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Thanks for the inputs and understand your concerns. The point in the comments made about the end rules still need to have the integrity (and proper due diligence) all are use too, may touch a little bit of what you bring up.
You caught us on the KDB needs expanded out and will do some editorial on expanding the further definition of new is needed in the rule, which is exactly why it was mentioned. As seen with many KDBs, they are to go beyond, add to, FCC interpretation and further detail on a subject, not to replace the rule, why the KDB was mentioned, to add to.
I vote Disapprove.
Here are some concerns:
(1) I cannot understand much of the proposed text. For example, I have trouble parsing: 'However, what if there are additional circumstances, for example, would shifting an existing technology to a new area of spectrum that is unique or significant be considered "New” technology?'
(2) The acronym "KDB" should be expanded but, in any case, I don't believe that providing examples of what is "new" would replace the need to define it.
(3) Having reviewed the FCC NPRM, I am troubled by some of the dissenting Commissioner's concerns. Some of these are addressed in the draft, but I worry about "Incumbents today are vulnerable to upstarts tomorrow. The rules proposed here—under the guise of spurring innovation—will give anyone threatened by change the ability to oppose what is novel and the right to stonewall progress." It seems that the proposed rules place requirements on the "new" petitioner but none on those opposing.
(4) The only real implication on the FCC that I can see in the proposed rules is that it would be "obligated to take some concrete action within one year that advances the development and use" once newness is ascertained. To me, it doesn't seem very effective to set up a deadline to do something without any clarity about what it is.
I don't plan to change my vote, but I do suggest you consider an editorial review.
On May 11, 2018 at 1:25:49 PM, Holcomb, Jay (email@example.com) wrote:
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