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.
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