Unlicensed Spectrum

Notice of Oral Ex Parte Presentation

Wireless Future — Thu, 20 Mar 2008 06:22:00 -0400

Marlene H. Dortch
Secretary
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554

Re: Notice of Oral Ex Parte Presentation in OET Docket No. 04-186

Broadcast to Broadband

Ron Tang — Sat, 01 Mar 2008 00:00:00 -0500

Although much public attention has focused on the US digital TV transition -- and the resulting reallocation of analog TV channels by auction to wireless carriers -- the US Federal Communications Commission will decide how to reallocate an even larger swath of prime TV band spectrum this year: the unused “white space” between occupied DTV channels. This reallocation of unused spectrum from broadcasting to broadband permits unlicensed access for both fixed and mobile applications.

In 2002, the FCC’s Spectrum Policy Task Force recommended that spectrum efficiency and innovation could be enhanced by reallocating unused and underutilized spectrum for both flexible-use licenses (by auction) and opportunistic use by smart-radio devices capable of sharing bands on an unlicensed basis.

Shortly after this report, the FCC surprised almost everyone by issuing a Notice of Inquiry asking for comment on the feasibility of reallocating the TV white space for advanced wireless services. In May 2004, under then-chairman Michael Powell, the FCC issued a Notice of Proposed Rule Making (NPRM), tentatively concluding that opening at least some of the vacant channels for unlicensed access would be feasible and beneficial.

Although this policy is strongly supported by high-tech companies and consumer advocates, it’s just as strongly opposed by broadcast licensees and other incumbent users of the TV band.

The opposition is primarily led by the band’s incumbent licensees -- the US National Association of Broadcasters (NAB) and wireless microphone makers and users (such as the sports leagues and entertainment venues that intermittently use white spaces). The NAB refers to white spaces as “interference zones,” and broadcasters agree because they feel mobile broadband devices, even operating at low power, would inevitably interfere with DTV reception and microphone systems. The NAB and its engineering affiliate, the Association for Maximum Service Television (MSTV), have filed studies showing that Wi-Fi-type devices could cause both co-channel interference (if they can’t reliably detect a DTV transmission in a given location) and adjacent-channel interference (the unlicensed device’s transmission could leak and disrupt DTV reception).

In contrast, high-tech firms and consumer groups have argued that a variety of proven technologies are capable of avoiding interference with DTV reception. Intel, Dell, Microsoft, Google, and other members of the high-tech White Spaces Coalition argue in their filings that because proven technologies exist for detecting and avoiding DTV signals, barring mobile devices represents an enormous loss for consumers and potential broadband innovation.

For its part, the FCC has consistently assumed that several technologies are capable of ensuring that white-space devices can identify vacant channels in a local market and operate without interfering with DTV reception on neighboring channels (or in neighboring media markets). In its 2004 NPRM, the FCC’s Office of Engineering and Technology (OET) described three different approaches that white space devices could use to avoid such interference:

Geolocation / database. In this scheme, the unlicensed device (such as a wireless ISP access point) would use a GPS receiver to cross-check its own location against an online database of licensed TV transmitter locations.
Beacon permission. An alternative approach, aimed at allowing networks of mobile devices, would require that an unlicensed device not transmit unless it receives a “green light” signal indicating that the specific channel is free to use in that locality.
“Listen-before-talk” sensing. Another approach strongly favored by the high-tech company coalition would require that each individual device scan and identify unused TV channels before transmitting (with the accuracy enhanced by sharing sensing data with other devices in range)...

For the full text of Calabrese's article, please see the PDF attached below.

Defense News Quotes J.H. Snider on Shared Spectrum, DARPA

Communications — Mon, 16 Apr 2007 20:40:00 -0400

The warnings are dire: The number of available radio frequencies is declining, say U.S. government officials, and with it the Pentagon’s ability to introduce new communications technology...But a seven-year-old firm a stone’s throw from the Capital Beltway says it can harness “white space” in the spectrum to provide interoperable communications. The 30-employee firm, Shared Spectrum, had 2006 revenues of “about $8 million to $9 million” and expects about the same this year...In a test last summer by the Defense Advanced Research Projects Agency (DARPA) at the U.S. Army’s Fort A.P. Hill in Virginia, Shared Spectrum demonstrated that it could send data on frequencies being used by other nearby radios without interference...Shared Spectrum is developing a follow-on radio with partner M/A-COM, a unit of Tyco Electronics and a provider of wireless radio, microwave and millimeter-wave components. They are working together on DARPA’s “Wireless After Next” project, which seeks a radio for less than $500...One wireless policy observer, J.H. Snider, who directs research at the Washington-based New America Foundation’s Wireless Future Program, has criticized other attempts by commercial interests to use spectrum white space. But in an e-mail, he was positive about what Shared… more

J.H. Snider on White Space Spectrum in Broadcast Engineering

Communications — Mon, 19 Mar 2007 21:05:00 -0400

A coalition of major technology companies continue to aggressively lobby federal officials to use the white space spectrum between television broadcast channels, for wireless consumer devices as well as new Internet access. Now, with critical technology beginning to be tested by the FCC, the stakes are raised for broadcasters, production companies and Internet service providers...Using unlicensed white space spectrum is a politically charged issue in Washington because of the perceived threat of competition it holds for the powerful telecom and cable television companies. Broadcasters are worried about interference with their transmissions, and production companies fear their wireless mics and other equipment will be stepped on..."The telephone companies are terrified they'll lose 40 percent of their wireless minutes, because you'll be able to connect from work or home and bypass their wireless networks," J.H. Snider told MarketWatch. Snider is research director of the wireless future program at the New America Foundation, a Washington-based policy institute that has long advocated allowing use of white spaces...

For the complete article, please visit the Broadcast Engineering website.

J.H. Snider on Microsoft's Wireless Prototype in Dow Jones Marketwatch

Communications — Fri, 09 Mar 2007 14:51:00 -0500

SAN FRANCISCO (MarketWatch) -- When Microsoft Corp. delivers a mysterious prototype for government testing this coming week, it will mark a crucial juncture for a high-stakes bid to change the way consumers get their Internet access. That bid has cast Microsoft and a group of powerful allies from Silicon Valley in the relatively unfamiliar role of Washington policy players. Microsoft's (MSFT) prototype, delivered on behalf of the group, is a wireless device that could provide the public with free and more widespread access to the Web instead of relying on networks owned by big telecom and cable firms. That breakthrough, tapping into an unused part of the nation's airwaves, is politically charged because it threatens to shift the Internet-access business away from telecom and cable companies that are historically well-connected in Washington, throwing open the field to a brand new batch of competitors.It all hinges on how well the prototype performs in tests by the Federal Communications Commission. Microsoft and allies must prove that such devices, which can connect users via unlicensed portions of the nation's wireless spectrum known as white spaces, won't interfere with airwaves that major license holders acquired for… more

J.H. Snider Explains Spectrum Auction's Promise to the Associated Press

Communications — Fri, 27 Oct 2006 23:44:00 -0400

The last time a company run by Allen B. Salmasi was a top bidder in a government airwaves auction, it took eight years and the Supreme Court to unravel the mess that followed.

Now he's back.

Salmasi controls AWS Wireless Inc., one of the leading bidders in the airwaves auction currently under way.

The auction is expected to raise up to $15 billion and increase by half the amount of spectrum available to the mobile wireless industry. The expansion is large enough to create new competitors, improve service for existing customers and allow for new features, like streaming video.

In 1996, Salmasi was chairman and CEO of NextWave Telecommunications Inc., when the company bid a record $4.74 billion to buy the rights to 95 spectrum licenses. It was a large enough chunk of the public airwaves to provide coverage for nearly 94 million potential cell phone users.

Unfortunately, the company couldn't make its payments and filed for bankruptcy. The Federal Communications Commission repossessed the licenses and re-auctioned them for about $16 billion. NextWave claimed its bankruptcy protected the company's hold on the licenses, and eventually the Supreme Court agreed.

In 2004, NextWave and the FCC reached a settlement, ending the dispute and freeing the extraordinarily… more

J.H. Snider on the FCC's Spectrum Decision in the Los Angeles Times

Communications — Fri, 13 Oct 2006 23:45:00 -0400

WASHINGTON — The Federal Communications Commission on Thursday struck a compromise that would give technology companies some access to the white space between television channels while addressing broadcasters' fears that new gadgets could interfere with their signals.

Under pressure from Congress, the FCC took the first step toward allowing fixed wireless devices, such as broadband receivers in homes, to use most of the vacant channels in any given market after the digital TV transition in February 2009....

A major telecommunications bill pending in the U.S. Senate calls for the vacant white space spectrum to be opened to unlicensed devices and directs the FCC to develop rules for use of the spectrum within 270 days of the bill's passage. The pressure forced the FCC to act, said J.H. Snider, research director for the Wireless Future Program at the New America Foundation, a nonpartisan think tank.For the complete article, please visit the Los Angeles Times website.

RCR Wireless News Quotes J.H. Snider on Secrecy, Delays in Spectrum Policy Reform

Communications — Fri, 13 Oct 2006 19:21:00 -0400

WASHINGTON -- Nearly two years after President Bush authorized the creation of an advisory committee as part of spectrum policy initiative launched in 2003, the National Telecommunications and Information Administration has yet to disclose identities of members, whether any meetings have been held or explain what progress has been made on White House-driven spectrum program that from the beginning has been shrouded in secrecy and yielded few tangible results to date....

One think-tank scholar said NTIA's handling of the advisory committee is symptomatic of a broader spectrum management issue and raises questions about the Bush administration's commitment to take on tough spectrum reform challenges.

"The delays and secrecy associated with setting up the advisory panel are indicative of a much larger problem of delay and secrecy in bringing accountability to federal use of spectrum," said J.H. Snider, research director of the New America Foundation's Wireless Future Program.

Snider was a candidate for the advisory panel, but apparently was passed over.

"The administration and much of industry knows there is serious mismanagement of federal spectrum. But the administration faces a dilemma," said Snider. "On the one hand, it wants to avoid political heat by saying it is doing something about the problem. On the other… more

J.H. Snider Discusses Unlicensed Spectrum in Government Technology

Communications — Thu, 12 Oct 2006 01:36:00 -0400

When do we recognize a shift in the fundamental social fabric of civilization? Where do we look to find better exemplars of participatory democracy? When do we realize that notions of justice have to expand to include a new ways of thinking about human rights? How do we change our institutions to support a more just and equitable world? These are the questions that thought leaders in the community and municipal wireless movement have been asking themselves more and more over the past few years.

Many telecommunications scholars have written that the first decade of the 21st Century is a "critical juncture" in communications history....

However, certain tools were consistently mentioned by those interviewed for this series as useful to digital inclusion efforts -- "more unlicensed spectrum," "low-cost hardware," and "education initiatives" for the general public and local, state, and national policy makers were all discussed by multiple interviewees. As Jim Snider, Senior Research Fellow at the New America Foundation, warns, for wireless systems, "the network can ultimately only be as good as the spectrum it uses." Many thought leaders see one promising avenue as the growing support for "bipartisan legislation in Congress to open up the TV white spaces for… more

J.H. Snider Comments on Efforts to Curb White Space in Policy Tracker

Communications — Fri, 15 Sep 2006 16:27:00 -0400

Critics are skeptical of the proposals arguing that the fact that the ">projected schedule released on September 11, came just a day ahead of FCC Chairman Kevin Martin’s confirmation hearing before Congress is cause for concern. ‘On the one hand we believe that this is largely a manoeuvre to defang Congress and shift the battle back to the FCC where the TV "white space" initiative can be further delayed and ultimately even killed,’ says J.H. Snider, Research Director of the New America Foundation’s , Wireless Future Program. Pressure on Congress is being brought to bear by companies like Microsoft, Intel and to some extent Cisco which have an interest in using this spectrum.

Proposals for the use of unlicensed devices in the broadcasters’ unused spectrum or so-called “white space” were put forward by the last FCC administration. The objective was to replicate the success of WiFi but with longer range. The spectrum below 900 MHz is desirable because of its propagation characteristics; it travels through walls and signal quality extends much further.

This project apparently ground to the halt under Martin who is criticised for having no interest in spectrum or in creating controversy. ‘It is noteworthy that this FCC initiative… more