This semester, TLPC student attorneys Marcus Degen, Kolton Ray and Jeff Westling continued work on the clinic’s Petition for Rulemaking regarding spectrum interference dispute resolution. With the help of Silicon Flatirons Fellow Pierre de Vries, the student attorney’s analyzed, synthesized and replied to comments and concerns raised in the docket by various stakeholders regarding the Clinic’s proposed ALJ option: where issues arising from spectrum management could be resolved by the Commission’s Office of Administrative Law Judges.
The Clinic incorporated this research, in addition to the feedback from attorneys, technologists and policymakers, into a reply comment filed with the FCC late last week. The reply rebuts negative assumptions and responds to key concerns; the key takeaway is that numerous parties agree that there is a problem with the current system of interference dispute resolution. With this filing, we urge the FCC to take the next step and initiate an NPRM to develop a timely, transparent, and fact-based mechanism to resolve spectrum interference disputes.