Analysis of NPRM Docket ET-49 5GHz spectrum and DSRC

Current Ex-parte Activity

ECFS Feed - Proceeding Number is 13-49


Analysis of First Round Comments



Part 1 of 2


Name of Filer
Analysis
Date Received
Date Posted
Exparte
Type of Filing
Documents





Wireless Internet Service Providers Association
WISPA supports opening the UNII-4 band to unlicensed devices because (1) of the economic needs and benefits of expanding Wi-Fi to rural areas via UNII devices; and (2) there are "no registered Road Side Units ("RSUs")." The comments begin by noting the dearth of broadband internet access in rural areas, and point out the economic benefits that Wi-Fi broadband can have on these areas, using the FCC’s Eighth Broadband Report (2012) as a source. WISPA believes that wireless broadband, through UNII devices, is the optimal way to provide internet access to rural populations. If the UNII-4 band were opened, “WISPs would be extremely well positioned to expand their coverage areas and to initiate service to those consumers and businesses that currently lack access to fixed broadband services” (p. 5), and would therefore address the FCC’s concerns about limited rural internet access. WISPA claims that opening the UNII-4 band to unlicensed devices should be done with respect to incumbents (DSRC), but points out that “there appear to be only seven active non-exclusive licenses and no registered Road Side Units ("RSUs"),” therefore the FCC should allow sharing of the band; at the least, spectrum sharing should be explored. This can be countered by investigating the FCC's Universal Licensing System to find (a) the number of DSRC licensees and (b) the number of DSRC units. Another weakness of WISPA’s argument is that they admit that exceptions to harmonizing technical rules across the UNII-3 and UNII-4 bands can be made; perhaps the band in which DSRC devices operate can be an exception.
05/28/2013
05/29/2013
N
COMMENT
(26 pages)





Toyota Motor North America, Inc.
The 5.9 GHz band has already been allocated to "safety-of-life" DSRC applications which can address 80% of road collision scenarios. As "the only communication option at this time capable of effectively and reliably providing this safety-of-life capability" (p.3), DSRC and its spectrum band should remain protected by the FCC unless all stakeholders arrive at a technical solution that ensures minimal risk of harmful interference to DSRC safety applications.
05/28/2013
05/29/2013
N
COMMENT
(20 pages)





Time Warner Cable Inc.
TWC proposes opening the UNII-4 band to sharing with unlicensed devices, and supports harmonizing the technical rules across the UNII-3 and -4 bands. Specifically, TWC supports a 1-watt power limit on devices, and opposes any restrictions on outdoor use of devices. TWC's main reason for supporting spectrum sharing is that the 5 GHz band is the best opportunity, technically and economically speaking, for TWC to implement a gigabit Wi-Fi network. According to TWC, such a network will have enormous public interest benefits. TWC does not mention DSRC explicitly, but does state that it is open to working with the FCC and the ITS community to ensure that spectrum sharing can be successful.
05/28/2013
05/29/2013
N
COMMENT
(16 pages)





Volkswagen (Thomas Zorn)
Although Volkswagen is not categorically against spectrum sharing, Volkswagen recommends that before making any rulings concerning the 5.9 GHz band, "any decisions regarding the 5.9 GHz band should be carefully considered and fully vetted to ensure the incumbent applications are not compromised" (p. 1).
05/28/2013
05/29/2013
N
COMMENT
Volkswagen Comments (3 pages)




The Alliance of Automobile Manufacturers, Inc. and the Association of Global Aut
Automakers in the United States, Europe, and Asia have invested large amounts of resources and time in DSRC safety technology, resulting in a technology that has the potential to address a significant portion of road vehicle collisions and is nearing readiness for deployment. DSRC technology is being deployed internationally, but the FCC's actions concerning the 5.9 GHz band threaten to deny American motorists the safety benefits that stem from this technology. "The Commission should not allow U-NII use of the 5.9 GHz band unless a set of rules can be developed and shown, through rigorous bench and field testing, to protect 5.9 GHz 'safety-of-life' DSRC systems from harmful interference. Moreover," the FCC should seek public comment on the ability of such rules to "adequately protect DSRC services." (p. 3)
05/28/2013
05/29/2013
N
COMMENT
(82 pages)





Telecommunications Industry Association
Generally, TIA wants to harmonize rules across all 5 GHz UNII bands in order to reduce wireless network congestion, but only if incumbent users, DSRC included, are protected using "technologically neutral" solutions. The TIA feels that the licensed spectrum cannot meet either the growing demand or the requirements for gigabit wireless internet networks in the near future. TIA urges the FCC to take the lead in solving technical issues posed by spectrum sharing through a well-defined "series of reports and orders" which should be carried out in conjunction with the involved parties.
05/28/2013
05/29/2013
N
COMMENT
(21 pages)





Car 2 Car Consortium
The Car 2 Car Consortium argues that the 5.9 GHz band should not be opened because the safety applications of DSRC take precedence over unlicensed U-NII devices. The Consortium has not seen any technical solution that justifies the possibility of opening the DSRC band to unlicensed devices. The Consortium argues that to open the spectrum, testing needs to be done that proves that spectrum sharing is safe. According to the NTIA (and the Consortium), this is exceptionally difficult, and a technical solution to sharing is not feasible. Furthermore, the Consortium points out that in Europe, these devices operate in the same spectrum range, and will be rolled out very soon.
05/28/2013
05/29/2013
N
COMMENT
(3 pages)





Shared Spectrum Company
Although the Shared Spectrum Company does not mention DSRC specifically, their comments make clear their support for the FCC's proposal to share the 5 GHz band. The SSC urges the FCC to utilize frequency sensing technologies that may enable the 5 GHz to be shared by incumbents and unlicensed users. Most of this brief document is dedicated to a discussion of how unlicensed devices can avoid interfering with Doppler radar through frequency sensing.
05/28/2013
05/29/2013
N
COMMENT
(7 pages)





Savari, Inc.
As a producer of ITS wireless communication devices, Savari Inc. is against the FCC’s proposal to open the 5.9 GHz band to use by U-NII devices because the record of public comments regarding this NPRM cannot provide the technical analysis necessary to determine that spectrum sharing “with unlicensed devices will not compromise the safety of the traveling public.” Furthermore, “the proposal to share spectrum allocated for safety of life services with unlicensed devices must face a high burden of demonstrating that DSRC will not be compromised” (p. ii).
05/28/2013
05/29/2013
N
COMMENT
Savari Comments (39 pages)




SPITwSPOTS, Inc.
SPITwSPOTS provides broadband wireless to rural Alaska using the 5470-5825 MHz band. They are against the FCC’s proposal to harmonize the technical rules of the 5725-5850 MHz band, currently described in Section 15.247, with the stipulations of Section 15.407, because doing so would disrupt the long-range links which connect the company's rural clients to the Internet.
05/28/2013
05/29/2013
N
COMMENT
(5 pages)





SES S.A. and Intelsat S.A.
SES and Intelsat ask that the FCC abandon its proposal to open the 5.9 GHz band to unlicensed device use because the NPRM “fails to appreciate the serious interference” that would hamper SES/Intelsat’s C-band fixed satellite services. SES/Intelsat note that although the FCC considered the impact of aggregate interference to FSS from DSRC when it allocated 5.9 GHz band to DSRC in 1997, the Commission is not taking into account similar considerations in this NPRM, and should refrain from making rule changes on the 5.9 band until additional analysis of the risks to FSS have been made.
05/28/2013
05/29/2013
N
COMMENT
(15 pages)





SAE International
DSRCS are incumbent in the 5.9 GHz band and should remain so “because while the Middle Class Tax Relief and Job Creation Act of 20121 required the Commission to modify its regulations to allow certain unlicensed use of spectrum in the 5.4 GHz band, the law as passed does not include a directive to open the use of the 5.9 GHz band to unlicensed U-NII use.” [SAE, p. 3] Based on DSRCS’ incumbent status and ability to save lives, the FCC should “ensure that any deployment of other technology will not interfere with the safety mission of DSRC” [p. 3] until “the effects of any interference issues on safety benefits of this nascent communications-based system are confirmed” by the US DOT and NTIA [p. 4].
05/28/2013
05/29/2013
N
COMMENT
(4 pages)





Ruckus Wireless, Inc.
Ruckus Wireless, Inc. “supports efforts to both broaden the available 5 GHz spectrum for use with unlicensed Wi-Fi devices and to harmonize the rules between U-NII bands” in order to support the adoption of 802.11ac-compliant devices. Ruckus does not mention any protections for incumbents.
05/28/2013
05/29/2013
N
LETTER
(1 page)





QUALCOMM Incorporated
Qualcomm is in favor of spectrum sharing, but has two proposed solutions which could solve interference issues without delaying DSRC rollout. Qualcomm's position in both the DSRC field and the Wi-Fi industry means that it has a stake in the development of both technologies. It has therefore devoted the entirety of its comments to proposing a technical solution to the issue of interference between DSRC and UNII devices. Qualcomm proposes dedicating the top 20 or 30 MHz of the proposed UNII-4 spectrum to safety communications so that DSRC can be rolled out without delay. Furthermore, Qualcomm recommends studying the possibility that DSRC and 802.11ac devices can share the remainder without interference. The entire proposed UNII-4 spectrum can then be shared if and only if the research shows that spectrum sharing "can be proven to work successfully on a completely non-interfering basis." (p. iii) Qualcomm is thus dedicated to both DSRC rollout and spectrum sharing. The technical details of Qualcomm's proposal needs to be assessed.
05/28/2013
05/29/2013
N
COMMENT
(25 pages)





IEEE 802
IEEE 802 believes that the current rulemaking cycle is insufficient to determine “whether a [spectrum] sharing case exists, much less whether it can be proved out to the satisfaction of stakeholders.” However, they would be in favor of opening the band should “a potential sharing solution that can protect mission-critical DSRC automotive uses” be proven viable to the satisfaction of all stakeholders (p. 4) – a scenario that is possible because 802.11ac- and 802.11p-enabled devices are of the same “family” and feature some of the same capabilities (p. 29). Because the issue of interference with DSRC in the 5.9 GHz band is new and novel, IEEE 802 recommends that “stakeholders from both sides hold a series of meetings to (1) exchange information on respective requirements, (2) discuss possible mitigation solutions prepared by the technical experts from the 802.11 community, and (3) come to an agreement on a mutually acceptable solution for testing/implementation” (p. 30). The Wi-Fi Alliance echoes these three suggestions word-for-word on page 27 of their comments. In the event stakeholders come up with an acceptable solution, “then industry participants would need to work closely with FCC and other government agencies to develop certification rules that unlicensed devices will use to gain FCC approval, including potentially additional tests to ensure the certification rules operate as needed” (p. 30).
05/28/2013
05/29/2013
N
COMMENT
(42 pages)





OmniAir Consortium
OmniAir asks the FCC not to open the 5.9 GHz band "until substantial testing has been completed that proves that additional non-licensed use of this space will not interfere with" the potentially life-saving applications of DSRC (p. 2). OmniAir provides descriptions of 15 DSRC deployment projects that unlicensed use of the 5.9 GHz band would affect.
05/28/2013
05/29/2013
Y
NOTICE OF EXPARTE
OmniAir Response to NPRM regarding 5 9 GHz Band (13 pages)


National Cable & Telecommunications Association
NCTA is in favor of opening the 5.9 GHz band because of the supposed lack of DSRC installations and the desire of their members to extend Wi-Fi networks as widely as possible using the 802.11ac standard. The NCTA argues that a widespread, wireless gigabit internet network would increase the economic benefits of unlicensed U-NII devices which already contributes $50-100 billion to the national economy (p. 3). The NCTA also points to the high level of investment in Wi-Fi network, in terms of access points as well as dollars, and to the fact that U-NII devices capable of operating in the 5 GHz band are already on the market. The NCTA asks the FCC to apply U-NII-3 rules to the 5.9 GHz band, raise the power limits of unlicensed devices, and get rid of indoor restrictions. The NCTA asks that the FCC take action before the formal adoption of 802.11ac by the international community.
05/28/2013
05/29/2013
N
COMMENT
(52 pages)





National Association of Broadcasters (NAB)
NAB focuses their comments on the proposed U-NII-2B band. However, they are opposed to opening either the U-NII-2B or -4 band, pending the results of further study (proposed by the NTIA) on the potential effect of unlicensed devices on federal incumbents.
05/28/2013
05/29/2013
N
COMMENT
(8 pages)





Motorola Solutions, Inc.
MSI is strongly in favor of opening the 5 GHz band in general, including the DSRC segment. They are interested in "a variety of new services and applications" that would result from increased use of new 802.11ac technology. With regards to DSRC, MSI proposes adopting the UNII-4 band and harmonizing the rules for this band with other UNII bands, therefore allowing unlicensed devices to operate in the 5.9 GHz range. Also, MSI argues that the NTIA has identified possible interference mitigation techniques which, if applied to the DSRC band, might allow spectrum sharing. While MSI admits that opening the DSRC band would have to be done with respect to incumbent devices/applications/stakeholders, the DSRC band falls under their larger argument that the entire 5 GHz band should be opened for unlicensed UNII device use.
05/28/2013
05/29/2013
N
COMMENT
(16 pages)





Motorola Mobility LLC
Motorola Mobility is in favor of opening up the 5.9 GHz band in order to help create four 160-MHz channels or nine 80-MHz channels available for unlicensed, 802.11ac-compliant devices. Motorola Mobility does not mention DSRC explicitly in its comments. They do state that the FCC should make the 5.9 GHz band available to unlicensed U-NII devices “on a shared bases with current federal and non-federal incumbents”; however, they do not offer any suggestions on how to accomplish this, opting instead to urge that “the Commission should decline to adopt additional sharing requirements or other restrictions” for the proposed U-NII-4 band (p. 7).
05/28/2013
05/29/2013
N
COMMENT
(9 pages)





Mercedes-Benz USA, LLC
Mercedes-Benz is against sharing the DSRC band because potentially harmful interference from U-NII devices may interrupt the communication systems which enable safety-critical applications to work. The company urges the FCC not to open the band to spectrum sharing unless U-NII proponents engage with “all interested parties” to develop sharing techniques that pass rigorous testing.
05/28/2013
05/29/2013
N
COMMENT
(3 pages)





Cambium Networks
Cambium Networks is concerned with the 5.7 GHz band and does not mention DSRC. Cambium is in favor of exploring the possibility of opening the 5 GHz band to use by unlicensed devices only if such use is on a secondary basis which protects incumbents. Furthermore, Cambium rightly points out that there are problems with certain spectrum sharing techniques that have been proposed in the first round of comments, such as the suggestion made by Google and Microsoft that U-NII devices reference geolocation databases in order to avoid interference, because incumbents [such as DSRC] are “nomadic or mobile.”
05/28/2013
05/29/2013
N
COMMENT
(7 pages)





Intelligent Transportation Society of America (Squire Sanders (US) LLP)
The argument made in ITS America's comments is as follows: (a) DSRC has the ability to save lives and drastically reduce the economic impact of vehicle collisions; (b) DSRC is the recognized incumbent of the proposed U-NII-4 band; (c) multiple deployments of DSRC technology in various locations across the country deserve, and are legally entitled to, protection from disruptive interference; (d) the NPRM has created an uncertain regulatory environment that is not based on thorough testing and which threatens upcoming deployments representing substantial investment from public and private stakeholders. ITS America therefore urges the FCC to "affirm that it will continue to provide a stable and secure platform in the 5.9 GHz band for DSRC" (p. i).
05/28/2013
05/29/2013
N
COMMENT
Comments of ITS America (61 pages)




Information Technology Industry Council
The ITI is in favor of opening the proposed U-NII-2 and -4 bands to unlicensed device use because (a) the 5 GHz band is the best candidate to meet the ever-growing demand for data throughput, and (b) the economic rewards from this will be huge. ITI does not offer any technical solutions beyond noting that "ITI's members are confident that sharing technologies can be developed to protect the primary users in the 5 GHz band," and because DSRC and Wi-Fi are based on the IEEE 802.11 standard, "there is good reason to believe that a mutually acceptable sharing mechanism can be developed (p. 8).
05/28/2013
05/29/2013
N
COMMENT
(10 pages)





Hubbard Broadcasting, Inc.
Holland & Knight LLP
05/28/2013
05/29/2013
N
COMMENT
(15 pages)





Hans Klein

05/28/2013
05/29/2013
N
COMMENT
Comments by ITSPAC Intelligent Transportation Systems Program Advisory Committ (4 pages)

Greg Larson

05/28/2013
05/29/2013
N
COMMENT
(2 pages)





Google Inc. and Microsoft Corporation
Google and Microsoft are in favor of opening the 5.9 GHz band, and the 5 GHz band in general, in order to pave the way for gigabit Wi-Fi technology. In particular, these comments mention the possibility of widespread two-way video streaming and of improved internet access for rural areas. Like many other comments, those from Google and Microsoft advise raising device power limits, reducing indoor restrictions, and harmonizing technical rules across the 5 GHz band. Unlike the others, however, these comments offer a technical alternative to Dynamic Frequency Selection in which unlicensed devices would ping a geolocation database to determine whether or not there is a possibility of signal interference at that location. According to Google and Microsoft, such techniques promise an alternative to spectrum sharing that is cheaper and more user-friendly than DFS.
05/28/2013
05/29/2013
N
COMMENT
(13 pages)





Globalstar, Inc.
Lawler, Metzger, Keeney & Logan, LLC
05/28/2013
05/29/2013
N
COMMENT
(14 pages)





Ford Motor Company

05/28/2013
05/29/2013
N
COMMENT
(3 pages)





First Step Internet, LLC
Rini O'Neil, PC
05/28/2013
05/29/2013
N
COMMENT
(5 pages)





Fastback Networks
Goldberg, Godles, Wiener & Wright LLP
05/28/2013
05/29/2013
N
COMMENT
(11 pages)





Ericsson
Ericsson supports the FCC's suggestion to open the 5.9 GHz band to sharing by applying similar technical rules across the proposed U-NII-3 and -4 bands. They note that DSRC is an incumbent in the band, however, and ask that the FCC study the possible co-existence of DSRC/ITS applications and U-NII devices, with the eventual goal of expanding the spectrum available for Wi-Fi use. Ericsson suggests three possible techniques for sharing the U-NII band in general: DFS, geolocation database checking, beaconing/pilot channels.
05/28/2013
05/29/2013
N
COMMENT
(13 pages)





Engine Advocacy

05/28/2013
05/29/2013
N
COMMENT
(2 pages)





Wi-Fi Alliance
The Wi-Fi Alliance is in favor of opening the 5.9 GHz band, but argues that before the FCC implements new rules, it is necessary to test the ability of spectrum-sharing technology to protect incumbents in the U-NII-4 band such as DSRC. The Wi-Fi Alliance states that there should be "no harmful interference to incumbent use" (p. iii). Furthermore, the Wi-Fi Alliance agrees with IEEE 802 regarding the utility of the FCC comment-reply comment cycle in determining the necessity or viability of spectrum sharing technologies. The Wi-Fi Alliance echoes the IEEE word for word in this passage, found on p. 27 of the Alliance's comments: "stakeholders from both sides [should] hold a series of meetings to (1) exchange information on respective requirements, (2) discuss possible mitigation solutions prepared by the technical experts from the 802.11 community, and (3) come to an agreement on a mutually acceptable solution for testing/implementation…If brought to fruition, then industry participants would need to work closely with FCC and other government agencies to develop certification rules that unlicensed devices will use to gain FCC approval, including potentially additional tests to ensure the certification rules operate as needed."
05/28/2013
05/29/2013
N
COMMENT
Wi Fi Alliance Comments (49 pages)




Consumer Electronics Association
The Consumer Electronics Association is in favor of opening the 5.9 GHz band for unlicensed device use, but only if incumbents such as DSRC are protected. The CEA states that unlicensed device use "would be secondary to licensed operations and therefore must provide for protection of licensed operations" (p. 15)
05/28/2013
05/29/2013
N
COMMENT
(20 pages)





Comcast Corporation
Comcast is in favor of designating the U-NII-4 band for unlicensed device use. Comcast acknowledges that incumbent users of the proposed U-NII-4 band exist, and although they state that incumbents such as ITS licensees "would continue to be able to operate in this spectrum," they do not propose any technical solutions to spectrum sharing other than DFS. A large portion of Comcast's comments focus on competing benefits, such as building gigabit wi-fi capacity using the 5.9 GHz band.
05/28/2013
05/29/2013
N
COMMENT
(33 pages)





Cisco Systems, Inc.
Cisco is not categorically against opening the 5.9 GHz band to unlicensed devices. However, their comments clearly state their position, which is that DSRC has the potential to significantly reduce the number of road collisions, has been steadily moving towards fruition, and as an incumbent, therefore deserves protection from the FCC until a consensus of stakeholders, government and private industry included, has developed a criteria for avoiding harmful interference as a result of spectrum sharing.
05/28/2013
05/29/2013
N
COMMENT
(126 pages)





Cablevision Systems Corporation
Cablevision does not explicitly mention DSRC, but it is in favor of harmonizing technical rules across the U-NII band, and is therefore in favor of opening the DSRC band. Specifically, Cablevision supports raising the power level for devices in the U-NII-1, -3, and -4 bands; eliminating outdoor use restrictions in U-NII-1 and -4; and is against imposing DFS requirements outside of the U-NII-2 band. This would obviously disrupt DSRCS, but Cablevision makes no statements regarding the incumbent status of DSRC nor the corollary rights to protection.
05/28/2013
05/29/2013
N
COMMENT
(9 pages)





Baron Services, Inc.
Baron is “a leading manufacturer of C-band broadcast weather radar systems,” and as such has “deep concern regarding the Commission’s consideration of expanded [U-NII] operations in the 5 GHz band. Baron urges the FCC to ban unlicensed use of the 5 GHz band, particularly the 5.35-5.47 GHz portion.
05/28/2013
05/29/2013
N
COMMENT
(39 pages)





BNetzA Germany

05/28/2013
05/29/2013
N
COMMENT
(3 pages)





American Honda Motor Co.,Inc.

05/28/2013
05/29/2013
N
COMMENT
Honda Comment (5 pages)




American Association of State Highway & Transportation Officials
Shulman Rogers Gandal Pordy & Ecker, P.A.
05/28/2013
05/29/2013
N
COMMENT
(22 pages)





Advanced Designs Corporation
Fletcher, Heald & Hildreth, PLC
05/28/2013
05/29/2013
N
COMMENT
(5 pages)





ARRL, the national association for Amateur Radio
Booth, Freret, Imlay & Tepper, P.C.
05/28/2013
05/29/2013
N
COMMENT
Comments of ARRL the national association for Amateur Radio (14 pages)


General Motors Company

05/24/2013
05/28/2013
N
COMMENT
(3 pages)





Association for the Advancement of Medical Instrumentation

05/24/2013
05/28/2013
N
COMMENT
(16 pages)





Part 2 of 2


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Name of Filer Lawfirm Name Date Received Date Posted Exparte Type of Filing Documents
Wireless Internet Service Providers Association Lerman Senter PLLC 05/28/2013 05/29/2013 N COMMENT (26 pages)
Toyota Motor North America, Inc. 05/28/2013 05/29/2013 N COMMENT (20 pages)
Time Warner Cable Inc. 05/28/2013 05/29/2013 N COMMENT (16 pages)
Thomas Zorn 05/28/2013 05/29/2013 N COMMENT Volkswagen Comments (3 pages)
The Alliance of Automobile Manufacturers, Inc. and the Association of Global Aut Hogan Lovells US LLP 05/28/2013 05/29/2013 N COMMENT (82 pages)
Telecommunications Industry Association 05/28/2013 05/29/2013 N COMMENT (21 pages)
Søren Hess Car 2 Car Communication Consortium 05/28/2013 05/29/2013 N COMMENT (3 pages)
Shared Spectrum Company St. Ledger-Roty Neuman & Olson LLP 05/28/2013 05/29/2013 N COMMENT (7 pages)
Savari, Inc. Venable LLP 05/28/2013 05/29/2013 N COMMENT Savari Comments (39 pages)
SPITwSPOTS, Inc. Rini O'Neil, PC 05/28/2013 05/29/2013 N COMMENT (5 pages)
SES S.A. and Intelsat S.A. SatCom Law LLC 05/28/2013 05/29/2013 N COMMENT (15 pages)
SAE International 05/28/2013 05/29/2013 N COMMENT (4 pages)
Ruckus Wireless, Inc. 05/28/2013 05/29/2013 N LETTER (1 page)
QUALCOMM Incorporated 05/28/2013 05/29/2013 N COMMENT (25 pages)
Paul Nikolich 05/28/2013 05/29/2013 N COMMENT (42 pages)
OmniAir Consortium 05/28/2013 05/29/2013 Y NOTICE OF EXPARTE OmniAir Response to NPRM regarding 5 9 GHz Band (13 pages)
National Cable & Telecommunications Association 05/28/2013 05/29/2013 N COMMENT (52 pages)
National Association of Broadcasters (NAB) 05/28/2013 05/29/2013 N COMMENT (8 pages)
Motorola Solutions, Inc. 05/28/2013 05/29/2013 N COMMENT (16 pages)
Motorola Mobility LLC 05/28/2013 05/29/2013 N COMMENT (9 pages)
Mercedes-Benz USA, LLC 05/28/2013 05/29/2013 N COMMENT (3 pages)
Mark Thomas 05/28/2013 05/29/2013 N COMMENT (7 pages)
Intelligent Transportation Society of America Squire Sanders (US) LLP 05/28/2013 05/29/2013 N COMMENT Comments of ITS America (61 pages)
Information Technology Industry Council 05/28/2013 05/29/2013 N COMMENT (10 pages)
Hubbard Broadcasting, Inc. Holland & Knight LLP 05/28/2013 05/29/2013 N COMMENT (15 pages)
Hans Klein 05/28/2013 05/29/2013 N COMMENT Comments by ITSPAC Intelligent Transportation Systems Program Advisory Committ (4 pages)
Greg Larson 05/28/2013 05/29/2013 N COMMENT (2 pages)
Google Inc. and Microsoft Corporation 05/28/2013 05/29/2013 N COMMENT (13 pages)
Globalstar, Inc. Lawler, Metzger, Keeney & Logan, LLC 05/28/2013 05/29/2013 N COMMENT (14 pages)
Ford Motor Company 05/28/2013 05/29/2013 N COMMENT (3 pages)
First Step Internet, LLC Rini O'Neil, PC 05/28/2013 05/29/2013 N COMMENT (5 pages)
Fastback Networks Goldberg, Godles, Wiener & Wright LLP 05/28/2013 05/29/2013 N COMMENT (11 pages)
Ericsson 05/28/2013 05/29/2013 N COMMENT (13 pages)
Engine Advocacy 05/28/2013 05/29/2013 N COMMENT (2 pages)
Wi-Fi Alliance 05/28/2013 05/29/2013 N COMMENT Wi Fi Alliance Comments (49 pages)
Consumer Electronics Association 05/28/2013 05/29/2013 N COMMENT (20 pages)
Comcast Corporation Wiltshire & Grannis LLP 05/28/2013 05/29/2013 N COMMENT (33 pages)
Cisco Systems, Inc. 05/28/2013 05/29/2013 N COMMENT (126 pages)
Cablevision Systems Corporation Jenner & Block LLP 05/28/2013 05/29/2013 N COMMENT (9 pages)
Baron Services, Inc. Holland & Knight LLP 05/28/2013 05/29/2013 N COMMENT (39 pages)
BNetzA Germany 05/28/2013 05/29/2013 N COMMENT (3 pages)
American Honda Motor Co.,Inc. 05/28/2013 05/29/2013 N COMMENT Honda Comment (5 pages)
American Association of State Highway & Transportation Officials Shulman Rogers Gandal Pordy & Ecker, P.A. 05/28/2013 05/29/2013 N COMMENT (22 pages)
Advanced Designs Corporation Fletcher, Heald & Hildreth, PLC 05/28/2013 05/29/2013 N COMMENT (5 pages)
ARRL, the national association for Amateur Radio Booth, Freret, Imlay & Tepper, P.C. 05/28/2013 05/29/2013 N COMMENT Comments of ARRL the national association for Amateur Radio (14 pages)
General Motors Company 05/24/2013 05/28/2013 N COMMENT (3 pages)
Association for the Advancement of Medical Instrumentation 05/24/2013 05/28/2013 N COMMENT (16 pages)