FCC VHF UHF Part 90 Radio Narrowbanding Reminder

In December 2004, the FCC issued an Order mandating that all Part 90 business, educational, industrial, public safety, and state and local government private land mobile radio (PLMR) licensees operating in the VHF (150 – 174 MHz) and UHF (421 – 512 MHz) bands convert their dispatch, paging, and data/SCADA radio systems from legacy wideband (25 kilohertz) to narrowband (12.5 kilohertz or equivalent) operation by Jan. 1, 2013. That date is now LESS THAN 32 MONTHS away.

Contrary to what some may have heard or been led to believe, the Order does not require licensees to change to new radio frequencies or different frequency bands, nor does it require moving from analog to digital or from a conventional to a trunked radio system. However, these are options that some licensees may want to more fully explore with the guidance of a qualified radio communications system professional. The Order also doesn’t mean that licensees need to replace all their current radio system equipment — only any soon-to-be-non-compliant equipment.

What the FCC’s mandate does require is that all wideband-only conventional or trunked VHF and UHF radios, including handheld portables, vehicle-mounted mobiles, dispatcher stations, wireless data, telemetry, or supervisory control and data acquisition (SCADA) link radios (called subscriber radios) and any associated wideband-only conventional or trunked base or repeater stations (called infrastructure radios), be replaced with narrowband capable equipment prior to the 2013 date to continue legal use of Part 90 radio frequencies beyond that date. FCC radio system licenses must also be modified to reflect the change to narrowband emissions and operation.

Migration Steps

Over the last several years, in response to the mandate, many licensees have started the narrowband migration process by deploying dual-mode subscriber radios — those capable of both wideband and narrowband operation — as new radios have been added to their systems or as older wideband-only radios were lost, damaged beyond repair or otherwise removed from service. While this strategy is a practical, cost-effective approach, particularly by those with large numbers of subscriber radios in their fleets or those with multiple radio frequencies, base stations and repeaters in their systems, this method addresses only the first step of a multi-step process.

Unless a radio system is initially implemented as a narrowband system - as most new systems have been during the past eight to ten years - many dual-mode replacement subscriber radios deployed into pre-mandate or older, conventional or trunked VHF or UHF radio systems have typically been programmed for wideband rather than narrowband operation. This best-practices method was necessary to retain compatibility with existing wideband subscriber and infrastructure radios in use in those systems. (NOTE: the mixing of wideband and narrowband radios on the same frequency of a system is generally not encouraged nor recommended. Doing so has the potential to render most voice - and especially data - transmissions between wideband and narrowband radios unintelligible, distorted or unreliable). The method also allowed the expense of replacing infrastructure radios at the same time to be deferred, as the year 2013 seemed a long way off.

In many instances, however, the need to address the deferred replacement of wideband-only infrastructure radios may have inadvertently been overlooked or even forgotten by some licensees or radio system managers. This is particularly true when it comes to the many smaller business, educational, and industrial users of two way radio who typically don't keep up with current FCC Rules or the responsibilities that go along with being a Part 90 licensee, and, who quite often simply take the use and benefit of their radio systems for granted.

Consider this post a "wake-up" call to all licensees that, until all subscriber and infrastructure radios are fully migrated to narrowband operation, many radio systems may still be operating in the wideband mode, which is legal only until Jan. 1, 2013.

Migration Planning

Has your company or organization developed a migration plan and budget to address the next steps necessary to complete the narrowband migration process and become fully FCC compliant? These steps include replacing any remaining wideband-only subscriber radios still being used; procuring and installing narrowband base stations, repeaters or other infrastructure radios as needed; preparing a well-planned, coordinated approach to re-programming all radios to narrowband operation; and modifying a radio station license to reflect any new emissions designators. Click here for more migration suggestions.

The 2013 date isn’t that far away, particularly if funding needs to be secured and budgets prepared or, when any operations dependent on uninterrupted radio communications may be jeopardized.

Companies and organizations that recognize and appreciate the value of their Part 90 two-way voice and data radio communications systems are advised not to wait until the last minute to begin or complete the narrowbanding process. By waiting, they are risking not only the loss of use of their current radio frequencies, but the return on the investment (ROI) and associated benefits provided by their radio system equipment as well.

More Information

For on-line discussions regarding the mandate, licensees and others interested in narrowbanding are invited to join the LMR Narrowbanding Yahoo! Group

Additional Part 90 Narrowbanding information and resources are also available here: http://www.wirelessradio.net


NR

IP to kill radio in public safety market

It's absolutely amazing (and disturbing) to see these types of what could be deemed mis-leading if not mis-representative articles from so-called industry experts who should know better.

Mr. Filipowski must be what some would call a "futurist". Who knows - perhaps many of his predictions will come to pass in the distant future but, after reading (and re-reading) this article several times to convince myself that he actually said what he said, I'd suggest that his BER needs some immediate attention in the interim.

He is way off-frequency when it comes to his belief that 1) radio is obsolete; 2) IP technology will replace radio; and 3) that cellular/public networks are public safety's salvation.

It might do him some good to get out of his lab and into the real world sometime soon - before making himself look any more foolish than he already has.

NR

Senate Committee ok's "Spectrum Chaos"

Today (08/05/2009) a Senate Committee ok'd the use of cell phone "jammers" in prisons. Here's the committee's press release with an overview of the bill:

Senate Commerce, Science, and Transportation Committee Cellular Jammer Press Release

Which has prompted this "spurious emission"....

Ok, everyone - calm down a moment and read the press release (above) Yes, the lid to Pandora's Box may have been cracked open a bit today but the good news is that jammer devices have NOT been approved by the full Congress or the FCC - yet. However, because of the actions of this Senate committee, we as an industry need to work even harder to keep their bill from ever becoming law.

NOW - today - is the time for those seriously concerned about this matter to "express themselves" - before this nonsense is allowed to go very much further and the lid to Pandora's Box actually is opened completely with the possible legal approval of these "spectrum chaos" causing devices.

If you care, you need to speak out now before it's too late. Here are a couple of links with contact info to help get you started:

U.S. Senate Contact Info

U.S. House of Representatives Contact Info


I hope many of you will join me in "expressing" yourself to your Congressional Representative.


NR

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

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

Are You Ready for FCC Part 90 UHF/VHF Radio System "Narrowbanding"?

In December 2004, the FCC issued an Order mandating that all Part 90 business, educational, industrial, public safety, and state and local government VHF (150 – 174 MHz) and UHF (421 – 512 MHz) private land mobile radio (PLMR) licensees convert their radio system operations from legacy wideband (25 kilohertz) to narrowband (12.5 kilohertz or equivalent) operation by Jan. 1, 2013.

Contrary to what some may have heard or been led to believe, the Order does not require licensees to change to new radio frequencies or different frequency bands, nor does it require moving from analog to digital or from a conventional to a trunked radio system. (These are, though, alternative radio system options that some licensees may want to more fully explore with the guidance of a qualified radio communications system professional.) The Order also doesn’t mean that licensees need to replace all their current radio system equipment — only any soon-to-be-non-compliant equipment.

What the FCC’s mandate does require is that all wideband-only conventional or trunked VHF and UHF radios, including handheld portables, vehicle-mounted mobiles, dispatcher stations, wireless data, telemetry, or supervisory control and data acquisition (SCADA) link radios (called subscriber radios) and any associated wideband-only conventional or trunked base or repeater stations (called infrastructure radios), be replaced with narrowband capable equipment prior to the 2013 date to continue legal use of Part 90 radio frequencies beyond that date. FCC radio system licenses must also be modified to reflect the change to narrowband emissions and operation.

Migration Steps

Over the last several years, in response to the mandate, many licensees have started the narrowband migration process by deploying dual-mode subscriber radios — those capable of both wideband and narrowband operation — as new radios have been added to their systems or as older wideband-only radios were lost, damaged beyond repair or otherwise removed from service. While this strategy is a practical, cost-effective approach, particularly by those with large numbers of subscriber radios in their fleets or those with multiple radio frequencies, base stations and repeaters in their systems, this method addresses only the first step of a multi-step process.

Unless a radio system is initially implemented as a narrowband system - as most new systems have been during the past six to nine years - many dual-mode replacement subscriber radios deployed into pre-mandate or older, conventional or trunked VHF or UHF radio systems have typically been programmed for wideband rather than narrowband operation. This best-practices method was necessary to retain compatibility with existing wideband subscriber and infrastructure radios in use in those systems. (NOTE: the mixing of wideband and narrowband radios on the same frequency of a system is generally not encouraged nor recommended. Doing so has the potential to render most voice - and especially data - transmissions between wideband and narrowband radios unintelligible, distorted or unreliable). The method also allowed the expense of replacing infrastructure radios at the same time to be deferred, as the year 2013 seemed a long way off.

In many instances, however, the need to address the deferred replacement of wideband-only infrastructure radios may have inadvertently been overlooked or even forgotten by some licensees or radio system managers. This is particularly true when it comes to the many smaller business, educational, and industrial users of two way radio who typically don't keep up with current FCC Rules or the responsibilities that go along with being a Part 90 licensee, and, who quite often simply take the use and benefit of their radio systems for granted. This blog post is a reminder to all licensees that until all subscriber and infrastructure radios are fully migrated to narrowband operation, many radio systems may still be operating in the wideband mode, which is legal only until Jan. 1, 2013.

Migration Planning

Has your company or organization developed a migration plan and budget to address the next steps necessary to complete the narrowband migration process and become fully FCC compliant? These steps include replacing any remaining wideband-only subscriber radios still being used; procuring and installing narrowband base stations, repeaters or other infrastructure radios as needed; preparing a well-planned, coordinated approach to re-programming all radios to narrowband operation; and modifying a radio station license to reflect any new emissions designators. Click here for more migration suggestions.

The 2013 date isn’t that far away, particularly if funding needs to be secured and budgets prepared or, when any operations dependent on uninterrupted radio communications may be jeopardized. Companies and organizations that recognize and appreciate the value of their Part 90 two-way voice and data radio communications systems are advised not to wait until the last minute to begin or complete the narrowbanding process. By waiting, they are risking not only the loss of use of their current radio frequencies, but the return on the investment (ROI) and associated benefits provided by their radio system equipment as well.

More Information

Follow these two links to official documents and complete background information on the FCC’s narrowbanding mandate:

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-292A1.pdf (2004 Order)

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-271692A1.pdf (2007 Update)

or, for on-line discussions regarding the mandate, licensees and other interested parties are invited to join the LMR Narrowbanding Yahoo! Group


NR
(Re-post2)

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

U.S. Spectrum Management according to Wikipedia.....

The folks at the Portals (FCC) and the NTIA might be interested in this....

Current Spectrum Management in the United States

Wireless (RF or radio) spectrum management in the United States should be a cooperative exercise in balancing disparate stakeholder interests through effective user education and the enforcement of regulatory policies and rules that reflect practical reality, political responsibility, economic common sense, and, an understanding of the laws of physics. Unfortunately, this is not the case.

There is no concise, up-to-date, national radio/RF/wireless spectrum management policy practiced by the FCC and/or the NTIA in the U.S today. In addition, either very out-dated, convoluted, complex or very lax or non-existent regulation (often determined by the agendas of political and special interest groups more than by anything else) is the norm, with little effective enforcement of spectrum use rules.

Source: http://en.wikipedia.org/wiki/Spectrum_management

It looks like the word is beginning to get out to the general public if one takes Wikipedia's definition at face value....although, when one thinks about it, the definition really isn't that far off the mark - is it?

NR

FCC's Strategic I.T. Plan - FY 2008-2012 - Ver 1.0

The Federal Communications Commission's 2008-2012 IT Strategic Plan (ITSP) sets forth the current and future foundation and guidelines that direct Commission-wide IT (information technology) activities for building an information systems architecture that is increasingly interoperable and migrates toward a single vision of IT at the FCC.

The ITSP is a five-year look at managing IT at the FCC. To prevent obsolescence of the information contained within the ITSP, periodic verification and validation activities will occur.

An annual validation of the information contained in the ITSP will be performed and updates will be made accordingly. A shift in Commission goals will trigger a review and update to the ITSP to reflect evolving FCC IT objectives

This ITSP is used in conjunction with the FCC's IT Tactical Management Plan which is an evolutionary document that maps out and schedules all IT initiatives and guides IT projects and activities. The Office of the Managing Director maintains and performs frequent updates to the IT Tactical Management Plan.

Examples of activities in the ITTMP include:

• Hardware Life Cycle Replacement Projects/Initiatives
• Application Software Projects/Initiatives
• Telecommunications (Data/Voice) Life Cycle Projects/Initiatives
• Infrastructure Consolidation Projects/Initiatives
• Federal Compliance Reporting Activities



You'll note that this plan is dated October, 2007 -- but is also labeled Version 1.0 -- something I'd think many would find rather interesting, considering that information technology (and the use and distribution of it) in the private sector is much further advanced.

Hmmm.....could this be part of why the Commission is struggling in so many ways when it comes to the allocation, management, and regulation of the radio spectrum?


NR

Wireless Spectrum Links & Resources

Those concerned or interested in learning more about U.S. spectrum regulation and frequency allocation policies and their impact on radio and wireless communication devices may want to begin paying very close attention to the Notices, actions and decisions made by the FCC's Wireless Telecommunications Bureau (WTB), the 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.

Authorization

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.


NR
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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

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.


NR

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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

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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."

Hmmm....as 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.


NR

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

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