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After several years here at Blogspot, a free Google service, SpectrumTalk is moving over to an updated Marcus Spectrum Solutions website, www.marcus-spectrum.com

The new URL for the blog is 

http://www.marcus-spectrum.com/Blog/Blog.html

RSS Feed:

http://www.marcus-spectrum.com/Blog/files/blog.xml

The older content will stay here.  Some will be ported to the new site as resources permit.

New posts will only be on the new site.

Thanks you, Google, for the hosting in the past.  You probably won't miss the traffic.

Please contact me if you have any problems or any other comments:

Reboot FCC.gov Update

Your Blogger's Suggestions Doing Well

In the voting on the FCC suggestion site, your blogger's suggestions seem to be doing rather well.

The top suggestions so far deal with the following:

• Require at least one FCC Commissioner to be an engineer - 30 votes
• Get rid of the BPL - 25 votes
• Automatically renew an Amateur Radio License for a full 10 year term when the operator upgrades - 19 votes
• Get rid of rules that cannot be enforced such as the GMRS license requirement - 18 votes

These seem to have significant input from the personal radio crowd!  No one seemed to pay any attention to how FCC would "require at least one FCC commissioner to be an engineer".  No one seemed to notice that some engineers favored BPL

But the next highest vote is the suggestion shown at the top of the pagee.  If you agree, could you surf over to the website, signin in with either your Facebook/Google/Yahoo etc. account or you can create a new UserVoice account, and consider voting for this suggestion and others you find of value.  Better yet, input your own ideas

 I received the following reply from Steve Crowley to a previous blog post which I shall repeat here:

"Relatedly, in September, the FCC received a Petition for Rulemaking from a proponent of wireless technologies intended to reduce cell phone use that might cause distracted driving. As far as I know there was no Public Notice from the FCC. I wonder if there have been similar filings, given the current elevation of the issue of distracted driving? Thus, I support your proposal to publish lists of all Petitions that have been filed.

The Petition I am referring to can be found on the proponent's web site:

http://www.trinitynoble.com/pdf/FCC_Petition_4_Rulemaking.pdf"

This complements well a suggestion by Richard Weil that I have commented on at the FCC site.  You might want to support that suggestion also.

Legislative Action on 2 Spectrum Bills

The House Energy and Commerce Subcommittee on Communications, Technology and the Internet has approved the following 2 spectrum bills:

HR 3019  Spectrum Relocation Improvement Act of 2009 - Amends the National Telecommunications and Information Administration Organization Act to require the National Telecommunications and Information Administration (NTIA) to post on its website detailed transition plans from each federal entity that is eligible for payments from the Spectrum Relocation Fund for costs related to the reallocation of frequencies from federal to nonfederal use. Requires the federal entities, to the fullest extent possible, to provide for sharing and coordination of eligible frequencies with commercial licensees. Requires federal entities to complete spectrum relocation within one year of receiving relocation payments.

HR 3125 Radio Spectrum Inventory Act - Amends the National Telecommunications and Information Administration Organization Act to require the National Telecommunications and Information Administration (NTIA) and the Federal Communications Commission (FCC) to create and maintain an inventory of each radio spectrum band of frequencies used in the United States Table of Frequency Allocations from 225 megahertz to 10 gigahertz and report to the Committee on Commerce, Science, and Transportation of the Senate and to the Committee on Energy and Commerce of the House of Representatives. Sets forth provisions concerning national security.

Interested readers may recall that I favor the spectrum inventory but am concerned that without some parallel work on clarifying the meaning of "harmful interference" that it will be a waste of time and resources.

Backers of the bill: 

• What do you think will happen after the inventory is done?
  
• How do you want FCC and NTIA to determine if apparently vacant spectrum can be used without causing harmful interference?

HR 3019 has some interesting provisions for independent review of agency transition plans for reallocations.  This is the first time I recall any proposal for some independent oversight of NTIA and federal spectrum management - a move  in the right direction.  Section 2(b)(6)(B)(ii) sets up a "Technical Panel" to review agency relocation plans.  Section 2(b)(6)(C) provides 

‘‘The Director of OMB, the Administrator of NTIA, and the Chairman of the FCC shall each appoint one member to the Technical Panel, and each such member shall be a radio engineer or technical expert not employed by, or a paid consultant to, any Federal or State governmental agency. NTIA shall adopt regulations to govern the workings of the Technical Panel after public notice and comment, subject to OMB approval, and the members of the Technical Panel shall be appointed, within 180 days of the date of enactment of the Spectrum Relocation Improvement Act of 2008."

The precedent of having an outside watchdog for federal government spectrum activities is a good counterbalance for the chummy atmosphere within the windowless IRAC meeting room.

Kudos to CTIA and Cellular Industry for Haitian Disaster Response

Texting Enables Instant Philanthropy

Faithful readers are aware that this blog has been critical of the cell phone industry and its trade association, CTIA, on numerous occasions.  While your blogger continues to believe that the specific criticisms of the past were well deserved, this week it is time for praise for their leadership in enabling the "instant philanthropy" that has raised at least $5,000,000 so far for earthquake relief in Haiti. (As of 5 PM, 1/14)

It appears that people are more willing to donate money if you can do it instantly without paperwork.  Also the cellular carriers appear to be waiving any fees associated with such texting.  It is clear that AT&T and T-Mobile are not collecting any commission off such donations.  Presumably the other major carriers are  also collecting commissions, but that is harder to confirm.  (T-Mobile and VZW have not updated the top level of their their websites to link to this issue, possibly because of an inflexible approach to web design.)

T-Mobile is going beyond the texting/donation issue by announcing

"For current T-Mobile customers who are trying to connect with loved ones in Haiti during the aftermath of the country’s devastating earthquake, T-Mobile USA is enabling phone calls to Haiti without charges for international long distance through January 31, 2010, and retroactive to the earthquake on January 12, 2010. Additionally, T-Mobile customers who may already be in Haiti will be able to roam on T-Mobile’s partner networks in Haiti (operated locally in Haiti under the names Voila and Digicel) free-of-charge through the end of the month. In both cases, T-Mobile will remove these charges from customer bills accordingly.

T-Mobile has also taken steps to assist with the restoration of the wireless communications infrastructure in Haiti – a key component in supporting the overall humanitarian and recovery efforts. T-Mobile has pledged its support to donate wireless equipment such as generators and phones."

 The Miami Herald  reports that  AT&T "is donating $50,000 to Telecoms Sans Frontieres, a humanitarian organization that has sent an emergency team with satellite mobile and fixed communications equipment to Haiti".  (BBC page on TSF - with videos.)

So our admiration to the cell phone industry for this outstanding job in responding to the disaster in Haiti! 
--------

UPDATE 1/19/10

mocoNews.Net reports that the amount raised for the Red Cross alone so far is $22M.  They add,

One problem with using cellphones is that it takes awhile for the money to get from the carriers to the people in need. However, given the dire circumstances in Haiti, a handful of carriers, including Verizon Wireless and T-Mobile USA, said they will pass along the money as soon as possible.

VZW has already sent $3M and T-Mobile will forward the money this week.  Both are, in effect, forwarding money they have not received in normal billing cycles.

Cost of Delay and Inaction at FCC

Docket 10-4: "FCC is Finally Moving on Signal Booster Use" Urgent Communications, 1/13/10

On January 6, FCC at long last started to take action on the long standing issue of cellular "signal boosters" or bidirectional amplifiers.  The current management can't be blamed too much for inaction because they inherited this mess and are at least taking action to start solving it.  But there are key lessons to be learned here on both FCC procedures and the cost of inaction to many different parties.

Here are some excerpts from the public notice initiating this docket:

By this notice, we seek comment on three Petitions for Rulemaking and two Petitions for Declaratory Ruling (collectively, Petitions) regarding the proper use of signal boosters on frequencies licensed under Parts 22, 24, 27, and 90 of the Commission’s Rules.
...
On August 18, 2005, Bird Technologies, Inc. (Bird Technologies) filed a Petition for Rulemaking to amend section 90.219 to outline specific technical and operational requirements for the use of signal boosters by Part 90 licensees.
...
On November 2, 2007, CTIA, the Wireless Association (CTIA) filed a Petition for Declaratory Ruling (CTIA Petition) regarding the proper use of signal boosters in Commercial Mobile Radio Services (CMRS).
...
On September 25, 2008, Jack Daniel DBA Jack Daniel Company filed a Petition for Declaratory Ruling seeking clarification of the Commission’s rules regarding signal boosters.
...
On October 23, 2009, the DAS Forum (a membership section of PCIA-The Wireless Infrastructure Association) filed a Petition for Rulemaking in response to the CTIA Petition stating that a rulemaking proceeding is needed to address the marketing, installation, and operation of signal boosters used in the Cellular Radiotelephone and Personal Communications Services.
...
On November 3, 2009, Wilson Electronics, Inc. (“Wilson”) filed a Petition for Rulemaking asking the Commission to commence a proceeding to amend Part 20 of its rules to establish standards for the certification of signal boosters for subscriber use on CMRS networks by developing equipment certification requirements to ensure boosters are available to the public.

So FCC has a series of petition on a technical wireless issue going back almost 5 years.  None of these have been on public notice or were even publicly disclosed by FCC.  Indeed, there was little indication other than press coverage that this issue existed.  While the CTIA petition was on its website, the other petitions were nowhere to be seen.  It is for this reason that your blogger has urged FCC to publish lists of all petitions that have been filed.  Note that this suggestion is doing rather well in the voting on the FCC reboot FCC site.  (Feel free to add your own vote!) Some quiet staff review time to decide whether a petition is redundant or not within the Commission's jurisdiction makes sense, but there should be weeks, not years!

We note that the NPSTC (a well respected federation of 13 public safety member organizations) 1/06 Newsletter had a lead article entitled "In-Building Coverage BDA Rule Changes Needed Today".  Yet the previous FCC management was unable to act.  So 2 private firms as well as CTIA and NPSTC urged Commission action years ago and nothing happened.

The recent PN says

When properly installed, these devices, which can either be fixed or mobile, can help consumers, wireless service providers, and public safety first responders by expanding the area of reliable service to unserved or weak signal areas. However, as articulated in the Petitions, improper installation and use of these devices can interfere with network operations and cause interference to a range of communication services.

This is partially correct.  But the issue is not just installation.  Some manufacturers' amplifiers are designed to prevent oscillations which are the dominant cause of interference to cellular systems.  Wilson Electronics states in its petition that all of its amplifiers have used such a design since 2006.  But because of FCC inaction this is not a universal practice.  So the result of inaction on the CTIA petition has been both the continuing sale of designs that are capable of causing interference, the loss of sales to manufacturers making better (more expensive) amplifiers, and capital formation problems for new companies that seek to make noninterferring equipment.  So it has been a lose/lose situation for everyone involved except those making cheap equipment capable of causing interference.

Of course, if CTIA and its membership had been more pragmatic and tried to negotiate a compromise with the amplifier manufacturers to ask FCC jointly for reasonable technical standards then this problem would be much closer to solution.  So there is enough blame to go around.

But the key thing to learn here is that the  3000 pages of FCC Rules deal with a highly technical jurisdiction and that they need fine tuning on a regular basis to address problems that were not considered when they were written or new technologies that might be implicitly forbidden.  This is not as exciting to the 8th Floor as other issues like broadband and broadcast ownership and content  but it also needs timely attention on a continuing basis.  The Commission must find a way to keep working on all parts of its jurisdiction all the time and not get sidetracked by the problem du jour.  So while Docket 10-4 has now started on its way to resolution, we must find a way to prevent future logjams like this.

Reboot FCC: Initial Results of Website

Suggestion Scorecard

Last week FCC opened the public version of reboot.fcc.gov including a call for suggestions in response to 47 issues.  Here is the scorecard of suggestions received as of10:30 AM EST 1/11.  The questions "How can the data released on FCC.gov/data be better formatted so as to be more useful to the public?" is by far the most popular.  Perhaps being first in the list is a major contributor to this lead.

In any case, vox populi, vox dei, we hope you check up on the suggestions, vote on those that are there, and input your own.  Oddly, using your Facebook account is the easiest way to sign in to input information or to vote.  No, you can not sign in using your FCBA membership or even your FRN.  That says something about the grassroot approach being used here!

Spectrum policy is too important to be left to lobbyists and lawyers!

Get involved!

2009 Regulatory Review: The Year of Rebuilding and Preparing for New initiatives

Wireless Design Special Issue Published

The December 2009 issues of both Wireless Design and ECN (formerly Electronic Component News) contain the insert shown above, "A Year in Wireless".

This includes a group of articles entitled "Leading Industry Alliances Speak Out" with articles from the heads of alliances dealing with Wi-Fi, WiMAX, ZigBee, and Bluetooth as well as an article by your blogger entitled "2009 Regulatory Review: The Year of Rebuilding and Preparing for New Initiatives" (p. 11-12).

An interesting package and recommended reading.

Origins of Wi-Fi and Bluetooth

May 9, 2010 will be the 25th anniversary of the FCC's adoption of the First Report and Order in Docket 81-413 - the rules that laid our the rules that became Wi-Fi, Bluetooth, Zigbee,  many of the cordless phones sold in the US, and a variety of niche products that enhance our lives.  In the next few months we will have several posts on how this all came about and its impact on today's world.

A Dutch team based at TU Delft/Delft University of Technology has completed a book on the background of this decision and the early history of Wi-Fi focusing on the factors that stimulated innovation.  (NCR's Utrecht Engineering Centre played a key role in early 802.11 standards formulation and its Vic Hayes, a coauthor of the book, was the founding chair of the group.) The book should be published later this year by Cambridge University Press.  

The 2008 George Mason University "Unleashing Unlicensed" conference also has a great deal of information on why this decision came about.  The paper presented by Vic Hayes and Wolter Lemstra  from TU Delft is a good preview of the coming book.

A shorter history, "A brief history of Wi-Fi" was published in The Economist in 2004.

Some people think this decision was the just FCC reacting in a dilatory way to a petition from industry - adding no value and just slowing down progress through mindless regulation of technology.  It wasn't. While the then Hewlett-Packard initially supported it, all other significant corporate interests at the time were against it. (The part of H-P that was involved then is now part of Agilent, not the present H-P.  It was supportive and then just lost interest in the topic with a corporate refocusing.)

The FCC initiative that resulted in these rules were an internal FCC initiative that came out of Carter Administration and then Reagan Administration belief that deregulation would stimulate economic growth.  

In occasional posts over the next few months we will review where this decision came from and lessons it offers for the present day.

"Looking back, it is clear that adoption of these rules was one

of the significant achievements of the Reagan FCC

- though I doubt if anyone thought so at the time."

Mark Fowler, FCC Chairman 1981-87, 4/08

A Tribute to Mrs. Viviane Reding

Outgoing European Commissioner for Information Society and Media (2004-2009)

"Strong competition and a functioning single market work in the best interests of European citizens and consumers."(11/23/09)

On January 1, Viviane Reding, European Commissioner for Information Society and Media will step down as part of a reshuffle of the EC cabinet in conjunction with the implementation of the new Treaty of Lisbon which makes major changes in the structure of the European Union.  It is expected that she will be appointed to a new position as Commissioner for Justice, Fundamental Rights and Citizenship.  (She previously had been European Commissioner for Education and Culture in 1999 - 2004.)

In the period from 2004-2009, she was, in effect, the "telecom policy czarina" of Europe.  As many readers know, telecom policy in Europe functions at both the national level with the longstanding multinational CEPT as the primary forum of national regulators and at the EC level with RSPG as a multinational forum in the spectrum area.  An additional complication is that CEPT has 48 members, including Russia, and the EC has 27 members.  But the EC is concerned about all social and economic issues in Europe while the CEPT is more focused - tunnel vision? - on the telecom sector.

Mrs. Reding (I have never seen her referred to as "Ms. Reding") was a client of mine while I lived in Paris.  I was appointed her "special advisor" in 2006 at the recommendation of Martin Cave.  (The details of the arrangement we made public the next year when a member of the European Parliament was concerned about cronyism in the selection of consultants by commissioners and demanded public disclosure of all details.  Unfortunately they did not publish the miserly per diem I was paid to stay in Brussels to talk with her and her staff.  However, I did get a first class Thalys train ticket between Paris and Brussels for the trip that gave me free coffee for the 90 minute ride.)

 "This is why (EC) President Barroso and I have proposed a 'Digital Agenda for Europe' to make sure that Europe focuses on:

    * the industries and applications that have the potential to lift Europe's performance and
    * the prominent place and role of consumers in this new environment".(11/12/09)

What really impressed me about dealing with her and her staff was the focus on helping the whole European economy and society develop, not focusing on the telecom industry in isolation and certainly not focusing on the major telecom operators and manufacturers as most national telecom regulators do.  Sometimes her strong pro-EU policies irritated the US, such as her backing for Galileo as a alternative to GPS and using EU funding for a European Google search engine alternative.  But such "nationalism" was quite popular in Europe and I could see some logic for it.  Her office also funded a lot of telecom R&D with joint projects with universities and private firms and at time I wondered about the WPA aspects of this.  But her continued focus on both the European economy and European society made her a much more insightful telecom policy maker than FCC and its national counterparts in almost every country.  Telecom policy need not be focused primarily on carriers, broadcasters, and manufacturers.  Telecom is a key infrastructure for economies and societies.

"ICT also contributes macro-economically to productivity growth and
 increased competitiveness of the European economy as a whole,
 and thus is a factor in growth and job creation." -- COM(2006) 334

I hope FCC and other regulators learn from her legacy.

European Telecoms and Media Commissioner Viviane Reding delivering the 2009 Ludwig Erhard lecture at the Lisbon Council in Brussels.

Will Free Wi-Fi Become the Norm?

Larry Magid of CBS News and the San Jose Mercury News had an interesting post on CBS News this week about the future role of Wi-Fi.  Of course, if would be a nice holiday present to all if it widely became free in public places.  It was stimulated in part by McDonald's announcement of free Wi-Fi starting in January.

I also note that AT&T Mobility CEO Ralph de la Vega has said that it will try to ease the load on its network overburdened by the success of iPhone, and perhaps somewhat underbuilt/underprovisioned, and to offload the carrier's cellular traffic to Wi-Fi hotspots and femtocells.

So as we approach the 25th anniversary next year of the Docket 81-413 rulemaking that brought forth Wi-Fi (and Bluetooth) over the opposition of most mainstream players at the time, who knows how big its long term role may be?

UPDATE

 Wired: Ford is making its cars into mobile Wi-Fi hot spots.