FCC Revives Marcus
"Interruptible Spectrum" Proposal

First Holiday Greetings to all readers. We are actually in Cape Town as I write this for vacation and about to head off to the local wine area and then off to see big game in a reserve.

But surfing the web yesterday with the laptop and Wi-Fi connection that came with my hotel here I was amazed to see the details of the new FCC proposals in Docket 06-229, "Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band/Development of Operational, Technical and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through the Year 2010". (PC World coverage)

In some ways the proposal follows what the UK is doing, although it never says acknowledges the UK precedent: The UK has implemented a nationwide law enforcement network using the European TETRAPOL technology which is hated by Motorola and the APCO establishment. More important than the technology choice and common to the FCC proposal is that fact that it is operated by a private carrier (BT, the old British Telecom/Post Office) which built it without public finding and sells service to the 50 odd local police agencies in the UK. (The UK government actually things there are too many police agencies in their country and want to decrease the number to about a dozen. They have no idea what the problem is in the US with thousands of independent police agencies, each picking their own uniforms, guns, and radio systems!)

The FCC proposal is avant garde in that it would use IP technology, leapfrogging the TETRAPOL issue with a more modern approach.

But what really got my attention was the following paragraph:

"41. Under our proposal, the national public safety licensee would be permitted to lease access to commercial service providers on an unconditionally preemptible basis and enter into spectrum lease arrangements with commercial service providers in the manner of a public/private partnership for joint provision of public safety and commercial services. A key element of permitting commercial service is a strict requirement that any commercial use be unconditionally preemptible by the national public safety licensee. Specifically, commercial users would be on plain notice that their use may be, without notice, subject to immediate termination at the sole discretion of the national public safety licensee. We propose that there would be no conditions placed on the national licensee prior to making a determination to cease secondary commercial use. The national public safety licensee would have the unfettered right, which cannot be compromised or contracted away, to unilaterally determine when a secondary commercial use must be discontinued in the interests of public safety. Clearly, then, commercial users would need to ensure that, as part of any business plan, they have spectrum or communications alternatives in place to anticipate the event that their use may be preempted. We also envision, however, that our dedication to creating a nationwide, interoperable, broadband public safety network could incent accelerated development and use of advanced technologies, such as cognitive radios, by both public safety users as well as secondary commercial users. We seek comment on our proposal to permit commercial use on an unconditional preemptible basis as described above."


This was a concept that came out of the Spectrum Policy Task Force deliberations at FCC and was first aired in a paper I coauthored with my FCC colleague, Mark M. Bykowsky. It was explored in the cognitive radio rulemaking, Docket 03-108 and was implemented in a very limited way - indeed commercial users were forbidden to lease public safety spectrum (the opposite of the new proposal) because of concerns of the public safety establishment that were, frankly, hard to understand. For my more recent thinking on this topic, please read my DySPAN 05 paper and presentation. {If you are interested in thse issues, let me strongly recommend you consider attending DySPAN 07 to be held April 17-20 in Dublin Ireland.}

So I am thrilled that the FCC has given the topic second thoughts and hope that the public safety community will be open minded this time also and consider the concept on its merits, not just tradition. I really believe that it will preserve the critical public safety telecom and provide some of the funding that is urgently needed. It will also increase spectrum productivity that will help all sectors of our economy.

Why Not a Wireless Advisor with Some Radio Technology Experience?

It has been a long time since we had a "wireless advisor" (FCC commissioner's personal assistant who deals with wireless issues) who had academic background or hands on experience in radio technology. Frankly, Ben Perez, is that last one who comes to mind and that was more than a decade ago. We have had some wireless advisors who had no explicit background, but had a true instinct for the technical issues. Elliot Maxwell, Dave Siddall, and Ken Robinson come to mind.

In recent years, the working arrangements of the "8th floor" have been structured to almost discourage getting someone with technical background since the various "advisors meetings" are key to the working of the 8th floor and they are arranged by industry, not by technical and legal issues. But this is not established by law or regulation, just a relatively recent habit.

Let's look at another agency where there was an original approach.

[Click on image to enlarge it]

Maybe it really does pay to advertise! NRC Commissioner Jaczko chose to advertise last summer in Science magazine for an assistant/advisor with a technical background. Are there people out there with a wireless industry technical background who had the policy skills and interests to work on the 8th floor? I think so. But who can be sure one way or other unless you try more aggressively to find them.

The Commission is probably breathing a sigh of relief that it "solved" the Nextel/public safety interference issue. I think it should be asking itself why this problem occurred in the first place and what it says about decisionmaking at FCC. (And while it is at it, it might consider that a technically different [but similar in policy nature] problem happened in the 1980s with interference from TV channels 14 and 69 to land mobile systems.)

So, Commissioners, next time you expect a vacancy in your "wireless advisor" position or if you are willing to restructure your staff when there is a vacany, why not advertise like Commissioner Jaczko? I would suggest IEEE Spectrum in this case over Science, but maybe try both since Science attracts a lot of people with technical policy interest.

Antennas & NIMBY
Part 1

Wireless systems need antennas. Many types of modern commercial wireless systems such as cellular radiotelephone and fixed wireless access systems need antennas sites throughout the service area with spacing of 1-10 km, depending on population density. These systems already require many antennas and will need more in coming years for a variety of reasons. NIMBY (“not in my back yard”) opposition to antenna siting in suburban areas is already a major issue in the rollout of new wireless services and is likely to worsen in the next few years. This blog entry will examine the nature of this problem. Future entries will review the regulatory response, and possible alternative approaches to defuse the situation.

This problem is most severe in suburban areas. In urban city cores it is relatively easy to place antennas on tall buildings with willing landlords and little visual impact. Generally, it is also easy to place antennas in rural areas where short spacing is not needed and antennas can usually be sited away from residences. But in suburban areas one has a bad combination of factors: need for close spacing of antennas due to population density, lack of tall buildings, and neighbors who are inevitably close to antenna sites.

How many antennas are needed in suburban areas? The FCC has estimated that in 2005

• “roughly 268 million people, or 94 percent of the U.S. population, live in counties with four or more mobile telephone operators competing to offer service. In addition, roughly 145 million people, or 51 percent of the U.S. population, live in counties with five or more mobile telephone operators competing to offer service, while 50 million people, or 18 percent of the population, live in counties with six or more mobile telephone operators competing to offer service.”

This was before the FCC finished auctioning off 6 licenses in each area for 3G cellular, formally call Advanced Wireless Service in the U.S. Now not all the new 3G license will result in new systems independent of the existing systems, scenarios with 10 mobile systems each with antenna requirements are possible.

At the same time interest in Fixed Wireless Access (FWA) is increasing with the new 2.5 GHz Broadband Radio Service as well as previously existing bands. FWA systems in a given location might number in the 5-10 range in the next decade. Thus the total number of independent antenna systems needed with spacing in the 1-10 km range may well be 15-20 in the next decade. This does not include public safety systems that may migrate to a cellular architecture to increase capacity and use higher frequency bands.

Antenna systems in suburban locations often arouse objections from neighbors. Sometimes these objections focus on RF safety issues, even though human exposure from such systems is almost always significantly less than generally accepted safety levels. Another issue, and one that may trigger the RF safety concerns, is that most suburban antenna systems “look like they were designed by engineers”! That is a common tower holds multiple antenna systems at different heights that appear to have been selected independently, perhaps with consideration for the maximum visual discordance. Depending on the local cell structure, similar antennas may be rotated in the horizontal plane with respect to each other.

The usual industry reaction to neighborhood opposition is building camouflaged towers, perhaps looking like trees, or trying to incorporate antennas into an existing high structure such as a church steeple or even building new steeples! These solutions are very expensive and of limited applicability, especially if a large number of antennas are needed at the same location.

[More next time on FCC attempts to deal with this issue and possible alternatives to break the stalemate.]

Rumored Personnel Changes in FCC/OET

Rumors are floating around FCC about 3 pending promotions in the Office of Engineering and Technology to refill the depleted management ranks. All 3 are career FCC employees who have been in OET for a while.

It is reported that Ron Repasi and Ira Keltz are about to move into the deputy office chief positions vacated by Bruce Franca's retirement and Julie Knapp's promotion to office chief - which has never been announced but is at least now on the posted organization chart.

Ron has been the FCC observer on IRAC - a key liaison role with NTIA and others on federal spectrum management issues. Ira has been chief of the Electromagnetic Compatibility Divisions, OET's analytical wing.

It is reported that Geraldine "Gerri" Matise is about to move into the key Policy & Rules Division slot vacated by Alan Scrime a few months ago. Gerri has been deputy chief and now acting chief of that division.

Reports are that all these moves are pending, they have been announced in internally, but have not received final approvals. My congratulations to all 3 on honors well deserved!

Japan Has a Spectrum Strategy -
Why Doesn't FCC?

I just returned from a 10 day trip to Japan for a keynote address at a conference on medical applications of wireless technology (ISMICT 06). I stopped by the Japanese equivalent of FCC, called MIC in English while the Japanese name is actually quite different. Meeting with Mr. Akira TERASAKI, an old friend who now has a senior position, I received a copy of the latest edition of Information and Communications in Japan, the annual white paper on telecom policy.

It is not the most profound document in the world and I don't agree with the approaches they are taking in many areas, but it is much better than anything the FCC has produced in the past year or so. At least Japanese industry and those interested in the Japanese market can see where their government is going in telecom policy and make investments accordingly.

Similarly, the FCC's UK counterpart, Ofcom, has published Spectrum Framework Review: Implementation Plan in which it "consults on the release of spectrum in 2005 – 08, and on extending spectrum liberalisation and trading to mobile services".

So in UK and Japan the general direction of spectrum policy is visible. Why not the US?

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On the lighter side, a friend in Japan gave me a copy of a hilarious parody from The Onion, "America's Finest News Source". A brief excerpt to tempt you:

WASHINGTON, DC—The Federal Communications Commission voted 3-1 Monday to require electronics manufacturers to make all television sets ADHD-compatible within two years.

To adhere to the guidelines, every program, with the exception of The Hi Hi Puffy AmiYumi Show, will have to be sped up to meet the new standard frame rate of 120 frames per second.

FCC Chairman Kevin Martin characterized the move as "a natural, forward-thinking response to the changing needs of the average American viewer."

...

The ruling represents a growing shift toward ADHDTV, a television format designed to meet the needs of an increasingly inattentive and hyperactive audience. The tuner includes a built-in device that automatically changes channels after three minutes of uninterrupted single-station viewing, as well as a picture-in-picture-in-picture-in-picture option. ...

Some networks, however, are embracing the change.

"A majority of our shows are only watchable for a few minutes at a time anyway," said Fox president Peter Liguori, whose recently unveiled fall 2007 TV schedule includes over 850 new series. " ...