These policy tradeoffs are interesting (and tricky) - if you have a huge number of different parties that are unorganized yet impacted by a policy, how do you ensure you have adequate representation from them when compared to a single well-organized party?
> The Petition recognizes that there currently are unlicensed part 15 devices operating in the Lower 900 MHz Band, but it is unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices. With respect to part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.” Id.
> NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices. See Petition at A-6 (proposing to amend § 90.361), A-11 (proposing to add § 90.1410(c)).
Requesting public comment is perhaps better than nothing (and likely better than just allowing lobbyists to influence policy behind closed doors), but it's a hard problem to quantify whether the collected comments are representative when one side is more heavily resourced and organized than the other?
Is it even possible to "work with unlicensed users to understand their spectrum requirements" in a way that doesn't ignore a potentially substantial long-tail of varied usage?
> The Petition recognizes that there currently are unlicensed part 15 devices operating in the Lower 900 MHz Band, but it is unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices. With respect to part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.” Id.
> NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices. See Petition at A-6 (proposing to amend § 90.361), A-11 (proposing to add § 90.1410(c)).
Requesting public comment is perhaps better than nothing (and likely better than just allowing lobbyists to influence policy behind closed doors), but it's a hard problem to quantify whether the collected comments are representative when one side is more heavily resourced and organized than the other?
Is it even possible to "work with unlicensed users to understand their spectrum requirements" in a way that doesn't ignore a potentially substantial long-tail of varied usage?