Friday, December 21, 2007

Kevin Martin's Top 10 Predictions for the 700 MHz Auction

Courtesy of Susan Crawford:

FCC Chairman Kevin Martin’s Top Ten Predictions for the 700 MHz Auction:

# 10. AT&T will say the outcome proves network neutrality is not necessary.

# 9. Google will say the outcome proves network neutrality is necessary.

# 8. NAB will say the outcome proves the XM-Sirius deal should be rejected.

# 7. I will say the outcome proves the country needs à la carte.

# 6. Congress will spend the auction receipts 10 times over before we cash the checks.

# 5. No matter how fast the D Block licensee builds out the public safety network, Commissioner Copps will say it was too slow.

# 4. Even if AT&T and Verizon bid against each other, costing each other billions, Consumers Union will claim they conspired to rig the bidding.

# 3. No matter who wins the A, B, C, D, and E license blocks, they will all end up suing Vonage for patent infringement.

# 2. If anything goes wrong, I will blame the subprime mortgage crisis.

# 1. If anything goes wrong, everyone else will blame me.

Merry Christmas and Happy New Year to all!


Wednesday, December 12, 2007

UPDATE: FCC Boss Under Scrutiny for Management Tactics

FCC Chairman Martin has dutifully responded to House Commerce Committee Chairman Dingell's recent inquiry regarding the management tactics employed by the chief of the nations wireless communications regulatory agency.

For those interested, here is Chairman Martin's 56 page initial reply.

Happy reading.



Monday, December 10, 2007

SDR, CR, DSA, & the 700 MHz Public Safety Band

The folks at the SDR Forum have released a new 23 page report addressing "Considerations and Recommendations for Software Defined Radio Technologies for the 700 MHz Public/Private Partnership" (Technology for 700 MHz Spectrum - Report # SDRF-07-R-0024-V1.0.0) just in time for review prior to the upcoming FCC auction.

Here's a summary:

The report describes how software defined radio (SDR) technologies can help achieve the public/private partnership goals of the upcoming U.S. FCC 700 MHz frequency band spectrum auction. This report also covers cognitive radio (CR) and dynamic spectrum access (DSA) technologies as well.

The context for the report is the Second Report and Order (FCC 07-132, released 10 August 2007) which establishes rules governing wireless licenses in the 700 MHz band. The SDR Forum
is uniquely positioned to consider the role of these new technologies in the 700 MHz band since its membership includes commercial mobile radio service providers, public safety representatives, technology developers, systems integrators and equipment manufacturers.

The information and recommendations in the report focusus on technology and related policy
considerations to (a) prospective bidders and service providers, (b) potential grantees of the Public Safety Broadband License, (c) equipment manufacturers, and (d) regulators.

Emerging SDR & CR technologies, along with DSA (
or DSM - Dynamic Spectrum Management) are believed to be the future of wireless communications.

The report is well worth the time to read for those interested or concerned with spectrum matters.



Saturday, December 8, 2007

FCC Boss Under Scrutiny for Management Tactics

"Martin's Management at FCC Under Scrutiny" is the "shocking" headline of a news report by Jeffrey Silva recently. It seems that the House Commerce Committee has launched an investigation into Federal Communications Commission Chairman Kevin Martin's management of the agency.

"Procedural breakdowns at the agency tasked with overseeing communications laws for our entire nation jeopardize the public interest it is bound to serve," said House Commerce Committee Chairman John Dingell (D-Mich.). "Our nation is founded on fair, open and transparent government, and the Federal Communications Commission is certainly no exception. When that openness and transparency is compromised, so too is public confidence in the agency."

In a letter to Martin, Dingell asked the FCC chief to commit in writing by Dec. 10 to publish proposed rules in advance of FCC meetings, and to provide sufficient time to review proposed orders and rules. In addition, Dingell wants Martin to agree to provide other commissioners with all data and information on which those proposed orders and rules are based.

The two Democrats on the GOP-led FCC, Michael Copps and Jonathan Adelstein, have been particularly critical of Martin's oversight of the agency; however, complaints about Martin's stewardship have not been confined to the two telecom regulators.

"I have received several complaints from the public and professionals within the communications industry about how Chairman Martin is conducting business at the FCC," said Rep. Bart Stupak (D-Mich.), chairman of the Commerce subcommittee on oversight and investigations. "It is one thing to be an aggressive leader, but many of the allegations indicate possible abuse of power and an attempt to intentionally keep fellow commissioners in the dark. I look forward to investigating these concerns to be sure that the FCC chairman is not disenfranchising his fellow commissioners and the American public he is supposed to serve." was previously reported here, perhaps the GAO auditors should join forces with Dingell's committee and dig a bit deeper; so far, they've only scratched the surface of what many believe may be a much larger management problem within this agency.


Friday, November 23, 2007

Google Pushing the Technological Envelope ?

Recently, Eric Schmidt, Google's CEO had some rather interesting - if not somewhat perplexing - comments about how he thinks technology has and will help the Internet search engine companys' pending venture (read ADventure) into the world of wireless. Here is an excerpt of the portion of the conversation between Schmidt and Spencer Michels of NPR's Online NewsHour that caught my attention:

MICHELS: I talked to an industry analyst a week or so ago, Andrew Seybold, and this is what he said and I'm kind of curious as to how you would answer it. "Google's view of the wireless world is an extension of the Internet. And as much as I respect Google, the wireless industry can't be an extension of the Internet because wireless bandwidth is finite. It's a fixed resource and a shared bandwidth. The more people who use it in a given area the less data speed they have, so you can't take the Internet model and just move it to the wireless world. You have to change that model a little bit as you move forward." Is that fair criticism?

ERIC SCHMIDT: That's exactly the same criticism that was said about the wired Internet 15 years ago. That somehow the wired Internet would not scale, would not grow, that we would not learn how to build applications that could work for example in shared what are called hybrid fiber coax networks which you have at your home. The fact of the matter is that the industry can solve these problems and solves them very well. I completely disagree of the characterization that somehow the wireless network is going to be any different than the wired network. People want to use the Internet and they want to use it at home and in their office and when they're on the go and when they're on the airplanes. And they want to use the same powerful applications whether it's a personal device that they're carrying or on their desktop or at the beach.

SPENCER MICHELS: People want to use all the water they want to use, but there isn't enough water, so some people don't have enough water to water their lawns. That doesn't mean it's there.

ERIC SCHMIDT: Technology is different and the technology can create things out of nothing. The fact of the matter is that there's enormous spectrum becoming available through licensing programs, better radio design, faster computers, and so forth that in the next five or 10 years most of us will be carrying around devices that could speak on networks that are faster than the networks we currently use.

SPENCER MICHELS: Do you agree with the boss?

ANDY RUBIN: Absolutely. This is Moore's Law for wireless, or Moore's Law for spectrum. You know when we're on the wired Internet, in my day we had dial-up modems. Then we got DSL, then we got broadband, we're in the megabit speeds. Same thing happened to wireless. Remember those old analog phones where you'd get a dropped call every mile you traveled? Now we have digital phones, we have newer modulations that are helping us pack, densely pack, more calls in a single channel. And I'm just very optimistic that we'll have newer modulations throughout time that'll just get us faster and faster in the broadband areas.

SPENCER MICHELS: So Seybold saying that the bandwidth is finite, is it relevant?

ANDY RUBIN: Technology doesn't stand still.

With all due respect to Mr. Schmidt et all, may I remind him that there are many major differences between a wired and a wireless network? Technology is indeed advancing, and, has certainly changed a great many elements in our lives and the world. However, the laws of physics, particularly those concerning RF and wireless, remain firmly in place. Last I knew, no one had figured out how to completely circumvent them yet, but I know some are working very hard at it. :>)

May I further suggest that it may be far wiser for Google and company - prior to purchasing ANY wireless spectrum - to invest a few of their many dollars and enroll Mr. Schmidt and Mr. Rubin in a Basic Radio (that's the original name for the resource that everyone now calls wireless) 101 course? (IMHO, Radio 101 should be a prerequisite for any IT professional who wants to become involved with wireless IT) Upon successful completion of the course, perhaps each of them will have a clearer understanding of the many differences between a wired (IT) and wireless (RF) network that RF professionals have been attempting to share with them (and that their own IT professionals may NOT have)

( you suppose my suggestion will help bring the IT and RF guys/gals a little closer to listening, understanding, and actually working with each other through some much needed and shared mutual collaboration? I suppose we can always hope!)



Saturday, October 13, 2007

Managing "Open Access", "White Spaces", & Unlicensed Spectrum

There's more than a few issues and challenges open for consideration and debate when it comes to allowing more and more "open access" and license-free use of the radio spectrum as the authors of this 2005 white paper attempt to point out....

"Managing Shared Access to a Spectrum Commons"
(Presented at the IEEE DySpan2005 - Baltimore - November 2005 By William Lehr and Jon Crowcroft)


The open access, unlicensed or spectrum commons approach to managing shared access to RF spectrum offers many attractive benefits, especially when implemented in conjunction with and as a complement to a regime of market-based, flexible use, tradable licensed spectrum.

However, as a number of critics have pointed out, implementing the unlicensed model poses difficult challenges that have not been well-addressed yet by commons advocates.

A successful spectrum commons will not be unregulated, but it also need not be command & control by another name. This paper seeks to address some of the implementation challenges associated with managing a spectrum commons. We focus on the minimal set of features that we believe a suitable management protocol, etiquette, or framework for a spectrum commons will need to incorporate.

This includes: (1) No transmit only devices; (2) Power restrictions; (3) Common channel signaling; (4) Mechanism for handling congestion and allocating resources among users/uses in times of congestion; (5) Mechanism to support enforcement (e.g., established procedures to verify protocol is in conformance); (6) Mechanism to support reversibility of policy; and (7) Protection for privacy and security.

We explain why each is necessary, examine their implications for current policy, and suggest ways in which they might be implemented.
We present a framework that suggests a set of design principles for the protocols that will govern a successful commons management regime. Our design rules lead us to conclude that the appropriate Protocols for a Commons will need to be more liquid than in the past: (1) Market-based instead of C&C; (2) Decentralized/distributed; and, (3) Adaptive and flexible (Anonymous, distributed, decentralized, and locally responsive).

Offered as suggested background reading and insight in light of the big push for these by the TV "white spaces" proponents, the Cognitive Radio/SDR folks, and the Google's, Intel's, and Microsoft's of the new wireless world.


Thursday, October 11, 2007

Radio, Wireless, & the Internet -- A Transformative Technology

Fellow blogger Susan Crawford has another excellent post to her blog which I would strongly encourage folks to read for a bit of historical yet very timely deja vu....

Here's an excerpt to get you headed over there:

Transformative Technology

"Another technology was said to overcome key barriers between the voter and the candidate: the barriers of distance, of time, of inertia, and of crowd psychology. It brought to the physically remote voter a type of first-hand information he had never had before.

There was great excitement. Would this new technology prick into quicker, more coherent action our unwieldy democratic giant? Or with its shining novelty would its seeming power too be gone? What were the inherent political potentialities of this new technology? Aside from the immense publicity value which its newness gave it, what could it actually effect in a presidential election?

The new technology was remarkable. It had found a way to dispense with political middlemen. In a fashion it had restored the demos upon which republican government is founded. No candidate would be able to stand up to it who was unprepared to enlighten the electorate. It potentially gave to every member of the electorate the possibility of a direct reaction to the candidates themselves. It reproduced to some degree, for the first time in the United States, the conditions of the Athenian democracy where every voter, for himself, could hear and judge the candidates.

The year was 1924: “…America finds herself this year in the act of virtually choosing her chief executive by an instrument that was up to a brief two years ago generally considered a freakish fad.”

You'll have to visit her site for the balance of her post, but, she's absolutely correct - radio or RF (now commonly labeled "wireless") and Internet technology has and will continue to transform virtually every aspect of our lives and the world in which we live.

Yet another of the many reasons why spectrum matters.....


Monday, October 8, 2007

GAO Report: FCC Violates Rulemaking Info Flow

A new report from the GAO (Government Accounting Office) titled “FCC Should Take Steps to Ensure Equal Access to Rulemaking Information,” says:

"As a regulatory agency,
FCC is routinely lobbied by stakeholders with a vested interest in the issues FCC regulates. It is critical that FCC maintain an environment in which all stakeholders have an equal opportunity to participate in the rulemaking process AND that the process is perceived as fair and transparent.

Situations where some, but not all
, stakeholders know what FCC is considering for an upcoming vote undermine the fairness and transparency of the process and constitute a violation of FCC's rules.

Since the success of lobbying for a particular issue can be highly dependent on whether an issue is being actively considered, FCC staff who disclose nonpublic information about when an issue will be considered could be providing an advantage to some stakeholders, allowing them to time their lobbying efforts to maximize their impact. As a result, FCC may not hear from all sides of the issue during an important part of the rulemaking process. This imbalance of information is not the intended result of the Communications Act, and it runs contrary to the principles of transparency and equal opportunity for participation established by law and to FCC's own rules that govern rulemaking."

The GAO report really isn't much of a surprise, at least to those of us who have been involved in the communications industry for any length of time; it's been quite evident for many years that the lobbying process itself has been more-than-a-little slanted in favor of large corporate entities (wireless and wireline telecommunication incumbents, media, and the broadcast folks come to mind here)......this report seems to "officially" validate that evidence albeit the facts are based on just a very small sample of the FCC's many proceedings.

Perhaps the GAO auditors should return and dig a bit deeper; so far, they've only managed to scratch the surface of what many believe may be a larger problem within this agency. Oh, by the way, the FCC declined to comment or refute the GAO's report.


Friday, October 5, 2007

NTIA Phase 2 BPL Report Finally Released - 3 Years Late the Feds have finally released the long-awaited Phase 2 BPL Report titled "Potential Interference From Broadband Over Power Line (BPL) Systems To Federal Government Radiocommunication Systems at 1.7 - 80 MHz". (That's the military HF, Amateur, and shortwave radio broadcast spectrum for those who might not know.)

How timely. It's only been
3 years since the NTIA's original Phase 1 report which warned of the potential for harmful interference to LICENSED users that very well could (and have) resulted from the deployment of UN-licensed, Part 15 BPL technology in that portion of the spectrum. The Phase 2 BPL report was supposed to have been issued several months later, but was never made public. One excuse offered for the delay was that there were only 2 report writers within the NTIA to author the Phase 2 report; however, in the opinion of many in the know, the completion and release of the report was deliberately withheld for strategic political reasons.

It's interesting to note that during this
3 year gap, the FCC managed to rush/push/shove their BPL Rules through the regulatory system despite the well-presented and documented concerns and objections of many users of this spectrum. (See the Comments and Reply Comments in the FCC's ET Docket 04-37 for more background and insight on this proceeding.)

It's also telling that a
recent report from NATO (9 MB file) seems to contradict some of the findings of the Phase 2 BPL report. I wonder how often certain elements of this report have been "revised" or glossed over in the last 3 years in an attempt to soften the impact of this "spectrum polluting" technology and promote the well-intended but mis-guided notion of BPL providing the so-called "3rd pipe" for wireless broadband access in rural areas?

Finally, isn't it odd that the release of the Phase 2 report comes on the same day the the FCC's own Inspector General released a report that claims the FCC did not withhold similar reports that were not entirely favorable to its policy positions? (Why do I have my doubts?)

Me thinks there is something not quite right here, but, as a good friend often says, I could be wrong....


Thursday, October 4, 2007

Say So Long to your Analog Cell Phone and Television

A reminder for those who haven't been paying attention, may have forgotten, or, are an analog wireless die-hard in the new digital world......(believe it or not, there are still many folks out there who fall into one or more of these categories!)

The FCC has issued a public notice that as of midnight on February 18, 2008, cellular telephone companies will not be required to provide analog wireless service. While most wireless telephone users will not be affected by this transition (often called the "analog cellular sunset"), some users may be affected.

In addition, the transition could affect some wireless alarm systems and some users of OnStar's in-vehicle communications service.

For more information about your options after Feb 18, 2008, you might want to read the FCC's factsheet at:

Don't confuse the analog cellular sunset with the up-coming DTV (digital television) transition.

In addition to the analog-to-digital transition for wireless
telephone service, Congress has separately set a deadline of February 17, 2009, for completion of the transition from analog-to-digital television broadcasting. (Yep - your analog TV set has (or will) also become obsolete relatively soon)

To learn more about how the digital television transition will affect you, visit


Monday, September 17, 2007

NATO Issues Warning on BPL and the HF Radio Spectrum

NATO's (North Atlantic Treaty Organization) research and technology arm recently issued a report warning of the potential impact that can be expected by the widespread deployment of BPL (Broadband over Power Lines - also referred to as PLC or PLT) in the HF portions of the RF spectrum.

What's important to understand here (and what most people don't realize) is that BPL technology, in case you were unaware, has never-the-less been approved for deployment in the U.S. by the Federal Communications Commission and the NTIA, to the dismay of many shortwave radio listeners, amateur radio operators, public safety communication system managers, high seas marine radio users, and military LMR and airborne radio system operators. (Take some time to review these comments from the FCC proceedings on this matter for further background and insight)

The entire report (9MB) titled "HF Interference, Procedures and Tools" includes this Executive Summary:

This Report presents the results of the work carried out by IST-050/RTG-022, the Research Task Group (RTG) on “HF Interference, Procedures and Tools”, to address the concerns raised by the potential for unintentional radio interference to be caused by the widespread operation of broadband wire-line telecommunications systems.

PowerLine TeleCommunications (PLT, PLC) and various forms of Digital Subscriber Line (xDSL) transmissions use the existing mains electricity or telephone wiring including in-premises cables for telecommunications with data rates higher than 1 MBit/s. As these lines were not designed for such broadband transmissions, they will cause unintentional RF emissions which may adversely affect the established radio noise floor directly, or by cumulative propagation from many such sources. The existing HF background noise possibly may be increased via ground wave and/or sky wave propagation.

Increase of the existing HF noise floor by widespread use of PLT and/or xDSL will bring up problems for Military Radio Users as well as for HF Communication Intelligence (COMINT) in all NATO countries. The signal-to-noise ratio thus may be reduced for tactical and strategic HF radio as well as for fixed sensitive COMINT sites.

Exact calculations of HF radio noise emissions from the new broadband wire-line telecommunications networks were impossible because of missing models for these transmission systems. Therefore methods have been investigated to find procedures, models and tools applicable for being able to determine the influence of PLT and xDSL on reception of HF radio signals. These are described in this report.

The RTG addressed itself to the HF radio emission effects of the new broadband cable transmissions. It investigated and found means that allow calculation of cumulative field strengths of HF noise radiated by PLT or xDSL. This will enable NATO and its nations to determine the threat to military HF radio communications and COMINT systems from PLT and xDSL and to take the appropriate steps. It should be noted here that the determination of the nature and the severity of any possible detrimental effect upon the military systems was outside the RTG’s expertise and ToR.

The RTG chose to concentrate its work on the PLT issue rather than xDSL because PLT will produce the most problems regarding HF interference (power lines have less symmetry and will have impedance discontinuities), they will be deployed in large numbers, and finally the current versions of xDSL have no documented HF interference-causing problems, while the VDSL variants covering the entire HF range are still in the definition phase.

In the course of the studies, the RTG determined that ITU-R P.372-8 noise curves (based on measurements carried out in the 1970s) are still valid in Europe. Recent measurements carried out in Germany and Great Britain indicated that there is no remarkable difference between these measurements, specifically no increase of the ambient noise in quiet rural zones within the last 30 years.

Based on these measurement results, the cumulative interference field strengths far away from telecommunication networks should not be higher than 15 dBìV/m (9 kHz bandwidth) across the entire HF range, if no measurable increase in minimum noise levels are to be tolerated. The RTG refers to this criterion as the Absolute Protection Requirement. It should be noted that this value is in the range of 10 to 1 dB below the ITU-R P.372-8 Quiet Rural noise curve, which are median values, across the HF band.

A couple of important tasks in the RTG’s work, namely, the appropriate measurement techniques and the most suitable propagation path loss models for interference studies, were addressed and completed.

The quantity of interest when considering cumulative effects in the far-field is the EIRP (equivalent (or effective) isotropic radiated power) per unit bandwidth caused by each signal source, in units of dBm/Hz, at different frequencies. The radiation pattern might also be of interest in some cases, but when summing up many different sources with different wiring geometries over a wide area, it is reasonable to approximate the average radiation pattern as isotropic (in elevation as well as in azimuth).

In modeling the emissions from an overhead Access PLT line, the PLT wires can be modeled as a successive set of dipoles, assuming that the standing waves present are the dominant emission source. Given the PLT geometry, the cylindrical coordinate system is more practical rather than the spherical coordinate system generally used in electromagnetics. In the vicinity of a PLT, up to 200 metres, the use of the expression for the exact solution of a dipole is recommended, which is valid at any distance in both near-field and far-field.

The RTG has developed a “Cumulative PLT Tool”, which was used to perform cumulative PLT noise calculations at several hypothetical sensitive receiver locations. For each receiver location and frequency, the percentage of parameter combinations was computed where the estimated cumulative PLT noise level is above the quiet rural level, above quiet rural +6 dB, and above the rural noise level. The results indicated the following:

a) High probability that PLT would cause increased noise levels at sensitive receiver sites given the projected market penetration; and

b) The percentages are highly influenced by assumptions on transmitter EIRP, PLT market penetration, and duty cycle.

The percentage of parameter combinations was also computed where the estimated PLT noise level is above the Absolute Protection Requirement. Again, the probability of the cumulative effect of PLT exceeding the Absolute Protection Requirement is predicted to be relatively large for all frequencies and receiver locations investigated.

Currently, there are no commonly accepted regulatory emission limits for PLT. While it is highly desirable that the regulatory limits on PLT emissions be harmonized throughout the NATO countries, the RTG recognizes that NATO, by itself, has no regulatory authority over the emission limits. Therefore, it is recommended that NATO seek the implementation of this goal by working together with the national and international regulatory authorities."

The complete NATO report sheds additional detailed information on this matter and should be of interest to those concerned with "spectrum pollution" matters.

Please pass along the link to this report to others who may not be aware of the potential disruptive and destructive impact of BPL technology on the RF spectrum.


Saturday, September 15, 2007

Dynamic Spectrum Management (DSM) - Regulatory & Allocation Method of the Future?

Radio (RF) spectrum is key to the future success of (wireless) radiocommunications. It is a valuable commodity and a unique, shared resource. Unlike other natural resources, it can be repeatedly reused - if certain technical conditions are met and user regulations are followed.

In practice though, it is a finite resource, accommodates a limited number of simultaneous users, and requires careful planning and management to maximize its value for all services and users
— especially since worldwide demand for communication spectrum is increasing rapidly.

Many new wireless technologies present significant challenges to the development of prudent business models as well as to long-established regulatory schemes for spectrum allocation and management.

Rigid spectrum allocation policies limit innovation and cannot readily accommodate pressing needs for more commercial bandwidth.
Operators look to evolve technologies that support their business cases. Licensing or policy making that would not allow this natural evolution or mandate a particular technology in a particular band is too rigid for many operators. New generation infrastructure and terminals must support ever wider ranges of frequencies, harmonized or not, to meet highly heterogeneous frequency plans in markets around the world. Terminals will need to operate worldwide and comply with numerous regulatory environments and market opportunities, thus supporting frequency allocation and heterogeneous technologies. New technologies such as software-defined radio (SDR) or cognitive radio (CR), wideband power amplifiers and filters are already available in the infrastructure and will soon be available in terminals, supporting frequency heterogeneity with minimal additional cost.

Within this context, traditional ways to assess the merits of new technical solutions, and
allocate and tax frequency use are inadequate. Consequently, this presents major challenges in the introduction of new technologies and efficient spectrum use, such as ensuring new spectrum is only assigned when really needed.

This 2006 Alcatel-Lucent white paper describes a new concept known as DSM (Dynamic Spectrum Management) which would enable wireless operators to dynamically access appropriate spectrum to deliver new wireless services, while providing greater choices for spectrum users. It provides an overview of DSM from the engineering, technology, economic and radio policy aspects and considers critical parameters that impact its implementation.

The paper should be required reading for anyone involved with or concerned about current methods of spectrum regulation and allocation in the U.S., and, perhaps even more importantly, with how any spectrum management methods chosen will ultimately serve to protect this resource from eventual political and economic oversell.


Monday, September 10, 2007

RF (Wireless) Spectrum Information & Resource Links

Those concerned or interested in learning more about spectrum regulation and frequency allocation policies and their impact on radio and wireless communication devices and users in the U.S. may want to begin paying very close attention to the Notices, actions and decisions made by the FCC's Wireless Telecommunications Bureau (WTB), their new Public Safety and Homeland Security Bureau (PSHS), and, their Office of Engineering and Technology (OET). More background information on spectrum policy, including the latest on the 700 MHz proceeding, can be found on the FCC's Spectrum Policy Task Force site. And, there's always the FCC's Daily Digest which provides a brief synopsis of Commission orders, news releases, speeches, public notices and all other FCC documents (with links to the full text of each) that are released each business day.

Finally, this 2006 paper Regulating Spectrum Management: Overview and Trends is intended to provide readers with a broad overview of wireless communications spectrum management concepts and issues, including a review of differences between traditional spectrum management methods and policy and recent innovations and practices due to technology advances. The approach taken is more descriptive than prescriptive, allowing readers to make up their own mind on various perspectives. It's interesting to note that the authors have found that there are no standard solutions that fit every situation.

Additional reading:

Spectrum Management Overview

Spectrum Policy and Planning

An introduction to spectrum management including best practices and considerations involved in the use and regulation of radio frequency spectrum. An outline of policy and planning considerations including technical standards and the allocation of spectrum.


An overview of the processes by which users gain access to the spectrum resource.

Spectrum Pricing

A review of the role of spectrum pricing and economics as it relates to the method of spectrum authorization being employed.

Spectrum Monitoring and Compliance

An overview of how spectrum monitoring and compliance can help users by avoiding incompatible frequency usage through identification of sources of harmful interference.

International Affairs

An overview of international harmonization of spectrum utilization.

Developing Spectrum Management Capacity

An overview of the strategies for organization, function, process development, staffing, staff retention and training for spectrum regulators.

Oh yes.....I almost forgot; here's how you can "express yourself" should some of the Commission's activities or policies stir you to speak up about spectrum matters.


Friday, September 7, 2007

Cognitive Radio Technology for VHF/UHF Public Safety & Business/Industrial LMR

While doing some research for a client recently, I came upon a very interesting paper written earlier this year by Nancy Jesuale and Bernard Eydt titled "A Policy Proposal to Enable Cognitive Radio for Public Safety and Industry in the Land Mobile Radio Bands".

The authors offer some interesting perspectives on the age-old problems associated with LMR system interoperability (a "hot topic" today, particularly when considering the current state of Public Safety radio system interoperability in much of the U.S.), a historical account of FCC and NTIA spectrum regulation and policy, the lack of innovation in frequency allocations, and more.

They also make the suggestion that an emerging new technology known as
Cognitive Radio (a term first coined in 1991 by Joseph Mitola) could improve spectrum efficiency and spectrum availability for all users in the VHF and UHF LMR bands. Here is the abstract:

"The frequency bands that have been licensed to the land mobile radio (LMR) services for decades are a tremendously fertile field for the deployment of cognitive radio technology. This paper outlines several reasons why policy-based cognitive radios would be particularly useful for modern public safety, federal non-military and business/industrial applications, especially in
the VHF and UHF bands, where 80% of the public safety, federal and business/industrial licenses are currently held.

This paper argues that many interoperability deficiencies are directly related to the original approach to spectrum policy and radio frequency regulation developed in the early 1920's, which segmented uses of LMR spectrum into several use classes.
It provides a historic perspective to explain why the current status of LMR infrastructure, operations and licensee behavior is a direct result of antiquated policies and technologies still applied and deployed in these bands. The paper discusses the reasons that cognitive radio could be a successful solution for the apparent congestion in the bands. It suggests that policy-based cognitive radio systems operated on a cooperative, shared basis could lower costs of use and aid coordination for emergency responders across both public and private sectors of the traditional LMR user community.

We discuss policy reforms and innovations such as spectrum pooling
and spectrum portability that could spur new shared infrastructure development and spectrum efficiencies. We suggest several key policy reforms for consideration, including immediate cessation of ongoing narrowbanding initiatives, decoupling of spectrum licenses from spectrum access, and national spectrum management by frequency coordinators."

The paper (12 pages) is well worth the time to review for those interested or concerned with spectrum matters.


Wednesday, September 5, 2007

OMG! - FCC labeled Washington's Worst Communicator

There were a few provocative(?) insightful (?) revealing (?) stories in the media today regarding the FCC's public communications skills....

This AP story by John Dunbar "
FCC's Methods Leaves Public in the Dark" suggests "It's odd for an agency that has the word "communications" as its middle name" to "routinely leave the public in the dark about how it makes critical policy decisions".

Cynthia Brumfield at The IP and Democracy site follows up with a claim that "the FCC is the worst communicator in Washington". "Clear answers are rare and, indeed, FCC rules dictate that agenda items (those issues to be voted upon by the Commissioners) are “non-public” information. Employees can get fired if they disclose anything the FCC is planning". She also provides links to a couple of additional pieces written by Ted Hearn at MultiChannel News who labeled the agency the “Federal Incommunicado Commission”.

She adds even more fuel to the fire by ranking the Commissions
web site as a "nightmare"--- a real nightmare.

Frankly, I don't understand what all the hullabaloo is about. The FCC long ago abdicated its responsibility to openly communicate with the general public (along with certain other spectrum management related duties) and is now the
best corporate and special interest facilitating entity that money and lobbying can buy. I guess some folks just can't get used to the way business is done at the Portals these days, but I can assure you that there's good reason for it. Just continue on as usual (spectrum matters are out of your league, anyway, right?) and everything will turn out just fine....


Friday, August 31, 2007

FCC Says No to M2Z

The FCC today finally responded to M2Z Networks' application for authorization to build and provide a free national wireless broadband network (as previously reported here) using 2.1 GHz spectrum - their answer was no.

In my view at least, that is a correct decision. Now, before anyone jumps to any conclusions about why I believe it correct, take the time to
read the Commissions Order yourself which may provide some insight and background that you were not aware of....then we can debate the matter!


Tuesday, August 28, 2007

Report to 110th Congress - Spectrum Management and the 700 MHz Auction

The Open CRS Network has released a report to members of the 110th Congress describing the FCC's spectrum auction process and key policy issues to be considered in the up-coming 700 MHz auction. It's an interesting read, particularly for anyone concerned with wireless spectrum matters.

According to the report, "The FCC has concluded that auctioning of spectrum licenses has contributed to the rapid deployment of new wireless technologies, increased competition in the marketplace, and encouraged participation by small businesses. However, many have questioned whether auction policy should be supplemented more aggressively with other market-driven solutions, and whether the existing auction process and administration can be improved."

The report also says that "Spectrum management is an exercise in reconciling divergent interests. Over time, developments in technology may significantly increase the amount of usable spectrum and consequently the ease with which a policy of equitable allocation and use can be crafted. For the immediate future, Congress may choose to debate and act on questions such as
reforming spectrum management and allocation mechanisms. Some observers argue that a fully-developed policy should take into account issues such as international competitiveness, the communications needs of public safety agencies and the military, the role of wireless technology in economic growth, and the encouragement of new technologies that make spectrum use more efficient and more beneficial to society as a whole. The stated objective of many policy reformers is a coherent national policy (FYI - such a policy DOES NOT CURRENTLY EXIST - NR) that provides the proper balance for existing applications while at the same time providing opportunities for future growth and development."

The report ends by stating "Given the number of objectives in the allocation and use of spectrum, and the differing solutions for achieving them, choices made for 700 MHz could be far-reaching in setting the direction for future policy decisions."

I hope that yours and my representatives in Congress take the time to read this relatively brief yet fact-filled (21 page) report. Hmmmm.....perhaps a few readers of this blog will be kind enough to forward a copy of the report to them along with your thoughts and suggestions on spectrum matters??


Wednesday, August 22, 2007

700 MHz, TV "White Space" Spectrum, the FCC and the Future of Wireless Communications

She's done it again! Susan P. Crawford, that is. In her latest working paper, The Radio and The Internet, she presents a broad overview and historical background (with many footnotes to more in-depth details for those with inquiring minds) of how the natural resource known as the RF spectrum has been allocated and managed (or, as many believe, mis-managed) by the FCC over the last several decades.

But, she also has done an excellent job (the best I've seen, at least) of putting into a pretty balanced context most of the unbalanced rhetoric, hype, and political posturing from all sides of the hotly debated 700 MHz auction rules proceeding that we've all just experienced.

She also reminds the regulators of the pressing need for them to be much more decisive than they have been regarding the definition of the "public interest" aspect of 21st century spectrum and technology matters during the on-going TV "White Spaces" debate which, by the way, will most certainly be the subject of the next big spectrum battle. Stay tuned - it's likely to be just as contentious if not more so than the 700 MHz debate was since it involves unlicensed use of the spectrum.

Here's the abstract of the paper, but the actual paper is a much better read and really deserves a few minutes of your time:


The airwaves offer the potential for contributing to enormous
economic growth if they are used more efficiently for facilitating
high-speed internet access, but recent industry and government
actions have failed to follow this path.

This article evaluates the multi-billion-dollar 700 MHz auction
regime established by the Federal Communications Commission
in August 2007 as a case study in our national approach to this
valuable resource, and argues that the public interest would
be served by having ubiquitous access to the internet be
the top
priority of communications policy.

The article criticizes the nearly exclusive focus of the FCC on the
interests of incumbents and law enforcement, and suggests that
spectrum policy be focused on enabling unlicensed uses of the
airwaves that can assist the nation with online access.

Download a copy and decide for yourself.


Tuesday, August 21, 2007

Imports, Toys, Food, and the FCC.....

If toy and food imports from China (and certain other countries) have managed to get through various government inspection systems designed to protect the often unenlightened public from nasty surprises, do you suppose it is at all possible that non-compliant electromagnetic-emitting electronic devices having the potential to pollute the RF spectrum might have evaded these systems as well?

For some insight to this question, you should read this commentary authored by fellow blogger Michael Marcus, a retired FCC engineer who (as per his blog) "focused on developing policies for cutting edge radio technologies such as spread spectrum, CDMA, and millimeter waves. The rules for Wi-Fi, Bluetooth, and most of the cordless phones sold in the U.S. are one outcome of his early leadership. He also had several key roles in the FCC’s Spectrum Policy Task Force."

Having been in the wireless communications industry for over 30 years, I've seen and experienced some of what he describes and, must agree with him regarding the business practices that some electronic equipment producers employ simply to maximize their profits. Unfortunately, many of them consider the few paltry fines imposed as "just a cost of doing business" and write the expense off.

Protection of the wireless/RF spectrum seems to have been relegated to the regulatory rear burner in many respects in favor of the many real or perceived economic benefits purportedly to be derived from this natural resource. Only after-the-fact, when problems surface, is any type of remedial action taken and, often, in the opinion of many, such action is both ineffective and mis-applied.

Much more proactive attention needs to be focused on protecting us from imports and U.S. produced products of ALL types - including those that emit unwanted electromagnetic radiation that can disrupt radio and wireless communications. We can ill-afford having to contend with any "spectrum disaster" created by the lack of ongoing and aggressive enforcement of spectrum policy and rules.


Wednesday, August 15, 2007

M2Z Networks to Sue FCC

Startup M2Z Networks is upset that the FCC has yet to take action on a 2006 spectrum application and proposal filed by the company so...... it's going to file a lawsuit against the regulatory agency.

M2Z Networks' proposal is (or maybe was) to offer free ad-supported wireless broadband to 95 percent of the U.S. within 10 years, using 20 MHz of spectrum in the 2 GHz band (2155-2175 MHz). The speed of the free tier — 384 kbps down and 128 kbps up - barely qualifies the service as broadband, but might be acceptable to the average sit-in-the-park-and-surf-the-web wi-fi user who has nothing better to do.

In addition, there would be a 3 Mbps 'premium' service available to paying subscribers. The company proposes to lease the spectrum in exchange for it giving the FCC 5 percent of the gross revenues realized from its premium service. Public Safety entities would also have access to the network at no cost other than for the hardware, if I recall correctly.

However, The Wall Street Journal claims that FCC Chairman Kevin Martin has shared a thumbs down opinion on the proposal with the rest of the commissioners. If the WSJ report is accurate, M2Z's legal threat may be pretty much meaningless.

As to the potential for success for this type of free network? Pretty questionable, at least in my opinion; most ad-supported free wi-fi networks have yet to pan out economically and most have discovered - the hard way - the many real-world realities inherent to wireless performance, coverage, and security. Not many have lived up to the promotional hype generated by their proponents nor delivered the user-experience expected. Besides, how much advertising can one take, anyway?

Check out M2Z's web site, then decide for yourself, though.


Monday, August 13, 2007

"White Space" Proponents to Try Again at FCC

Well....we didn't have to wait that long to learn the answer to the question I posed in a previous post concerning the TV "White Space" device testing proceeding, and, I don't think anyone will be very surprised as to what it is.

Microsoft filed a letter with the FCC today claiming that the scanner in one of two WSD prototypes submitted was damaged and "operated at a severely degraded level." The scanner in the wireless device is supposed to sniff for broadcasts in spectrum before transmitting in the band and switch to another band if the first one is occupied. The FCC found that the prototype did not consistently detect TV broadcast signals and could cause interference.

Also, this past Friday, the FCC extended an invitation to interested parties to participate in an on-site visit to the FCC Laboratory in Columbia, Maryland to observe and discuss the test set up and procedures for evaluating the performance of these devices.

The meeting will occur on Thursday August 16, 2007 at 1 PM at the Commission’s Laboratory in Columbia, Maryland. Parties interested in attending should send an e-mail to, identifying the organization and how many individuals plan to attend (space is limited). At the meeting, Commission staff will provide an overview of the tests, answer any questions, and consider suggestions for any further testing to evaluate the performance of TV White Space Devices. Directions to the Laboratory can be found at

Make your reservations early.....


Thursday, August 9, 2007

Invitation to the Spectrum Matters On-Line Discussion Group

Advancements in wireless (RF or radio) communications and information technology over the last decade have unleashed a flood of new devices, products, and services, provocative ideas and intriguing questions, political rhetoric and posturing, market-place confusion, controversy, and, a growing concern by many as to whether FCC and NTIA spectrum allocation, regulation, use, and rules enforcement policies are 'keeping up with the times' - or with technology.

As one might expect, all this hullabaloo has led to increasing calls by wireless stakeholders for something called "spectrum reform" that we're hearing more and more about each day.

Spectrum Matters is an on-line, moderated Yahoo! discussion group focusing on member-shared wireless spectrum news, information, and trends, responsible opinion, debate, ideas, experiences, commentary, and questions related to the real or perceived social, economic, and technical benefits or consequences that may be realized by updating legacy and/or implementing new wireless spectrum management policy to effectively address these important issues and concerns.

Topics and discussions are targeted towards
business, educational, industrial, enterprise, public safety, local, state, regional, federal government and similar types of PROFESSIONAL wireless mobile communication users who depend on access to the radio spectrum in their daily activities and who want to learn more about how and why wireless spectrum matters can, will, or already have had an impact on them.

If you are a professional wireless user and have an interest in wireless communications in general and spectrum issues in particular, please consider
joining us. (Membership approval requires a response to a New Member Confirmation Request emailed to you during the sign-up process)

Tuesday, August 7, 2007

FCC to Sprint/Nextel - Get The Job Done Or......

The Nextel interference debacle just keeps dragging on and on and on.....

Here's a report on the latest developments courtesy of the 08/07/07 Wall Street Journal:

• The Warning: The FCC is pushing Sprint Nextel Corp. to put an end to the disruption that its wireless system causes in emergency radio communications because its broadcast spectrum is interwoven with one used by police and firefighters.

• The Deal: The company agreed in 2004 to pay to move its service and public-safety agencies to separate channels, and was awarded 10 megahertz of coveted spectrum as an incentive.

• What's Next: With political pressure rising, the FCC says it may dictate a solution if the company doesn't pick up the pace.

(For more background and insight on this almost 10 year old and still unresolved problem, do a Google search using "800 mhz" "nextel" "rebanding" and "public safety" as the search words or, read over 3000 other entries from the industry available on the FCC's electronic comment site - enter "02-55" in the "Proceedings" field, then click "Retrieve Document List" at bottom of form)

Clearing Emergency Radio Waves
FCC Presses Sprint on Cellphone
Static Hindering Police Spectrum

August 7, 2007
Page A4 - The Wall Street Journal 08/07/07

Public-safety officials have been complaining for years about static from cellphones that disrupts emergency radio communications. Now the Federal Communications Commission is stepping up the pressure on Sprint Nextel Corp., the company whose signals are causing the most interference, to address the problem.

With talk of a renewed threat of a terrorist attack, the middle of the hurricane season approaching and the Minneapolis bridge collapse, some lawmakers are urging the FCC to take more control of the process. "The FCC needs to ensure that our police, firefighters and other first responders can use the spectrum without interference," says Sen. Frank Lautenberg (D., N.J.). "Communication on these frequencies is essential for public safety."

FCC Chairman Kevin Martin warns that he wants to see progress soon, or the FCC will dictate a remedy
. Sprint Nextel concedes it is taking longer than anticipated to solve the problem and attributes the delay to its efforts to do it as economically as possible.

The static is more than a nuisance. In Pennsylvania's Upper Uwchlan Township, police officers handling accidents on busy Route 100 regularly lose contact with dispatchers. Chief John De Marco says interference cut off a call he made during a traffic stop involving a fugitive; another time it happened when he was responding to a bank alarm. School-bus drivers, prison systems and utility workers have had calls interrupted by cellphone interference.

The problem has been intensifying with growing use of Sprint Nextel's network, the Nextel portion of which was created using a slice of the airwaves interwoven with the one used for emergency communications. Interference wasn't much of a problem when the spectrum was used as originally designated -- by construction crews, taxi drivers and other workers who needed souped-up walkie-talkies for short conversations.

In 2004, as use of Nextel service grew and static more frequently interrupted public-safety communications, the company, the FCC and safety groups agreed on a solution: Nextel would pay to move its service and public-safety agencies to separate channels. As an incentive, the FCC would give the company an additional 10 megahertz of coveted spectrum.

The company began negotiating with local public-safety agencies about the exact network upgrades they needed and how much the company would pay for them. The following year, Sprint Corp. acquired Nextel Communications Inc., making it necessary to mesh those two networks as well.

From the beginning, Sen. Lautenberg has questioned the legality of the deal. He says he remains concerned about the protracted process, in which hundreds of separate negotiations have ended up in mediation.

The fix was never expected to be easy or inexpensive. As part of its 2004 agreement with the FCC, Nextel promised to pay at least $4.86 billion - (
up from Nextel's original offer of $800 million) - and complete the job in three years. But many of the negotiations between Sprint Nextel and local authorities have landed in protracted mediation while interference has continued. (So far, with only 11 months left to go in the 36 month time-frame mandated by the FCC, the majority of Public Safety systems throughout the U.S. have yet to complete the process and, the interference continues, pretty much unabated)

"There's no way we're going to meet the 36-month end date, and there's very little sense of how much this could ultimately cost," says Robert Gurss, a lawyer with Fletcher, Heald & Hildreth PLC and director of legal and government affairs for the Association of Public-Safety
Communications Officials International.

While switching channels might sound easy, it isn't. Wireless-network equipment used by thousands of public-service agencies across the country needs to be modified, as does every mobile phone or other radio device the agencies use. As a measure of how much ground still
must be covered, Motorola Inc., a provider of equipment to the public-safety community, estimates it has shipped only 1% of the new phones and other equipment needed to complete the overhaul.

Ed Atkins, director of emergency services for Chester County, Pa., which includes Upper Uwchlan, has been negotiating for three yearswith Sprint to pin down the cost of preliminary studies to upgrade the police, fire and ambulance communications. He puts the initial costs
at about $650,000, substantially more than Sprint's $400,000 offer.

Mr. Atkins sees the price of the entire conversion ranging from as little as $18.5 million to as much as $150 million, depending on how many radios need replacing and how much of the county's communications infrastructure needs to be overhauled. "I was told we were going to
have our costs for this exercise covered," Mr. Atkins says. "I believe what people tell me: They say they are going to pay me. I believe they are going to pay me. It's very frustrating."

Sprint Nextel says by the end of this year, it will have spent about $1.5 billion. It acknowledges it has taken a tough stand in negotiations with public-safety officials, but cites that the original
agreement specified that it spend at least $4.86 billion. If the full project costs less, the difference goes to the Treasury; if it costs more, the Reston, Va., company is responsible for the costs.

"Every dollar we spend is a dollar that doesn't go to the U.S. Treasury," says Lawrence Krevor, Sprint's senior vice president, government affairs. "We don't have a lot of discretion. In fact, we
have very little discretion as to how we act here."

Some competitors may have been less than happy with the FCC's agreement to hand over coveted spectrum to Sprint. AT&T Inc. filed a complaint with the FCC in April in which it urged the agency to consider taking enforcement action, including possibly taking back the spectrum. The company says every time there is an incident of interference in areas in which it operates, it has to ensure it is not its signal which is causing the disruption, incurring costs in the process.

The FCC said Sprint should focus on getting the job done, not saving money for the Treasury. That statement "was a reflection of the commission's frustration with the current pace and a desire to motivate all the parties so that we really move forward in an expeditious manner," Mr. Martin says.

All sides acknowledge they hadn't anticipated just how difficult making changes would be. Public-safety networks, unlike commercial networks, can't be taken offline for repairs. "People's lives are hanging on this," said Steve Proctor, executive director of the Utah Communications Agency Network, which is supervising the channel switch in his state. "You're having to redesign and rebuild the airplane while it's still flying."

Write to Corey Boles at corey.boles @

Better yet, write or contact your congressman, senator, local or state public safety agency and the FCC to voice your concerns about this serious life-safety issue today.