On 8/11/15 FCC released the above NPRM in Docket 14-166 on wireless microphone use. Readers may recall a previous post entitled "Do FCC NOIs/NPRMs Have Too Many Poorly Organized Questions?" and a related one titled "How Many Questions in FCC NOIs/NPRM? 'Let me count the ways' " that included Elizabeth Barrett Browning's Sonnet 43 as a service to readers. But the Docket 14-166 may well set a new recent record for FCC!

Let me count the ways:

Above is a typical page with all the questions ending in question marks highlighted. There are 314 such questions and they appear on 49 different pages! Is that all? Of course not! The multiple authors of this document are very creative in making and hiding questions to make an exact count difficult. The word "seek" appears 158 times in such uses as

• "Further, we seek comment on proposals for authorizing wireless microphone operations in additional spectrum bands, consistent with the Commission’s overall spectrum management goals_ - para. 4
• "In addition, we seek comment on authorizing licensed wireless microphone operations in other bands. " - para. 30
• "We seek on comment on the different groups of wireless microphone operators and their various uses of microphones, including the particular applications served by the microphones, the types and number of devices used, the extent to which the devices are analog or digital, the settings in which they are used, and the frequency bands they use. " - para. 33
• "We also seek comment on the nature of the demand for wireless microphones by various wireless microphone users" - para. 38

Arguably some of the uses of "seek" in the text are not actually questions, so the count of 158 is a little high. But FCC staff has ways of asking questions without either the use of a question mark or the work "seek":

• "We ask that the different user groups, or the manufacturers of products for these groups, provide detailed information about the particular nature of wireless microphone uses by different groups of users." - para. 33

Your blogger actually compiled and submitted a list of all the 176 questions in Docket 14-177 (24+GHz 5G), but he does not have the patience to do the same in this tangled mess. As we have indicated in the posts mentioned earlier, both UK's Ofcom and Industry Canada number questions in their NOI and NPRM counterparts. Now some would say that they are not subject to the APA like FCC is, but having attended the FCBA reception at the Supreme Court last night, let me boldly say that I don't think the Supreme Court would remand an FCC decision just because its questions had numbers. It might remand a decision because it did not address the record and with so many tangled questions, how does one address the record?

Tags: Wireless Mic Issue, FCC Reform