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

FCC Part 90 Narrowbanding Info & Resource Site for LMR VHF UHF Licensees

With less than 36 months left until the FCC's 2013 Narrowbanding Mandate is due to take effect, and, because there continues to be a lack of user-specific, up-to-date, and accurate flow of information or guidance from both the FCC and the industry targeted to Part 90 VHF and UHF licensees, a new web site has been established to help spread the word.

Please feel free to refer this site to those who need to take action now in order to meet the narrowbanding deadline. Procrastination on the part of any licensee is not an option.


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

"White Spaces" Rules for TV Spectrum Released

On Friday (11/14/2008) the Federal Communications Commission (FCC) released their long-awaited and highly-debated Rules for the development and operation of so-called television band "white spaces" devices to be authorized under CFR 47 Part 15 sub-part H.


The following is excerpted from the FCC's "White Spaces" Order (FCC 08-260) on ET Docket No. 04-186 and ET Docket No. 02-380):

Introduction - Item 10. All Devices. All unlicensed TV band fixed and personal/portable TV band devices will be permitted to operate on TV channels 21-51, excluding channel 37. In addition, fixed TVBDs that only communicate with other fixed TVBDs will be permitted to operate on channels 2 and 5-20, except that they must avoid operation on channels used by private land mobile radio service (PLMRS), i.e., public safety, and commercial mobile radio service operations on channels in certain markets and areas adjacent to them. Also, in individual markets where there are Private Land Mobile Radio Service or Commercial Mobile Radio Service (PLMRS/CMRS) operations on channels 14-20, two channels in the range 21-51 will be reserved for operation by wireless microphones such that TVBDs will not be permitted on those channels. This plan for channel use is consistent with the requests of the various white space proponents and would reserve channels for a "safe harbor" for operation of wireless microphones and ensure protection of the public safety and other land mobile services that use channels 14-20. At this time, we are only permitting fixed TVBDs to operate on channels not that are not immediately next to (first adjacent on either side of) the channel of a TV station; personal portable devices will be allowed to operate on first adjacent channels to a TV station subject to the power limitation indicated above. All unlicensed TV band devices will be required to limit their out-of-band emissions in the first adjacent channel to a level 55 dB below the power level in the channel they occupy, as measured in a 100 kHz bandwidth. In addition, all TVBDs will be required to comply with a more stringent out-of-band emissions band at the edges of channels 36 and 38 that are adjacent to channel 37 in order to protect medical telemetry devices on that channel 37. Fixed devices will also be required to periodically transmit a signal with their identification when they are operating. This will facilitate identification of sources of interference. The database system for fixed stations and personal/portable devices with geo-location and database access capability will be managed by a database manager or managers selected by our Office of Engineering and Technology.

Full text of Order:

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-260A1.pdf


It'll be at least a year or more until any products or services are available to utilize this spectrum (none have been certificated by the FCC as yet and, you can probably count on both proponents and opponents continuing their war of words and legal challenges), so, this might be a good time to suggest that all potential "white spaces" users familiarize themselves with Appendix B of the Order which contains the Final "White Spaces" Rules and the new Part 15 Sub-Part H on Television Band Devices.


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

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
(Repost)

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

(Repost)

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

(Repost)

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

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

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

Transformative Technology

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

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

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

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

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

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


NR

NTIA Phase 2 BPL Report Finally Released - 3 Years Late

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

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

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

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

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

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


NR

NATO Issues Warning on BPL and the HF Radio Spectrum

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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