On July 11 the FCC and the National Telecommunications and Information Administration (NTIA) issued a joint Public Notice seeking comments on the creation of an urban test city to explore new ideas concerning spectrum. They refer to this as creating a Model City where it will be possible to have significant trials of spectrum sharing and other ways of stretching the existing wireless bandwidth. The two agencies are involved because the FCC oversees commercial spectrum and the NTIA the government spectrum.
I don’t think you can find anybody who is a big fan of the current spectrum rules. The FCC has tried to satisfy everybody, and by doing so has carved spectrum up into little discrete slices, most of it further subdivided into channels. There is a mix of side-by-side spectrum used for government purposes, spectrum used for commercial purposes and free spectrum. The result of the current spectrum policy is two-fold. First, in any given market there is a lot of bandwidth that is not used at all or is massively underutilized. Second, breaking a lot of the spectrum into channels makes it hard to deliver the wireless bandwidth that is needed today.
The FCC and the NTIA are hoping to find if there is some way to share spectrum among users such that the unused or underutilized spectrum in an urban area gets used to its potential. Today there are bands of spectrum, such as for cellular phones and WiFi that are full to bursting while other nearby spectrum sits mostly empty. The FCC has been trying to create new open swaths of spectrum by emptying out the underutilized pieces of spectrum and then reallocating them for other uses. However, the President’s Council of Advisors on Science and Technology has issued a report saying that this not a sustainable policy due to the high costs and lengthy time needed to implement change.
So this Public Notice is looking for suggestions about how to create a Model City where some new technological ideas can be tried, mostly having to do with spectrum sharing. The FCC has a process today for allowing limited trials of various kinds using spectrum, but these kinds of trials are not easy to arrange if they cross too many different bands of spectrum. So the concept is that a Model City will make it easier to test technologies since the spectrum owners in the market, commercial and government, will have agreed to allow trials that cross spectrum boundaries.
It is a great goal and I hope they can find some way to make this work. But there are a lot of impediments. Consider some of the following:
- The FCC in the most recent decade has been auctioning spectrum, and the buyers of that spectrum are not going to let others encroach on their investment unless there is some method of fair compensation for it.
- In the wireless world we have always had a catch-22 between the use of a spectrum and the availability of radios that can use the spectrum. When a new band of spectrum becomes available, the wireless equipment vendors won’t spend the money to develop radios until somebody is ready to place a large order. And nobody is ready to place a large order for equipment until they are positive that it will work. This dilemma was the primary killer of both the LMDS and the MMDS spectrum that the FCC auctioned off in the 90s.
- I’ve read several articles lately from engineers who say that the FCC is far too cautious about trying to avoid interference in spectrum use and that there are techniques that make it easier to avoid interfering with other providers. But from experience I can tell you that when interference raises its ugly head that it can be a catastrophe for a commercial provider. Spectrum sharing sounds good in principle, but interference is always going to be a concern. The last thing we want is to find are problems in the spectrum used for fire and safety or other critical uses.
- The agencies hope that this can be done without federal funds. It will be interesting to see who might step up to pay for this. Certainly the large cellular companies might since they would probably be the biggest beneficiaries of spectrum sharing. But they are also the ones who have paid for a lot of their spectrum, which might make them leery of the idea.
So there are a lot of issues to deal with and the FCC and NTIA are asking to hear about all of the problems that must be overcome to make this work. Our spectrum is mess, particularly in urban areas and so this is a trial worth undertaking. I look forward to reading some of the proposed ideas and solutions for tackling our spectrum in a different manner.