Microsoft Cognitive Radio Prototype Arrives at FCC

A 3/14/07 ex parte filing by the coalition of Dell, Google, HP, Intel, Microsoft and Philips confirms that the long awaited Microsoft-funded prototype cognitive radio has arrive at the FCC Laboratory for testing as part of Docket 04-186.

The coalition claims that this radio will function in the listen-before-talk mode and detect both TV stations and wireless microphones at low enough sensitivities in order to avoid occupied channels for TV band Wi-Fi-like use.

The FCC proposals in this proceeding have been extremely controversial, pitting new economy companies, such as the coalition members, against old economy companies like the TV broadcasters and manufacturers of UHF FM wireless microphones. At stake is providing low cost broadband access in rural America where TV frequencies are especially useful for long range communications in sparsely populated areas. The broadcasters claim the future of "free TV" is at stake.

The docket has accumulated 860 documents to date and no end is in sight.

Why Doesn't FCC Like Interagency Surveys?

About two months ago I wrote a posting about how FCC somehow avoided the OPM Federal Human Capital Survey 2006, a commendable Bush Administration initiative that "that measures employees' perceptions of whether, and to what extent, conditions characterizing successful organizations are present in their agencies." Last week I read in the Washington Post's Federal Diary column about another interagency survey - this time dealing with agency websites.

The University of Michigan's American Customer Satisfaction Index (ACSI) surveys quarterly 80-100 federal agencies' web sites to see how happy users are with them. Why do they do this? An OMB-sponsored website explains it this way:

You want people to be satisfied with your website – right? Measuring customer satisfaction is subjective – it tells you what they say they like and don’t like about your site, not necessarily what they do on your site. But it will tell you whether they happy or not, when they used your site, how likely they are to return, whether they’ll recommend your site to others, and much more.

The only specific survey mentioned on this site is ACSI and it is used by agencies large and small that want to see where they stand. Both large agencies and small agencies participate in ACSI. The Nuclear Regulatory Commission's website did reasonably well just as NRC did well in the Federal Human Capital Survey. (NRC is only slightly larger than FCC.)

Do you think I am unfair about the FCC's website? You may be aware that there is a very contentious petition (RM-11361) filed at FCC by Skype asking for part 68-like treatment of cell phones. Try to find it! Until recently the FCC search engine couldn't find it at all. Now the search engine can find the 3/15/07 Daily Digest that has a link to the order extending the comment cycle, but not to the original request for comments or the docket file.

The Bush Administration likes to measure results and hold people accountable for their results. Shouldn't FCC follow the White House lead and be willing to have its performance evaluated in interagency surveys like the Federal Human Capital Survey and American Customer Satisfaction Index?

Erika Olsen Joins the WAM*

A March 16, 2007 FCC press release announces several changes in the Chairman's Office. Of particular interest to readers is is the filling of the wireless advisor position, vacant since December 29, 2006 when Fred Campbell moved on to head the Wireless Telecommunications Bureau. Erika Olsen will be Chairman Martin's Acting Wireless Advisor.

Ms. Olsen most recently served as the Deputy Chief of the Telecommunications Access Policy Division in the Wireline Competition Bureau. Ms. Olsen joined the law firm of McDermott Will and Emery in 2000 and became a partner in 2006. She then joined the Commission later in 2006. It appears that her previous work at FCC dealt with the Rural Health Care Support Mechanism/Rural Health Care Pilot Program.

Ms. Olsen received her B.A. from Yale University, and her J.D., magna cum laude, from the Washington and Lee University School of Law, where she was elected to the Order of the Coif.

With this change, the apparent e-mail addresses of the WAM members are:

Erika.Olsen@fcc.gov,Barry.Ohlson@fcc.gov,Aaron.Goldberger@fcc.gov, Angela.Giancarlo@fcc.gov, John.Branscome@fcc.gov

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* WAM = wireless advisors' meeting, the regular meetings of the commissioners' wireless advisors in which the staff briefs them on pending policy issues and receives guidance on which direction to go.

I wrote the following article for the March 2007 issue of PolicyTracker, a London-based European spectrum newsletter and am using it here with their kind permission. So if the spelling seems a little unusual ... The wireless microphone issue is now getting a lot of attention at both FCC and the UK's Ofcom.

Wireless mics can enter the digital era

Complaints from the theatrical community in both the US and the UK are unjustified, says consultant Michael Marcus. He argues the problem is not an engineering one, but an issue of policy and economics.

A friend of mine in the US recently mentioned that he heard Sir Andrew Lloyd Weber on National Public Radio, the closest thing in the U.S. to BBC Radio 4, talking about the U.K.’s wireless microphone problem and the resulting threat to live theatre in London. I don’t know if any comparable U.S. figures have gone to London to give media coverage about their wireless microphone problem with FCC which allegedly threatens Superbowl coverage. How did this all start? In the days of analog TV, limitations of receiver technology made “whitespace”, i.e. vacant TV channels in a given area inevitable. Use of FM wireless microphones in this whitespace by broadcasters and theatres was a simple way to recycle this idle spectrum for something useful. Limiting eligibility to a small set of users meant they could mutually agree on its use. In this era, there was relatively little demand for spectrum anyway and no viable alternative for manual coordination. A lot has changed. DTV can use a higher fraction of available spectrum in a given region since receivers are more robust than analog receivers. This more intensive use of spectrum/ channels creates the “digital dividend” issue: one can either have more TV signals in the same amount of spectrum or pack the existing signals into a smaller TV band and ‘recycle” the remaining spectrum In the U.S. the TV stations of channels 2-69 will be packed into channels 2-51 in February 2009 as directed by Congress. There is also much more demand for wireless spectrum today than there was when the current wireless microphone use first developed. New cognitive radio technology now offers a more flexible alternative alternative to manual coordination of limited users for whitespace use. Thus a major policy challenge in both countries is how to address the needs for wireless microphones in today’s environment. In the U.K. Ofcom has proposed reserving one TV channel exclusively for wireless microphones. The broadcasters and theatres, ably represented by Sir Andrew, have stated that this will not be enough because they can only use today’s analog technology since digital technology will lead to audio delays that are unacceptable in live performance. ( See Digital Dividend Review: Ofcom fails to placate PMSE sector PolicyTracker 20.12.06) Now as a great admirer of Sir Andrew’s music, I am disappointed that he has taken to making poor engineering judgments. Does analog-to-digital conversion (DAC) always lead to large delays? No! No fee spectrum is part of the problem Linear predictive coding (LPC) is a DAC technology developed in the late 1970s for highly efficient compression of voice to binary data and is widely used in cell phones. Like other types of “source coding”, e.g. .zip and .jpg files, LPC involves a trade-off between delay and compression efficiency. But there are LPC parameter choices that trade-off delay for output data rate. There are also traditional DAC technologies without source coding where the delay is limited to the sampling interval, a small fraction of a millisecond. In wireless microphone applications distances are short so low data rates are not critical since the total amount of spectrum resource consumed in terms of bandwidth times area is small. 3G cellular technology can handle arbitrary digital streams including DAC from wireless microphones. Does the 3G industry offer a high quality wireless microphone today? No. There is no demand and hence no product development for spectrum efficient wireless microphones as long as low tech FM units have access to free spectrum use. Free spectrum is always cheaper than efficient wireless technology! Ofcom has proposed to dedicate one TV channel to wireless microphone use. In the U.S. FCC has proposed in Docket 04-186 to allow new unlicensed “TV band devices” to use TV whitespace alongside wireless microphones. The wireless microphone interests in the U.S. have strongly objected to the FCC proposals citing the technical complexity of protecting wireless microphones, which in theory are licensed, from the new unlicensed devices. They conveniently ignore the fact that most wireless microphone use in the U.S. appears to be by users who are not eligible for licenses under present FCC rules. Wireless microphones have real societal value as their proponents on both sides of the Atlantic argue. But the exclusive dedication of whitespace spectrum to them as in the U.S. status quo and the Ofcom proposal is clearly an inefficient use of spectrum since the spectrum use of this narrow application in time and space is quite limited. In view of the growing demand for all spectrum uses it makes more sense to accommodate the wireless microphone requirements in bands that are shared with other users and can give the wireless microphone systems the quality they need. The U.K. wireless microphone anti-digital claim is either a smoke screen to avoid increased costs for spectrum and equipment or arises from technical confusion. In any case, it is unlikely that there will be any development of more efficient alternatives for wireless microphones as long as regulators in the U.S. and U.K. allow indefinite use of today’s low tech models and don’t consider the opportunity cost of denying the whitespace spectrum to other users who could use it more effectively. •

O2 Airwave Service:

Achieving Public Safety Interoperability in UK

The US has a huge public safety interoperability problem and has known about it for a long time. FCC has announced a "First Responders Summit" on April 20, 2007 to address the issue. But the root cause of the problem is simple: the US has thousands of independent public safety organizations which are independently funded by local governments and feel that they can independently select their own uniforms, guns, and radio systems. Time and time again the FCC has seen that throwing more spectrum at public safety makes interoperability worse, not better, if you don't exert real leadership.

I spoke in London last week at a meeting. I was reminded about how they have addressed this issue. At present there are about 50 independent regional police forces in UK, probably being reduced to about a dozen in the next few years. As a result of leadership from the Home Office and Ofcom (and its predecessor) they all use one communications systems that is centrally managed: the O2 Airwave system. (O2 is the cellular operator that sprang out of the former British Telecom - the traditional monopoly telco in UK.)

Now Airwave uses TETRA technology, a European development that has been so vilified by APCO and Motorola over the past decade that no one could seriously consider it for use in the US. Anyway, like APCO-25 it is rather dated now anyway. Any new system started now should probably be IP-based.

My point here is not the desirability of TETRA but rather the strategy the UK used to implement nationwide interoperability: Spectrum was made available for the system, a competitive contract with detailed requirements was issued, and the police agencies were told to migrate. Now in the US "Washington" can't tell local police to migrate to anything, but you can make it very advantageous by giving financial support only to agencies that do the right thing.

The UK precedent recognizes that governments have trouble with financing initial startup costs but can buy services on a recurring basis. Thus O2 financed the system and had no trouble raising the money based on long term service contracts.

For more information on Airwave also see Police Information Technology Organisation which is the UK government body that contracts with O2 for the system.

The World of SpectrumTalk Readers

I thought readers would be curious where other readers are. This is a map of the last 100 readers. Since often they are in the same city, there are few pins shown. Looks like we have a Southern Hemisphere readership issue, I'll talk to the Sales Department!