Monday, July 22, 2013

When Sharing Spectrum May Not Be Progress

By Gregory J. Vogt
Visiting Fellow

Progress has been slow on the President’s announced policy to allocate 500 MHz of spectrum for wireless broadband use. It is still uncertain how much spectrum can be reallocated through the broadcast incentive auction. Other good sources of spectrum, however, are now used by government and could be relocated. In particular, the FCC, with vocal industry support, has expressed interest in reallocating 1755-1850 MHz for wireless broadband use because of its compatibility with existing wireless operations.
Although there are good arguments that the entire band should be reallocated over time, the government has a real opportunity to take near term action to move existing government operations and reallocate at least a portion of this band, 1755-1780 MHz. CTIA has requested that at least the lower 25 MHz of the 1755-1850 MHz band be reallocated in the near term, pending resolution of relocation issues in the upper part of the band. The government has already stated that this 25 MHz is ready for user relocation and spectrum reallocation, and this spectrum effectively can be paired with other available spectrum to create a viable spectrum block.
A recent bill to accomplish the prompt reallocation of this 25 MHz block has recently been reintroduced in the House of Representatives on a bipartisan basis. This is a welcome development.
Notwithstanding, recent government action seems to be backpedaling on the Administration’s goals. NTIA has cast significant doubt on whether the 1755-1850 MHz band can be reallocated due to existing uses and the alleged high cost of relocation. In fact, since the PCAST Report was issued most of the Administration’s effort has been promoting sharing of this spectrum, rather than reallocation.
Sharing may be viable in some circumstances, such as with the 1695-1710 MHz band where NTIA’s sharing recommendation is based on a limited number of exclusion zones. Although allowing commercial use in these types of circumstances is encouraging, the overemphasis on sharing of all government spectrum has serious drawbacks.  
First, there are significant delays inherent in the further studies and meetings contemplated by the June 14 Presidential memo encouraging agencies to explore sharing arrangements. And establishing necessarily complicated sharing arrangements between different types of spectrum users can take years to accomplish. The last time the FCC adopted spectrum sharing between different types of users, the white spaces proceeding, six years elapsed between the NPRM and the final rules. And then the databases necessary to effect the sharing took more than two additional years to be developed, tested, and approved.
Second, resolving engineering issues associated with sharing can produce even more difficulties due to divergent uses and limited public information. Most current uses affect national security or law enforcement, all of which are important and entail legitimate confidentiality needs. Use of the 1755-1850 MHz band includes satellite, air-to-ground, wideband fixed and transportable microwave, video surveillance, and other unspecified uses. If the white spaces sharing scheme produced serious complications between known uses and single incumbent user engineering parameters, how much more difficult would efficient sharing be with less than perfect knowledge about widely divergent uses with the attendant interference protection issues?
Third, sharing raises the costs of commercial operations.  Sharing between dissimilar users likely requires operation of interference protection databases, which themselves involve costs to establish, acquire agency approval, and continually update. Others have noted that costs increase with complexity, and the number of filings surrounding the white spaces database trials and approval process attest to these added costs.
Fourth, sharing can also affect the reliability of the commercial service, which can be degraded unpredictably by government use (some of the uses are temporary and mobile), which undoubtedly will have a higher priority status. Such potential unreliability is anathema to wireline broadband services, which are widely recognized as crucial to economic growth, innovation, and public safety.
Given the level of investment required to deploy broadband, as the Free State Foundation's Seth Cooper has previously identified, reallocation makes more sense than sharing on a permanent basis. But history proves that relocation and reallocation take time – almost always considerably longer than initial rosy projections. The most recent government spectrum reallocation of the 1710-1755 MHz block, took over eleven years from the time NTIA proposed reallocation until the spectrum was first auctioned. And that reallocation took an Act of Congress to ease relocation efforts and seven more years until the government completely stopped operations in the band.
This is not meant to discourage reallocation. To the contrary, it is intended to emphasize that the government has to improve its track record in order to achieve the Administration’s professed vision for wireless broadband on a timely basis.
CTIA’s approach to reallocate the 1755-1780 MHz block as promptly as possible seems to be a reasonable step that should be embraced. Long term sharing does not appear to be the best solution to meeting the broadband goal either for this 25 MHz or the entire 1755-1850 MHz block.