SpectrumTalk

The independent blog on spectrum policy issues
that welcomes your input on the key policy issues of the day.

Our focus is the relationship between spectrum policy
and technical innnovation.

Mysterious 10/24 "Special Commission Meeting"

10-24-14
Late Friday FCC released a very unusual sunshine notice for a “special commission meeting” on 10/24 at 2:30 PM - itself an odd time for such a meeting. What is going on?

In response to our tweet on the issue several speculated it deals with the **dskins matter. We don’t think so. The issue there is a challenge to a broadcast station renewal which is not an enforcement matter and will be dealt with in a different procedure on a less urgent basis.

Our best guess is that this is something that has lingered on circulation at FCC for a while with a cryptic title that no one noticed since there are often such cryptic enforcement titles on the list. The Chairman has great control over the FCC’s agenda and perhaps got fed up with this issue lingering on the circulation list without everyone voting on it and perhaps forced the issue to a head by calling an open meeting when they can force a vote if a quorum shows up. This presumes that at least 2 other commissioners want the issue resolved in a public way.

What type of issue would force such a confrontation on the 8th Floor? Most likely it is an issue that will be of interest to consumers - considering how close it is to the election.

One possibility is a net neutrality-like issue with a major ISP. While FCC has no specific net neutrality rules in place, a case could be make that some major ISPs has been deceiving customers - a violation of other rules that are in place. For example, my ISP charges me for 15 Mbps service and advertises that it meets or exceeds that goal, but when I use Netflix I am certain that the speed is much less.

On the other hand Communications Daily reported today that it is a routine enforcement matter that was about to meet a statute of limitations deadline and that the 2 Republicans had not voted yet on it during circulation due to concerns about an overly aggressive stance of the new EB leadership. As we have written before, the basic problem in recent years has been that EB has been too enforcement adverse. Clearly there is a disagreement on this issue on the 8th Floor. Commissioners generally want to be friends with various industries. Giving out things like spectrum gets you friends, taking enforcement actions doesn’t.
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Acceleration of Broadband Deployment by Improving Wireless Facilities Siting Policies

The title of this post is the title FCC used for today’s Report and Order on tower siting (presumably not “sitting” as one FCC announcement said.)

The discussed focused on the urgent need for wireless capacity and the related wireless infrastructure. WE FULLY AGREE!

But there were 2 key points that were not said, perhaps they would be awkward given the influence of the cellular establishment at FCC and in DC in general.

capacity
First, we have used this diagram from an Ofcom report several times although we have never seen a similar diagram in any FCC publication, let alone a CTIA one. Wireless capacity is a function of 3 different inputs: spectrum, technology, and “topology”/wireless infrastructure. Historically most of the increase in capacity has come from infrastructure growth, not spectrum increases. If you double the available spectrum for cellular carriers you may increase capacity by more than 2, but you will not increase it by a factor of 20. If you need a 10,000 fold increase in capacity you need a lot more infrastructure - that is why the issue is so important. But spectrum demands generally gets much more attention. Why?

NYC cell
Second, the discussion focused almost entirely on the problem being local governments that don’t appreciate how important wireless capacity is. For no rational reason, at least that was mentioned, do local governments question the proposed installations of the cellular establishment. Well, your blogger has a somewhat different viewpoint that has been stated here before: Too often cellular infrastructure looks like it was “designed by engineers” and does not consider the physical design of the immediate environment. Here is a pair of essays from your blogger and an industry engineer that discuss very different views on this issue. You decide.

Now the cell industry does sometimes due a good job in designing infrastructure to match its environment. Here are 3 examples of apparently modest cost installations that are reasonable design compromises. Note that in all 3 cases the covers/radomes of the antennas approximately match the surface they are mounted on; in addition there a no loose visually contrasting cables in these last 3 photos:

(In NYC only 2 blocks from the previous photo)
ant7 ant6 ant5

2 way
However, the unnecessary visual ugliness of the first photo is much more common than the good design of the next 3. If FCC and the cellular industry want local governments to be more cooperative, they should view cooperation as a 2-way street. Cellular infrastructure should more consistently consider its immediate environment as part of improving the interactions between the industry and local governments. Remember what Tip O’Neill famously said:

“All politics is local”

There is a limit how much the cellular industry can impose on local jurisdictions at the current ugliness levels without a grassroots political backlash. But well designed infrastructure need not be either ugly or very expensive. More consistent attention to physical design is urgently needed!

UPDATE

PCIA Press Release: PCIA Applauds FCC’s Order on Wireless Infrastructure – Streamlined Rules Will Speed Broadband Deployment

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HBO & CBS: Enabling Cutting Both the CATV and Spectrum "Cord"

hbo-go
Yesterday HBO announced that it would offer the Netflix video on demand model called HBO GO over Internet without requiring a MVPD/CATV-like subscription. It is time to remove all barriers to those who want HBO," the network's chief executive Richard Plepler said yesterday. "So, in 2015, we will launch a stand-alone, over-the-top HBO service in the United States." So why are we talking about this here in a spectrum blog? This is either the “elephant in the room” or the “camel’s nose under the tent” in the spectrum biz.

Even major NAB member CBS is jumping on the bandwagon of alternatives to spectrum! Today they announced CBS All Access:

“a new digital subscription video on demand and Nielsen-measured live streaming service for the CBS Television Network. CBS All Access will offer subscribers thousands of episodes from the current season, previous seasons and classic shows on demand, as well as the ability to stream local CBS Television stations live in 14 of the largest U.S. markets at launch”.



Since the end of WWII broadcast over-the-air (OTA) TV has been both a large spectrum user and a huge player in spectrum regulation. When I joined FCC in 1979, we were at the end of a spectrum policy era in which the TV broadcasters, Motorola, and AT&T were the key players and virtually dictated how spectrum would be divided between their constituencies. Now Motorola and AT&T are a shadow of their former selves and perhaps the time has come for the TV broadcasters to “exit left” from the spectrum policy dictating business.

Sources have told us that the early drafts of the National Broadband Plan pointed out that when 50+ Mbps broadband becomes a universal service-like national norm - something that is critical to US society and economy for reasons not directly related to spectrum policy, then spectrum for OTA TV in urban areas will no longer be important since the content can be easily distributed over the broadband. Now some will ask about the economically disadvantaged - a real concern. But is allocating 100s of MHz and pumping megawatts in the ether the only way to deal with universal access to “free TV”? Universal access could also be handled by providing Internet based distribution of “basic video” - the present “free TV” - on either a Universal Service Fund-like model or via a freemium pricing model where basic video is free over broadband and higher tier services are priced separately, either in packages or individually. You will not find any such discussion in the published NBP. It was too controversial and pressure from the Hill resulted in its deletion as a topic.

AlitoTV

Recall the Justice Alito 2012 quote shown above in a dialogue with Fox’s lawyer at the Supreme Court. Elected officials, FCC staff, and even FCC commissioners can not be as candid as Justice Alito who has life tenure. Maybe OTA TV will be here forever, but shouldn’t FCC and the spectrum policy community consider other alternatives?

The spectrum held by TV broadcasters today has huge economic value. Without worrying about issues of “unjust enrichment” we should let the broadcasters recoup that market value by programs such as the incentive auction so that the spectrum goes to its best uses - not necessarily the CTIA membership. The present OTA broadcasters will thus be compensated and the political process will not have to deal with determining fair compensation or the nuances of § 304. But the main reason OTA broadcasters use spectrum and megawatts of RF is get “must carry” rights to demand compensation from MVPD operators. The vast majority of US household simply do not watch OTA signals directly, although NAB and CEA can’t agree on the details of the data. There must be a better way!

We also note that this year HBO and Game of Thrones dominated Emmy nominations. Here's how the broadcast networks stacked up:

  • CBS – 47 nominations
  • NBC – 46 nominations
  • ABC – 37 nominations
  • PBS – 34 nominations
  • FOX – 18 nominations

And here's the list of non-OTA leaders
  • HBO – 99 nominations
  • FX Networks – 45 nominations
  • Showtime – 24 nominations
  • Comedy Central – 21 nominations
  • Lifetime – 17 nominations
  • FOX/NatGeo – 12 nominations

Notice a trend?


An Incorrect NerdAlert Prediction from 11/13

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866 Mbps Achieved in Unlicensed 60 GHz Band

As FCC prepares for consideration of an NOI on 24+ GHz mobile use on Friday, there is interesting news from Samsung on a major data speed increase in the 60 GHz unlicensed band. An October 12 press release says:

Samsung Electronics announced the development of its 60GHz Wi-Fi technology that enables data transmission speeds of up to 4.6Gbps, or 575MB per second, a five-fold increase from 866Mbps, or 108MB per second, the maximum speed possible with existing consumer electronics devices. As a result, a 1GB movie will take less than three seconds to transfer between devices, while uncompressed high-definition videos can easily be streamed from mobile devices to TVs in real-time without any delay.

“Samsung has successfully overcome the barriers to the commercialization of 60GHz millimeter-wave band Wi-Fi technology, and looks forward to commercializing this breakthrough technology,” said Kim Chang Yong, Head of DMC R&D Center of Samsung Electronics. “New and innovative changes await Samsung’s next-generation devices, while new possibilities have been opened up for the future development of Wi-Fi technology.”

Unlike the existing 2.4GHz and 5GHz Wi-Fi technologies, Samsung’s 802.11ad standard 60GHz Wi-Fi technology maintains maximum speed by eliminating co-channel interference, regardless of the number of devices using the same network. By doing so, Samsung’s new technology removes the gap between theoretical and actual speeds, and exhibits actual speed that is more than 10 times faster than that of 2.4GHz and 5GHz Wi-Fi technologies.

Until now, there have been significant challenges in commercially adopting 60GHz Wi-Fi technology , as millimeter waves that travel by line-of-sight has weak penetration properties and is susceptible to path loss, resulting in poor signal and data performance. By leveraging millimeter-wave circuit design and high performance modem technologies and by developing wide-coverage beam-forming antenna, Samsung was able to successfully achieve the highest quality, commercially viable 60GHz Wi-Fi technology.

In addition, Samsung also enhanced the overall signal quality by developing the world’s first micro beam-forming control technology that optimizes the communications module in less than 1/3,000 seconds, in case of any changes in the communications environment. The company also developed the world’s first method that allows multiple devices to connect simultaneously to a network.

As is the case with the 2.4GHz and 5GHz spectrum, the 60GHz is an unlicensed band spectrum across the world, and commercialization is expected as early as next year. Samsung plans to apply this new technology to a wide range of products, including audio visual and medical devices, as well as telecommunications equipment. The technology will also be integral to developments relevant to the Samsung Smart Home and other initiatives related to the Internet of Things

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Note the first sentence of the last paragraph: “As is the case with the 2.4GHz and 5GHz spectrum, the 60GHz is an unlicensed band spectrum across the world”. This did not happen by accident. It happened because of FCC initiatives in the 1980s and 90s that recognized technological advances had made new technology possible that was prohibited by anachronistic FCC rules at those times. The initiatives removed those prohibitions but did not require incumbent users to change their operations on bit nor did it increase their interference risk. As a result we have had technical innovation and economic economic growth.

Nitero
GIGAOM comments:

While other WiGig companies like Intel, Wilocity (now owned by Qualcomm) and Nitero have been developing super-fast radios that work 60GHz channel, Samsung claims they’ve actually produced these enhanced speeds by fixing interference issues caused by other devices on the channel.


Now the problem is that the new NOI is rumored to contain a discussion about possible partial or total repurposing of the 60 GHz band for cellular communications, presumably on a licensed basis. The question to be considered on the 8th Floor is how will the fording of the 60 GHz discussion impact capital formation for innovative unlicensed 60 GHz technologies. We are sure the 60 GHz companies have less visibility on the 8th Floor than the major CTIA members and their insatiable demand for spectrum.

We hope the 8th Floor considers carefully the wording of such discussion and its impact on capital formation for ongoing unlicensed 60 GHz systems.

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So When are the Comments on this NPRM Due?

NPRMdate

An interesting question heard both inside and outside FCC is “when are comments due to NPRM x?” When NPRMs and similar documents that result in comments are released they usually are written as shown above with a date relative to Federal Register (FR) publication. (The Net Neutrality NPRM was a notable exception and had a clear due date on the version released by FCC.) The reason for this relative date is due to uncertainty in FR publication date which can be large compared to the comment period in many proceedings. Your blogger believes that much of variable delays in FR publication is due to back office problems at FCC in work groups of career civil servants that have low visibility and low pay grades but perform key ministerial functions in the final release of FCC documents, oddly called the “BARF process”, and in the final formatting of the text for transmission to the folks at the FR. (When documents contain tables and other unusual formatting there are usually problems getting them in the specific forma acceptable to the FR. Incorporating nonfederal standard by reference, e.g. as in §15.31(a)(3), also adds uncertainty to the final approval process due to its complexity although it is generally desirable.)

So how do you find out when things are actually due? Large law firms have paralegals that scan the FR every day for FCC items and update internal data basis for their lawyers who then inform their clients. Important items make the news in expensive trade publications such as TR Daily. But what about the rest of us?

The bureaucratic answer is to search for the published items in either the FR site or the newer Regulations.gov, “Your Voice in Federal Decision-Making”.

(Regulations,gov is part the eRulemaking Program, established in October 200as a cross-agency E-Gov initiative under Section 206 of the 2002 E-Government Act (H.R. 2458/S. 803) and is based within the U.S. Environmental Protection Agency. The eRulemaking Management Office (PMO) leads the eRulemaking Program and is responsible for the development and implementation of the public facing website, Regulations.gov. FCC is not a “partner agency” in the eRulemaking Program because it required shared funding. FCC is classified as a “Nonparticipating Agenciesin the program and its is not fully integrated - again a nod to FCC’s perpetual budget problems. The Office of the Federal Register (OFR) of the National Archives and Records Administration (NARA), and the U.S. Government Printing Office (GPO) jointly administer the FederalRegister.gov website.)

While working at FCC, your blogger tried and experiment to address this issue. The attempt is shown below and actually still lingers with old data on the FCC’s vast disorganized website:

Circa 2006 Experiment in Making Docket Information More User Friendly (Click to expand size)
CommentsDue

This table with its links to both EDOCS and ECFS as well as comment date data is one simple, user friendly way to present data. Note the “title” of each proceeding is not the official title on the caption of the coverage of the FCC document. The official caption is often a cumbersome name or one assigned early in the drafting process before the scope of the proceeding was firmly established. The tile is a plain English description of what the docket is actually about, like “net neutrality”.

So why can’t FCC give us a simple way to find to when comments are actually due in its proceedings?

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