On February 24, 2010 Chairman Genachowski announced in a speech at the New America Foundation:

“First, we are going to announce a gameplan to unleash more spectrum for mobile broadband. The National Broadband Plan will set a goal of freeing up 500 Megahertz of spectrum over the next decade. We will work closely with NTIA to do so.”

CTIA had previously stated

“we need at least another 800 MHz within six years to meet the increasing consumer demand whether it's for mobile Internet, mHealth, smart grids, or a number of other wireless uses that change the way we live and work."

So the 500 MHz no doubt was a compromise number that attempted to address reality.
As shown at left, the published National Broadband Plan (NBP) complied with Chmn. Genachowski’s statement the day before. NBP gave a table of allocation changes that “ illustrates a schedule of actions that would fulfill this latter goal.” (Actually Exhibit 5-E shows allocation actions that would reach the 2015 goal of 300 MHz.) Missing from the discussions of goals is exactly how to do the math to reach 500 MHz if anything other than nationwide, full duplex, 24/7 1000ms/sec paired spectrum was made available.

Traditionally the cellular industry has used full duplex symmetrically pair spectrum. Thus the cellular 800 MHz band is 824-849 MHz (mobile-to-base) paired with 869-894 MHz (base-to-mobile). The same type of symmetric pairing was used for PCS and 3G in high bands. This was clearly necessary when the predominant use of cellular was 2-way voice which has little tolerance of time latency/delay. But the rapid expansion of mobile communication volumes predicted by CTIA and the NBP are not 2 way voice, rather they are Internet and video related - categories that are asymmetric in information flows and more tolerant in time latency. Many of these flows are also highly intermittent as compared to voice, with high peak to average data rates. Is the traditional type of allocations the best way or the only way to handle this type of growth?

Your blogger has no objection to the reallocation of 500 MHz of spectrum for the traditional paired symmetric use, but it is becoming increasingly clear to all involved that finding 500 MHz of such spectrum will be in the extremely difficult to nearly impossible range. In addition, the major need for spectrum is in major metropolitan areas and the focus on nationwide availability of spectrum ignore options. From what I have heard, the cellular establishment wants FCC and NTIA to find it spectrum that has all the following characteristics:

• Nationwide full time availability
• Paired
• In large contiguous blocks
• Consistent with international allocations and international standards (note that this is not a legal requirement except near borders with Mexico and Canada absent a bilateral agreement)

If FCC and NTIA find spectrum for reallocation that does not meet all these criteria, can it count towards the 500 MHz goal? While no one in public office wants to say so, it is increasingly unlikely that 500 MHz of such spectrum can be found. Indeed finding the part of it now used for TV requires Congressional action on incentive auctions and who knows what can happen in our increasing dysfunctional legislative branch as the 2012 election gets closer?

So isn’t it time to start thinking of Plan B? If 500 MHz of spectrum meeting the cellular establishment’s 4 conditions can not be found with politically acceptable impact on other federal and nonfederal uses, how would “noncomplying” spectrum count towards the 500 MHz goal? Maybe for tactical reasons the cellular establish doesn’t want to consider this possibility, but to many of us it is a quite real possibility as none of the “spectrum haves” are anxious to release their part of the 500 MHz or have any impact from its altered use, e.g. GPS/LightSquared problem.

CBO knows how to “score” budget proposals, should FCC and NTIA start thinking about how to “score” spectrum reallocations with respect to the 500 MHz goal?

[I help my international neighbors by reading in English to their 4 year old. While I was writing this post, one of the books he selected was this one.I recommend it!]

Tags: Spectrum policy

A new group, Mobile Future,

is dedicated to educating the public and key decision makers on innovations in the wireless industry that have transformed the way Americans work and play and to advocate continued investment in wireless technologies. We look forward to keeping you in the loop about our news and events.

It apparently is trying to do this by producing PR that trivializes key spectrum issues, rather than encouraging productive dialogue on the issue or even improving the governmental decisionmaking process.

Mobile Future is a mixture of cellular industry groups that partially overlaps the CTIA membership and some public interest groups. The industry membership includes AT&T, T-Mobile, Alcatel-Lucent, Qualcomm, Cisco, and Ericsson but does not include Sprint, Verizon, Nokia, or Motorola. Other members include Black College Communication Association, Labor Council for Latin American Advancement, National Gay and Lesbian Chamber of Commerce, and the National Association of Neighborhoods. You can be pretty sure that the first group of members named above are paying the bills and the second groups is there for “window dressing”.

The video uses the classic “pie” metaphor for spectrum, “the invisible magic that makes our mobile technology work”. “Image spectrum as a freshly baked pie” it goes on. “Spectrum is not an unlimited resource..we’re running low fast...If we don’t allocate more spectrum for mobile, our nation’s appetite for mobile will outstrip capacity in as little as 4 years”. “Too little spectrum means unreliable service and performance..even rationing of wireless services.”

Note that the “pie” shown here, only includes spectrum used by the sponsors with the except of “radio and TV” - would that spectrum management be so simple. In reality there is military use, there is FAA use, there is local, state, and federal public safety use. There is even amateur radio use, not to forget radio astronomy.

But is mobile capacity really proportional to available spectrum? We will not here get into the previously reported NAB and CTIA battling reports. Your blogger is closer to CTIA on that issue than NAB. But the Mobile Future viewpoint is just too much to swallow.

Ofcom, FCC’s well respected UK counterpart, released in January a report entitled 4G Capacity Gains. The study starts with a bold and simple statement that is usually fuzzified in the US cellular industry’s presentations:

Network capacity depends on three key factors as illustrated in Figure 1-2 (shown at left):

• Technology – the cell spectrum efficiency that can be realised by a given feature set
  
  
  
• Spectrum – the bandwidth allocated to a network
  
  
  
• Topology – the mixture of cell sizes and local environments in the network

The report concludes,

“ technology improvements alone will not meet forecast demand increases and that a mixture of changes in topology and spectrum will be required to meet this increase in demand. It is recommended that previous studies into the dimensioning of future spectrum requirements for 4G networks are revisited with the revised cell spectrum efficiency results recommended by this study in mind.”

Thus spectrum alone is not enough to solve the problem, changes in “topology” or number of cells is critical to meet capacity goals.

How is the US doing in this area? A topic the mainstream cellular industry doesn’t like to talk about. Here is one observer’s viewpoint.
FastNetNews reports

Robin Bienenstock of Bernstein makes clear why the U.S. has wireless issues: less investment. “Let's take California and Spain as an example. Telefonica has some 33,000 base stations in Spain (yes, miserable, economically imploding Spain). Conveniently, California is a similar size, has a similar topography, and has very similar population density.”

Yes, the cellular industry need more spectrum. But a singular focus on spectrum ignores the need for more infrastructure and improved technology. Indeed, the Commission’s sometimes indifferent view towards new technology and the capital investment needed to develop it is also a detriment to more wireless services to serve society and help the economy. Finally, the singular focus on spectrum is leading to more and more “food fights” over spectrum that FCC (and NTIA) is/are unable to resolve in a timely way.

UPDATE

Apparently, the real CTIA is perfectly capable of trivializing spectrum policy also. here is a tweet that CTIA sent out several times on July 22:

Tags: Spectrum policy

Your blogger’s April column has now been published in IEEE Wireless Communications. With the cooperation of the Editor-in-Chief, Prof. Michael Chang, University of Florida, an unusually fast turn around permitted it to deal with the National Broadband Plan.

On the same topic is a presentation you blogger gave on NBP in Japan on Monday to the Association of Radio Industries and Businesses (ARIB), an organization roughly comparable to TIA.

This year two new tools have appeared to try to illuminate spectrum data what was previously available but hard to use. One is from a private party and the other is from FCC as a byproduct of the National Broadband Report.

The private effort is Unwanted Emissions, a website developed by a federal government spectrum manager who is active in IRAC matters. However, this is a personal effort that was done with the approval of his agency as it only contains public information. (“Unwanted emissions” is an inside IRAC joke for referring to FCC-authorized systems.)

The UE site has allocation table information and includes both ITU and domestic footnotes (US, G, and NG ) for the spectrum from to 9 kHz to 1000 GHz. There is even a useful guide to allocation information.

“There’s an app for that” - a version of UE called “Allocations” exists as an iPhone/iPod touch App for $6.99.

Amusingly it has this one scathing review on the Apple app site from a ham, “If there was a lower rating than 1 star. i would want as low as I could. I been a ham radio op. for 40+ years this is the most useless app I’ve seen.” Well, for most hams it is probably pretty useless, but I suspect readers of this blog will have a different viewpoint.

Both UE and Allocations allow easy access to all footnotes - not so convenient in paper versions.

From FCC NBP team we get Spectrum Dashboard which has both allocation and licensing information - at least for some bands. It also gives your lines to FCC rule parts - unfortunately it gives you the GPO site for the appropriate part of the FCC Rules, e.g. Part 90. Where that band is in the Part 90 rules in up to you to find - it can be tough in many cases. It also only deals with 225-3700 MHz while UE covers the entire allocation table to 1000 GHz. Now for most commercial systems, 225-3700 is of primary interest and this is still the beta version, so let’s not be too harsh.

You can search for a spectrum block and get something that looks like the NTIA spectrum chart for that block that tell you what services are allocated. But the information is presented in allocation jargon such as “This band is used for the Mobile Satellite Service. This is allocated for both Federal and Non-Federal use” with no indication of what the use is called in normal jargon of if the band is actually in practical use. However, you can search more in a window alongside the NTIA-like chart and find what bands in a specific service are in the frequency range of interest and then you get a plain language description of what is happening such as:



The “View Enhanced Information” button then gets you a list of licenses in that band! This was available before in ULS, but this method is much easier. You can even get maps showing the amount of spectrum available in various counties.

A downside of the Dashboard is the focus on present allocations and the lack of any information on transitions in progress and pending actions. For example a search on 2120-2180 MHz gives the following information:
Want to buy a 2130-2150 Fixed license cheap? There is no hint at all about the AWS-3 band (2155-2175/80 MHz). No sign that the days of Fixed in this band are limited. No mention of the pending NPRM in Docket 07-195, let alone the NBP plans for this band.

In Spectrum Policy Task Force days we were trying to develop a web page with information about ongoing proceedings and WRC actions included with current allocations. Unfortunately, the resources were not available at that time. Hopefully the next version of the Dashboard will consider making this information available also.

Both websites are useful tools for the spectrum community and both need user feedback to help them evolve in the directions that users need. Feel free to post to this blog your comments to guide them and congratulations to the developers of both!

Tags: alllocation table, spectrum management

With a little more time to review the National Broadband Plan, we can start commenting on its spectrum provisions.

First, at the risk of saying the obvious, we now have a rather detailed statement of strategy for spectrum - something the FCC has not had for a long time. I have previously written how other countries such as Japan and UK had such strategies and how the public availability of such information improves transparency and stimulates R&D. So whether the plan is perfect, good, or even bad, just knowing about current thinking is a great improvement over the past.

On the eve of the report’s release, the New York Times commented how the previous commission was obsessed with broadcast indecency while the current one is focusing on broadband issues. There is some truth to this. But this also points out a fundamental management problem in the FCC structure: the FCC focuses “from crisis to crisis” and the many parts of the FCC can not function in parallel while the 8th Floor is distracted by one megaproblem. Thus when the crisis of the day was indecency then spectrum policy was given little attention and now when the crisis is broadband - admittedly a broad topic - other issues get scant attention. I think FCC should look at how the UK’s Ofcom is organized and observe how this problem is not as severe in their arrangement where the board at the top acts like a corporate board overseeing top managers, not like a group of micromanagers afraid to delegate authority and who fundamentally limit overall productivity of the agency.

To me, the most exciting part of the plan was the public safety issue:

Create a Nationwide Interoperable Public Safety Wireless Broadband Communications Network.

Broadband technologies will give first responders new tools to save American lives. The nation needs a nationwide public safety broadband wireless network that allows first responders nationwide to communicate with one another at all times and without delay. A three-pronged approach will allow the speedy deployment, operation, and continued evolution of such a network. The three prongs are:

1. An administrative system to ensure that public safety users of broadband spectrum have the capacity and service they require for their network; they also should be able to leverage commercial technologies to take advantage of the vast number of applications and devices that are being developed for commercial wireless broadband networks.
2. An emergency response interoperability center to ensure that first responders nationwide can communicate with one another via public safety wireless broadband communications.
3. A grant program to help fund the construction, operation and evolution of the public safety broadband network to ensure resiliency and ubiquitous coverage.

Previously FCC has tried to solve the public safety Tower of Babel problem by throwing more spectrum at the problem. Repeatedly this has resulted in just more layers to the tower and new bands with interoperability problems. However, manufacturers may have been pleased with the new bands. He who pays the bills can select the technology and if the feds pay the bill they can make the public safety telecom systems as compatible as the Interstate Highway System is.

Another great recommendation is

RECOMMENDATION 5.6:

Congress should consider granting authority to the FCC to impose spectrum fees on license holders and to NTIA to impose spectrum fees on users of government spectrum.

One interesting point is that this addresses Federal Government spectrum at all! In the draft Spectrum Policy Task Force report there was one point that just suggested NTIA might consider one new policy and the NTIA and IRAC staff were so incensed that they got the language deleted from the report. Clearly NTIA and FCC are worked together better now and thinking about the public interest, not just the near term convenience of the IRAC membership. There is even this example from the UK:

The UK has been in a leader in both creating a nationwide interoperable public safety systems and in creating incentives for government spectrum users to trade off efficient technology for less spectrum use.