[By Phil Bellaria, Director, Scenario Planning, and John Leibovitz, Deputy Chief, Wireless Telecommunications Bureau]

Apple’s iPad announcement has set off a new round of reports of networks overburdened by a data flow they were not built to handle.  These problems are reminiscent of the congestion dialup users experienced following AOL’s 1996 decision to allow unlimited internet use.  For months users had trouble connecting and, once they did connect, experienced frequent service outages.  The FCC even held hearings on the problem. 

The congestion problem circa 1996-97 revealed an intense latent demand for Internet access.  Similarly, wireless network congestion today reveals intense demand for wireless broadband.  Widespread use of smartphones, 3G-enabled netbooks, and now, perhaps, the iPad and its competitors demonstrate that wireless broadband will be a hugely important part of the broadband ecosystem as we move ahead. 

Eventually, AOL was able to resolve its problems by upgrading its modem and server capacities.  Wireless providers today, too, will be able to deal with congestion issues but only if they have adequate spectrum.  Reaching an always-on wireless broadband future means that spectrum can no longer remain attached solely to uses deemed valuable decades ago.  The broadband plan will suggest ways of moving more spectrum into high value uses, such as broadband access, to help ensure that we don’t get stuck in 1997 dialup-style congestion.

With the iPad pointing to even greater demand for mobile broadband on the horizon, we must ensure that network congestion doesn’t choke off a service that consumers clearly find so appealing or frustrate mobile broadband’s ability to keep us competitive in the global broadband economy. 

Very early in the process of developing the National Broadband Plan, we recognized the impact that exploding growth in wireless broadband usage would have on spectrum policy. Though the Plan will make recommendations spanning many areas of spectrum policy - including getting spectrum "in the pipeline" to market and fostering more productive use in existing broadband bands - there's no getting around the need to reallocate some spectrum from current uses to broadband use.  We must get more spectrum out there for broadband if we want a world-leading broadband infrastructure.

The perception, reinforced by recent press articles and television commercials, is that any such reallocation effort creates “winners” and “losers”. So, the public discussion about spectrum policy has centered on reallocations and, more specifically, reallocation from TV broadcasters.  It’s just more interesting and tangible to talk about or report on something that could have winners and losers… human nature, I suppose.  I hesitate to perpetuate this over-emphasis on one aspect of spectrum policy, but given the attention it’s received, I do think it’s important to explain our current thinking.

The most attractive spectrum for wireless broadband is below 3.7 GHz; since broadcast TV bands occupy 294 MHz within that sweet-spot, they have naturally been one of the areas we are examining. For example, on average there are 20 full-power TV stations in the top 10 markets; they directly use only 120 MHz of the 294 MHz allocated to broadcast TV. Across all markets, they only directly use on average 54 MHz (9 channels) of the 294 MHz total.  Naturally, we asked the question – is there a more efficient way to deliver free over-the-air TV and reallocate spectrum for broadband use?

In trying to answer this question, we have followed 3 core principles:

• Preserve free, over-the-air TV
• Reallocate a portion of the broadcast TV bands to broadband use
• Establish a market-based mechanism to effect that reallocation

Initially, we identified a set of scenarios that would meet those principles through various means.  We analyzed the impact of each scenario on consumers and spectrum reallocation, gathered feedback on the scenarios from broadcasters and other stakeholders, and absorbed thousands of pages of public filings, analyst reports, and other research material – all to refine and narrow options.  Sounds a lot like a typical strategic planning process, huh?

Where have we landed?  Of course, the process is not done yet, but our current preference is to establish a voluntary mechanism through which owners of broadcast TV stations could choose what they want to do with the spectrum they current license.  Some may choose to retain all of it; some may choose to share bandwidth with another station for continued high-definition, standard-definition, and/or mobile DTV broadcasts; some may relinquish their license to pursue alternative business models.   Station owners could receive a share of the auction proceeds from the spectrum they relinquish.  We would repack remaining stations in the most efficient manner, and reallocate the spectrum “freed” to flexible, broadband use.

I hate to disappoint, but such a mechanism wouldn’t create winners and losers, only winners and… more winners.  Broadcasters would win more options in a challenging business and investment climate for the industry; consumers would win more innovation in wireless broadband services and continued free, over-the-air television; auction winners would win capacity to meet customer needs (but pay for that capacity, of course).

Like any strategic planner would, we continue to explore other alternatives if the voluntary mechanism doesn’t receive Congressional authorization or result in sufficient spectrum reallocation – e.g., changes to the broadcast architecture to reduce spacing between channels, auctions of overlay licenses, mandatory channel sharing options. 

Those alternatives are fraught with complexity and tradeoffs.  We can get out of the “winners and losers” mindset if we actively support and pursue a voluntary, market-based mechanism to effect the reallocation of spectrum to meet the country’s future needs for wireless broadband.

Quick follow-up to my previous post:

This week, we also released a Public Notice asking for comments on spectrum for wireless broadband.  Essentially, we'd love data, analysis, and focused comments in the following areas for mobile wireless broadband, fixed wireless broadband, and wireless backhaul:

• How does the capacity of existing spectrum allocations compare to current and future expected demand for wireless broadband & backhaul services?
• How should we calculate the relative value of different uses of spectrum?  (e.g., wireless broadband, broadcast TV, mobile and fixed satellite services, military, federal government, other industrial uses)?  How should we calculate the relative value of unlicensed vs. licensed spectrum?
• Which other spectrum bands might be appropriate to repurpose for wireless broadband?
• What mechanisms could facilitate the transition from incumbents to new users in these bands?
• What other spectrum management practices should we consider to ensure spectrum is being used most productively?

The basic "who, what, where, when, why, how" questions about spectrum.  For more details, background and context, see the Public Notice.  You can respond directly to this blog or file comments through ECFS Express (or our standard submission page if you need to attach a file). Please title comments and reply comments responsive to this Notice as "Comments (or Reply Comments)-NBP Public Notice # 6."

Thanks,

Phil

Last Thursday, September 17, we held a workshop on Spectrum.  Though I may be slightly biased (and very geeky), I thought it was the coolest workshop to date.  Where else can you have well-informed people disagree so starkly on such key issues as the need for more licensed spectrum (some say we need it now, others that we still have a lot of idle capacity) and sources of that spectrum (some say the government, others point to specific commercial users)?   At what other workshop have panelists thrown out such cool terms as "White-Fi" and "self-optimizing networks," then actually been able to explain their application to the real world?

Though it's nearly impossible to capture the essence of such a rich discussion, I drew 3 conclusions from the workshop.

1.      The usage of wireless broadband services is growing at a faster rate than technological advances and other innovations to make more efficient use of spectrum.  At some point, therefore, we will face a spectrum supply-demand imbalance.

2.      There are numerous approaches to address the supply-demand imbalance, all of which are important and none of which can alone solve the problem:

• A complete, dynamic database of current occupants, licensed and unlicensed, by time, geography, and frequency, would help bring transparency to the marketplace.
• Building on this database, a well-functioning secondary market would facilitate movement of spectrum licenses to their most productive uses.
• Investment in and commercialization of innovative new technologies will continue to deliver more efficient and economic usage of existing spectrum allocations.
• We can only squeeze so much juice out of the orange, so to speak.  We will need to find additional sources of spectrum to allocate to wireless broadband services to meet growing demand.

3.      Finally, wireless broadband service is critical to solving our broadband deployment and adoption challenges - we need to start working on solving the spectrum supply-demand imbalance today, even if it won't reach "crisis" stage until some point in the future.  Coleman Bazelon, one of the panelists, summarized the importance best when he said that no other current commercial usage of spectrum delivers as much economic value as wireless broadband service (I paraphrase, of course).

Another point came across clearly during the workshop: we can learn a lot about using spectrum more efficiently from the explosion of devices and applications in unlicensed spectrum, and from non-commercial use of cognitive radios and ad hoc networking driven by DARPA for military applications.

Like any animated discussion, though, the workshop also raised more questions in my mind:

• How much additional spectrum will we need for wireless broadband service to close the supply-demand gap?
• By when will we need this additional spectrum?
• From whom do we get this additional spectrum?  How?
• What policies will enable continued innovation in spectrum efficiency and migration towards more productive uses of spectrum?  What policies would hurt?

I'm very interested to read what others think about the spectrum challenges and opportunities we face today.  I encourage you to engage in this process by continuing the discussion thread on the blog or by filing comments with ECFS Express (or our standard submission page if you need to attach a file).  You can also file comments responding to the Wireless Innovation NOI using the same docket number, 09-51.  Thanks in advance for your input!