More Efficient Use, More Spectrum Both Needed to Address Spectrum Shortfall

Leibovitz’ comments expanded on a speech last week by FCC Chairman Julius Genachowski, who said the broadband plan will recommend the commission make available 500 MHz of spectrum over the next 10 years, in part through a “mobile futures” auction in which broadcasters could voluntarily give up part of their spectrum, in return for part of the proceeds (CD Feb 25 p1).

“We have to ask ourselves, I think, what happens when every American has an advanced smartphone, or an aircard, or both or some new device that hasn’t been invented yet,” Leibovitz said. “Today, over 25 percent of Americans are cord cutters. What happens when these people on the move take the next logical step and really embrace mobile broadband?” The government itself will drive demand, he added. “Everyone from the commander in chief on down now depends on BlackBerry e-mail,” he noted. “What happens when these people move to next generation apps delivered over mobile broadband? The answer is we're going to need a lot more network capacity.”

Leibovitz said if more spectrum isn’t made available for wireless carriers “networks will cost more to build and operate, quality will suffer, and, ultimately, prices will be higher.” Carriers need to make more-efficient use of the spectrum they have, but “at some point it’s impractical to add capacity without adding spectrum,” he said. “Betting our entire mobile future on a demand reduction strategy doesn’t seem like the right approach from where we sit at the FCC.”

All of the spectrum the FCC will make available won’t be just for licensed use, to be deployed by carriers, Leibovitz said. “The wording of this is very important,” he said. “The recommendation speaks to broadband generally, not to exclusively licensed spectrum, not even to mobile use.” The plan will discuss mobile satellite service (MSS), wireless communications service (WCS) and TV band spectrum, he said. “We won’t limit ourselves to those specific bands,” he said. “The plan will suggest a way forward on the full range of bands within the FCC’s inventory, which includes AWS 2 and 3, for example.”

TV spectrum in major markets where network congestion is the greatest will be particularly critical, Leibovitz said. “Because of the interference protections given to TV licensees, freeing up a single six MHz channel actually frees up 6 to 12 MHz of other spectrum, according to the models we have run,” he said. “We expect that the mobile future auction could turn out to be as important to many different spectrum allocations over the next 20 years as the standard FCC auction has been over the past 20 years.”

Cooper, founder of ArrayComm, a company that develops technology for making wireless networks more efficient, said he’s concerned about what he’s hearing from the FCC. “The spectrum plan mentions very briefly the possibility of new technologies expanding the capacity of systems, but all of the verbiage talks about taking spectrum from one party and giving it to another party,” Cooper said. “That’s really not going to accomplish very much because there is only a limited amount of beachfront spectrum. The reality is that existing technologies have the ability to multiply the capacity of the spectrum by many times.”

The FCC and NTIA should propose incentives to promote new technologies “rather than providing a red herring that in essence says we don’t have to worry about new technologies, you can just have new spectrum,” Cooper said. “That’s the message we are sending to people who have spectrum requirements.” Carriers like AT&T are “going to solve their problems, but they're not going to resolve them by waiting 10 years,” he said.

“We're not talking about taking away spectrum, we're talking about flexibility,” Leibovitz responded. “We have baked into our analysis the assumption that even for sort of the more conventional licensed spectrum mobile technologies there will be greater efficiencies in technology, there will be more new-style deployments.” Addressing huge demand increases “is not feasible with spectrum alone, especially given the timeline, it’s going to rely heavily on technology in the early years and we're banking on that,” he said.

The broadband plan will also recommend that Congress allocate money to research and development, Leibovitz said: “We think it’s important to invest for the long term and also the really long term, making sure that we have a good pipeline of technology as we reach the limits of what we have now.”

The plan will lead to both rulemakings and inquiries, Leibovitz said. “In most cases we will strive to be clear about proposed rules,” he said. “In some other cases we will start with notices of inquiry to flesh out key parameters before going to rulemaking. You should expect these proceedings to unfold over the next 12 to 18 months following the plan.”

Getting more spectrum into the pipeline for carriers to use is critical, said Neville Ray, senior vice president of engineering operations for T-Mobile. “From a commercial wireless operator’s perspective, timeframes are always a concern here and 10 years is a lifetime in this industry, which changes almost every quarter, let alone every year,” Ray said. “I just would remind us all of what’s happening in other parts of the world. One specific large European nation is just going to auction inside the next couple of months with well over 350 MHz of spectrum, across multiple bands. Other nations around the world are really seizing this opportunity and moving forward with it very aggressively and in much faster timeframes than we are talking about.”

CSMAC also heard a presentation by Karl Nebbia, NTIA associate administrator, Office of Spectrum Management, on the work of the federal government’s Interdepartment Radio Advisory Committee (IRAC). Nebbia was asked if the government’s system for managing its own system is broken. “We need and we're in the midst of taking some major steps forward on our data capabilities,” Nebbia replied. “We're working on a major upgrade to our system.” But he said IRAC is working well. “I am amazed at what the federal government does in the spectrum that it has,” he said. “For example, when we began to move out of the 1710-1755 MHz band we had nationwide mobile operations in there. We had airborne telemetry systems. We had fixed microwave lengths, some of them transportable for the military,” but the government made the change without a serious hitch. “All these things are just kind of operating together, the agencies are talking together, communicating when there are issues and resolving them,” he said.

NTIA is looking forward to reports CSMAC is completing on a federal spectrum inventory, transparency, adjacent band interference, dynamic spectrum access and incentives for spectrum sharing, said Anna Gomez, deputy administrator. “It’s a truism that good spectrum policy is as important as ever,” Gomez said. “Being weeks away from the release of the National Broadband Plan, it is more and more apparent that good spectrum policy is the foundation of good broadband policy.” Gomez said spectrum scarcity will be an issue. “If there is one thing we know about spectrum it’s that there is increasing scarcity in beachfront properties,” she said. “If we're going to get better at expanding the availability and affordability of broadband we need to get better at sharing - - between federal users, between commercial users and between federal and commercial users.”