The National Telecommunication and Information Administration (NTIA) is looking for comments about the country’s long-term strategy for the way we use spectrum. I strongly urge rural communities and rural carriers to comment because current spectrum rules favor the use of spectrum in urban use and effectively block deployment for rural broadband.

Comments are due by midnight January 22. The Docket number is 181130999-8899-01.  NTIA doesn’t have a slick website for providing comments and comments are instead emailed to: spectrum-strategy-comments@ntia.doc.gov. These should be Word documents with no password protection.  The press release concerning the comments is here.

The Problem. Today most spectrum is being used in urban areas but not deployed in the surrounding rural areas. It’s hard to fault the cellular companies for this practice. The low customer density in rural areas doesn’t support the deployment of the same mix of spectrum needed to satisfy urban cellular bandwidth needs.

However, this unused spectrum could be used for spectacular fixed wireless broadband – something that is not part of the business plan of cellular companies. If we freed idle and unused rural spectrum, we could offer great rural broadband with today’s technology – we could deploy broadband at hundreds of Mbps including wireless products that would carry through forests and other impediments. The spectrum exists to provide great rural broadband, but the companies willing to invest in such deployments can’t get the needed spectrum.

Current Spectrum Rules Favor Urban America. There are a few reasons why spectrum sits idle in rural America today:

Large Footprints of Licenses. The FCC has historically licensed spectrum for huge footprints, normally centered around at least one urban center. The cellular companies that buy the spectrum largely deploy it in the urban centers and ignore the surrounding rural areas.

Inadequate Coverage Rules. Most FCC licenses come with coverage requirements. For instance, a given spectrum might need to eventually be deployed to cover something like 70% of the households in a license area. Spectrum holders can deploy in the urban areas and satisfy the coverage requirements while potentially ignoring a huge part of the geography of a license footprint.

FCC Doesn’t Enforce Timelines. Most spectrum comes with defined timelines for deployment, but the FCC routinely ignores license holders that are late to deploy or else grants long extensions to meet the requirements.

Spectrum Speculators. Too much spectrum is purchased by speculators who have no plans to operate the spectrum but instead buy it in hopes of eventually selling to the larger carriers in the future. These speculators often maintain their licenses using fake deployments – creating wireless links that carry no bandwidth in order to maintain their licenses.

Large Carriers Want No Hassles or Strings. The large wireless carriers lobby against any spectrum rules that might cause them to share spectrum or to deal with even the slightest hint of interference. It’s hard to blame them for this, but the result is unused spectrum simply due to the unwillingness of the large carriers to compromise for the greater good.

The Solution. I don’t profess to have all of the needed solutions to the problem. Ideally, unused spectrum should be made available to those willing to use it in a given geographic footprint. I can think of a few changes that would make a huge difference to free up rural spectrum:

Smaller Footprints for Licenses. The FCC recently rejected several opportunities to license spectrum in smaller footprints. It’s easy for them to justify not licensing in smaller footprints because it’s administratively more difficult, it probably lowers the license fees from an auction and most importantly because the big carriers lobby against it. However, smaller footprints would provide significant opportunities for smaller rural ISPs to obtain spectrum that otherwise goes unused.

Spectrum Sharing. We now have technologies that can allow multiple carriers to share spectrum, particularly in areas where the primary license holder is only sporadically using the spectrum. Smart radios can give priority to the primary license holders while making idle spectrum available to others. The big carriers love this policy when it allows them to dip into WiFi spectrum, but they don’t want to allow others to dip into their licensed spectrum.

Use It or Lose it. If coverage rules included a geographic test then we could easily identify areas where the primary license holder is not deploying spectrum. The FCC should either reclaim unused spectrum or else force the carriers to sub-license it to somebody who will use it. One easy change would be to require coverage maps for each deployment which would identify wireless dead zones – something that is easy with today’s software.

Dissuade Speculators. The FCC could require better proof of deployments including have a revenue test to uncover fake deployments that are for the sole purpose of maintaining licenses.