Working With the FCC for Spectrum Allocation for Schools.

An address by Jim Burger


Macarthur Study Workshop


Cost-Effective Networking Technologies for School and School/Home K-12 Networking.

Council for Chief School Officers
1 Massachusetts Ave, 7th Floor
Washington, D.C.
July 7th, 1995

Good afternoon. I'm Jim Burger, Director, Government Affairs for Apple Computer. But my alter-identity is as a diehard, not-recovering, spectrum addict.

The topic Curt suggested for me is: "Working With the FCC for Spectrum Allocation for Schools." How great it is that I don't have to describe "Working Against the FCC!" It hasn't always been that way.

I'd like to start by staking down Apple's position on today's FCC. Cutting back or eliminating government is this election-cycle's buzz-concept. So I want to make it clear from the outset that, of course, we want all possible improvements to government. But, when we get to the FCC, we distance ourselves from those who want to maim it or kill it off, and now I'll try to explain why. "Making Government Work" isn't always the same as "Making Government Disappear," and the FCC is a case in point.

The computer industry developed in obscure corners around the country, none of which were in easy reach of this town--which may have some significance. We've been extraordinarily free from, and blissfully ignorant of, regulation and the political arts and occult sciences thereof. There never was a Federal Computer Commission, and if there had been, Apple would never have been born. In fact, your typical computer person skips through the House and Senate vote tallies in his newspaper and heads straight for "Dilbert," the archetype of almost everybody I know on Apple's Cupertino R&D campus. And I utter that with the deepest respect and admiration for all of them.

Several years ago, we came to the stark realization that computers aren't number-crunchers;--they are, deep within their user-friendly megabyte-souls, basically communicators. Moreover, they are information-hungry communicators. Computers and their keepers devour whole data-bases and come back, licking their mice-whiskers, for ever-more. They're insatiable.

Getting info-nourishment requires being connected beyond one's reach. Until recently the technology of connection was to run a wire or cable or fiber. In fact now you run enough cables that they can become occupational hazards. We had a good grasp of that early on, and every MacIntosh computer ever shipped has built-in, plug-and-play networking. But we didn't realize that more always would be needed. All because info-hunger feeds on one word: Bandwidth.

Communications bandwidth is the fundamental resource for the information industry. It's right up there next to or even above silicon.

So when we had this communications epiphany, we set out to develop every possible way to connect computers. About that same time, along came laptop computers. Laptops equal portability and mobility. And portability and mobility translate directly to wireless. I don't have to prove that point to this assembly.

So we looked about, and found to our surprise that wireless computing, of the kind we sought, wasn't legal. You could go to jail, I guess, if you sent an Email message wirelessly. There wasn't any spectrum .

So now to the epic drama of our quest for wireless bandwidth and our working with the FCC.

Four and a half years ago, we came to the FCC portal with ideas and visions, and a radical proposal. What if we had a dedicated piece of spectrum for computer data communications? What could we do with it? Who could benefit? We asked for 40 precious MHz for unlicensed, simple-to-use data communications in places like schools and hospitals and business. Not covering the world, but replacing or augmenting that snake-nest of under-desk wires.

We found a receptive FCC, and we worked with them to refine our requests and, along the way, check our sometimes questioned sanity. As recent events have shown, we were just asking for something like Four Billion Dollars worth of spectrum, and we needed to get it for free.

Apple's fabled "Data-PCS" petition hit the newswires and it took just one day to arouse demands for wireless computing. Our industry competitors joined in--IBM, to name but one, became one of the most effective supporters, and this was long before Apple and IBM were on speaking terms. So did medical groups, but the most passionate and eloquent support came from school-persons. A single letter, from a school administrator in Pinellas County, Florida, to our Dave Nagel, now our Senior Vice President, released Apple's energies and they're still going. Within a few weeks we also got endorsed and encouraged by virtually every educational association in the country.

We then spent four years working the regulatory arena, on the Hill, in the Commerce Department. A core group of computer companies, software developers, users and institutions has tromped the staircases together, ignoring our hot competitive roles. We went before Committees, and "en banc" FCC hearings, made numerous demonstrations and filed an unbelievable number of formal documents at the Commission. And after Chairman Hundt came on, we really started to win.

Now, I'll apply Apple's best data-compression technology to my narrative, and go quickly to February 7, this year. That's the day we heard the FCC grant us 10 MHz, positioned as favorably as it possibly could be, ready to use. I'd describe it as the ideal nutrient for development of wireless networking in schools.

Because it isn't heavily occupied, and because the Rules for using it were developed by Apple and our industry relatives, it's possible to cut hardware costs by two-thirds, and we can triple or quadruple the performance, which reminds us, of course, of that word Bandwidth.

I think that Chairman Reed Hundt's focus on education played a big part in our industry's win. Computers and Communications are one organism that can't survive separation. And computers in education seem to be his favorite subject.

One of the first signals of Chairman Hundt's computer awareness, was his plea for a hard-core, competent computer-industry expert to join the FCC, full time, to help set policy on computer issues from the inside. You met Mark Corbett earlier, and Mark represents not just his own dedication but the Chairman's wisdom in attracting someone of Mark's quality. By engaging Mark, the Chairman has blunted some of the traditional ways that spectrum decisions were influenced because now there's internal competence. We no longer measure spectrum in terms of Lawyers per MegaHertz. Public benefit, not lobbying prowess, counts now.

About six weeks ago, Apple took another big leap into the spectrum trough. We filed another petition, our second major one, asking for 300 MHz for the necessary unlicensed wireless elements of the NII. We call it our "NII Band" petition.

We're trying to widen that wireless bandwidth to accommodate the growth in multimedia and other information-rich tools. Whereas we can finally do Ethernet-grade service in our recently-acquired ten MHz, we want to be able to "unwire" whole schools and campusses, and hospitals and all the rest, and it'll take more than 10 MHz.

Meanwhile, another need has been revealed.

Earlier this spring Apple hosted the "Ties That Bind" conference that Curt referenced earlier in his agenda. That assemblage was of Community Networkers, some of the most dedicated, altruistic and competent people you could meet. NTIA Administrator Larry Irving was a stellar keynoter and a willing, accessible, dialog-engager.

What was demonstrated over and over by the Community Network people was that there is a gap in the communications network fabric. It's a distance gap. It isn't possible in many places to get on-line access, with high Bandwidth (there's that word again!), to resources like the Internet today. Tomorrow, without new spectrum, it'll still be impossible or overwhelmingly expensive in some places to reach the NII, however the NII may develop. One technology today is to spend 2 or 3 Hundred Thousand $$ on a microwave link.

We think it should be a few hundred, not hundred thousand, dollars and your source could be Radio Shack or your computer dealer. With your purchase you could span 5 or 10 or 15 miles, depending on local factors. We therefore have asked for new FCC rules, and an appropriate allocation, to provide an unlicensed, available-to-everyone, spectrum domain that can bridge the distance gaps in addition to offering more local bandwidth..

Almost before our ink was dry, the Commission called us and others in the industry, some with other good ideas, to discuss the needs, the technologies, the benefits of our proposed NII Band. That's an incredible pace for regulatory agency.

We actually had started moving and evangelizing the need for a wireless NII Band immediately after the White House introduced its landmark NII paper, Agenda for Action, almost two years ago. We've spoken to any person or group who would listen, and we've hosted some big Washington personalities at Apple to see our technologies in action.

This week, in fact around five pm Tuesday when firecrackers were going off, a member of the press put on line, his really forceful article about Apple's NII Band quest. He said our petition is "the summer's best read." He suggested that people take part in shaping the NII Band and, especially, to join the chorus of spectrum-seekers. He included the Email address for my associate in Cupertino who is most involved. Sharply on the heels of that, Curt, here, made his own powerful posting and call to action.

An hour later, six pm on the Fourth, the Email in-basket was overwhelmed. As of about 5:30 this morning our time, according to my latest update from the person spending the night in Cupertino trying to keep up, we've gotten hundreds of first-rate, high-quality personal offers for help and better yet, suggestions for how the band should be developed. These are not your typical joiners of causes. These are from all sectors of society and include well-recognized names. Curt can testify to all this better than I can.

Our web posting of our NII Band petition has now been "hit" many thousands of times, and by counting how many Megabytes have been pulled down, it looks like more than five thousand copies of our petition are now downloaded and probably read, and this pace is increasing as of a couple of hours ago.

The near-irony of this is that we are using the NII, to develop the NII. It's wonderful. It may be a first, but we can be sure it won't be the last.

Let me wind up, away from my unpaid commercial for the "NII Band," and get back to the FCC. Just one essential function of the FCC, that of spectrum allocation, is the most difficult one they face, they say. If the FCC were to be wiped out, the proposed way of spectrum management is to let market auctions make the allocation decisions. I'm here today to say, as strongly as I can, that without this FCC, there would be no public spectrum for schools or anyone else lacking immense pockets and a profit angle. The FCC is a regulatory agency and is equally a society shaper. We need a strong FCC; this FCC.

In a word, "Working With The FCC" is fantastic. Why don't you come join us?

Thank you.