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Comparing FCC and Ofcom NOI's on MillimeterWave Mobile

On October 17, 2014 FCC released a Notice of Inquiry on “Use of Spectrum Bands Above 24 GHz For Mobile Radio Services”, Docket 14-177. On January 16, 2015 its UK counterpart, Ofcom, released a Call for Input on “Spectrum above 6 GHz for future mobile communications”. These two documents are nearly simultaneous and cover almost the same area. They provide a good opportunity to study differences between FCC and Ofcom and their approaches with dealing with the public in proceedings subject to public comment.

Readers may recall that we have previously commented that FCC’s NOIs and NPRM’s had too many questions and that the questions were poorly organized. We even pointed out that the controversial net neutrality NPRM had a grand total of 345 questions by our count. Did this high number illuminate things and remove ambiguity. I think few would say so.

But in our previous exempts of Ofcom request for comments and Industry Canada requests, we never had a comparison between 2 documents on the same topic that were nearly simultaneous. Now we do!

As we pointed out previously, the FCC NOI has 176 questions scattered throughout the NOI and not numbered in any way. They range from good questions like “To that end, how essential is global harmonization of technical and regulatory requirements to the success of advanced mobile services?” to truly bizarre/voyeuristic questions like “What does industry see as the leading design for ICs that should be used in equipment for frequencies above 24 GHz? “ - exactly what does IC design have to do with spectrum management decisions? But then again, there is the super odd pair of questions: ”What maximum transmit power and/or EIRP limits would be appropriate for mobile services in the mmW bands? Is the +55 dBW EIRP limit currently applicable in the 27.5-28.35 GHz band and 39 GHz band appropriate?” (For non-techies, apparently like the author of this question, “55 dBW” is 316,227 W in more familiar terms. 55 dBW is a reasonable power for a fixed antenna at the top of a tower pointing a narrow beam at another antenna off in the distance, it is an absurd amount of power for a handheld device both in terms of safety to the user and battery power - considering the limited antenna gain possible in a handheld unit. If I worked on the 8th Fl. I would ask how did this crazy question ever get into the NOI where it discredits the FCC as the “expert agency in spectrum management”.)

By contrast, Ofcom only asks 14 questions. They are each repeated twice: first in the context of a discussion on a general topic, and then they are grouped together at the end in Annex 4 on p. 24-25. How civilized! Here is an example of discussion followed by a clear question, readily identified due to its gray brackgound:

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