Tweet the FCC on Twitter

To stimulate public dialogue over the development of a National Broadband Plan, (GN Docket 09-51) the Federal Communications Commission (FCC) has initiated a new blog called "Blogband." The blog will chronicle the development of the broadband plan and invites comments from its readers.

Take a look here: http://blog.broadband.gov/

And, the Commission also has joined the Twitter revolution:

http://www.twitter.com/fccdotgov

Nice to see the folks on the 8th floor at the Portals finally making an effort - albeit a somewhat radical one - to reach out to America (and the rest of the world as well), particularly in view of the way former Chairman Martin communicated with the public.

I'm sure the "new" FCC will get much more "dialog" and "stimulation" than they may be expecting from these initiatives once the general public discovers them (there are already over 10,000 responses to the Broadband Plan on the FCC's ECFS site). There's no doubt that both of these new sites will be ones to keep your eye on.

NR

Spectrum Policy in the Age of Broadband: Issues for Congress

A little light reading from the Congressional Research Service (CRC) for those at all interested in or even a bit concerned about the future of the RF spectrum from a policy standpoint.....

Spectrum Policy in the Age of Broadband: Issues for Congress

Summary

The convergence of wireless telecommunications technology and Internet protocols is fostering new generations of mobile technologies. This transformation has created new demands for advanced communications infrastructure and radio frequency spectrum capacity that can support high-speed, content-rich uses. Furthermore, a number of services, in addition to consumer and business communications, rely at least in part on wireless links to broadband backbones. Wireless technologies support public safety communications, sensors, medicine and public health, intelligent transportation systems, electrical utility smart grids, and many other vital communications.

Existing policies for allocating and assigning spectrum rights may not be sufficient to meet the future needs of wireless broadband and national broadband policy. A challenge for Congress is to provide decisive policies in an environment where there are many choices but little consensus. In formulating spectrum policy, mainstream viewpoints generally diverge on whether to give priority to market economics or social goals. Regarding access to spectrum, economic policy looks to harness market forces to allocate spectrum efficiently, with spectrum license auctions as the driver. Social policy favors ensuring wireless access to support a variety of social objectives where economic return is not easily quantified, such as improving education, health services, and public safety. Both approaches can stimulate economic growth and job creation. Choices about the direction of policy, however, can favor some industries over others.

Deciding what weight to give to specific goals and setting priorities to meet those goals pose difficult tasks for federal administrators and regulators and for Congress. Meaningful oversight or legislation may require making choices about what goals will best serve the public interest. Relying on market forces to make those decisions may be the most efficient and effective way to serve the public but, to achieve this, policy makers may need to broaden the concept of what constitutes competition in wireless markets.

This report considers the possibility of modifying spectrum policy: (1) to support national goals for broadband deployment by placing more emphasis on attracting new providers of wireless broadband services; and (2) to accommodate the wireless broadband needs of industries that are considered by many to be the economic drivers of the future, not only communications, but also areas such as energy, health care, transportation, and education.

Among the spectrum policy initiatives that have been proposed in Congress are: allocating more spectrum for unlicensed use; auctioning airwaves currently allocated for federal use; and devising new fees on spectrum use, notably those collected by the Federal Communications Commission (FCC). The FCC’s statutory authority to implement these measures is limited. Substantive modifications in spectrum policy would almost surely require congressional action. The Radio Spectrum Inventory Act introduced in the Senate (S. 649, Senator Kerry) and the similar House introduced Radio Spectrum Inventory Act (H.R. 3125, Representative Waxman) would require an inventory of existing users on prime radio frequencies, a preliminary step in evaluating policy changes. The FCC also has the opportunity to establish a new course for spectrum policy in the preparation of a Congressionally mandated report on broadband policy, due in February 2010.


NR

Cell Phone "Jammers" = "Pandora's Box"

If you are one of those who are thinking of purchasing a so-called "signal blocker" or cell 'phone "jammer" -- an electronic device designed to curb the real or perceived inappropriate use of wireless phones in restaurants, theaters, commuter trains, hospitals, and other similar public gathering places -- and, which are being advertised and sold on numerous Internet web sites, you may not know or realize that such devices (with certain well-defined exceptions) are nonetheless illegal to use in the United States.


I won't bore you with a long dissertation on the supposed pros and cons of the devices or the consequences that could result from the unchecked and potentially dangerous use of them. Rather, I have chosen to share the following pertinent excerpts from the U.S. government and the FCC for your information instead.


FCC Public Notice DA # 05-1776 - June 27, 2005

Sale or Use of Transmitters Designed to Prevent, Jam or Interfere
with Cell Phone Communications is Prohibited in the United States

http://www.fcc.gov/eb/Public_Notices/DA-05-1776A1.html

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-1776A1.pdf


Additionally, below are what appear to be the applicable Rules regarding "signal" or "cellular jamming" or similar devices. Perhaps the Commission should be sharing this information with those who apparently are in violation both Section 302 [47 U.S.C. 302], Section 333 [U.S.C 47 333] and, possibly other sections of the Act?

Communications Act of 1934, as
Amended by the Telecommunications Act of 1996

TITLE III--PROVISIONS RELATING TO RADIO
PART I--GENERAL PROVISIONS

SEC. 302. [47 U.S.C. 302] DEVICES WHICH INTERFERE WITH
RADIO RECEPTION.

(b) No person shall manufacture, import, sell, offer for sale, or
ship devices or home electronic equipment and systems, or use
devices, which fail to comply with regulations promulgated
pursuant to this section.

SEC. 333. [47 U.C.S. 333] WILLFUL OR MALICIOUS INTERFERENCE.

No person shall willfully or maliciously interfere with or
cause interference to any radio communications of any station
licensed or authorized by or under this Act or operated by the
United States Government.

TITLE V -- PENAL PROVISIONS -- FORFEITURES

SEC. 501. [47 U.S.C. 501] GENERAL PENALTY.

Any person who willfully and knowingly does or causes or suffers
to be done any act, matter, or thing, in this Act prohibited or
declared to be unlawful, or who willfully and knowingly omits or
fails to do any act, matter, or thing in this Act required to be
done, or willfully and knowingly causes or suffers such omission
or failure, shall upon conviction thereof, be punished for such
offense, for which no penalty (other than a forfeiture) is provided
in this Act, by a fine of not more than $10,000 or by imprisonment
for a term not exceeding one year, or both; except that any person,
having been once convicted of an offense punishable under this
section, who is subsequently convicted of violating any provision
of this Act punishable under this section, shall be punished by a
fine of not more than $10,000 or by imprisonment for a term not
exceeding two years, or both.

SEC. 502. [47 U.S.C. 502] VIOLATION OF RULES, REGULATIONS,
AND SO FORTH.

Any person who willfully and knowingly violates any rule,
regulation, restriction, or condition made or imposed by the
Commission under authority of this Act, or any rule, regulation,
restriction, or condition made or imposed by any international
radio or wire communications treaty or convention, or regulations
annexed thereto, to which the United States is or may hereafter
become a party, shall, in addition to any other penalties provided
by law, be punished, upon conviction thereof, by a fine of not
more than $500 for each and every day during which such offense
occurs.

SEC. 510. [47 U.S.C. 510] FORFEITURE OF COMMUNICATIONS DEVICES.

(a) Any electronic, electromagnetic, radio frequency, or similar
device, or component thereof, used, sent, carried, manufactured,
assembled, possessed, offered for sale, sold, or advertised with
willful and knowing intent to violate section 301 or 302, or
rules prescribed by the Commission under such sections,
may be seized and forfeited to the United States.

The text of the entire Act can be found here:

http://www.fcc.gov/Reports/1934new.pdf


In view of the above, consider yourselves forewarned about the use of "jammers" ......because spectum matters.


NR

Defining the "Harm" in "Harmful Interference"

Here's a post from CommLawBlog which readers might find both interesting and informative when it comes to radio and wireless communications system interference....

(Excerpt): "The concept of “harmful interference” is central to FCC spectrum policy. (It might surprise you however, that) the FCC has never said just what the term means. Oddly, though, that might be a good thing.

Nearly every band of the radio spectrum is shared among two or more categories of users. If we think of the spectrum as being spread out horizontally, the users of each band are stacked vertically. To see how this looks, click here.

Each band has a predetermined pecking order among its users: primary, secondary, and unlicensed. The relationships among all of these turn on harmful interference. Specifically:

• “Primary” users are protected against harmful interference from all other users.
  
  
• “Co-primary” users – services in the same band jointly designated as primary – may not cause harmful interference to each other.
  
  
• "Secondary” users may not cause harmful interference to primary users, and must accept harmful interference from primary users.
  
  
• Unlicensed users may not cause harmful interference to primary or secondary users, and must accept harmful interference from everybody.

The notion of harmful interference being key to the whole enterprise, we might expect to find a crisp and objective definition in the FCC rules. But when we look, we find something else. " (End excerpt)

Take a few minutes to learn more about the often mis-understood element of "harmful interference" - which is found in all radio and wireless communications systems - and the criteria that the FCC uses to help define it, here:

http://www.commlawblog.com/2009/01/articles/broadcast/finding-the-harm-in-harmful-interference/

It's actually a pretty tough job these days, especially when spectrum matters....

See http://en.wikipedia.org/wiki/Spectrum_management for more insight.

NR

Latest Wireless Absurdity from Congress

Politicians on Thursday (02/19/09) called for a sweeping new federal law that would require all Internet Service Providers (ISP's) and operators of millions of Wi-Fi access points, including hotels, local coffee shops, and private in-home users, to keep records about users who access their networks for two years to aid police investigations. They even have come up with a silly acronym so that the title of the bill - Internet Stopping Adults Facilitating the Exploitation of Today's Youth Act - spells out "Internet SAFETY Act."

More on this absurdity here:


http://news.cnet.com/8301-13578_3-10168114-38.html?part=rss&subj=news&tag=2547-1\
_3-0-20


Geeez...and to think we elected some of these folks. What's the matter with us, anyway? Would someone explain to me just how this law will help prevent the "exploitation of today's youth"? IMHO, the promoters of this legislation have either lost track of reality or, are suffering from a high BER. (Actually, it's probably some of both!)


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)

FCC staffer: This place is hell; silent protest planned

Interesting blog post about life at the Federal Communications Commission....

Excerpt:

A Federal Communications Commission employee called me on Friday and said that this Tuesday, the third anniversary of Kevin Martin's tenure as Chair of the FCC, at least some staff will arrive at work dressed in black. A "silent but expressive protest" is what they're calling the move. What for? I asked. "Because this place is hell," came the reply.

A super-politicized environment

It appears that a critical mass of FCC grunts are sick of what they experience as a super-politicized work life in which just about anything that they want to do has to get the go-ahead from the top, that being Kevin Martin. "Nothing happens in the Commission without the approval of the Chairman's office," my source told me. "It is incredible. We have become so political."

Do you have any sense of the logic of these directives from the Chair? I asked. "Nope," came the reply. "It seems as random as he got up this morning and ate his breakfast and just decided to do it."

Why are FCC employees upset about this? Not because they disagree with Kevin Martin's perspective on this or that FCC issue, but because, according to my source, he and his top subordinates demand that staff skip proper procedures and leapfrog various rules, even Congressional mandated rules, on a day-to-day level.

"In the past I may or may not have agreed with the outcome, but at least the proper procedures were followed. Now they tell us 'what are the media reform groups going to do: file a class action lawsuit? Just do it.' But ethically I have to sleep at night. It's not the decision, it's how the decision is reached. The situation has become arbitrary and capricious."

So....what else is new? This just points out how more and more obvious it is that some changes are needed in the way top brass at the FCC conduct themselves when attending to spectrum matters and other regulatory business that impacts us all.

NR

Wireless "Property" Rights - The Next Frontier of Spectrum Policy Reform

Phil Weiser and Dale N. Hatfield, frequent contributors of papers on wireless spectrum policy, have recently released a new article titled Spectrum Policy Reform and the Next Frontier of Property Rights.

Here is an abstract of their paper for your review and contemplation.

The scarcity of wireless spectrum reflects a costly failure of regulation. In practice, large swaths of spectrum are vastly underused or used for low value activities, but the regulatory system prevents innovative users from gaining access to such spectrum through marketplace transactions.

In calling for the propertyzing of swaths of spectrum as a replacement for the current command-and-control system, many scholars have wrongfully assumed the simplicity of how such a regime would work in practice. In short, many scholars suggest that spectrum property rights can easily borrow key principles from trespass law, reasoning that since property rights work well for land, they can work well for spectrum rights as well. But as we explain, spectrum is not the same as land, and a poorly designed property rights regime for spectrum might even be worse than the legacy model of spectrum regulation.

This Article addresses three central questions that confront the design and implementation of property rights in spectrum. First, it suggests how policymakers must develop a set of rights and remedies around spectrum property rights that reflect the fact that radio signals defy boundaries and can propagate in unpredictable ways. In particular, if policymakers simply created rights in spectrum and enforced them like rights in land (i.e., with injunctions for trespass), they would invite strategic behavior: spectrum speculators would buy licenses for the sole purpose of suing other licensees when their transmission systems created interference outside the permissible boundary (i.e., act as spectrum trolls).

Second, it rejects the suggestion that policymakers establish a unitary property right for spectrum, arguing that policymakers should zone the spectrum by establishing different levels of protection against interference (i.e., an ability to transmit signals with more latitude) in different frequency bands.

Finally, this Article discusses what institutional strategy will best facilitate the development of the property right and its enforcement, concluding that an administrative agency - be it a new one or a reformed FCC - is better positioned than a court to develop and enforce the rules governing the use of spectrum so as to facilitate technological progress and prevent parties with antiquated equipment from objecting to more efficient uses of spectrum. (End abstract)

There is absolutely no doubt that U.S. spectrum policy (and stronger enforcement of new or legacy regulations concerning use of this important resource) needs urgent reform. Hopefully, this paper will help shed some much needed light on the challenges involved as well as generate meaningful discussion on the subject.

NR

FCC Mulls Value vs Efficiency of Licensed vs Unlicensed Wireless Spectrum

After being silent on spectrum matters for almost 5 years, the FCC's OSP (Office of Strategic Planning and Policy Analysis) has issued 3 new working papers on potential spectrum management policy now being evaluated.

Working Paper #41, “Enhancing Spectrum’s Value Via Market-informed Congestion Etiquettes”

Working Paper #42, “Modeling the Efficiency of Spectrum Designated to License Use and Unlicensed Operations,” examine ways in which spectrum designated to licensed and unlicensed use can be more efficiently used.

Working Paper #43, “A Market-based Approach to Establishing Licensing Rules: Licensed Versus Unlicensed Use of Spectrum,” examines the feasibility of employing a market mechanism to determine whether spectrum should be designated to either licensed or unlicensed use.

According to the Commission's press release:

Working Paper #41, “Enhancing Spectrum’s Value Via Market-informed Congestion Etiquettes” and Working Paper #42, “Modeling the Efficiency of Spectrum Designated to License Use and Unlicensed Operations,” examine ways in which spectrum designated to licensed and unlicensed use can be more efficiently used.

Combining economic theory and experimental analysis, Working Paper #41 (and its more theoretical companion Working Paper #42) evaluates the ability of different wireless spectrum congestion etiquettes to promote the efficient use of wireless spectrum in the presence of licensed and unlicensed operations. Under the examined environment, theory predicts that society leaves half of the value it can receive from spectrum “on the table.”

One new approach utilizes various types of user information to address the inefficient use problem. Assuming a close similarity between the naturally occurring environment and the experimental one, analysis reveals that the average efficiency of the existing etiquette employed in most unlicensed equipment is 42%. In comparison, experimental analysis reveals that the average efficiency of one market-informed etiquette - the Informed Greedy Algorithm - is 70%.

This and other results form the factual basis for generating an entirely new type of spectrum allocation wherein a given band of spectrum is treated as a common pool resource in the absence of excessive spectrum congestion, but is treated as an excludable private good in the presence of such congestion.

Working Paper #43, “A Market-based Approach to Establishing Licensing Rules: Licensed Versus Unlicensed Use of Spectrum,” examines the feasibility of employing a market mechanism to determine whether spectrum should be designated to either licensed or unlicensed use.

Working Paper #43 addresses the issue of how best to identify the most desirable allocation rules for spectrum. This OSP paper focuses on issues associated with licensed use and unlicensed operations. Spectrum designated to unlicensed use is made freely available for uses that comply with appropriate technical standards. Spectrum allocated to licensed use is typically assigned to license owners through an auction. Moreover, winners of the auction are granted the right to exclude non-payers from using their spectrum. The allocation between licensed and unlicensed use, however, is based on the FCC’s judgment, which in turn relies on information provided by interested parties seeking to use the spectrum.

One method of reducing the incentive that parties have to exaggerate the value they place on a given licensing regime involves creating a market for such rules. The study examines the feasibility of using a “clock auction” to determine, based on bids submitted by market participants for the corresponding licensing rules, the efficient allocation of a given amount of spectrum between licensed and unlicensed spectrum use. This study finds that market forces, in the form of a clock auction, can be used to determine the efficient assignment of license rules (i.e., those associated with licensed use and unlicensed operations) to spectrum.

If you are at all interested in or concerned about the FCC's future spectrum allocation and management agendas, these papers deserve your attention - and your input. Catherine Bohigian is Chief of the Office of Strategic Planning and Policy Analysis. Elizabeth Andrion is Deputy Chief. The Commission's Chief Economist, Greg Crawford, also makes his home in OSP and he reports to the Chairman on economic issues. Ms. Bohigian, Ms. Andrion, and Dr. Crawford can be contacted by phone at (202) 418-2030.


NR

TV "White Space" Spectrum Debate Simmers

For those following the TV spectrum "white spaces" debate currently simmering on the FCC's back burner, here is a policy backgrounder worth a read from Sascha Meinrath and the New America Foundation:

According to Meinrath, "smart" wireless devices can use the unassigned frequencies between broadcast TV channels to offer wireless broadband and other innovative services. A rulemaking is pending at the FCC (Docket 04-186 - with over 11,000 comments from the public and industry to date) as to whether to permit unlicensed access to this currently wasted spectrum, subject to technical requirements that will protect television reception from interference. Access to the vacant TV channels in each market has been the subject of intense lobbying, yet far too many of the arguments against "white space" devices rely upon misinformation about the technologies and the FCC process that will prevent harmful interference to DTV reception and other incumbent services.

This policy backgrounder offers a summary analysis, and is an effort to help policymakers strike the appropriate balance between protecting existing services from interference while making the benefits of mobile broadband services available and affordable for all consumers. It provides policymakers with:

1. a brief historical background to the current FCC proceedings;
2. a description of White Space Device (WSD) technologies;
3. a “Myths vs. Facts” section addressing the key concerns raised about WSDs;
4. an overview of the public benefits of WSDs; and
5. a concise summary of where we are in the multi-phase process of adopting WSD technologies for consumer use.

The complete document should be reviewed by anyone interested in or concerned about the development of "white space devices" (WSD's), FCC regulation, and technology -- because spectrum matters.

NR

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

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.


NR

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.


NR

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.


NR

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

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!

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

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.


NR

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)