Archive for the ‘Broadband’ Category

It says “handsets”

Wednesday, June 4th, 2008

I finally just had a chance to read the FNPRM for the rules governing the C Block in FCC’s recently concluded 700 MHz Auction and it says “handsets”! Why is this significant?

For the C Block, comprising 22 MHz in the upper 700 MHz band, the FCC created special open access provisions. The FCC will require licensees to provide a platform that is open to third party devices and applications. Specifically, licensees must allow customers, device manufacturers, third-party application developers, and others to use any device or application of their choice on their networks in this band, subject to certain limited conditions. Licensees may not “lock” handsets to prevent their transfer from one system to another, or to other services that compete with wireless service providers’ own offerings. The FCC concluded that these rules were justified because it did not find “that competition in the [mobile] marketplace is ensuring that consumers drive handset and application choices, especially in the emerging wireless broadband market…. it is easy for consumers to differentiate among providers by price, most consumers are unaware when carriers block or degrade applications and of the implications of such actions, thus making it difficult for providers to differentiate themselves on this score.”

Insight: Beware the law of unintended consequences. Here it is not the proverbial monkey wrench, but a pair of bolts, literally, which could bring the FCC’s policy to a grinding halt. Implicit in the service rules is the assumption that the band will evolve to resemble the next generation of the current mobile market in the US. But assumptions like this never last. I wonder if it is possible for clever operator could escape the open handset requirement by providing fixed services. The 700 MHz spectrum is particularly well suited to a variety of applications, one of which might be fixed broadband. In rural and suburban areas fixed wireless broadband could be an effective competitor to wireline. Presumably these areas would be sufficiently competitive that the FCC’s finding would not hold (remember it is limited to handsets, and not even service plans). Thus, if the licensee is bolting “pizza boxes” to the side of homes, would this type of network not be subject to the open access provisions? It’s unclear, but something to think about.

Wi-Fi on Steriods

Monday, May 26th, 2008

Google’s Larry Page spoke at a recent New American Foundation event, calling for “Wi-Fi on steroids” for the TV White Spaces.  Every time I hear this, I cannot help but think, “Oh great, a radio that is hyper-aggressive, muscle-bound, and impotent.  Why would I want such a technology?!” All joking aside, I approve the sentiment, but a little more careful analysis is need.There is here a unique window of opportunity to allow new uses of the TV spectrum which is currently inefficiently used.  For the past 9 decades, the FCC has regulated high power uses of the radio spectrum, such as broadcasting.  The FCC has also for the past 7 decades permitted low power uses, with increasing success.  The TV White Space presents the opportunity to permit medium power uses of the spectrum – something between Wi-Fi and TV.  However, neither the high-power of low-power paradigms seems to fit.  Licensed approaches typically allocate use to a single entity which makes decisions about use.  As a result, much remains unused at any given time.  The rules created are hard to change and do not afford much flexibility in terms of decisions regarding use by the licensee.  In contrast, unlicensed approaches strictly limit the radio energy which a device can radiate into the ether.  By controlling the emissions, the rules limit the possibility of harmful interference.  These rules create a much more flexible set of permission, but due to the stringent power limitations ranges of the radio devices can be extremely short.  What is needed is a new form of coordinating spectrum uses for medium power applications, which holds the benefits of both approaches while minimizing the potential downsides.

Insight:  Fortunately, some of the FCC’s best and brightest have been working this issue.  In a previous Cool Stuff, I wrote about my FCC Working Paper, which lays out ideas for the implementation of economic congestion etiquettes which would allocate spectrum use in real time to its highest monetary value uses.  This approach could significantly improve the value society receives from the use of the radio spectrum, without the need for dangerous pharmaceuticals.

Measuring Unit Prices for Communications Bucket Plans Using the Black-Scholes Model for Valuing Options

Friday, May 16th, 2008

Telecommunications network operators have traditionally charged on a unit basis for messages sent and received. Dating back to the heyday of telegraphy, operators charged by the word. With the rise of the Bell System telephony was charged on a per minute basis. The 1984 Divesture of AT&T saw the rise of two part tariffs, to separate costs related to access and long lines networks. However, the basic premise was a per minute charge (oftentimes including a connection or first minute charge). This arrangement was simple and allowed for easy comparisons of unit charges, dividing total revenues by total minutes of use (MoUs). This price per minute is an easily comparable metric – a voice minute has changed little since Alexander Graham Bell famously whispered, “Watson, come here I need you.” Regulators could employ price per minute performance as a gauge on the efficacy of policies, and consumers could understand the value of what they are getting.

However, now, driven by competition in mobile telephony, communications carriers have offered an alternative set of arrangements (the same is now true for fixed line carriers and even some data networks). These have been variant of the flat rate plan, mixing flat rate and per unit pricing plans. Under such “buckets of minutes” plans, customers pay a flat rate for a huge number of minutes whether they use them or not. If their usage is over the allotted amount, then they pay on a per minute basis at a rate much higher. The per-minute charges are not intended to be used on a routine basis; rather, they are set at high or punitive levels, so as to enforce the need to upgrade to the next higher band as the customer’s usage increases over time. These plans are most appropriately viewed as representing banded flat rate arrangements. There are different bands, representing different numbers of total MoUs per month. In the United States, these banded flat rate plans have been well accepted by consumers and industry. They probably track underlying costs of mobile telephone service reasonably well, to the extent that usage-based average incremental costs in the United States are primarily a function of air time. Customers appreciate the predictability and the relative simplicity of the plans. So long as the consumer does not exceed the maximum number of minutes in the band, the consumer will tend to think of the plan as being purely flat rate.

The introduction of bucket plans, however, frustrates any calculation of per minute unit price. Plans of this type usually incorporate a per-minute charge for minutes, but it would be a mistake to analyse a banded flat rate plan as if it were a simple two-part tariff. In calculating per minute charges it is unclear whether to utilize actual minutes of use consumed or plan minutes sold, but not used. The results would be quite different. The former would yield a higher price, but would not indicate the value “left on the table” by the consumer. While the latter would tend to under represent the actual cost by making implicit the value of the option of further minutes of use at zero incremental price.

Insight: The appropriate way to regard bucket plans, and hence, to value per minute unit prices, is as a permutation of a financial call option. A call option affords the right, but not the obligation of use at a specified price, called the exercise or strike price, on or before a specified date. The intuition begins with a graphical analysis, see inserted figuresValue of an Option. The graphic on the right displays the payoff of a financial option at various prices. The x-axis represents the price of the underlying security and the y-axis represents the potential profit or loss. The value of the option stays flat until the market price exceeds the strike price. At this point, its value increases and becomes positive once it exceeds the cost of the acquiring the option. Now consider the figure on the left. It shows the cost of two bucket plans. The x-axis is still the independent variable: minutes of use. TValue of a Bucket Planhe value (or price) of the plan is flat until exceeds the flat-rate portion of minutes. It then increases at a linear per minute rate, until at some point it is preferable for the customer to take the larger bucket. These two graphics look virtually identical, suggesting that the option valuation method holds promise as an effective metric.

The value of options can be captured by a complicated formula developed by Fischer Black and Myron Sholes in the early 1970s (the two shared the Nobel Prize for this observation). The option value is based, inter alia, on the current market price, the strike price, the variability of market price with regard to the strike price, the risk free cost of capital, and the maturity of the option. By finding equivalents for these variables in bucket plans, we can easily derive per minute values for under bucket plans.  I realize that this may be a bit of an oranges-to-tangerines comparison. There are certain items not present in the derivatives markets in these service plans. Nonetheless, such a calculus would allow for straight forward comparisons of the price of services plans across firms, countries and over time series where such plans might not exist.

Next Generation Spectrum Policy

Wednesday, March 5th, 2008

I am very pleased to announce that the FCC has just published a suite of papers which I worked on while I was there. This work sought to tackle some of the intractable problems facing spectrum policy. For nearly a century, spectrum policy has focused on “scarcity” and resolving “harmful interference”. This was largely due to limits of the technology of the day. Now radios fueled by semi-conductor processing power, are enabling spectrum policy to evolve. We can now focus on a much more efficient principle of “use coordination”. The first paper in the series, OSP Working Paper #41, examines the Tragedy of the Commons and how economic protocols might be employed to alleviate this problem, while preserving the openness and innovation associated with unlicensed operation. It achieves this by coordinating competing demands on the spectrum. There are several different means for assigning priority to allocate use. However, allowing would-be users to express their willingness to pay seems to be the most economically efficient. Through an economic coordination protocol, usage at any given time is awarded to those with the highest value. OSP Working Paper #43, looks at how the set of rights which underlie this regime can be assigned through auctions.

Insight: Of all the work I have done in my professional career, this is the product of which I am most proud. The future of spectrum policy will be one of “use coordination”, where the “exclusiveness” of a license will be determined at an auction along with which entities are assigned the license. We are back to First Principles. This work holds the promise to wrestle the spectrum from the hands of a few powerful entities and put it back in our hands. In addition, it is likely to increase efficiency and hence the benefit we all receive from its use. The beauty of the system is that if the current spectrum arrangement is the most efficient, then it will emerge as such. At the very least, we will have exposed society to a huge upside with very little downside risk. It also would allow us to grant priorities to those whose ability to pay is diminished, such as public safety and financially disadvantaged users.

As a body of work, it has far reaching implications. At the recent FCC field hearing on network management (viz. Net Neutrality), there was much reasonable debate on what constitutes reasonable network management. There were many views as to how to handle competing demands on limited network resources. To my mind, the most efficient way will be some variation on willingness to pay, perhaps through an economic coordination protocol.

White Space and Gray Matter

Tuesday, February 12th, 2008

Congressman Jerrold Nadler recently published an Op-Ed in the New York Times. His analysis is so off-the-mark, I felt compelled to respond.

I want to begin with some terminology. He describes the White Spaces as being the “intervals between television channel frequencies.” This could mean the geographic separation between grade contours, the guard bands, or even the blanking intervals in NTSC progressive interlace. At any rate, white spaces are “white” because at a given time and place the frequencies are not being used as carrier waves. If the spectrum is not being used then, by definition, there cannot be interference. And not just interference alone, but harmful interference is the statutory level of protection.Now I am not sure about the previous white space tests, as I lack the engineering experience to adequately review the opinions. But, I have see arguments suggesting the are conclusive and ones stating that they are not dispositive. Either way, technology will eventually overcome these issues. There are, however, more glaring failures of Rep. Nadler’s arguments.

“Microsoft, Google and others are asking permission to use white spaces — free of charge — for millions of unregulated and unlicensed devices for personal networking systems that they would like to sell, including P.D.A.’s, wireless broadband devices and even toys. These devices could disrupt the new digital TV signals that government and industry have spent so much time and money to promote.”

This is misleading by misstatement and by omission. Misstatement: unlicensed devices are not “unregulated”. Omission – the broadcasters did not pay for their spectrum either. Moreover, who cares what the broadcasters sunk costs might be. Suppose Google and Microsoft will spend more to develop more important technologies.

Rep. Nadler goes on to say, “And because these personal devices would be unregistered, there would be no effective way of recalling them or curtailing their use, much less assuring that standards were adhered to their manufacture.” If you read the FCC Part 2 and Part 15 rules you will find that this is dead wrong. When I was at the FCC, I spent a lot of time working on precisely this issue. Before any radio device, be it licensed, unlicensed, or licensed-by-rule, can be imported or marketed in the US, it must be certificated to comply with FCC standards. In addition, users of unlicensed devices have “no vested right to continued operation.” So, if in the future, the FCC decides that white spaces are best left white, it has the power to make operating these devices a crime. When Wi-Fi is outlawed, only outlaws will have Wi-Fi.

Further, without a single iota of economic evidence, Rep. Nadler values digital terrestrial TV over all other uses of the spectrum. Moreover, he values co-primary access according to his own wants and desires. It is a cute device when he argues for the protection of football games and Broadway musicals alike, but this too is misleading. Who is to say that a football game or Broadway show (both of which take place in large controlled Faraday cages) is more important than my wireless email?! I don’t like football, but I like email. How about public safety? I think that’s a better use of the white space. And, would it not be better public policy if we were helping “[l]ow-income households, the elderly and people living in multifamily buildings who don’t have cable service and rely on antenna systems” to get online with cheap unlicensed broadband access, and not to watch more TV?

Finally, if the Broadway star and star quarterback are counting on unfettered spectrum access (a concept whose time has come and gone) they should pay for that access. Otherwise, they should share the spectrum with the rest of us who get great value out of unlicensed use.  Both types of spectrum access will and must coexist in the future.  The future of spectrum policy will not be about “scarecity” or “interference” so much as it will be about coordination of use.

Insight: People, I cannot stress this enough, use your gray matter before you talk about the white space.

A Challenge to the Next FCC Chairman: Make the US Last in Broadband Adoption

Thursday, February 7th, 2008

No matter what the outcome in November’s presidential election, about a year from now, the FCC will be anticipating the arrival of a new Chairman.  I present the following challenge to the next Chairman, whoever he/she may be: make the US last in the world rankings of per capita broadband adoption.  What?!  Stay with me for a sec.

The FCC defines “broadband” as any access technology providing at least 200kbps in one direction.  This standard was appauling when it was introduced nearly a decade ago;FN1 it is simply laughable now.   Shouldn’t this standard evolve at least a little bit over time?  Consider for a second Moore’s Law on computing per unit cost, which stipulates that preformance roughly doubles every two years.FN2    So, between January 1999 and January 2009, the price preformance of the electronics which enable a broadband connection should have increased by a factor of 32.  Thus, a resonable standard for broadband today would be 6.4 Mbps (200kbps X 2 X 2 X 2 X 2 X 2 = 6,400kbps).  Let’s say I missed my guess by a bit and an appropriate standard is 5 megs.  (Neither a particularly high threshold and about what I get at my home in a small suburb outside of Bonn, Germany.) In that same decade, the US rank in the world in terms of broadband adpotion has fallen from 3rd to 15th to 20th, by some counts.

Insight:  According to the FCC’s most recent data, in December 2006 there were 82.5 million broadband lines in the US.FN3  Using the 5 meg standard this number would drop to roughtly 11.5 million lines.FN4  The effect of reporting this as the number of broadband lines in the US would be to be to drop the US to a per capita broadband adoption rate of Slovakia or Mexico.  Only then would it be undeniable that the US is falling behind in the adoption of next generation networks.  And, only then would the FCC have the imperative necessary to take the steps which other nations are taking and “encourage the deployment on a reasonable and timely basis of advanced telecommunications capability to all Americans,” per the FCC’s mandate. 

FN4: This is a bit of a fudge factor, but good enough for the back of the envelope.  Since the FCC only reports lines with speeds between 2.5 megs and 10 megs, I assumed that only 1/4 of the 34.7 million lines in this category were greater than 5 megs – I eyeballed this from the skew of distribution.

Irish International Advisory Forum on Broadband

Wednesday, February 6th, 2008

I am very please to announce that I have been appointed to an International Advisory Forum on Next Generation Broadband Networks.  Minister Eamon Ryan of the Department of Communications, Energy and Natural Resources established this Advisory Forum of senior telecoms experts and CEOs from around the world in order to advise him on the optimum role for Government in the development of Next Generation Broadband in the Republic of Ireland.

Insight:  As side for being a fantastic opportunity for me, I think this is right approach to policy formation, broadband or otherwise.  Policy makers should always pursue the “optimum role for Government.”

Classical conservative political though holds that “government is the problem,” and that a laissez faire approach is best.  Conversely, liberal politics hold that the profit motive is a sufficiently corrupting influence that in the absence of rules constraining the market place, the private sector will steal everything that is not nailed down. I am a lawyer, so I see these two statements as not mutually exclusive and both possible true.  I am also an MBA, so I can also see that there is some tradeoff between the two approaches.  And, if there is a tradeoff, it follows that there must me some optimization: one rule too many and government throws up barriers to entry to the market place; one government employee too few and the Invisible Hand can get into the Invisible Cookie Jar.  Thus, the policymaker should always be managing regulation to this efficiency frontier.