Probabilistic… Easy For You to Say

I’ve written about this think tank before, the Open Technology Institute at New America (OTI), covering their numerous FCC filings touting, virtually to the point of hysteria, the unbelievable, unfathomable benefits that will be unleashed should the FCC authorize Very Low Power (VLP) devices and higher power for indoor-only (LPI) devices at 6 GHz. According to OTI in an ex parte filed on August 28, these changes “are crucial for digital equity and inclusion, for continued U.S. leadership in next generation Wi-Fi, and for virtually all consumers, businesses and community anchor institutions.” What an incredible exaggeration, and while I’m at it, what the heck is a “community anchor institution?” Does the definition include utilities who maintain the electrical grid? Who elected these guys pope anyway?   

And if you thought for one moment that OTI gave a hoot about incumbent fixed operations, nay nay! For illustrative purposes, OTI offered that “the record is now complete with updated analyses that demonstrate the risk of actual harmful interference is exceedingly unlikely.” Or, based on “probabilistic” analyses (translation - what probably will happen!), and “applying the most conservative standards supplied by 6 GHz incumbents, there is no meaningful risk of harmful interference to fixed link operations.” And “based on conservative assumptions … [studies] demonstrate even more conclusively than previous work that the risk of harmful interference to incumbents from VLP devices is insignificant.”  

Well, there you have it!  It’s crystal clear.  Unless of course when there are instances of harmful interference. OTI does not speak to that probabilistic outcome or to the need for incumbent remedies.  

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