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March 1, 2011

Spectrum is abundant

Elliot Noss, CEO of Tucows, has adopted a quirky and admirable approach to submitting filings to official bodies looking for comments on policies. Rather than writing the traditional legalistic brief, he has been commissioning pieces more readable by the non-lawyerly. I wrote an essay for him on copyright, and he’s just submitted and posted a second one by me on spectrum policy. [Disclosure: 1. Elliot is my friend. 2. He offered to pay me for writing this.]

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May 22, 2010

Understanding spectrum

Christian Sandvig explains spectrum and spectrum policy in this Radio Berkman interview.

Christian — who is both brilliant and a wonderfully generous colleague — textifies the main points here.

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March 8, 2010

Harold Feld explains spectrum

Harold Feld is one of my favoritist writers about the FCC, telecommunications, spectrum, and the whole enchilada. He has posted a piece that explains the intricacies of some recent spectrum policy announcements. It matters a whole lot.

This is not to say that Harold’s post is easy. It unpacks lots, but there’s lots packed in there. Skip to the first subheading for the Explainer part of the piece, and then keep going. And, bear in mind that Harold is partisan and admits it. Which I like. (I also find it refreshing when Brooke Gladstone in passing interjects where stands on an issue.)

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January 5, 2010

Department of Justice on a weakness of auctions. Susan Crawford comments.

The Department of Justice has filed comments on the FCC’s broadband plans. Susan Crawford, ex of the White House, blogs her reaction. For me, the most interesting of Susan’s comments is:

Re-allocation of spectrum makes sense. But the “foreclosure value” to market-powerful incumbents of buying that spectrum – and keeping their competitors from buying it – may exceed its market value. So DOJ very gently (with lots of caveats) suggests that the highest value use for new spectrum may actually be to make it available for license by new rivals.

This refers to this in the DoJ comments:

The goal in assigning licenses to any such new spectrum designated for commercial services should be to ensure that it generates the greatest ultimate benefits to the consumers of those services. When market power is not an issue, the best way to pursue this goal in allocating new resources is typically to auction them off, on the theory that the highest bidder, i.e., the one with the highest private value, will also generate the greatest benefits to consumers. But that approach can go wrong in the presence of strong wireline or wireless incumbents, since the private value for incumbents in a given locale includes not only the revenue from use of the spectrum but also any benefits gained by preventing rivals from eroding the incumbents’ existing businesses. The latter might be called “foreclosure value” as distinct from “use value.” The total private value of spectrum to any given provider is the sum of these two types of value. However, the “foreclosure value” does not reflect consumer value; to the contrary, it represents the private value of forestalling entry that threatens to inject additional competition into the market.

This is one of the places where pure market forces (whatever that means since we’re already talking about a highly constrained and artificial auction) can work against the social values we’re trying to achieve. I hope the Omnibus Broadband Initiative folks receive the DoJ’s gentle hint as if it were delivered with a 2×4.

[Self-serving:] (I have been posting interviews wit the Broadband Initiative folks at Broadband Strategy Week.

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December 7, 2009

Google pushing for open spectrum

Kevin Fitchard at TelephonyOnline reports that Google’s Vint Cerf is pushing for open spectrum among mobile operators.

Vint Cerf, Google’s chief Internet evangelist, is advocating a policy of spectrum sharing among operators. At the Open Mobile Summit, Cerf said that new modulation schemes in wireless would allow for the simultaneous occupation of the same spectrum by multiple parties, making the notion of a single operator/single license obsolete. For instance, orthogonal frequency division multiplexing access, which is the basis for WiMax and long-term evolution, abandons the notion of a single wide channel and instead splits a band into multiple sub-channels or tones, which could be used to dynamically create channels of varying widths. By tweaking the technologies already in development today for multiple entities, the industry could make a huge leap forward in more efficiently utilizing public spectrum resources, Cerf said.

An open spectrum policy would allow transmitters and receivers to decide in real time which frequencies to use, rather than assigning them frequencies ahead of time. This would enable more efficient use of spectrum, so long as the technology is capable of doing the real-time negotiating. It would also royally piss off carriers who have paid tons of money — billions — to buy allocations of spectrum.

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December 2, 2009

FCC moving on “white spaces” to make more spectrum usable

Harold Feld has a great post on movement at the FCC to make more spectrum available.

According to Harold, the FCC has requested proposals for databases to manage access to the “white spaces” between the frequencies assigned to TV stations. Those frequencies were left unused because analog TV originally needed lots of room between frequencies, which is why your analog stations tend to count by two’s. Plus, the switch to digital TV opened up some more frequencies. So, last year, the FCC voted 5-0 to make those frequencies available for unlicensed use. This will provide more room for innovation. It’s a very big deal.

The white spaces will be made available for fixed band devices, as well as for lower-power ad hoc usage. But, how will a device maker know what slice of spectrum is available? One approach would be to count on smart devices sensing which bands are uncongested and dynamically switch to them. But the FCC says that the sensing devices are not yet reliable enough. So, it is creating a database of white space spectrum usage. And it is allowing others to create databases as well. Those who create databases will be allowed to charge for allocating fixed spectrum and for accessing the database.

So, who gets to build and maintain these databases? How will they make money? How will they ensure accuracy? These and other questions are being left up to those who submit proposals. Harold Feld considers this to be a “good but weird” approach, since usually the FCC lays out the specifications before asking for proposals.

By the way, Harold’s preferred approach:

From my perspective, the most logical model is a non-profit operating on a non-exclusive basis and funded by the industries that benefit. The actual cost of running and managing this is pocket change to the likes of Google, Microsoft and Motorolla (which came up with this scheme in the first place). We shall have to see if they are that enlightened. But whoever is selected, it is important for the FCC to maintain a level of oversight that would prevent this from morphing into a bottleneck at some point in the future. Frankly, this is another reason why a coalition or non-profit with multiple stakeholders would be preferable to a single vendor/manager.

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February 13, 2009

Things you can’t do with real estate

David Reed blogs about recent research on “practical ways to construct EM (radio) waves with new, complex 3D structures that propagate while maintaining that structure, not necessarily in spherical or cylindrical shapes.” I am not even close to understanding the physics, but, as David writes, this sort of possibility makes it clear how foolish it is to regulate the airwaves as if they were real estate that has to be divided up into slices that are awarded as monopolies to the highest bidder. David writes:

… the policy issue is that such systems for multiplexing such EM fields don’t fit the “law of the land” regarding sharing the medium. So, like UWB [ultra wideband] and spread spectrum underlay, and white spaces, all that capacity will evaporate in attempting to fit the technology into the procrustean bed of the FCC’s “property rights in spectrum” legal framework.

The “property rights” model of spectrum allocation and radio regulation is based on physics-by-analogy, ignoring the reality of propagation. It’s time to end the ignorance of economists and lawyers, and replace physics-by-analogy with better physical analysis.

Or, to put the analogy the other way, if real estate operated the way energy and information do, the little slice of beach front you’re charging $5,000 a night for would go from having room for four honeymooning couples to being the 127 miles of the New Jersey coastline and simultaneously a set of holiday villas in Brazil, just because a Swedish scientist found some new way of twisting it around. In such a case, the FCC (Federal Coastal Commission) would probably want to rethink its rules for allocating beachfront properties. [Tags: ]

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December 17, 2008

Radio Berkman podcast: Free, national, and for five-year-olds

In this week’s Radio Berkman podcast, I interview Stephen Schultze about the FCC’s auctioning off spectrum to a national provider who would be required to use 25% of it for free, nationwide wifi. There’s only one catch: That wifi would have to only connect to sites and services that are safe for minors (defined as people between 5 and 18).

After we had recorded this interview last week, the FCC postponed voting on the proposal, and since it’s the baby of the outgoing Chair, it’s probably postponed forever. Still, the idea raises some really interesting issues. Steve and I focus on the free speech considerations, although the opposition from other spectrum-holders certainly could not have encouraged the FCC.

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November 4, 2008

FCC approves unlicensed White Spaces

The FCC has approved unlicensed use of the White Spaces. This frees up spectrum for innovation. See Harold..

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August 19, 2008

Free the white space

Google is taking to the public in its lobbying of the FCC to make the “white space” available for wireless broadband. This is the space between designated channels. Right now, we use it as sort of bowling alley gutter bumpers between assigned frequencies, but given modern technology, we can make better use of it, if only we’re allowed to.

Google has a form for sending a message to the FCC, as well as some useful explanatory materials…

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