Report Highlights Link Between Spectrum Policy and National Security

A new report published by the Center for Strategic & International Studies (CSIS) warns that absent a heightened focus on our national spectrum policy, "[t]he security of the United States as a market democracy is at stake." In the simplest of terms, online activity is only as secure as the underlying apps and network infrastructure over which it occurs. If that software and hardware is to come from trusted sources, policymakers must foster an environment in which America's mobile marketplace maintains a powerful say in global technology development, "especially as autocratic nations seek to dominate."

In Part 1 of "Concrete National Security Benefits of Spectrum Allocation for Commercial 5G," CSIS Strategic Technologies Program Senior Fellow Clete Johnson identifies two "difficult technical feats" that the U.S. must and can accomplish if it is to achieve the scale necessary to drive technology development down a secure and trusted path. The first is to better harmonize frequency use, as "[t]he more that U.S. spectrum use is harmonized with that of allies and global markets, the more scale trusted suppliers have for secure technology development." The second is to allocate sufficient spectrum so that capacity does not constrain the economic might of American consumers.

Harmonizing the frequencies allocated to 5G (and successor standards) is essential to achieving economies of scale because technology development is frequency specific: equipment developed for one band typically cannot be used in other bands. As the report points out, however, "the United States is becoming a mid-band spectrum 'island,' operating largely outside the core globally harmonized spectrum bands. If this trajectory continues, the U.S. technology ecosystem will be confined to a U.S.-only spectrum 'dialect' that lacks global influence and scale."

Allocating sufficient spectrum to satisfy growing mobile broadband demand, meanwhile, maximizes the economic ability of 350 million American consumers to shape global technology decisions. As the report explains:

U.S. wireless companies need sufficient spectrum resources to collaborate with like-minded nations in innovating and manufacturing advanced wireless technologies and components – including chipsets, software, radios, and more – for use in both the commercial and federal sectors…. The existing disparity between U.S. licensed mid-band spectrum allocations as compared to the rest of the world has become a major national security challenge, as it has created a platform for China to shape the near-term and future technology environment to its strategic advantage.

The report proposes several ways to address this situation. They include:

• Reframing the spectrum deficit as "an optimization challenge, not a scarcity problem."
• Moving from a "zero-sum" mindset that pits government and commercial uses against each other to a collaborative environment that promotes "static" and, in the longer term, "dynamic" spectrum sharing solutions.
• Restoring the FCC's spectrum auction authority.
• Aggressively pursuing harmonization opportunities, which may include the 7/8 GHz band, so that America speaks the same "frequency 'language'" as its allies.

The report's forthcoming Part 2 primarily will focus "on the importance of agile spectrum management capabilities in the context of electronic warfare."

FCC Issues 2.5 GHz Spectrum Licenses, But Agency Still Needs Auction Authority

On February 29, 27, and 1, the FCC granted long-form applications to wireless providers, including T-Mobile, for several thousand spectrum licenses in the 2.5 GHz band won in Auction 108.  

The results of Auction 108 were announced way back in September 2022. Yet the Commission's authority to conduct spectrum license auctions lapsed in March 2023, and Chairman Jessica Rosenworcel has determined that the lapse of that authority prevented the agency from issuing those licenses. At the end of last year, Congress passed the 5G Sale Act, conferring on the FCC a 90-day window to grant licenses won in Auction 108. The Commission's February orders granting the 2.5 GHz band licenses were based on the Act.

 

It is welcome news that parties who successfully bid on spectrum licenses at auction receive the licenses they won and paid for. Also welcome is the news that more mid-band licensed spectrum finally will be put into use for commercial wireless services as a result of Auction 108. However, the lapse in FCC spectrum license auction authority remains, and there also remains a shortage of licensed spectrum for supplying growing wireless data demands on 5G and future 6G networks. Spectrum allocation and harmonization by the NTIA, FCC, and other agencies is a priority. But it also is necessary that Congress spectrum license auction authority to the Commission. 

 

For more on what Congress needs to do, see Senior Fellow Andrew Long's July 2023 blog post, "Congress Should Reinstate the FCC's Spectrum Auction Authority," as well as his August 2023 blog post, "Commissioner Carr to Congress: Renew FCC's Auction Authority."

Report: More Licensed Commercial Spectrum Needed to Avoid Looming Deficit

On April 17, CTIA publicly released a report by the Brattle Group, "How Much Licensed Spectrum is Needed to Meet Future Demands for Network Capacity?" This interesting report, which is worth reading in full, presents a scenario regarding macro cellular wireless networks that Congress and federal agencies ought to take very seriously:

We find that if no new spectrum bands are allocated for terrestrial mobile use in the next 5 years, then the U.S. is expected to have a capacity deficit of roughly 10 exabytes per month and a spectrum deficit of roughly 400 megahertz. In ten years, without new mobile spectrum, the capacity deficit will increase to almost 17 exabytes per month and the spectrum deficit will more than triple to approximately 1,400 megahertz.

The Brattle Group's report includes a brief overview analysis of why, in their view, possible technical solutions to reduce or avoid such a spectrum deficit, including Wi-Fi offloading, increased spectral efficiency, and construction of more physical facilities such as towers and small cells will be inadequate means to accommodate growing mobile data traffic demand. Indeed, the report includes the Brattle Group's projection that mobile data traffic in North America will increase from 5,846 petabytes (PB) per month in 2022 to 33,918 PB per month in 2032. 

 

The report's prescription for more commercial licensed spectrum availability is spot on. On the same day of the report's release, the Free State Foundation filed public comments with the NTIA for its Development of a National Spectrum Strategy proceeding. Those comments called attention to the empty spectrum pipeline and called for the repurposing of at least 1,500 MHz of mid-band spectrum for licensed commercial use.