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CTIA Presses for more 5G Spectrum

It’s no surprise that the CTIA – the lobbying arm of the cellular carriers is making a big pitch for getting more spectrum for 5G. At a recent hearing of the U.S. Senate Committee on Commerce, Science and Transportation, Meredith Attwell Baker, the president and CEO of the CTIA made a pitch to senators to provide significant amounts of new bandwidth for 5G.

Specifically, the CTIA wants access to 400 MHz of mid-band spectrum, which is a giant swath of spectrum. The FCC already plans to auction off 70 MHz of 3.5 GHz spectrum, but it’s going to take a lot more spectrum than that to satisfy the CTIA’s request. The FCC is considering what to do with the 3.7 GHz band which will be the next block being eyed by the wireless carriers.

Atwell Baker supported the need for spectrum by saying that the wireless carriers are poised to invest $275 billion in 5G-related networks which will create 3 million new jobs and add $500 billion to the economy. The CTIA claims that 1.3 million of those jobs and $274 billion of the benefit will come from mid-range spectrum. That overall 5G investment claim sounds crazy to me when put into context. I’ve seen several estimates that the cost to build fiber to everybody in the country ranges between $60 billion to $100 billion. Why would the cellular carriers spend so much for a 5G network if every home and business could have a fiber connection to everybody for a third of the 5G cost? It’s likely that the figures cited by Atwell Baker are overinflated, as seems to be everything claimed for 5G. The jobs number is also overinflated and likely represents labor years, not permanent jobs since most of the jobs benefit from 5G would be temporary while networks and equipment are built. 5G is not going to be adding many jobs to the cellular carriers, and in fact they have all been cutting employees recently. For example, Verizon announced layoffs last year of 44,000 workers – 30% of its workforce. Verizon is not going to be hiring back those 44,000 employees as a result of 5G, let alone hiring ‘millions’ of employees.

Don’t take my skepticism to mean that 5G is not an important innovation, but the 5G hype has been ludicrously extreme starting with Qualcomm’s claim that the implementation of 5G is more important to mankind than the implementation of electricity.

Now that I see the CTIA asking for 400 MHz of spectrum I’m starting to think that the 5G hype has been part of a long-term plan by the cellular carriers to grab more spectrum. The wireless industry’s overhyped claims about 5G make it sound mandatory to repurpose most of our mid-band spectrum for 5G, regardless of other needed uses of the spectrum. Maybe the 5G hype has been nothing more than a coordinated landgrab for spectrum.

Of course, the cellular carriers won’t get the spectrum for free and any new spectrum will be auctioned. But there are only a few serious bidders for the spectrum, and if the FCC really makes big swaths of spectrum available then each of the big carriers should be able to get all the spectrum they want for a reasonable price. There won’t be any need for the wireless carriers to bid up auction prices if the FCC is going to make 400 MHz of spectrum available over time.

My problem with this landgrab for spectrum is that it doesn’t consider the other ways that spectrum could benefit the economy. For example, if we set aside large swaths of spectrum for rural broadband we could have wireless products today that could deliver speeds of hundreds of Mbps.

Wireless ISPs have floated several suggested ways that the FCC can satisfy the cellular carriers while also being able to use the spectrum for rural broadband. One of the best ideas is spectrum sharing where spectrum can be used for 5G in metropolitan areas while being repurposed for wireless broadband in rural areas. Unfortunately, the big carriers don’t want the distraction of spectrum-sharing if it means it will inconvenience them. Alternatively, the FCC could set aside a slice of each mid-range block specifically for rural broadband. That’s is not as good for 5G or rural broadband as sharing spectrum – but it would still improve rural wireless broadband.

It’s a lot easier for the big carriers to invent a 5G spectrum crisis than it is to work out spectrum solutions that help the whole country. Apparently the 5G hype is working because politicians from the White House to state houses seem to have accepted the need to make 5G a priority, making it easier to let the FCC give spectrum to the cellular carriers with no strings and no obligations to share spectrum. The cellular carriers have already won the public relations and political war.

The problem with just handing the spectrum to the cellular carriers is that it will eliminate any meaningful push for sharing spectrum for many decades. That will mean decades where a lot of rural America will not get the speeds they need to be part of the modern economy. Like any new technical idea, we are just at the beginning of developing ways to share spectrum and I have no doubt that over time that we’ll find ways to minimize interference. But we’ll never get a shot to try it if Congress or the FCC buys the cellular carrier’s 5G hype.

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Regulation - What is it Good For?

Chance to Comment on US Spectrum Policy

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.

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Current News Regulation - What is it Good For?

The Wireless Model City

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.