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February 14, 2002


Re: Revision of Part 15 of the Commission’s Rules Regarding Ultra-Wideband Transmission Systems, First Report and Order (ET Docket No. 98-153-).

Spectrum management decisions are always complex and challenging. In an environment where the amount of unencumbered spectrum is decreasing while demand continues to grow, it is even more critical we make interference and sharing decisions that do not waste this precious natural resource. Inevitably, we will depend more and more on sharing the spectrum currently available to avoid such waste. Sharing decisions are made particularly difficult in the context of the “fiefdom” mentality that seems to characterize players who fervently guard their spectrum “turf,” regardless of whether additional use can be accommodated. Unfortunately, the result is often unrealized potential that can never be recaptured.

I am excited that ultrawideband technology, which operates at powers 10,000 times lower than PCS handsets, will allow us to take sharing to new levels, and help avoid such waste. These sophisticated applications can potentially co-exist with spectrum users in any frequency, while promising a host of exciting military, public safety, medical and consumer uses. Firefighters, police officers and emergency personnel can make use of this technology to detect and image objects that are behind walls, buried underground or even inside the human body. Automotive applications such as collision avoidance and improved airbag mechanisms will have a direct consumer safety impact. Consumers also stand to benefit from enhanced laptops, phones, video recorders, and personal digital assistants that can wirelessly send and receive streams of digital video, audio and data.

Most importantly, ultrawideband challenges the notion that use of particular frequencies or bands is necessarily mutually exclusive. In defiance of our traditional allocation paradigm that often forces us to pick “winners and losers” in the face of competing demands, this technology seems to allow more winners all around.

I am disappointed that we did not, at this time, adopt more flexible limits that may have allowed for even more widespread use of this technology. I look forward to re-examining the technical parameters established in this order once we have more data that will address the interference concerns expressed by NTIA


I am optimistic that future technological developments will provide the Commission with more such opportunities to insist on increasingly efficient use of current spectrum. Ultimately, the amount of available spectrum and our ability to use it is perhaps limited only by technology. Today, however, we must act rationally to make the best choices within the spectrum constraints that face us now.