June 09, 2004

Short Summary of TV Spectrum Situation

This one-page document from the NTIA is excellent in its brevity and completeness.

The State of the Debate

I just got back from the Aspen Institute's inaugural roundtable on spectrum policy. Aspen brings together heavy-hitters from industry, government, Wall Street, and academia to hash out important policy issues. For the first time, spectrum was broken out separately from Aspen's broader communications policy program, recognizing its importance.

The comparison with the Aspen workshop I participated in two years ago was striking.

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June 08, 2004

New America on the Transition to DTV

Mail from the New America Foundation's Spectrum Policy group:

This Wednesday, June 9th, the Senate Commerce Committee will convene a 9:30 AM hearing on "Completing the Digital Television Transition," (). The Committee will hear testimony from spectrum policy experts, including the New America Foundation's Michael Calabrese, who will present a plan using targeted, consumer subsidies to rapidly complete the DTV transition, while also generating tens of billions of dollars against the deficit with the swift return of analog broadcast spectrum.
[...]
Building on the success of the nine-month Berlin, Germany DTV transition, the Issue Brief details how progressive consumer subsidies can quickly move the remaining 15% of U.S. households that only receive "over-the-air" broadcast TV to purchase inexpensive, set-top converter boxes to enable them to receive digital signals. By tapping less than 2% of the expected revenues from the auction of analog broadcast spectrum to pay for the subsidy, the politically tricky DTV endgame can be accomplished by the end of 2007, freeing up valuable spectrum for wireless broadband services and establishing a much-needed trust fund for the future of public television.

The proposal document is here (PDF).

The Philosopher's Stone of Spectrum

The battle over increasing unlicensed wireless spectrum is obviously more than just another FCC regulation. Most issues the FCC deals with, even contentious ones like limits on ownership, are changes within regulatory schemes. The proposal to move the maximum percentage of a market a media company could own from 35% to 45% took the idea of the ownership cap itself at face value, and involved a simple change of amount.

Unlicensed spectrum is different. In addition to all the regulatory complexities, there is an enormous philosophical change being proposed here. Because of advances in wireless technology, what spectrum is, at least in a regulatory setting, has been transformed, and the FCC is being asked to ratify that transformation.

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More Spectrum, But For What?

There is a crying need for reallocating spectrum from broadcast to two-way communication, and in general introducing a more rational and economically efficient spectrum management scheme. But how will this newly freed-up spectrum be used? We hear about all the innovative new services that will be created. But the main use of the additional spectrum will be--voice! (For quite a few years, anyway.)

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Abolish the FCC -- but for a different reason

Declan McCullagh's recent diatribe, "Abolish the FCC" is kind of right, but for some seriously wrong reasons. Declan observes correctly that the FCC has been fumbling the UNE-P issue, bumbling around the edges of censorship with Stern punishment, and crumbling computer functionality with broadcast flags. As Declan points out, the FCC is crimping the Constitution, cheating on its charter, overreaching it orders. But he misses the fact that all of these briar patches are application-layer issues. And in his resulting confusion, he erroneously looks to the physical layer -- the regulation of spectrum -- to "solve" app-layer problems.

Further, Declan discredits himself by choosing a real estate metaphor for spectrum, suggesting that a 6 megahertz TV channel could be handled, literally, just like a piece of real estate. So, he extends,

What if disputes over spectrum arose? The answer is simple. Whoever owned the rights to that slice of virtual real estate would locate the illicit broadcaster, march into the local courthouse and get a restraining order to pull the plug on the transmitter. Trespass is hardly a new idea, and courts are well-equipped to deal with it.
Simple? Too simple. Trespass and interference are not equivalent "crimes." Trespass is a deliberate act. But interference is not -- it is a characteristic of a receiver. If an ultra-high-tech receiver in Chicago receives a channel from St. Louis, the St. Louis station owner is not trespassing on the property of the Chicago station owner. There are just too many important cases where the real estate metaphor does not apply.

Also, the real estate metaphor is too limiting. It was a better fit in 1934 when the prevailing technology could provide selectivity only by frequency. But now we have listen-before-transmit, steerable directional antennas, dynamic power adjustment, frequency agility, multiple modulation techniques, addressable packets and packet relay. It is short-sighted, downright wrong, to stuff all of these -- and future improvements -- into a real-estate model.

Sure, the FCC is a bureaucratic agency that is executing poorly on its overly-diverse and expanding mission. But if it is to be abolished, it should be abolished precisely because spectrum is NOT property. When modern techniques like dynamic power adjustment and packet relay are used, spectrum can have properties of a commons -- a super-commons where there is no tragedy because there's enough for everybody. If there's enough for everybody, the need to regulate who gets what diminishes and eventually disappears.

The question remains whether the low-level technology is operating properly. So there's still a need for a Federal Device Commission. Because the Internet architecture creates a clean separation between the physical medium and the application by interposing Internet Protocol between them, the Federal Device Commission would have a much simpler task. It would regulate simply to provide unabridged freedom of speech and the press simply by regulating the well-specified physical-layer properties of devices.

How Low Can You Go?

Why does it matter that wireless capacity be freed up at low frequencies? And what is low, anyway?

A rough definition of "low-frequency" is below one gigahertz (1 GHz). That's where broadcast services operate today, taking up most of the allocated frequencies. There's a reason why these bands are referred to as the "beachfront property" of spectrum -- it's the easiest and cheapest place to build systems designed to reach large numbers of people.

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June 05, 2004

Cartoon Guide to Spectrum Policy (no, really)

The New America Foundation, publishers of Kevin's terrific Radio Revolution paper as well as a graphics-heavy presentation of a Citizen's Guide to the Airvaves, has now published a Cartoon Guide to Spectrum Policy, which describes the current limitations of spectrum policy in citizen-friendly terms.





It's a tool for getting your non-techie friends to understand both what's wrong with the way we allocate spectrum today and what's at stake for the future.

June 04, 2004

Some useful FCC comments

I've been looking at some of the comments filed in response to the 2002 NOI on using vacant TV channels for unlicensed Internet access.

Attention FCC! Your comment system needs an editor! It is not a flat space. The chairman of the audio committee of Podunk Baptist Church has a right to be worried about whether the wireless microphones that send sounds of worship to the back pews will work when besieged by hoardes of heathen Internet devices. But this is quite different than when Intel presents data to counteract specific NAB (National Association of Broadcasters) claims about interference, or when the IEEE Radio Regulatory Technical Advisory Group weighs in.

The FCC should hear from the public, and the FCC should weigh public opinion in making decisions, but there's got to be a better way than treating everybody's comments "equally" like they do here.

Powell: Let's break the broadband duopoly

Yesterday, FCC Chairman Michael Powell told the Wireless Communications Association:

Magical things happen in competitive markets when there are at least three viable, facilities-based competitors. And we are looking to wireless to help deliver that Triple Crown.

Powell's remarks centered on liberalizing regulation in a licensed 2.5 GHz band (the MDS-ITFS services), but this will occur in parallel with the vacant TV channel initiative, broadband over power line, and several other FCC initiatives. Powell's FCC is determined to do for broadband what PCS did for mobile telephony.

June 03, 2004

WiMAX Forum Joins the Fray

The WiMAX Forum has established a working group on global regulatory issues. The aim is to "ensure availability and global harmonization of 'WiMAX friendly' spectrum worldwide." The press release (PDF) is here.

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The New Communications Ecosystem

The movement to free up wireless capacity for innovative uses is part of a larger shift in the communications world. Services and business models are changing, but so are the players. The neat separation between "technology" and "telecom" companies is breaking down.

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June 02, 2004

Good for the Broadcasters Too

Why do incumbent broadcasters oppose unlicensed allocation of low-frequency spectrum? They could be some of the biggest beneficiaries.

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More unlicensed spectrum: What's not to like?

I'm ploughing through the original Notice of Inquiry, December 2002.

FCC Commissioner Kevin Martin's comments are downright discouraging. He says he's in favor of freeing up some new spectrum, but not THIS spectrum.

He's afraid that the new uses for TV spectrum might slow the transition to Digital TV. He writes:

I fear that these unlicensed devices will create additional interference problems when digital television gets underway. Interference already threatens to impede the introduction of digital television. Although digital television stations have begun operating only in the last twelve months, we have received several reports of interference problems. For example, we are currently adjudicating a claim that a digital station in Norfolk, Virginia (WHRO-DT) is causing interference to an analog station in Salisbury, Maryland (WBOC-TV).

Then Commissioner Martin questions the benefits of the proposal. Then he questions the timing.

Martin's comment on the NPRM, May 2004, is short and tepid too, even though the NPRM goes a long way towards addressing his concerns with the earlier NOI.

Note that in neither case does Martin suggest where alternative spectrum might be found.

I suspect that his bottom line is that TV trumps Internet. He must not be watching much TV lately. Or using the Internet enough.

The Economics of Connectivity

One of the key differences between traditional wireless networks and unlicensed systems such as WiFi is the way they distribute costs. It's not just a question of cheaper or more expensive. Who pays, for what, and at what point can determine adoption patterns more than the aggregate level of spending.

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