1.0" encoding="utf-8"?>
<rss version="2.0" 
    xmlns:dc="http://purl.org/dc/elements/1.1/"
    xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
    xmlns:admin="http://webns.net/mvcb/"
    xmlns:rdf="http://www.w3.org/1999/02/22-rdf-syntax-ns#"
    xmlns:content="http://purl.org/rss/1.0/modules/content/"
	xmlns:itunes="http://www.itunes.com/dtds/podcast-1.0.dtd">
	<channel>
<title>SpectrumTalk Feed</title><link>http://www.marcus-spectrum.com/index.html</link><description>SpectrumTalk Blog Update</description><dc:language>en</dc:language><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><dc:rights>Copyright 2010 Michael Marcus</dc:rights><dc:date>2010-07-24T11:00:20-04:00</dc:date><admin:generatorAgent rdf:resource="http://www.realmacsoftware.com/" />
<admin:errorReportsTo rdf:resource="mailto:mjmarcus@marcus-spectrum.com" /><sy:updatePeriod>hourly</sy:updatePeriod>
<sy:updateFrequency>1</sy:updateFrequency>
<sy:updateBase>2000-01-01T12:00+00:00</sy:updateBase>
<lastBuildDate>Sat, 24 Jul 2010 12:17:22 -0400</lastBuildDate><item><title>CTIA&#x2c; SF&#x2c; &#x26; SAR: Round 2 - The Craziness Continues</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>RF Safety</category><dc:date>2010-07-24T11:00:20-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/5654cde944f0a5b41972d14f0efcf823-119.html#unique-entry-id-119</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/5654cde944f0a5b41972d14f0efcf823-119.html#unique-entry-id-119</guid><content:encoded><![CDATA[Yesterday, CTIA opened Round 2 of its struggle with the elected government of San Francisco.  

...Today, CTIA-The Wireless Association&reg; filed a lawsuit in the U.S.   District Court Northern District of California San Francisco Division to block enforcement of the San Francisco &ldquo;Cell Phone Right-to-Know&rdquo; ordinance.   The ordinance challenges the Federal Communication Commission&rsquo;s (FCC) determination that all FCC-compliant wireless handsets are safe by mandating that retailers post Specific Absorption Rate (SAR) values.   The ordinance misleads consumers by creating the false impression that the FCC&rsquo;s standards are insufficient and that some phones are &ldquo;safer&rdquo; than others based on their radiofrequency (RF) emissions. 


The CTIA complaint filed in federal district court is shown at left and linked to the image.    In filing this complaint CTIA has engaged 4 different law firms:


...DrinkerBiddle - &ldquo;We lead complex and sophisticated business transactions and litigate many of the most important legal challenges that our clients face.&rdquo;


...Is that why you don&rsquo;t have money for buildout of new systems?


Since voice minutes are actually decreasing due to the growth of smartphones which are much more intensive users of your networks and for which SAR values are much lower, why does this really matter now?


The CTIA Complaint drafted by its 4 pricey law firms states that 


&ldquo;the Ordinance is expressly preempted by Section 332(c)(3)(A) of the Communications Act, which prohibits state-imposed conditions on &ldquo;entry&rdquo; to the wireless market, including point of sale &lsquo;warning requirements&rsquo; and labeling requirements&rdquo; (p.3, l.7-9)


A quick review of Section   332(c)(3)(A) finds no mention of &ldquo; &lsquo;warning requirements&rsquo; and labeling requirements&rsquo;&rdquo;.


...The FCC has stated that any cell phone that complies with the (SAR) standard is safe, regardless of whether its SAR value is at or somewhat below the SAR limit&rdquo; (p. 1, l. 27-28, emphasis in original)


Yet later on when it discussed this in depth the only reference it gives to FCC&rsquo;s safety finding is a URL to the Commission&rsquo;s Consumer & Governmental Affairs Bureau webpage, not to a finding by the Commission in a decision.  

...The FCC requires cell phone manufacturers to ensure that their phones comply with these objective limits for safe exposure.   Any cell phone at or below these SAR levels (that is, any phone legally sold in the U.S.) is a "safe" phone, as measured by these standards.   The FCC limit for public exposure from cellular telephones is an SAR level of 1.6 watts per kilogram (1.6 W/kg). 


I have trouble going from this FCC staff remark on a web page to the CTIA viewpoint stated about: &ldquo;The FCC has stated that any cell phone that complies with the (SAR) standard is safe, regardless of whether its SAR value is at or somewhat below the SAR limit&rdquo;.


CTIA&rsquo;s ever quotable John Walls said in the press release &ldquo;The problem with the San Francisco ordinance is not the disclosure of wireless phone SAR values &ndash; that information is already publicly available.&rdquo;    Yes now it publicly available, but no thanks to CTIA and its membership.    Ten years ago they strongly fought Chairman Kennard on this issue when he sought to follow the UK in making the SAR data readily available to the public.    They tried to keep the information as buried as possible within the FCC&rsquo;s ever chaotic website.  


...Walls, why aren&rsquo;t you also suing or at least expelling VZW, a major member of CTIA because it routinely does what SF is requiring: shows SAR data along with other key information on each model it sells.    Isn&rsquo;t VZW implying that &ldquo;some compliant phones are &lsquo;safer&rsquo; than other compliant phones based on their RF exposure test results.&rdquo;  ]]></content:encoded></item><item><title>H. R. 5081 Advertising</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>Public safety</category><dc:date>2010-07-21T20:18:47-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/2496b3af326482e531889e22f560e9e6-117.html#unique-entry-id-117</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/2496b3af326482e531889e22f560e9e6-117.html#unique-entry-id-117</guid><content:encoded><![CDATA[I was downtown today and picked up copies of 2 local &ldquo;rags&rdquo; that focus on politics: The Hill and Politico.    They both had the same full 1 page ad from the National Sheriffs&rsquo; Association that is shown at left, complete with a 9/11 picture of heroic firemen - not sheriff&rsquo;s deputies.    The ad urges readers to support HR 5081, the&rdquo;Broadband for First Responders Act of 2010&rdquo;.    The ad states,


On 1/23/10, the NSA adopted a Resolution calling on Congress to oppose the FCC&rsquo;s plan to outsource police communications to a private carrier.   The safety of America is too important to privatize to companies more interested in profit than ensuring state-of-the-art public safety communications.   History has shown that commercial networks have not provided the level of service necessary in times of need for public safety during critical events.


What is surprising is that if this is so vital to National Sheriffs&rsquo; Association, why isn&rsquo;t the issue even mentioned on the home page of their website?    APCO seems to also be in favor of HR 5081, but they at least have a cryptic link to the issue on their home page.


Now for the statement &ldquo;History has shown that commercial networks have not provided the level of service necessary in times of need for public safety during critical events&rdquo;, could this NSA and APCO please tell us what they think of the UK experience where a privately operated system provides all public safety communications in the UK and was built under contract with private funding and annual service fees from public safety users?


I know that APCO and others have vilified the TETRA technology used by Airwave for decades, quite possibly at the behest of a major manufacturer whose public safety market share would be threatened by TETRA, but TETRA is now a dead issue in the US for a variety of reasons.


Why do privately operated systems work in the UK but are impossible here?    Do the grass root members of both APCO and this NSA actually support this position or is it mainly supported by certain corporate interests?
]]></content:encoded></item><item><title>Snowe/Kerry Spectrum Bill</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>None</category><dc:date>2010-07-20T14:08:28-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/1807d16a7ad6f505d062d58edd87b7b5-116.html#unique-entry-id-116</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/1807d16a7ad6f505d062d58edd87b7b5-116.html#unique-entry-id-116</guid><content:encoded><![CDATA[From a 7/19 release from my fellow New Englanders, Sen. 

...Snowe (R-Maine) and John Kerry (D-Mass.) today introduced the Spectrum Measurement and Policy Reform Act, comprehensive spectrum reform legislation to modernize the nation&rsquo;s radio spectrum planning, management, and coordination activities. 


&ldquo;This legislation will lay the groundwork to develop a strong and effective 21st century comprehensive spectrum policy that will provide consumers with additional choices, greater innovation, lower prices and more reliable services,&rdquo; said Senator Snowe.   &ldquo;Our nation&rsquo;s competitiveness, economic growth, and national security demand that we allocate the necessary attention to current policy shortcomings, and enactment of this vital legislation will help avert the looming spectrum crisis and allow us to continue to enjoy the boundless benefits of spectrum-based services.&rdquo;


&ldquo;Our nation&rsquo;s airwaves are finite resources, and we need to use them as efficiently as possible,&rdquo; Senator Kerry said.   &ldquo;This analysis will help us empower innovation, encourage competition, and lower prices for emerging technologies nationwide.   Steps like this are essential to expanding broadband internet access while providing a platform where entrepreneurs can create new services and generate jobs.   We can and should know how our spectrum is being used and do more to encourage more efficient and productive use.    We look forward to working with the Administration and the communications community to move forward with this important legislation.&rdquo;


Senators Snowe and Kerry, senior members of the Senate Committee on Commerce, Science, and Transportation and longtime champions of spectrum reform, designed the bipartisan measure to complement the Federal Communications Commission's (FCC) National Broadband Plan in promoting more efficient use of spectrum and ensuring that the proper framework is in place to meet the future telecommunications needs of the nation.    Specifically, the Spectrum Measurement and Policy Reform Act tasks the FCC and the National Telecommunications and Information Administration (NTIA) to perform much needed spectrum measurements to determine actual usage and occupancy rates.    This data will assist policymakers and the public in making informed decisions about future spectrum uses.    In addition, the bill requires greater collaboration between the FCC and NTIA on spectrum policy and management related issues, implementation of spectrum sharing and reuse programs, as well as more market-based incentives to promote efficient spectrum use; and, sets a deadline for the creation of the National Strategic Spectrum Plan, which will provide a long-term vision for domestic spectrum use and strategies to meet those needs.  


...Section 4(b)(1) 0f the bill requires NTIA and FCC to identify based on actual surveys:


(A) 120 megahertz below 4 gigahertz worth of close proximity electromagnetic spectrum that is most feasible for spectrum sharing opportunities for commercial and government users;


(B) 120 megahertz below 4 gigahertz worth of close proximity electromagnetic spectrum that is most feasible for spectrum reuse opportunities for commercial and government users;

(C) 120 megahertz below 4 gigahertz worth of electromagnetic spectrum that is most feasible for temporary or dynamic short-term assignment and use;


(D) 120 megahertz below 4 gigahertz worth of close proximity electromagnetic spectrum that is most feasible for spectrum layering opportunities for commercial and government users.


Section 6(b)(2)  lets NTIA withhold spectrum from federal users, charge federal users an annual fee based on market value, and allows incentive awards for agencies that allow their spectrum to be auctioned


Section 6(g) creates an IRAC &ldquo;shot clock&rdquo; to require IRAC to &ldquo; act within 30 days&rdquo; on certain items.


My sometimes clients at New America Foundation commented:


"We applaud Senators Kerry and Snowe for their forward-looking efforts to promote spectrum access and mobile broadband innovation," said Michael Calabrese, who directs the New America Foundation's Wireless Future Program.    "The Kerry-Snowe bill maps a path to opening enormous amounts of grossly underutilized spectrum, especially federal government bands, for licensed, unlicensed and shared access by the private sector."


The more establishment trade organizations have not commented yet on the bill.    I will add this comments when available.
]]></content:encoded></item><item><title>Qualcomm Cognitive Radio Contest on Wireless Microphone Detection</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>None</category><dc:date>2010-07-20T14:04:18-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/7bd9068a4f9f4d538c449304981cf62b-115.html#unique-entry-id-115</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/7bd9068a4f9f4d538c449304981cf62b-115.html#unique-entry-id-115</guid><content:encoded><![CDATA[A group of students of the ECE Illinois won the 2010 Qualcomm Cognitive Radio Contest.   While the 3rd Smart Radio Challenge consisted in developing an integral framework for detection and tracking of different radios on an emergency scenario, the 2010 Qualcomm Cognitive Radio Competition required students to develop and implement algorithms that detect wireless microphone signals within a spectrum band.


While detecting digital television signals using the ATSC (American standard for digital television broadcasting) is not a big deal (given their embedded pilot tones), detecting 200 KHz wide wireless microphone signals with the detection performance required by the FCC proposal becomes a challenge.   Qualcomm provided the different teams with training data, consisting on both signal sets with a wideband of 6 MHz and information on the frequencies where microphone signals were located.   Contestants had to use this data to find a fitting model for the microphone signals and develop algorithms to detect them.   The algorithm was judged based on its performance, novelty and implementation complexity.


...They determined a baseline noise correlation matrix from a data set with no wireless microphone signals.   To see if a signal is present in a new environment, they compare the new correlation matrix with the baseline matrix using singular value decomposition.   If their algorithm determines there is a signal, it calculates the center frequency from the measured auto correlation of the signal."


...Veeravalli, commented that the key problem was learning to distinguish wireless microphone signals from narrowband interference caused by other electrical devices.   They addressed this problem by characterizing the unique features of this narrowband interference. 


...The Qualcomm contest requires students to develop an algorithm and software that detects if a wireless microphone signal is present within a spectrum, so the cognitive devices can avoid causing interference to it.   The wireless microphone needs to be protected from interference as it holds the primary license for that spectrum.


...Raja said that Qualcomm provided the contestants with &ldquo;training data,&rdquo; which specified the frequencies where microphone signals were located.   Contestants were expected to use this information to learn models and develop algorithms to classify the signals.


&ldquo;The spectrum they provided was six megahertz wide, but the wireless microphone signal is very narrow, less than 200 kilohertz wide, and it can be anywhere in the spectrum, which makes it hard,&rdquo; Unnikrishnan said.


...&ldquo;It&rsquo;s so narrow, and it can be anywhere in the spectrum.&rdquo;


Kannan said the key problem was learning to distinguish wireless microphone signals from unintended narrowband interference caused by electrical devices in the vicinity.


"We solved this by identifying features that characterize narrowband interference," Kannan said.


The algorithm was judged based on its performance, novelty and implementation complexity.


&ldquo;We needed to keep in mind its practical applications, which was hard because we&rsquo;re used to working with the theoretical,&rdquo; Kannan said.


The group persisted and developed a strong, unique algorithm that classified signals with good confidence levels, which contributed to their win.   If implemented into Qualcomm applications, their algorithm could help target open bandwidth and channel it into use.


&ldquo;One potential application of cognitive radios is to bring high speed Internet to rural areas where it&rsquo;s not presently available,&rdquo; Raja said.


...These kinds of competitions help us connect theory to practical applications and even guide futuristic research,&rdquo; Kannan said. ]]></content:encoded></item><item><title>FCC and NTIA Leadership BOTH Send Evasive Letters on Key Spectrum Issues</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>spectrum policy</category><dc:date>2010-07-15T13:14:15-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/01d1c6bab67c1a9a85b76ed4ee6201d1-114.html#unique-entry-id-114</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/01d1c6bab67c1a9a85b76ed4ee6201d1-114.html#unique-entry-id-114</guid><content:encoded><![CDATA[In the past 2 weeks, both Chairman Genachowski and NTIA Administrator Strickling - two men I both greatly respect - have sent evasive letters on key spectrum management issues that need to be addressed and resolved.    I hope that both letters were the result of rushed staff work and not signs of indifference to key spectrum issues.


...Strickling replied to IEEE-USA&rsquo;s May 6 letter urging FCC and NTIA to work together to clarify what is &ldquo;harmful interference&rdquo; since this phrase is used repeatedly in the Communications Act and the only formal definition is one recycled for the ITU that is murky in many practical situations.   (FCC has not yet responded to this letter.)   In practice, drawn out harmful interference determinations by both NTIA and FCC have significantly delayed access to spectrum for new technologies.


...Strickling seems to agree with the basic premise of the IEEE-USA letter, saying


&ldquo;NTIA currently works to establish spectrum rights and responsibilities for all spectrum users, particularly with respect to interference and interference protection, whenever, possible and practical.    When we are able to do so, the time taken by long drawn-out interference disputes is shortened or eliminated without detrimentally affecting reasonable expectations of all interested parties, promoting greater access to, and more efficient use of spectrum.


But the letter then goes on to reference an NTIA report that is almost 5 years old: Interference Protection Criteria: Phase 1 - Compilation from Existing Sources,  NTIA 05-432, Oct 2005 .    This report is a good background study reporting mostly on ITU-R recommendations relating to well known systems.    The ITU-R recommendations are not generally binding on FCC and NTIA in the usual case of a domestic system sharing with another domestic system, although they are important in the case of satellite systems and systems near the US and Canadian borders. 


The report was supposed to be part of the 2 phase study.  

...In the second phase of this study, NTIA will review the relevant federal government policies and practices regarding IPC and recommend regulatory and technical refinements that may improve IPC application&rsquo;s scope, utility, clarity, or effectiveness.


...	&bull;	Will NTIA involve the public in this issue?  


	&bull;	Will it work jointly with FCC on this issue?	


On May 28, Senators Rockefeller and Kerry sent Chmn. 

...We are writing to urge you to immediately begin a comprehensive inventory of the use o f radio spectrum by non-federal government licensees and users under the Federal Communications Commission's jurisdiction.<br><br>

Radio spectrum is a scarce, but valuable resource.   As more and more of our communications take place using wireless technology, it is vitally important for us to understand how spectrum is allocated and used.   Indeed, gaining a better understanding of how we use spectrum is the first step toward identifying how we can use this resource most efficiently to carry out critical government missions and to help bring more advanced communications services to consumers across the country.


...He focuses on work completed to date including the Spectrum Dashboard and the National Broadband Plan.  

...&ldquo;the general public with access to information about various spectrum bands, including usage and licensee information, mapping and analysis tools, and the ability to browse and download data.&rdquo;


...	&bull;	Will the &ldquo;usage&rdquo; information include information based on any actual observations or just the reformatting of data presently in FCC databases?


	&bull;	Since cellular carriers do not now report cell site location and coverage data, how will you present CMRS information?


	&bull;	Current broadcast contours used for Part 73 licensing and used for protection of broadcast spectrum in some contexts are based upon Part 73 propagation models that assure &ldquo;administrative certainty&rdquo; for broadcasters but do not realistically portray their actual coverage, will broadcast spectrum use be presented based on these traditional models or based on contemporary readily available propagation models?
]]></content:encoded></item><item><title>FCC Significantly Improves in OPM Employee Survey</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>FCC Reform</category><dc:date>2010-07-14T10:20:39-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/4a88345465904c807fa1665235dda5b3-113.html#unique-entry-id-113</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/4a88345465904c807fa1665235dda5b3-113.html#unique-entry-id-113</guid><content:encoded><![CDATA[Monday, FCC issued a press release on the results of the 2010 OPM Viewpoint Employee Satisfaction Survey that quoted Chairman Genachowski as saying,


&ldquo;I am delighted that the FCC has been recognized as the &lsquo;most improved&rsquo; federal agency.   The survey results reflect the hard work being done throughout the agency to make the FCC a model of excellence in government.<br><br>

"The FCC&rsquo;s reform agenda, which builds on the impressive strides made by Commissioner Copps as acting chairman, includes creating new opportunities for employees to provide feedback; improving employee communication through technology and new media; and focusing on leadership development and opportunities for employees.   I applaud the work of the FCC management and staff and look forward to more great things to come."


Long time blog readers may recall that this survey, previously called the Federal Human Capital Survey, has been a recurring topic here.    A topic in which FCC has done extremely poorly in the past.


...Its score of 55.0 also put it lower than all the large agencies except the Department of Transportation.   The only small agencies scoring worse than FCC were: International Boundary and Water Commission, Selective Service System, Broadcasting Board of Governors, and Federal Labor Relations Authority.   Also (only) 20 out of the 216 ranked "agency subcomponents" ranked lower than FCC including FAA, FEMA, TSA, and FCC's neighbor - Bureau of Engraving and Printing. 


NTIA was not treated as a subcomponent so there is no data on it.&rdquo;


Earlier we described how the Commission&rsquo;s ancien regime had dodged early OPM surveys even though they were a well publicized and admirable Bush 43 Administration initiative.    Well FCC is now fully on board and is moving up in the ratings, although Chmn.   G. did overreach a bit on the &ldquo; &lsquo;most improved&rsquo; federal agency&rdquo; a bit.    As the image above from the report shows, OPM only identified FCC as one of 11 agencies with the &ldquo;highest increases since 2008&rdquo;.


The raw data shows the very positive improvement since the former chairman left.    On the questions &ldquo;I feel encouraged to come up with new and better ways of doing things&rdquo;, in 2008 52% of FCC staffers either strongly agreed or agreed, now it is 62%.


On &ldquo;My work gives me a feeling of personal accomplishment&rdquo;, formerly 60% either strongly agreed or agreed, now it is 70%.


On &ldquo;I can disclose a suspected violation of any law, rule or regulation without fear of reprisal&rdquo;, there was a big jump: formerly 45% either strongly agreed or agreed, now it is 67%.    Perhaps this points to the need to have a credible long term inspector general at FCC - a recurring theme in this blog.    While it is laudable that there is great improvement here, what can be done to prevent a low score in the future?


There were also large increases in positive responses to both &ldquo;Arbitrary action, personal favoritism and coercion for partisan political purposes are not tolerated.&rdquo; and  &ldquo;Prohibited Personnel Practices are not tolerated&rdquo; making one wonder what was really going on under the ancien regime?    Perhaps another indication of what happens when there is not a credible IG in an agency or perhaps this is why the previous chairman did not want a credible IG!


Finally on &ldquo;I have a high level of respect for my organization&rsquo;s senior leaders&rdquo; formerly 38% either strongly agreed or agreed, now it is 62%!


...Genachowski and the new team on this major turn around!]]></content:encoded></item><item><title>International Calling Rates: A Case of Market Failure?</title><dc:creator>mjmarcus@marcus-spectrum.com</dc:creator><category>None</category><dc:date>2010-07-12T09:44:09-04:00</dc:date><link>http://www.marcus-spectrum.com/Blog/files/83d7e42bdd63d47570c5929bef63379d-111.html#unique-entry-id-111</link><guid isPermaLink="true">http://www.marcus-spectrum.com/Blog/files/83d7e42bdd63d47570c5929bef63379d-111.html#unique-entry-id-111</guid><content:encoded><![CDATA[Purposes of chapter; Federal Communications Commission created


For the purpose of regulating interstate and foreign commerce in communication by wire and radio so as to make available, so far as possible, to all the people of the United States, without discrimination on the basis of race, color, religion, national origin, or sex, a rapid, efficient, Nation-wide, and world-wide wire and radio communication service with adequate facilities at reasonable charges, for the purpose of the national defense, for the purpose of promoting safety of life and property through the use of wire and radio communications, and for the purpose of securing a more effective execution of this policy by centralizing authority heretofore granted by law to several agencies and by granting additional authority with respect to interstate and foreign commerce in wire and radio communication, there is created a commission to be known as the &ldquo;Federal Communications Commission&rdquo;, which shall be constituted as hereinafter provided, and which shall execute and enforce the provisions of this chapter.


The above are the stated goals of the Communications Act of 1934, as amended.    While originally these goals were met mainly through regulation, both the Commission and Congress have found that in most cases competition is more effective in regulation in meeting these goals.    Thus &sect; 203 tariff regulation is generally a historic relic.    Although my copy of the Act still states in &sect; 201: 


&ldquo;All charges, practices, classifications, and regulations for and in connection with such communication service, shall be just and reasonable, and any such charge, practice, classification, or regulation that is unjust or unreasonable is declared to be unlawful&rdquo;.


Let me be clear, I think competition has been generally more effective than regulation, but market failure is always a possibility that makes competition ineffective in protecting the public interest and the goals of the Act.    There are clear indications that in the international telephony market there has been market failure and that both the wired and wireless carriers are exploiting this to frustrate the goals of the Act.


Let&rsquo;s focus on the wireless case.    I recently was in Singapore and bought a prepaid SIM card from the store closest to my hotel which turned out to be M1 Ltd.   (Being Singapore, one of many countries where anonymous prepaid cards are illegal, they sensibly and quickly made a copy of my passport as a prerequisite for buying the card.)    The pricing of call was quote interesting: 8&cent;/minute for both domestic calls and international calls to India, Macau, Bangladesh, Brunei, China, Vietnam, Malaysia, Australia, Thailand, Laos, Hong Kong, New Zealand, Taiwan, Puerto Rico, USA, Russia, Canada, United Kingdom and South Korea.   Philippines, Indonesia, and Saudi Arabia were somewhat higher at 22 - 45&cent;/minute.    (These prices are in Singapore currency which is worth about 70% of US currency.)


Now I can see that the cellular network in compact Singapore is very different than that in the US with thousands of miles to cover and lots of rural areas, but I am having trouble seeing how that would affect international calling rates.


So what do US carriers charge?    They all have a 2 tier system that pressures you to buy a monthly or annual plan for the privilege of paying market-based rates.    If you do not subscribe to their &ldquo;plan&rdquo; and make a call in a rush here&rsquo;s what you pay per minute for calls to the UK:


						AT&T	$1.29


...						T-Mobile 	$1.49


						VZW		$1.49


(I should note that Tracfone, the prime trafficker of anonymous prepaid phones and the only carrier that does not even ask you for a name and address [very convenient for criminal elements - making up fake names and addresses for dozens of throw away phone is really just a drag isn&rsquo;t it?], offers calling to 60 countries at their normal domestic rate which is 17-35&cent;/minute depending on how many minutes you prepay for.)


So, big 4 US carriers:  Do the goals of the 1934 Act apply to you?  


FCC: How long will you look the other way while these carriers, and their landline counterparts, charge 1980s AT&T monopoly rates for international calling where the real cost has fallen close to zero and where truly competitive pricing confirm that?]]></content:encoded></item></channel>
</rss>