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A Tribute to Mrs. Viviane Reding

Outgoing European Commissioner for Information Society and Media (2004-2009)

"Strong competition and a functioning single market work in the best interests of European citizens and consumers."(11/23/09)

On January 1, Viviane Reding, European Commissioner for Information Society and Media will step down as part of a reshuffle of the EC cabinet in conjunction with the implementation of the new Treaty of Lisbon which makes major changes in the structure of the European Union.  It is expected that she will be appointed to a new position as Commissioner for Justice, Fundamental Rights and Citizenship.  (She previously had been European Commissioner for Education and Culture in 1999 - 2004.)

In the period from 2004-2009, she was, in effect, the "telecom policy czarina" of Europe.  As many readers know, telecom policy in Europe functions at both the national level with the longstanding multinational CEPT as the primary forum of national regulators and at the EC level with RSPG as a multinational forum in the spectrum area.  An additional complication is that CEPT has 48 members, including Russia, and the EC has 27 members.  But the EC is concerned about all social and economic issues in Europe while the CEPT is more focused - tunnel vision? - on the telecom sector.

Mrs. Reding (I have never seen her referred to as "Ms. Reding") was a client of mine while I lived in Paris.  I was appointed her "special advisor" in 2006 at the recommendation of Martin Cave(The details of the arrangement we made public the next year when a member of the European Parliament was concerned about cronyism in the selection of consultants by commissioners and demanded public disclosure of all details.  Unfortunately they did not publish the miserly per diem I was paid to stay in Brussels to talk with her and her staff.  However, I did get a first class Thalys train ticket between Paris and Brussels for the trip that gave me free coffee for the 90 minute ride.)
 "This is why (EC) President Barroso and I have proposed a 'Digital Agenda for Europe' to make sure that Europe focuses on:

    * the industries and applications that have the potential to lift Europe's performance and
    * the prominent place and role of consumers in this new environment"
What really impressed me about dealing with her and her staff was the focus on helping the whole European economy and society develop, not focusing on the telecom industry in isolation and certainly not focusing on the major telecom operators and manufacturers as most national telecom regulators do.  Sometimes her strong pro-EU policies irritated the US, such as her backing for Galileo as a alternative to GPS and using EU funding for a European Google search engine alternative.  But such "nationalism" was quite popular in Europe and I could see some logic for it.  Her office also funded a lot of telecom R&D with joint projects with universities and private firms and at time I wondered about the WPA aspects of this.  But her continued focus on both the European economy and European society made her a much more insightful telecom policy maker than FCC and its national counterparts in almost every country.  Telecom policy need not be focused primarily on carriers, broadcasters, and manufacturers.  Telecom is a key infrastructure for economies and societies.

"ICT also contributes macro-economically to productivity growth and
 increased competitiveness of the European economy as a whole,
 and thus is a factor in growth and job creation." --
COM(2006) 334

I hope FCC and other regulators learn from her legacy.

European Telecoms and Media Commissioner Viviane Reding delivering the 2009 Ludwig Erhard lecture at the Lisbon Council in Brussels.

The rest of the story ...

Will Free Wi-Fi Become the Norm?

Larry Magid of CBS News and the San Jose Mercury News had an interesting post on CBS News this week about the future role of Wi-Fi.  Of course, if would be a nice holiday present to all if it widely became free in public places.  It was stimulated in part by McDonald's announcement of free Wi-Fi starting in January.

I also note that AT&T Mobility CEO Ralph de la Vega has said that it will try to ease the load on its network overburdened by the success of iPhone, and perhaps somewhat underbuilt/underprovisioned, and to offload the carrier's cellular traffic to Wi-Fi hotspots and femtocells.

So as we approach the 25th anniversary next year of the Docket 81-413 rulemaking that brought forth Wi-Fi (and Bluetooth) over the opposition of most mainstream players at the time, who knows how big its long term role may be?


 Wired: Ford is making its cars into mobile Wi-Fi hot spots.

The rest of the story ...

Multiplex DTV European Style

A Primer on an Alternative Path for DTV

Readers may recall that your blogger started his consulting business in Paris after retiring from FCC.  Thus events and policies in Europe are of more interest to him than to many on this side of the pond.

The FCC 12/2/09 public notice on "Data Sought on Uses of Spectrum" raised the following issue, 
"There may be opportunities for broadcasters to share 6 MHz channels in a market without significantly disrupting the free over-the-air television service that consumers enjoy today."

While this might seem like a strange concept, the chart at the top of this page shows it is reality in Europe.  The purpose of this post is to summarize and give links to additional data on the European situation in order to stimulate discussion in the US spectrum community.

DTV developed first in the US while the original concept of analog HDTV developed in Japan.  As in many cases, the early adopter had fewer options than the later adopters and the US ATSC group selected 19 Mb/s 8-VSB as the over-the air transmission standard.  The Europeans later chose the DVB-T standard.  DVB-T is an OFDM standard somewhat related to both WiMAX and LTE. 
(8-VSB uses a high speed 6 MHz signal with 11 million broadband signals/s so each group of bits is sent sequentially.  OFDM divides the TV channel into many parallel smaller channels and then send the binary data in parallel over the parallel channels.  In a perfect world they would be similar in performance, but the real world has propagation problems that have to be corrected at the receiver and they have different approaches to correcting such problems.  An added complication is that European TV channels are 8 MHz wide.)

A senior staffer at the FCC's UK counterpart, Ofcom, has provided the following factual summary of the UK use of multiplexes to carry several video and audio streams on one DTV signal. "DTT"  is used  in UK-speak for "digital terrestrial TV" ).  Ofcom has no position on this US domestic issue:
The DTT platform in the UK comprises six multiplexes. The BBC and Arqiva Ltd. each operate two multiplexes, and the remaining multiplexes are operated by Digital 3&4 (carrying services from ITV, Channel 4 and Teletext Ltd.) and SDN Ltd. (a wholly-owned subsidiary of ITV plc.) respectively.

Information on the programme services carried on each multiplex is available at
www.dmol.co.uk: DMOL manages common technical aspects of the DTT platform, and is made up of representatives of the four multiplex operators. The composition of the multiplexes is slightly different in those areas of the UK which have been through digital switchover (DSO), and listings for the pre-DSO and post-DSO configurations are provided on DMOL’s site.  Each DVB-T multiplex carries between four and nine individual standard definition video streams.

In September this year, the BBC’s second multiplex, multiplex  B, was cleared of its standard definition services in those areas which had been through DSO, and will be converted to operate as a DVB-T2 multiplex as DSO progresses across the UK. The DVB-T2 multiplex will also be broadcast on temporary frequencies as a ‘seventh’ multiplex from five of the UK’s major TV transmitters (these transmitters do not switch over until later in the regional DSO sequence, but serve significant  populations). We expect that multiplex B will have capacity for up to four HD services (three services at launch).

The BBC has announced a schedule for launching the DVB-T2 multiplex, including ‘retrofit’ launches at transmitters which have already been through switchover, and the ‘early launch’ sites using  temporary frequencies. The schedule is available at

More information on the multiplex reorganisation and capacity allocation process for HD services on DTT is available on our website at
A senior source at Arqiva recommends Chapter 4 and 8 of Ofcoms's "The Future of Digital Terrestrial Television - Enabling new services for viewers" 2007 consultation (NOI) as a good summary of present and future plans for DTV in the UK.

Note that the UK has started an evolution from DVB-T to DVB-T2 as the modulation of DTV/DTT multiplexes.  DVB-T2 can deliver 40.2 Mb/s in an 8 MHz channel to fixed receivers.  (Delivery to mobile receivers is less efficient since extra coding/error control is needed.)  DVB-T operates 18 or 24 Mb/s at present in the UK, although they all will become 24 Mb/s when the DTV switchover is finished.  DVB-T2, though now operate in the UK at 40.2 Mb/s.  Original DVB-T receivers can not receive information from DVB-T2 transmissions.  (Most of the cost of higher end DTV receivers is not in the receiver electronics, but in the display.  So an external receiver with an interface such as HDMI could add upgraded performance to existing TV sets.)

A parallel issue to channel modulation is digital coding.  ATSC started with MPEG-2 picture coding, but now supports H.264/MPEG-4 AVC.  Europe is actively pursuing MPEG-4 to increase the capacity of existing multiplexes.

The Ofcom Future of DTT report, cited above, says (p. 5-6)
An improved video and audio coding compression standard called MPEG-4. This is expected (over time) to operate at up to double the efficiency of the coding standard that is used at the moment on DTT, MPEG-2. This means that a DTT multiplex could carry up to twice as many services using MPEG-4 as can currently be achieved using MPEG-2, whilst maintaining similar picture quality.

A new transmission standard, known as DVB-T2. This is expected to deliver an increase of at least 30% in the capacity of a DTT multiplex over the current standard, whilst maintaining the same coverage. This standard is a development of the existing DVB-T standard used in the UK since 1998. DVB-T2 is still undergoing development by DVB5 in Geneva, but is expected to be finalised in spring 2008.

It is important to note that MPEG-4 and DVB-T2 differ in one important respect. MPEG-4 can be introduced within a multiplex (so it can offer a mix of services coded in MPEG-2 and MPEG-4). But the introduction of DVB-T2 requires a whole multiplex to be converted from DVB-T. This is, of course, a larger step-change.

The introduction of these two technologies could, if combined, increase the capacity of a multiplex by up to 160%. This is a very large increase. It is the equivalent of raising the number of Standard Definition (SD) services that can be carried on a DTT multiplex from around eight currently to around 13-15 at DSO, and over 20 in the longer term. HD is generally regarded as unfeasible on DTT in the UK without use of MPEG-4: but with the use of these two technologies combined, a single DTT multiplex could in time offer at least four HD services. (Emphasis added)
While Europe is using MPEG-4 with DVB-T and DVB-T2 transmissions, it is also usable with the ATSC 8-VSB technology to get more video waveforms/TV channel.

The rest of the story ...

NYT's David Pogue Takes on VZW

I always find David's writing on new technology both informative and humorous.

But he has taken an interesting position in the telecom policy area by locking horns with Verizon Wireless.

As he says in today's NY Times,
A few weeks ago, I wrote about two particularly nasty Verizon Wireless practices. First, Verizon doubled the early-cancellation fee for smartphones, the price you pay for canceling before your two-year contract is up (it’s now $350).

Second, I passed along a note from a Verizon whistleblower who identified a really outrageous Verizon profit center: if you accidentally hit one of the arrow keys on your Verizon cellphone (which come premapped to various Verizon Internet functions), you’re charged $2 instantaneously, even if you cancel instantly. (Verizon confirms that on many models, you can’t remap those buttons to other functions even if you’re tech-savvy enough to try.)
VZW has finally responded, after requesting a delay, and he calls their response "outrageous".  So read for yourself and see what you think of the VZW response to this matter.

Pogue ends with this line,

"In short, the headline for this entire episode might as well be:
'Verizon to FCC and Customers: Go Soak Your Heads.' "
An odd PR move from a cellular company that is pressing FCC to reallocate 800 MHz! 
A Pogue Video with links to others:

A reader pointed out the original link above was actually to an unrelated VZ FCC filing.  I pointed this out to David and he quickly corrected the link, which has been changed above.

Comm. Clyburn's 12/23/09 Statement on VZW Letter
An excerpt:
 "I am concerned about what appears to be a shifting and tenuous rationale for ETFs. No longer is the claim that ETFs are tied solely to the true cost of the wireless device; rather, they are now also used to foot the bill for ‘advertising costs, commissions for sales personnel, and store costs.’ Consumers already pay high monthly fees for voice and data designed to cover the costs of doing business. So when they are assessed excessive penalties, especially when they are near the end of their contract term, it is hard for me to believe that the public interest is being well served.
I am also alarmed by the fact that many consumers have been charged phantom fees for inadvertently pressing a key on their phones thereby launching Verizon Wireless’s mobile Internet service. The company asserted in its response to the Bureau that it ‘does not charge users when the browser is launched,’ but recent press reports and consumer complaints strongly suggest otherwise."
  Business Week/Bloomberg coverage
  Huffington Post coverage
  ars technica coverage

The rest of the story ...

FCC Hiring Associate Managing Director New Media None Too Soon

The above job posting, DEU-OMD-2010-0008, can be found on the FCC website.  The job description reads 
"As the Associate Managing Director New Media, the incumbent is charged with managing the Agency's new media efforts including responsibility for the Commission's web design, information and data architecture, data transparency and search operations. Advises the Managing Director and Chairman and Commissioners, on matters pertaining to new media issues.  The work involves identifying, planning, designing and recommending actions that will contribute to changing the existing systems and technologies into integrated enterprise systems that support the Commission's strategic goals and policies.  Oversees and leads the revitalizing and re-tooling of web and search services to increase participation and communications through the Agency's web site and other network services. Manages a team of data and web application developers in the execution of this effort.  Initiates and/or is apprised of all FCC's data transparency and web system architecture projects and assignments and advises the Managing Director on matters of major concern.  Coordinates routing matters and projects among the New Media and Technology staff where such coordination is required and in the day-to-day relationships acts for with the full confidence of the Managing Director.  Formulates, develops and implements policies, standards, criteria and guidelines for the implementation of online media initiatives; and defends the Agency's position on key/critical policy initiatives and issues.  Formulates, develops, recommends and implements long-range strategic plans for the evolution of the Agency's overall web design, information transparency, and open data initiatives.  Plans, manages and conducts comprehensive risk analysis and assessments of critical systems operations, to identify and quantify threats to the integrity and security of sensitive new media technology resources. Conducts continuous evaluations of the Commission's business needs by ensuring that the Agency can use the internet and other new media tools to broaden and strengthen the Agency's reach and presence.  Represents the Agency in conferences, planning and briefing sessions, etc., relative to plans and policies affecting new media technology." (Emphasis added)

Of course, it is almost impossible to read on the website itself because the text keep rolling on and on without a return (viewed in both Firefox and Google Chrome).  Thus new leadership for the website part of the FCC is desperately needed.  Note also who several fonts are used on this page without any particular logic.  Note the special instructions for "ICTAP eligible candidates" without any indication what that refers to.

Finally, since you have gotten this far on the web site, note that there are no vacancies listed for any entry level employees, engineers or otherwise.  This no doubt means that FCC has yet to start any college campus recruiting.  This is not the first time I have written about recruiting at FCC.  

FCC's ambivalence about recruiting top new graduates probably comes from budget watchers who don't want to do any recruiting until they know exactly what the new appropriation is.  Budget wonks: FCC has been around since 1934, its predecessors even earlier.  It will be here next year and for the next 10 years. How many entry level engineers will it need?  I don't know.  But it will certainly need at least 5 this year and possibly 10-20.  The personnel mess at FCC and many other federal agencies with an unbalanced age distribution, did not happen by accident.  It results from odd staffing decisions during the Reagan years when year after year hiring was deferred.  We are now seeing the inevitable consequences of not hiring then.

I was in the Air Force at the end of the Viet Nam War.  I was puzzled why the military was "hiring" lieutenants and privates while it was RIFing all sorts of other people.  A wise colonel explained that the only way to keep the long term personnel pool balanced is to continually have entry level hiring at some level.  FCC needs to learn that also.


House Hearing on the Radio Spectrum Inventory Act and Spectrum Relocation Improvement Act

On Tuesday,  December 15, 2009 the House Subcommittee on Communications, Technology, and the Internet held a legislative hearing on H.R. 3125, the Radio Spectrum Inventory Act, and H.R. 3019, the Spectrum Relocation Improvement Act of 2009.
 The witnesses were:
  •  Michael Calabrese, Vice President and Director, Wireless Future Program, New America Foundation
  •  Dale Hatfield, Adjunct Professor, Interdisciplinary Telecommunications Program, University of Colorado at Boulder
  •  Ray O. Johnson, Ph.D., Senior Vice President and Chief Technology Officer, Lockheed Martin Corporation
  •   The Honorable Steve Largent, President and CEO, CTIA - The Wireless Association
  •  The Honorable Gordon H. Smith, President and CEO, National Association of Broadcasters
  •  Thomas Stroup, Chief Executive Officer, Shared Spectrum Company
Their prepared statements , along with with Chairman Waxman's initial statement, are on the website of the parent House Committee on Energy and Commerce.

New America's Michael Calabrese, a client of your blogger from time to time, was kind enough to cite several times "New Approaches to Private Sector Sharing of Federal Government Spectrum", a report he commissioned that showed that spectrum sharing of federal spectrum would be much more effective for all parties involved if future federal systems were designed with sharing in mind and preemption for emergencies.

My former boss, Dale Hatfield, pointed out that "there are combinations of newer management techniques and technological advances that can go a long way toward alleviating the shortage in spectrum capacity."

Lockheed Martin's Ray Johnson apparently was the front man for the Pentagon at this hearing.  He was also a big cheerleader for the "military industrial complex:
"According to the Aerospace Industries Association, the aerospace and defense sector was the largest net positive contributor to the US balance of trade, logging a $57 Billion surplus in 2008, with U.S. military aircraft representing a $54.7 Billon export market; and, in 2007, U.S. defense exports alone constituted a $25 billion market."
He also raised concerns about
"potential inadvertent message to our allies in the international community, given the scope of the frequencies being inventoried and the provision requiring recommendations for reallocation. The Department of Defense and the defense industry have worked hard to promote, achieve, and maintain international spectrum harmonization to support allied interoperability of equipment, technologies, and capabilities."
For example, perhaps we should keep 225-400 MHz, 175 MHz of beachfront spectrum underutilized in the USA in urban areas where spectrum is in short supply, at low utilization in the future so that we can show our allies how important this spectrum is?  Wouldn't a responsible sharing system with civil users that allows the military immediate preemption send a better message?  When does the Federal Government get the money from to pay the Pentagon and its contractors like Lockheed Martin?

Isn't it from skimming off 4-6 % of GDP?  Since the lesson of the past 8 years is that politicians and the voters want both "guns and butter", the 4-6% number is not going to change so the only way to increase military spending is to grow the GDP - which is what happens with more effective civil communications.  It not only enriches CTIA members and equipment manufacturers, it makes other businesses more efficient and enables whole new businesses that are users of new services. (Think Amazon and Netflix.)

NAB President Gordon Smith's presence was continuing proof that the broadcasters have great political influence and can demand a seat at the table whenever they want - even if they have nothing germane to say.  Smith praised his community "innovation and efficiency drive broadcast operations". His key point was "We believe that broadcast operations and the expansion of broadband availability and adoption are by no means mutually exclusive." That is, leave our spectrum alone is finding spectrum for the CTIA crowd and kill the FCC PN on "Use of Spectrum".

On this topic of inventory, there is a lively discussion going on now in the Linkedin's Spectrum Experts group (I am a member but I did not select this name).  Here is a recent contribution from Saul Friedner of UK's  Mott MacDonald consulting group, reprinted with his kind permission:

"Sorry to intrude in what is a totally national matter for the US but I thought it might be helpful to make you aware, if you're not already, of the work that has been going on in the UK. The Ministry of Defence has been engaged in a Spectrum Reform Programme which has included an Audit of public sector spectrum holdings. This reform programme has identified surplus spectrum which could potentially be released to market that will cover what is called AIP (Administered Incentive Pricing) or charges levied by the Treasury on unused public spectrum.

Much of this work was initiated by the Treasury and supported by other Government Departments a lot of the work and output can be found at

Ofcom the UK regulator also plays a vital part in this Programme to facilitate the technical and regulatory aspects and much of the work can be found on their web site

I appreciate the framework for spectrum management in the US is different to the UK and Europe but de-regulation of spectrum is on the agenda of many Governments. A push to shake up public sector use of spectrum is a growing concern as demand continues to grow for services. The balance breaks down only when the two sides cannot agree a common ground.

I would like to comment further that any Audit or Inventory to be done should be conducted in stages and prioritised this way two outcomes could emerge:
1) Spectrum becomes available in the most efficient way
2) The spectrum identified as 'potentially difficult' to allocate or assign i.e. adjacent to military/public safety bands become the first barrier to overcome, therefore becoming easier as the inventory develops."


FCC Alums in Germany Write About Novel Spectrum Policy Alternatives

Two of my former FCC colleagues, Ken Carter and Scott Marcus (not a relative) have worked in WIK [Wissenschaftliches Institut für Kommunikationsdienste /Scientific Institute for Communication Services], "Germany’s leading research and advisory institute for communication service", for several years.  They have collaborated with two others on the new report pictured at left entitled "Next Generation Spectrum Regulation for Europe: Price-Guided Radio Policy".

Here is a summary of the paper:
This project examines how market signals in the form of pricing information can be introduced into spectrum management in order to optimally guide not only assignment, but also determinations concerning type of use, emissions characteristics and exclusivity. We construct a mathematical model to illuminate how one possible implementation of such price-guided policy might function to make these determinations. For the past nearly two decades, spectrum management authorities have used market mechanisms such as auctions to determine spectrum assignment in an effort to ensure that the right to utilize the spectrum is held by those who value it most. As compared to conventional spectrum auctions, price-guided mechanisms for determining allocation and policy would arrive at an assignment of spectrum rights to the highest value users as well as ensure that the contours of those rights were the most efficient possible.
In the mathematical model presented in this paper, participants in a hypothetical auction are free to express their demand for spectrum licences which are different on several dimensions such as permissible power output and bandwidth. These demands are dic- tated by what is necessary to satisfy a specified a pre-specified level data rate using wireless communications ability. We use the Shannon-Hartley Theorem to model the possible tradeoffs between permissible signal strength and allotted channel bandwidths. As a proof of concept of the mathematical model, we created a simplified MS Excel- based version of the model. The model’s output was also a mix of high and low power users, at various channel bandwidths and winning bids. We also review the implications of German Law and EU for such price-guided policy. Price-guided spectrum policy is viable in Europe. However, price-guided policies cannot be used to determine allocations and assignments in internationally harmonised bands. The most actionable initial implementations include determinations of maximum power limits, bandwidth, duration of rights and channelisation. Other early potential implementations include boundary interference standards and possibly congestion-based protocols.
Price-guided policy holds substantial promise because it encourages allocative effi- ciency of spectrum due to the fact that bidders can acquire exactly the set of spectrum rights they need. Further, price-guided policy mitigates the allocation errors inherent in administrative determinations.
While I disagree with the degree they think "tragedy of the commons" is inevitable with respect to spectrum use, I think this is a promising approach to stimulate technical innovation in radio technology through deregulation.  It is odd that it comes from Germany which has a reputation as being the most rigid country with respect to "command and control" spectrum management.

So don't count on these ideas being implemented in Europe too soon, although the UK regulator, Ofcom, is both open minded and the the geographic convenience to be able to try new ideas without having land borders except with Ireland.


Other Publications Chime in  on Recent Topics Other Publications Chime in  on Recent Topics Other Publications Chime in on Recent Topics

This week, two other, larger publications have discussed recent topics you read about in SpectrumTalk .  (Oddly, Broadcasting & Cable remains silent on the 12/2/09 FCC Public Notice on use of broadcast spectrum.)

The Wall Street Journal had an oped yesterday entitled "The Rabbit-Ear Wars" by Holman W. Jenkins, Jr.  It begins,
"You stupidly built a drive-in theater in the desert just as your customers were all deciding to stay home and watch HBO. Fortunately, the theater turns out to be sitting on a mountain of oil.

With a few asterisks, such is the situation of old-style TV broadcasters, whose viewers have fled to cable or satellite but whose spectrum is lusted after by the wireless industry. According to a much-noted study sponsored by the Consumer Electronics Association, in the hands of the broadcasters, that spectrum is worth a mere $12 billion. In the hands of mobile phone carriers struggling to meet explosive growth for mobile broadband, it would be worth $62 billion."
Jenkins describes the basic situation, but goes on to say,
"But the FCC is in no position to know whether mobile broadband is that higher and better use. A reason is the regulatory straitjacket, including ownership limits, that for decades has prevented license holders themselves from exploring new broadcast business models."
At the expense of sounding like a schill for for FCC's Evan Kwerel, let me remind reads that Evan wrote about this with John Williams in 2002's OPP Working Paper 38.  They proposed

"to facilitate the rapid transition from administrative allocation of spectrum to market allocation, this paper proposes that the FCC (1) reallocate restricted spectrum to flexible use; (2) conduct large-scale, two-sided auctions of spectrum voluntarily offered by incumbents together with any unassigned spectrum held by the FCC, and (3) provide incumbents with incentives to participate in such “band restructuring” auctions by immediately granting participants flexibility and allowing them to keep the proceeds from the sale of their spectrum."
In other words a real deregulatory approach in which NAB and MSTV members could decide for themselves what the highest use of their spectrum is and how to maximum the value of their spectrum resource.

Next, the somewhat more obscure CED magazine, "The Premier Magazine of Broadband Technology", published an article by FCC alum Jeff Krauss entitled "Jamming Cell Phone Signals".  Jeff does a balanced job explaining the pros and cons of the prison cell phone jamming issue and the pending legislation and petition at FCC. He ends with this observation,
"So here we are again. The FCC hates to make a decision when there are opponents with strong views and strong arguments. And whenever an entity with strong lobbying ties to the FCC exerts pressure, the FCC takes the path of least resistance: delay."

UPDATE 12/11/09

Having got its marching orders from NAB, Broadcasting & Cable is now talking about the spectrum proposal:
NAB: Use Airwaves To Fight Potential Spectrum Grab 
"According to a copy obtained by B&C of the e-mail from Smith and the chairs of the Spectrum Commitee and TV board, NAB has produced a 30-second TV spot to "help position the spectrum issue in a pro-broadcaster, pro-consumer light" as a response to TV spots by wireless and telco groups "attempting to position a national broadband plan as having no potential drawbacks." "


Who Reads SpectrumTalk?

It has been about a year since we started tracking the location of our readers using the free services of ClustrMaps .  About is a map of where viewers have been coming from.

US readers are concentrated on the East Coast, but there are several 1000+ points west of the Mississippi.

At left is the tabular data for the top 30  countries.  I guess my friends in Japan must be regular readers because of the 81 hits from there.  The relative high rank of the Cayman Islands is surprising.  Either a lot of people are taking breaks from beach vacations or the offshore bankers there are looking for this material.

In any, thank you faithful readers and best wishes for the Holiday Season!

Cayman Islands Mystery Solved!
(It's the local "FCC")


Unintended Consequences: NY Times on History of Cellular Driving Safety Issue

Yesterday's NY Times has an article on "who knew what when" on the issue of cellular/texting use while driving.  It starts with this anecdote:
"Martin Cooper, who developed the first portable cellphone, recalled testifying before a Michigan state commission about the risks of talking on a phone while driving.

Common sense, said Mr. Cooper, a Motorola engineer, dictated that drivers keep their eyes on the road and hands on the wheel.

Commission members asked Mr. Cooper what could be done about risks posed by these early mobile phones.

'There should be a lock on the dial,” he said he had testified, “so that you couldn’t dial while driving.'
It was the early 1960s"
The article also quotes Bob Lucky, one of Bell Labs' superstars and founding chairman of the FCC's Technological Advisory Council (TAC):
Other early innovators of cellphones said they felt nagging concerns. Bob Lucky, an executive director at Bell Labs from 1982-92, said he knew that drivers talking on cellphones were not focused fully on the road. But he did not think much about it or discuss it and supposed others did not, either, given the industry’s booming fortunes.

“If you’re an engineer, you don’t want to outlaw the great technology you’ve been working on,” said Mr. Lucky, now 73. “If you’re a marketing person, you don’t want to outlaw the thing you’ve been trying to sell. If you’re a C.E.O., you don’t want to outlaw the thing that’s been making a lot of money.
What seems to be lost here is that early cell phones were bulky systems that were only used in cars and lunchbox sized units.  Thus the inevitable marketing focus was on car use.  Only with new semiconductor technology, a spinoff of DoD research, did handheld and pocket cell phones become a reality.
The NY Times seems to have problems with the cell phone industry.  On December 12, they followed up on the above article with an editorial entitled "Turn Car On; Turn Phone Off":

Like drivers chattering on their mobile phones, the cellphone industry was for years too distracted — by rising profits — to see the dangers ahead. As Matt Richtel wrote in The Times last week, the mobile phone industry promoted the glamour and convenience of “car phones” for years while failing to heed warnings that driving and phoning can be a deadly mix.
One ad from 1984 shows a bigwig driver on the phone and tellingly asks, “Can your secretary take dictation at 55 m.p.h.?”
A great measure of responsibility for safety lies with drivers. But now, as study after study shows the hazards of talking on the phone, or especially texting, while driving, it is time to ask why the wireless phone industry fought controls for so long on a product that could be used so dangerously.
It brings to mind that row of tobacco company executives who swore to a Congressional subcommittee 15 years ago that their products were not addictive. Or the car companies that went on making hefty S.U.V.’s that had a record of rolling over.
The reasons the cellphone industry representatives have given to block bans on phone use while driving sound straight out of the “Thank You for Smoking” playbook. One refrain was that the evidence was not settled, an assertion that continued as the industry itself was beginning to warn drivers about driving while phoning.
In California, the mobile industry fought off bans on talking while driving for years, at one point arguing that they were looking out for consumers. Consumers want to use their cellphones, that is true, but most who drive would also prefer to make it to their destinations. And distracted drivers put everyone else on the road at risk.
Even though the police are too seldom required to determine whether cellphone use was involved in an accident, the data about texting or phoning while driving is alarming. Harvard researchers estimated that drivers on cellphones cause about 2,600 fatal crashes a year and 570,000 accidents. Hands-free devices do not eliminate that risk. Other studies show that someone legally drunk could outperform a person texting behind the wheel.

Congress has slowly begun to focus on this issue and proposals for bans are now circulating in both houses, some with support of the cellphone industry. None of them are terribly high on Washington’s agenda, however. It is time for Congress and the wireless phone industry to take highway safety a step beyond seat belts and air bags.


Commissioner Meredith Attwell Baker Speaks on  Spectrum Policy Commissioner Meredith Attwell Baker Speaks on  Spectrum Policy Commissioner Meredith Attwell Baker Speaks on Spectrum Policy

On December 3, Comm. Baker gave a speech entitled "A Spectrum Management Framework" to  The Phoenix Center for Advanced Legal &  Economic Public Policy Studies 2009 Annual U.S. Telecoms Symposium.  As far as I am aware, this was the first speech this year by a commissioner to basic spectrum policy issues.  Comm. Baker is particularly well qualified in this area as a past head of NTIA.

Her key points were :
"1.    An up-to-date, strategic spectrum management framework that includes achievable and clear short and longer term goals. A transparent plan will provide a predictable flow of spectrum resources to broadband providers to allow for planning by both existing providers and new entrants, as well as more flexible use of existing allocations.
2.    Economic and regulatory policies to facilitate investment in mobile broadband networks—including deploying 4G networks and enhancing 3G infrastructures. These policies need to support the continued success of the competitive wireless market, but not to the exclusion of entrepreneurs and new entrants. We also need to align the incentives to deploy wireless services to unserved and underserved areas.
3.    A policy plan to actively promote innovation, including cutting edge research and development in areas that will help increase the efficiency of spectrum use. Mobile broadband would not exist today without basic research conducted years ago and relentless applied research and development. We cannot expect to benefit from the types of advances that took us from brick phones to smartphones without a comprehensive commitment to world-class research and development in the area of mobile technologies—here in the United States. This could include enhanced collaboration with
technical advisors and other spectrum experts and the adoption of policies that foster further innovation."
Let me focus on the 3rd point, "A policy plan to actively promote innovation, including cutting edge research and development in areas that will help increase the efficiency of spectrum use." The free enterprise system has done amazingly well in this country in bringing us the benefits of the information society.  Wireless innovation lags innovation in other areas because of government regulation of spectrum which is needed in some degree because of the limited nature of the spectrum resource and the potential for interference.  (My Mac doesn't interfere with your PC so there is no need for government to get involved in computer technology regulation.  Nor is there a finite amount of semiconductors available for computers.)

The key policy challenge for FCC
and NTIA is how to craft spectrum policy to encourage private capital formation for R&D.  (Since many new innovations raise questions of interference to federal users and NTIA has effective veto power over FCC actions in such areas, NTIA is also a key player here.) Such policy should deal fairly with both existing manufacturers and operators and entrepreneurial ones. (Remember not that long ago both Microsoft and Qualcomm were startups!)  The current spectrum policy deliberations are so drawn out and complex that capital formation is certainly inhibited.  Whether you agree with M2Z's business  model or not, should it really take 3+ years to resolve whether TDD can be used in AWS-3?

She fully supports the
spectrum inventory concept
"One critical tool government and industry needs is a spectrum inventory to better understand how spectrum is being used today across all bands. Such an inventory should be dynamic and focused on data that will inform and facilitate additional spectrum use. The output should be a user-friendly resource for all interested parties and should be able to be incorporated into more sophisticated spectrum management tools. Such an inventory will be critical to government efforts to manage spectrum more effectively as well as spectrum users trying to find fallow spectrum that can be transformed into greater connectivity and new services."
I support it also.  But I recognize that without some progress on clarifying "harmful interference" and speeding adjudications of "harmful interference" the spectrum inventory will be a waste of time and resources.  Why?  Going back to the AWS-3 case, everyone agrees that 2155-2175 is empty of other primary users.  But there is huge disagreement on what use of this band is acceptable without causing "harmful interference" to the lower adjacent incumbents.  This is a pattern repeated many times for innovative technologies.  We need a system that deals with these issues in a timely and transparent way.  The Docket 09-157 NOI asked some key questions in this area (para. 34-37).  It states
Spectrum allocations and access often hinge on controlling interference between new services and incumbent services, as do licensing and service rules to some extent. The resolution of disputes about potential or actual interference in rulemakings can pose a major impediment to the introduction of new services, devices and technologies, either as a result of long delays in the establishment of service rules or the imposition of onerous and perhaps unachievable technical standards.
These "long delays" and "onerous/unachievable standards" are also key factors in inhibiting innovation.  Unfortunately, few of the commenting parties so far have offered helpful improvements.  In general, the "haves" are happy with the status quo and they don't realize that it will prevent the inventory from having much impact.


After the Spectrum Inventory

The legislation for a spectrum inventory is gaining momentum and hearings will be held shortly.  This week I sent a paper to the NTIA Commerce Spectrum Management Advisory Committee on what is likely to happen after the spectrum inventory is completed.  My prediction: gridlock.

Let us take the example of the technical issues in the AWS-3/M2Z controversy.  Everyone agrees that the band has no primary occupants in it anywhere in the US.  The key technical controversy that has dragged on for 3+ years is how the band can be used without impacting the incumbents in the lower adjacent band - mainly T-Mobile.  This, in turn revolves on what constitutes "harmful interference" and to a lesser degree on what receiver immunity is reasonable before an adjacent channel users  can complain of interference.  So if this is the mess we get with a completely vacant band, imagine the mess we will get with bands that have use in some areas but not others and have intermittent users.

I propose that we decrease this controversy by having NTIA and FCC work in parallel with the inventory to improve the definition of harmful interference, develop improved transparent procedures for making harmful interference determinations in a timely way, and clarify receiver expectations.

Otherwise the inventory will likely be, in the words of the Bard of Avon:

... a tale
Told by an idiot, full of sound and fury,
Signifying nothing.