GAO to FCC & DHS - Improve Emergency Communications & Collaboration

The following was excerpted from a recently released United States Government Accountability Office (GAO) Report to the Chairman, Subcommittee on Communications, Technology, and the Internet, Committee on Commerce, Science & Transportation, United States Senate titled

"EMERGENCY COMMUNICATIONS - Vulnerabilities Remain and
Limited Collaboration and Monitoring Hamper Federal Efforts"

"Limited collaboration and monitoring jeopardize federal emergency communications efforts, even as the federal government has taken strategic steps to assist first responders. Federal agencies have demonstrated limited use of some best practices that GAO previously reported as helpful for addressing issues like emergency communications. Delays in establishing the Emergency Communications Preparedness Center, which would help define common goals and mutually reinforcing strategies—two collaboration best practices—undermine the National Emergency Communications Plan’s implementation. DHS and FCC have also not applied these practices in FCC’s effort to promote a public safety network for emergency communications. Agency officials reported it was either too early or not the agency’s responsibility to use these best practices in developing this network. DHS did not submit formal comments to FCC and FCC officials described its proposed network as separate from DHS emergency communications efforts. However, GAO found potential opportunities to align these agencies’ efforts. Another collaboration best practice is leveraging resources, which DHS has done in providing emergency communications technical assistance and planning guidance. But efforts have focused on state and local jurisdictions and less on federal agencies, some of which lack formal emergency communications plans. Monitoring is also crucial in helping agencies meet goals."

You'll need to read the report to learn what the four recommendations made to improve federal agencies’ collaboration and monitoring in efforts related to emergency communications were.

NR

The Great "White Spaces" Challenge

Google (and its technology partners) are facing the great "white spaces" challenge - the next big spectrum allocation battle - from the politically powerful NAB (National Association of Broadcasters) and others.

On the one hand we have the over-the-air TV broadcasters (who rarely offer much worth the bandwidth it takes to beam it into our living rooms) insisting that the spectrum will "suffer" from the use of unlicensed wi-fi like devices operating near THEIR frequencies.

On the other hand, we have pretty much the rest of the country clamoring - no, make that screaming - for the opportunity to deploy "innovative" wireless communications devices and services, "stimulate" our economy, and make "better use" of nearly the very SAME spectrum - all on an unlicensed basis with little if any regulatory enforcement of that use. (Which, IMHO, is a somewhat worrisome scenario to begin with considering the historical track record over the years of the FCC's ability to "protect" the natural resource we call the RF spectrum, AND, the purported "better use" and "innovation" that the "white spaces" proponents claim they'll make with the resource.)

This spectrum battle should prove VERY interesting to say the least. Let's hope the regulators make the right decision - whatever "right" is deemed to be these days.


NR
(Repost)

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!


NR

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.


NR

(Repost)

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)

(hmmmm....do 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!)

NR

(Repost)

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....


NR

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??

NR

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:

Abstract:

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
best 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.

NR

"White Space" Prototypes Fail FCC Test

Not so good news about those prototype devices from Microsoft and a group made up of Dell, EarthLink, Google, HP, Intel, Microsoft, and Phillips Electronics who have been pushing hard for approval of unlicensed operation in the "white spaces" of the the TV broadcast bands....


Initial Evaluation of the Performance of Prototype TV-Band White Space Devices - July 31, 2007

Conclusions: This report determined that the sample prototype White Space Devices (WSD's) submitted to the Commission for initial evaluation do not consistently sense or detect TV broadcast or wireless microphone signals. Our tests also found that the transmitter in the prototype device is capable of causing interference to TV broadcasting and wireless microphones.

However, several features that are contemplated as possible options to minimize the interference potential of WSDs, such as dynamic power control and adjustment of power levels based on signal levels in adjacent bands, are not implemented in the prototype devices that were provided.

Given these results, further testing of these devices was not deemed appropriate at this time.


Prototype Devices Report FCC/OET 07-TR-1006 (85 Pg PDF)
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-275666A1.pdf

Direct Pickup Report FCC/OET 07-TR-1005 (28 Pg PDF)
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-275668A1.pdf


So....the question to be asked seems to be.... will they try again?


NR

Will The Failure of FCC Spectrum Auctions Impact 700 MHz?

hmmmm.....

According to this May 2006 paper from the Center for American Progress (quote) "The Federal Communications Commission’s auctioning of spectrum licenses is a failure. The auctions have been subject to collusion and manipulation by big business, and as a result have failed to meet legislative guidelines." (end quote)


(Quote) "Analysis of the last ten years of FCC spectrum auctions reveals that these auctions have met neither the standards nor the expectations expressed by Congress in their authorization. They do not facilitate the development of robust markets or meet the needs of the broader public interest. Instead these auctions, as they have been conducted, appear to serve the narrow interest of dominant actors in the telecommunications industry. They have systematically resulted in market concentration and the growth of the oligopolistic market power of major actors in the telecommunications industry. They have been pervious to manipulation by tacit collusion among bidders in ways which no minor amendment of the auction process could possibility remedy. Even the often made argument that FCC spectrum auctions maximize revenue fails in the face of both FCC mispricing of licenses, reflected in the large number of licenses which fail to be auctioned because no bidder meets the reserve price, and substantial evidence that strategic behaviors like preemptive bidding can guarantee better capitalized bidders licenses at consistently lower prices than their competitors. What has principally driven the adoption of spectrum auctions by the FCC and Congress has been ideologically-libertarian economic theory, captured in simplistic models which ignore inconvenient facts. Game theory is a powerful tool for analysis of economic behavior. However, a game-theoric model is only as good as its assumptions. Assumptions about information, bidder resources, risk-acceptance and -aversion, and the structure of bidder preference all matter, because they imply things about how the real world operates. All modeling is along a continuum between analytical tractability and empirical verisimilitude: the more mathematically tractable the model is, the less it resembles the real thing being modeled. It is for this reason that social scientists frequent evaluate and refine such models through experiments to see whether an analytically tractable model captures what really matters about the thing it models. The past ten years of FCC spectrum auctions have amounted to such an experiment, and the experiment demonstrates that the models on the basis of which Congress and the FCC were persuaded to adopt spectrum auctions fail dramatically in their prediction of real-world outcomes. When tested by the actual performance of such auctions, the chasm between the outcomes predicted by theory and the outcomes observed is immense. In sacrificing the public interest in pursuit of hypothesized market efficiencies and greater revenue we have arrived at the worst of both worlds: FCC spectrum auctions neither serve the public interest nor realize the promised economic efficiencies and revenue maximization touted by their advocates." (end quote)


(Quote) "Until the FCC can demonstrate that it can conduct auctions in the public interest, Congress should halt the ongoing plans to auction licenses to the public spectrum." (end quote)



Kinda makes one question just how small business entrepreneurs, women, minorities, and public safety/first responders will fare in the up-coming - and perhaps most important auction of all - that of the 700 MHz spectrum.


NR

Wireless Stakeholder Comments in 700 MHz Public Safety Proceeding

For your Memorial Day weekend reading pleasure, here's a compilation of all 300+ Comments made to the FCC by industry stakeholders in the 700 MHz Public Safety broadband proceedings (Dockets 96-86 & 06-229)....and a link to the 9th NPRM (Notice of Proposed Rulemaking) for your attentive review -- offered in an effort to assist readers in learning more about why spectrum matters.


By the way, Reply Comments are due May 30th unless the Commission extends the date...if you have been thinking about "expressing yourself", now's the time to do so. You can file them here.


NR