Rulemaking Comments Filed by Clarendon Foundation

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Comments Filed by Clarendon Foundation

1. Amendment of Part 74 of the Commission’s Rules Governing Use of Frequencies in the Instructional Television Fixed Service, Mass Media Docket No. 93-106

Document: Comment
Position: Support Proposed Amendment of ITFS Rules to Permit Channel Loading
Docket: 93-106
FCC No.: FCC 93-183
Citation: 8 FCC Rcd 2828; 58 FR 26728
Date: 06/14/93

2. Amendment of Part 74 of the Commission’s Rules with Regard to Instructional Television Fixed Service

Document: Comment
Position: Support Adoption of Window Filing System; Filing Practices to Impede Frequency Speculation
Docket: 93-24
FCC No.: FCC 94-148
Citation: 9 FCC Rcd 15; 9 FCC Rcd 3348; 59 FR 35665
Date: 08/29/94

3. Amendment of Parts 2 and 15 of the Commission’s Rules to Permit Use of Radio Frequencies Above 40 GHz for New Radio Applications

Document: Comment
Position: Request that FCC Reserve Certain Spectrum in 40 GHz Band for Educational Use
Docket: 94-124
FCC No.: FCC 97-153
Citation: 11 FCC Rcd 4481 (1995)
Date: 01/30/95

4. Consulting Engineers Petition Requesting Revision of Initial Filing Window for Two-Way Multipoint Distribution and Instructional Television Service. Denied ITFS 2020 Emergency Petition for a Nine-Month Postponement of the Filing Window (15 FCC Rcd 10912; 65 FR 39900).

Document: Opposition
Position: Opposition to FCC Request for Delay in Filing Window for Licenses for Two-Way Digital Service
Docket: 97-217
FCC No.: DA 00-1401
Date: 06/20/00

5. Amendment of Parts 21 and 74 to Enable Multipoint Distribution Service and the Instructional Television Fixed Service Amendment of Parts 21 and 74 to Engage in Fixed Two-Way Transmissions

Document: Comment
Position: The proposed amendment of ITFS Regulations should facilitate the deployment of next-generation digital technology, not impose rules to support obsolete instructional television technology. Licensees in each market should be permitted to reallocate channels, depending upon the technologies being utilized, analog or two-way digital, and fixed or mobile services.
Docket: 97-217; RM-10586
FCC No.: FCC 03-56
Date: 11/18/02

6. Amendment of Parts 1, 21, 73, 74 and 101 of the Commission’s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Educational, and Other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands (RM-10586)

Document: Reply Comment
Position: Support for change of FCC’s long-standing eligibility restrictions by permitting commercial interests to hold ITFS licenses and requiring them to make capacity available for educational use.
Docket: 03-66
FCC No.: FCC 03-56
Statements: Abernathy, Copps, Powell
Citation: 18 FCC Rcd 6722; 68 FR 34547
Date: 10/23/03

7. Applications of Nextel Communications, Inc. and Sprint Corporation for Consent to Transfer Control of Licenses and Authorizations

Document: Comment
Position: Support the applications filed by Sprint Corporation and Nextel Communications, Inc. to consent to merger
Docket: 05-63
FCC No.: FCC 05-148
Citation: 20 FCC Rcd 13967
Date: 04/18/05

8. Petition of Extraordinary Relief of the ITFS/2.5 GHz Mobile Wireless Engineering & Development Alliance, Inc., WT Docket No. 3-66 (July 14, 2005)

Document: Comment
Position: Reject contention by ITFS Licensees that Clarendon Foundation’s lease of excess channel capacity to Sprint is indefinite and inconsistent with FCC’s eligibility requirements for EBS licenses.
Docket: 03-66
FCC No.: FCC 05-63
Date: 08/02/05

9. Amendment of Parts 1, 21, 73, 74 and 101 of the Commission’s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Education and other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands, WT Docket No. 03-66

Document: Ex Parte Presentation
Position: Oppose efforts to limit excess capacity airtime leases of EBS channels to a maximum of 15 years. Support the rule establishing the maximum term of an EBS lease at 30 years.
Docket: 03-66
FCC No.: FCC 06-46
Date: 12/05/05

10. Order on Reconsideration and Fifth Memorandum Opinion and Order and Third Memorandum Opinion and Order and Second Report and Order, Promoting Efficient Use of Spectrum Through Elimination of Barriers to the Development of Secondary Markets: WT Docket No. 03-66, RM-10586, Docket No. 00-230 (rel. April 27, 2006) (“2006 EBS Final Rules”)

Document: Petition for Reconsideration
Position: Request for the Commission to clarify its rules for leases of EBS channels with autonomic renewal provisions.
Docket: 03-66, RM-10586
FCC: Report 2783
Citation: 71 FR 44029
Date: 07/19/06

11. Amendment of Parts 1, 21, 73, 74 and 101 of the Commission’s Rules to Facilitate the Provision of Fixed and Mobile Broadband Access, Educational and other Advanced Services in the 2150-2162 and 2500-2690 MHz Bands – WT Docket No. 03-66 (“2008 BRS/EBS Order”)

Document: Ex Parte Letter
Position: Request for clarification of FCC Order concerning rules on leasing EBS spectrum
Docket: 03-66
FCC No.: FCC 08-83
Citation: 73 FR 26032
Date: 05/09/08

12. Applications of Sprint Nextel Corporation and Clearwire Corporation For Consent to Transfer Control of Licenses and Authorizations File Nos. 0003462540 and 0003368272 et al., WT Docket No. 08-94

Document: Comment 
Position: Support the proposed merger of the assets of Clearwire and Sprint Nextel into the New Clearwire for the deployment of a nationwide mobile WiMAX network
Docket: 08-94
FCC No.: FCC 08-259
Date: 07/24/08