"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

FCC Mulls Value vs Efficiency of Licensed vs Unlicensed Wireless Spectrum

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

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

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

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

According to the Commission's press release:

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

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

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

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

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

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

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

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


NR

TV "White Space" Spectrum Debate Simmers

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

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

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

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

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

NR

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

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

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

Abstract

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

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

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

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

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


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


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

RF (Wireless) Spectrum Information & Resource Links

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

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

Additional reading:

Spectrum Management Overview

Spectrum Policy and Planning

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

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

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

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

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

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

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

Abstract:

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

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

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

Download a copy and decide for yourself.

NR