Friday, October 21, 2011

4G Wireless Future Requires Rapid Action to Make More Spectrum Available

On October 17, NTIA issued its Second Interim Progress Report on the Ten-Year Plan and Timetable. NTIA is coordinating an interagency effort to meet the President's goal of making 500 MHz of spectrum available for commercial use by 2020. This effort includes the goal of making 115 MHZ available by 2015 through a fast track evaluation of certain priority spectrum bands.

More spectrum needs to be repurposed and auctioned by the FCC for commercial use to accommodate the continuing increase of mobile wireless and mobile broadband usage. With the ongoing roll-out of 4G wireless networks, data-rich mobile wireless traffic will continue to skyrocket. Prior history regarding FCC spectrum auctions suggests an inevitably lengthy turnaround in identifying spectrum preparing it for auction. Not to mention the additional time it takes for prospective auction-winning wireless carriers to construct and calibrate their networks for commercial wireless service. This means that time is not a luxury that Congress, NTIA, or the FCC can afford in implementing the plan.

I made many of these same points in discussing NTIA's spectrum identification and reallocation plan in a November 2010 blog post titled "Calling for Speedy and Purposeful Action on the Spectrum Plan." As I wrote in my prior post, "[i]t is critical that federal agencies — and NTIA and the FCC, in particular — act with seriousness of purpose and speed in reallocating and auctioning new spectrum for commercial use."

At the same time, I also observed that NTIA's initial "Fast Track Evaluation" of spectrum left out the 1755-1780 MHz band. NTIA acknowledged that the 1755-1780 MHz band "is harmonized internationally for mobile operations, wireless equipment already exists, and the band provides signal characteristics advantageous to mobile operations," making it highly sought after by wireless carriers. But NTIA also insisted there was not enough time to complete its analysis and transition plans regarding that spectrum in time for its October 2010 report. This led me to insist that "NTIA must live up to its word in treating that slice of spectrum as a priority" and "demonstrate its seriousness of purpose by getting its "Fast Track Evaluation" of the 1755-1780 MHz band completed, and fast."

Now with the release of the Second Interim Progress Report, the good news is that positive steps have been taken. As described in this latest Report, this year NTIA established a priority ranking for evaluating particular spectrum bands. And the agency "commenced a detailed analysis of the 1755-1850 MHz band," which it now considers "the highest ranked priority band for repurposing."

NTIA identifies sixteen different federal agencies utilizing over 3,000 frequency assignments in the 1755-1850 MHz band for a variety of functions. Those agencies have submitted information to NTIA regarding timelines and costs for their respective relocation that would free up that spectrum for future commercial use. NTIA now promises a separate report in November summarizing its study of the band and making recommendations regarding the reallocation of the spectrum.

Interagency reviews delayed the initial release of NTIA's "Ten-Year Plan and Timetable." Hopefully, those agencies' respective cost and timeframe estimates will not be unreasonable and will allow NTIA, for its part, to act expeditiously in preparing the 1755-1850 MHz band for commercial use. Persistence is imperative every step of the way.

Among other things, the Second Interim Progress Report points out that in June an advisory group to NTIA recommended consideration of the 5350-5470 MHz band for expanding unlicensed Wi-Fi access. As NTIA explains, "[u]nlicensed Wi-Fi has become a significant component of commercial wireless services by allowing the offloading of data, thus saving capacity on commercial wireless network[s]." Obviously, auctioning is not required in reallocating spectrum for unlicensed use. But preparatory work would nonetheless be required. According to the Report, to ensure compliance with existing spectrum use rules and to protect co-channel and adjacent use, "NTIA, FCC, federal agencies, and industry would need to determine the feasibility of expanding" unlicensed Wi-Fi into the 5350-5470 MHz band.

NTIA doesn't specifically identify agency or interagency action on the 5350-5470 MHz band in the Second Interim Progress Report's table of planned and ongoing actions. One must hope, however, that that work is already underway. Given the current state of technology, it is generally preferable to license and auction spectrum to better ensure such spectrum is put to its best and highest use. However, the unique characteristics of certain bands can make unlicensed spectrum a helpful compliment to existing wireless services using existing licensed spectrum. Making more unlicensed spectrum available for Wi-Fi access to help relieve network congestion and improve capacity is an excellent idea and must be pursued for feasibility.

A vibrant 4G wireless future depends upon the availability of more spectrum to handle the growing demands of wireless consumers. Once again, when it comes to identifying and reallocating additional spectrum for commercial use, NTIA, the FCC, and all federal agencies involved must act with a renewed sense of urgency and purpose in implementing the spectrum "Plan and Timetable." Leading the way, NTIA must continue to act promptly in reallocating the 1755-1850 MHz band and other spectrum bands for licensed commercial use. And all agencies involved should likewise act with speed in examining and potentially reallocating the 5350-5470 MHz band for unlicensed Wi-Fi use.