At the July 27 meeting of NTIA’s Commerce Spectrum Management Advisory Committee (CSMAC) the report of the Interference and Dynamic Spectrum Access Subcommittee was approved “subject to edits”. The final text is not yet available, but the version discussed briefly at the meeting is posted on NTIA’s site.

For reasons discussed below this report is, or at least should be, a major embarrassment to NTIA as it is inconsistent with both the President’s spectrum policies and the charter of the committee. It both evades some major issues and pushes the parochial agendas of some committee members without trying to relate them to the broader public interests.

The White House has said

“(N)ew technologies have the potential to free up spectrum from many of its existing uses. In combination with regulatory changes, new and emerging technologies can facilitate the repackaging, reallocation, and even sharing of spectrum. Reallocating spectrum to its most valuable use promises to be a win-win effort – creating value that not only spurs new innovations and creates new jobs, but also benefits existing spectrum users by allowing them to raise funds for transformative new investments.

This CSMAC report repeatedly takes a negative view towards all innovation and an absolute priority on protecting incumbents. For example on p. 7 it says, “If an incumbent service makes changes to its system’s architecture or modulation technique that results in new interference, then the spectrum to be used to establish any guardband protections should be provided by the service making such changes.” So no matter how outdated an incumbent’s equipment is, no matter how inefficiently an incumbent uses spectrum, no matter how lightly loaded an incumbent’s band is, the burden of protecting the incumbent always falls entirely on the new comer in the mind of CSMAC - which just happens to be dominated by incumbents.

Much of the report echoes the broadcast industry’s view on the database approach to TV whitespace, Docket 04-186. Perhaps not surprising since MSTV’s David Donovan, a lawyer, chaired this group. In private discussions, many CSMAC members observed that much of the long database discussion in the report was aimed at the FCC rulemaking and was irrelevant to the NTIA issues.

One might think that the “Interference Subcommittee” might spend some effort discussing what is “interference”? They dismiss this topic quickly:“Because of the different policy concerns, the Subcommittee makes no judgment as to the appropriate definition of interference that would trigger legal action. Accordingly, we use the term “interference’ in its generic sense.” (p.16)

Hey guys, maybe defining interference in detail is beyond your scope, but how about a few words on whether the current 47 CFR 2.1 definition is workable? What about the FCC view in the Wireless Innovation NOI:

“The viability of spectrum access for new radio services often centers on whether the new service may cause harmful interference to incumbent services. This can lead to delays through protracted rule making proceedings that can create uncertainty and discourage investment. Are there ways the Commission can improve upon this process?” (para. 34)

Does this issue apply to NTIA processes also? Are NTIA harmful interference determinations any faster or more transparent than FCC ones? Will sharing of Government spectrum by technical innovators be that much more attractive than allocations in NG spectrum? CSMAC - the world wonders?

The report was not content at sniping at the TV WSD intruders, it appears Mr. Donovan gave “professional courtesy” to his peers in the cellular establishment since cellular carriers and their allies were also well represented amount the committee members. Thus the report also took a cheap shot at the AWS-3 proceeding saying

•There is widespread consensus on the mechanisms and dangers of creating interference when licensing services that employ different duplexing technologies in adjacent spectrum.

•Industry stakeholders recently demonstrated the risks associated with plans to permit TDD operations in AWS-3 spectrum, without adequate allowances to protect adjacent AWS-1 FDD operations. (emphasis added)

Note the use of the word “stakeholders” here rather than “incumbents”. Don’t the stakeholders in FCC proceedings include also the public who could benefit from new service and the advocates of new service? The use of “stakeholders” in the report draft clearly shows the consistent bias in favor of incumbents. In any case, the demonstration was that referred to is controversial and the issue has not been resolved by FCC almost 2 years later.

Does the Interference Committee have any views at all on whether intersystem interference should be judged always on worst case/“minimum coupling loss” geometry or whether in some circumstances stochastic/probabilistic modeling should be used as it is from time to time in CEPT and ITU studies?

Filters have a big impact on all types of interference other than cochannel interference. Does the committee have any thoughts on whether filters are getting better and how that might impact sharing and guardbands?

Many types of wireless equipment now have a service life of a few years. Should this be taken into account in sharing and guardband determinations as the major cellular carriers have argued that PCS H block entrants can use increased power after existing handsets are replaced with newer models with better intermodulation immunity?

Finally, since this is a report on both interference and DSA, shouldn’t it at least mention the observation of Preston Marshall, formerly of DARPA, that cognitive radios could be designed to select not just idle frequencies but idle frequencies that will not cause interference to receivers with limited interference rejection capabilities that are nearby in frequency and space ?

John Muleta, former Chief of FCC/WTB, and I wrote a statement on this for the CSMAC that received little interest at the meeting in the rush to approve the flawed report. Readers might want to compare it with the report draft and draw their own conclusions. Please tell us what you think.

We will post a link to the final version of the report when it is released.

[MSS has done work for M2Z Networks and Adaptrum, Inc., but this post is not part of that work and is solely the view of MSS.]

In the past 2 weeks, both Chairman Genachowski and NTIA Administrator Strickling - two men I both greatly respect - have sent evasive letters on key spectrum management issues that need to be addressed and resolved. I hope that both letters were the result of rushed staff work and not signs of indifference to key spectrum issues.

On July 2, Asst. Sec. Strickling replied to IEEE-USA’s May 6 letter urging FCC and NTIA to work together to clarify what is “harmful interference” since this phrase is used repeatedly in the Communications Act and the only formal definition is one recycled for the ITU that is murky in many practical situations. (FCC has not yet responded to this letter.) In practice, drawn out harmful interference determinations by both NTIA and FCC have significantly delayed access to spectrum for new technologies.

Asst. Sec. Strickling seems to agree with the basic premise of the IEEE-USA letter, saying

“NTIA currently works to establish spectrum rights and responsibilities for all spectrum users, particularly with respect to interference and interference protection, whenever, possible and practical. When we are able to do so, the time taken by long drawn-out interference disputes is shortened or eliminated without detrimentally affecting reasonable expectations of all interested parties, promoting greater access to, and more efficient use of spectrum.

But the letter then goes on to reference an NTIA report that is almost 5 years old: Interference Protection Criteria: Phase 1 - Compilation from Existing Sources, NTIA 05-432, Oct 2005 . This report is a good background study reporting mostly on ITU-R recommendations relating to well known systems. The ITU-R recommendations are not generally binding on FCC and NTIA in the usual case of a domestic system sharing with another domestic system, although they are important in the case of satellite systems and systems near the US and Canadian borders.

The report was supposed to be part of the 2 phase study. Five years ago, the report stated:

In the second phase of this study, NTIA will review the relevant federal government policies and practices regarding IPC and recommend regulatory and technical refinements that may improve IPC application’s scope, utility, clarity, or effectiveness.

That is really the question at hand. Asst. Sec. Strickling,

• Does NTIA have schedule for doing this?
• Will NTIA involve the public in this issue?
• Will it work jointly with FCC on this issue?

On May 28, Senators Rockefeller and Kerry sent Chmn. Genachowski a joint letter:

We are writing to urge you to immediately begin a comprehensive inventory of the use o f radio spectrum by non-federal government licensees and users under the Federal Communications Commission's jurisdiction.

Radio spectrum is a scarce, but valuable resource. As more and more of our communications take place using wireless technology, it is vitally important for us to understand how spectrum is allocated and used. Indeed, gaining a better understanding of how we use spectrum is the first step toward identifying how we can use this resource most efficiently to carry out critical government missions and to help bring more advanced communications services to consumers across the country.

Chmn. Genachowski replied yesterday, on Bastille Day. He focuses on work completed to date including the Spectrum Dashboard and the National Broadband Plan. He mentions that the Dashboard provides

“the general public with access to information about various spectrum bands, including usage and licensee information, mapping and analysis tools, and the ability to browse and download data.”

Chmn. Genachowski,

• Will the “usage” information include information based on any actual observations or just the reformatting of data presently in FCC databases?
• Since cellular carriers do not now report cell site location and coverage data, how will you present CMRS information?
• Current broadcast contours used for Part 73 licensing and used for protection of broadcast spectrum in some contexts are based upon Part 73 propagation models that assure “administrative certainty” for broadcasters but do not realistically portray their actual coverage, will broadcast spectrum use be presented based on these traditional models or based on contemporary readily available propagation models?