Posts Tagged ‘Spectrum’

Rethinking the White Spaces decision

Thursday, September 23rd, 2010
Manneken Pis

Unlicensed operation in the yellow spaces.

I watched the FCC’s monthly agenda meeting today where it unanimously adopted its Second Memorandum Opinion and Order which will enable unlicensed operation in the TV White Spaces.  As I have said in a previous Cool Stuff,  I do not think given the way in which operation will be permitted will be truly unlicensed.  However, what I found most interesting about the meeting was what the Chairman and Commissioners said and did not say in their comments from the dais when voting out the item.

Almost universally the five:

  • Thanked Julie Knapp and his staff (This is to be expected.  I used to work down the hall from Julie, Alan and Hugh, and they are a bunch of really great, really smart fellows);
  • Stated that the Order would unleash a wave of innovation, broadband access, “Wi-Fi on steroids,”  and other Really Cool Stuff (RCS); and
  • Acknowledged, however, we have to protect the incumbent users such as broadcast TV and wireless microphones.

Insight: What was universally not said was that broadcast TV and wireless microphones are not the future.  Granted, regulators want to provide regulatory certainty and are loathe to picking winners and losers; however, this glaring absence begs the question: if all of the innovation, job growth, and economic development will come from the unlicensed use of the White Spaces, why aren’t we protecting those uses?  I cannot help thinking that we might have done this wrong and have locked in the wrong incentives for the next 40 or 50 years.

Spectrum Auctions in Japan?!

Wednesday, September 22nd, 2010

I was not the first to advocate for spectrum auctions, only the most vociferous.

The Japanese wireless market must be for Evan Kwerel akin to what the Duck-billed Platypus is for Charles Darwin. The Platypus is an egg-laying, venomous, duck-billed, beaver-tailed, otter-footed mammal, and would seem defy evolutionary theory.

The Japanese wireless market is well developed, with at least 5 competitors offering some of the lowest priced, highest speed, and most advanced networks of anywhere in the world. Yet, according modern economic theory, this should not be. The Japanese government has never held an auction to assign spectrum licenses. Economic theory suggests that auctions are more efficient (see, Cool Stuff) at assigning spectrum rights to their highest monetary value use than other means such as comparative hearings (currently used in Japan) or lotteries. If you are interested in auctions in Tokyo have been in Tsukiji –  the 5 AM fish market – has traditionally been your best bet.

Charles Darwin

If it walks like a duck, and talks like a duck… this makes no sense, it can’t be a mammal.

I have head rumors that the reason the Japanese government has never held spectrum auctions was not for fear of creating distortions in the market but so as not to upset the balance of power among the various ministries (i.e. Finance, Industry, Posts and Telecommunications). The US Treasury and the FCC got along fine once the FCC started sending enormous checks.

That might all change as the government of Japan is considering how it might employ spectrum auctions. A friend in Tokyo sent me a recently published copy of the Cabinet’s decision on a new strategy for growth.  Item 35 on page reads as follows:

電波の有効利用のための制度の見直し (1)割り当て済みの電波について、より必要性の高い用途に利用できるよう、既存の利用者を他の周波数へ速やかに移行させ、迅速かつ円滑に周波数を再編するための方策について平成22年度に検討、結論を得、平成23年度に措置する。 (2)再編に要するコストについて、再編後の周波数を新たに利用する者が、市場原理を活用して負担する等、オークション制度の考え方も取り入れた措置について平成22年度に検討、結論を得、平成23年度に措置する。

Tsukiji

Maguro auctions at Tskiji.

My Japanese is not so strong, but if you read this in context as Kasumigaseki Bungaku (roughly, “Beltway Literature”), as I was admonished, you can interpret this mean that the Cabinet is directing the Ministry of Information and Communications to review how market forces can be employed to rapidly and efficiently reassign radio usage rights. According to my vague understanding of what is suggested, the MIC will pursue a limited use of auctions to reassign spectrum licenses. Auction prices will be limited to the costs of relocating the existing users from the band. The MIC will then auction participant’s bids as part of its analysis in some sort of comparative hearing. License winners will have to pay their bid eventually.

Auction Theory in Tsukiji

Ken, we want you to rework the Part 15 Rules for sashimi - we'll call it “Unlicensed and Uncooked.”

Insight: To be fair, I think this is a really clever idea, but am not convinced it will work. For my Next Generation Spectrum Policy study,  I considered a very similar idea, whereby the spectrum management authority would have access to pricing information to make band-planning determinations. This idea is, in fact, the origin of the term I coined for the study, “price-guided policy.” I eventually rejected the idea before concluding the study because I became convinced that as long as you are going through the trouble to hold the auction, you might as well have it do all of the hard work up to and including assignment. I am very curious to see how this develops. I am not sure whether auctions will make the Japanese wireless market more advanced, or whether they will simply screw things up. I will keep you posted.

The New Dutch Auction

Friday, May 7th, 2010

A Dutch auction is typically one where prices go down.  The auctioneer starts with a high price and then asks for lower prices.  The first person to call out gets the item at that price.  However, this is not how it worked in Holland last week.

A week ago, the Dutch telecommunications regulator Agentschap Telecom completed a spectrum auction for licenses in the 2.6 GHz band.  Five bidders spent just over €2.6 million to acquire 130 MHz of the 190 MHz in the band, but they did so in an unusual way.  Agentschap’s auction had two parts.  In the first part, bidders vied for a certain amount of spectrum.  In the second round, the bidders competed for specific 5 MHz blocks, with the option of single 5 MHz blocks of unpaired (TDD) spectrum or 2 x 5 MHz blocks of paired (FDD) spectrum.  This determined the pairing the band.  No FDD spectrum was acquired.

In this way, the auction determined whether the spectrum would be used for cellular type uses (FDD) or for WiMax-type uses (TDD).  To my knowledge, Agentschap’s auction was only the second time an auction was used to determine not just assignment but allocation as well.  In 2008, ComReg in Ireland used a very similar auction in the 26 GHz band.

Insight:  In a previous Cool Stuff, I wrote about my work to design an auction which could not determine not only who gets the spectrum rights, but what the contours of those rights are.  I called this approach: Price-Guided Radio Policy.  Now, we have two data points to suggest that this approach can work and can efficiently determine not only spectrum assignments but allocations as well.

The Spoon

Wednesday, May 5th, 2010
Don't try to bend the spoon.

Don't try to bend the spoon.

In the classic 1999 film The Matrix, the protagonist, Neo, played Keanu Reeves, goes to see an oracle.  In the waiting room, he happens upon one of the oracle’s child disciples who is sitting zazen and melting a metal spoon with mind.

Spoon boy: Do not try and bend the spoon. That’s impossible. Instead… only try to realize the truth.

Neo: What truth?

Spoon boy: There is no spoon.

Neo: There is no spoon?

Spoon boy: Then you’ll see, that it is not the spoon that bends, it is only yourself.  (Source IMDB)

By the same token, I have long wondered if there is no radio spectrum.  This fact is among the reasons that the unlicensed regime works so well.  It is spectrum policy, just without the spectrum

The jurisprudence underlying the Part 15 rules is that unlicensed spectrum is not spectrum at all…. It is merely an idea – a concept – a way of describing and organizing the physical world in our minds and in our actions. Spectrum is a legal and engineering construct to control for an immutable fundamental physical property… (Source: Unlicensed to Kill)

The Part 15 rules simply consider what is the maximum amount of irradiated power which can be emitted by a device without an unacceptable probability of causing harmful interference.

However, most of spectrum policy other than the Part 15 rules deals with regulating the “airwaves”.  Yet treating radio operations as spectrum or airwaves or property is a false paradigm.  This point was driven home to me a few years ago when I was an FCC staffer.  I was once filling out my timesheet at the FCC.  One of the lines on the sheet was “spectrum” and it dawned on me that I was spending more than 66.7% of my time dealing with something which had momentum, but no mass.  Somewhat paradoxically, electromagnetic energy behaves simultaneously like a wave and like a particle, carried by photons.  This is an important and powerful observation.  In fact, it was for this observation (the so-called photo-electric effect), and not General or Special Relativity, that Albert Einstein was awarded the Nobel Prize.

So, while we are regulating the airwaves, who is regulating the photons?!

Insight:  I raise this issue now because just last week the FCC announced the (re)establishment of its Spectrum Task Force.  Honestly, I am not exactly sure what implications for radio policy of considering the dually of electromagnetic radiation as both a wave and a particle might be; however, going forward perhaps the STF should undertake critical rethinking of this crucial policy area from the basics up.

Since we cannot bend the spoon, perhaps it is time we bend ourselves.

Wi-Fi? Wi-Not?

Thursday, February 18th, 2010

In the past several weeks, there have been several news articles and blog posts about the possibility of Wi-Fi being a solution to congested mobile networks.  There was a piece in Total Telecom, one by Maggie Reardon, and one by Stephen Rayment for the FT.

The argument is that the widespread adoption of smart phones and mobile Internet has congested mobile wireless networks to the breaking point.  In order to alleviate congestion on their 3G or 4G network, carriers could offload traffic onto Wi-Fi networks (including those of other operators).  This would free up the carriers’ limited spectrum resources which they obtained at auction through the licensing process.  And, it could be done more cheaply than upgrading existing cell sites. (Dana Blankenhorn at ZDNet correctly points out the inconsistency of giving more spectrum to wireless carriers if unlicensed operation is the solution. It was not so long ago that wireless carriers were crying foul that all Wi-Fi networks such as the now defunct Cometa presented unfair competition because they had not spent billions to acquire their licenses at auction.)

Insight:  Integrating mobile networks with Wi-Fi is a good idea.  It is, however, not a new one.  At a conference nearly eight years ago at Columbia University and in the ensuing paper, I suggested that wireless carriers consider incorporating Wi-Fi into their networks.  My reasoning was not so much about load balancing as it was about market segmentation.  Complementing existing 3G networks with Wi-Fi would enable carriers to offer tiered services – a best efforts service and a better than best efforts service – charging different prices for both and increasing profitability.  I also suggested it would be possible to use spectrum not licensed to the carrier such as the spectrum which has been allocated to CB RadioGMRS, or FRS.  A 2003 FCC rule change would allow handsets cable of operating both on mobile networks and in these bands. In this way, carriers could offer services like push-to-talk or walkie-talkies without encumbering their already burdened spectrum and networks. Users would be able to speak directly to others in their area, even users on other carriers’ networks.  Alas, there was not much economic incentive for carriers to sell such handsets because it would reduce the mobile termination revenues which carriers charge one another (and eventually their subscribers) for completing calls over their networks.  However, with the balance of market power tipping away from networks and in favor of handset providers recently, it might be possible that we would see such enabled handsets in the next few years.

Next Generation Spectrum Regulation

Wednesday, December 9th, 2009
Spectrum band plan created by price-guided mechanisms

Spectrum band plan created by price-guided mechanisms

Winston Churchill famously said, “democracy is the worst form of government except all the others that have been tried.”  Perhaps the same can be said of spectrum auctions.  Auction mechanisms have been used starting in New Zealand in 1994 to award spectrum licenses to those who have the highest monetary value. Spectrum auctions have generally been highly effective, with the occasional failure.

Despite their success, auctions have some notable drawbacks such as the so-called winners curse and the fact the up-front license fees require spectrum users to raise capital beyond the princely sums necessary to build a wireless network – a barrier to entry.  However, auctions are far better than the administrative processes which have been used for nearly a century to determine spectrum assignments.  Administrative decisions tend not to be economically efficient because the regulator has limited access to information which market participants would be more able to amass and utilize. There are also problems of political independence and of regulatory capture.

While auctions have been used to determine who gets spectrum rights, they have not really been used to determine the contours of those rights.  These contours are still determined through administrative decisions.

I have just completed a major study on next generation spectrum regulation which can serve as the basis for removing certain barriers to spectrum access, allowing more effective sharing and efficient allocations.

I can think of no reason why a properly designed auction could not determine not only who gets the spectrum rights, but what those rights are.  (Think of it this way: an auction on eBay for a car could determine not just who gets the car, but the color of the car and whether it comes with, say, leather seats or alloy wheels.)  I built a mathematical model of a next-generation spectrum auction using the Shannon-Hartley Theorem as a means modeling behavior by valuing the spectrum when considering the actions of other would-be users.  In my model bidders could express their demands for not just bandwidth, but power, modulation, underlay/interference, and other characteristics.  When I ran an MS Excel-based version of the model, the result was a mix of high and low power uses in the winning bids.  The low power bidders (similar to UWB spectral densities) could in a second round be aggregated into some form of licensed commons with the coordination protocol determined in that part of the auction.  The outcome would resemble a shared use or common arrangement where no one party controlled the spectrum.  However, the most interesting thing was that because bidders could obtain spectrum allocations that more closely fit their needs, more than 40% of the spectrum bandwidth available in the auction was left unsold.  This spectrum was valued by the market to be best allocated to either public sector use or even low- to mid-power unlicensed use.

Insight:  You cannot see, touch, taste, smell, or hear radio spectrum.  Spectrum is not a thing; it is an idea – a legal and engineering construct that explains a physical phenomenon and helps us arrange our behavior accordingly.  That fundamental physical phenomenon is the fact that when electromagnetic waves are: (1) harmonic in frequency; (2) incident in time; and (3) alight on the same reception device, the ability of those waves to be used as information carriers is degraded.  This deleterious effect is known to us as interference.  Without some form of intervention, it is impossible to exclude or limit the use of a common resource such as spectrum. Without exclusion, users consume the spectrum without regard to fact that their usage causes the deleterious effect of interference for other would-be users.  Policies which help to mitigate inference with the least amount of effort will be the most socially beneficial.

Unlicensed and Unleashed

Monday, July 28th, 2008

My article Unlicensed to Kill: a Brief History of the FCC Part 15 Rules has just gone to press and will be published in the journal Info.  I originally gave the paper at The Genesis of Unlicensed Wireless Policy conference organized by Tom Hazlett at George Mason University Law School.  (Yes, dear reader, Tom Hazlett hosted a conference on unlicensed.  The Seventh Seal is broken and the End of Days is truly upon us.)

The conference looked at the origin and evolution of the FCC’s Part 15 rules.  There were several interesting takeaways.  Most of these are lessons which we already know, but all too often take for granted.  Keynote speaker Michael Marcus reminded the audience that people frequently act in their short term interest, in a way in which they foreclose long-term opportunities for themselves.  Dr. Marcus described the regulatory battles of the 1980s during the FCC’s rulemakings where cordless manufacturers fought fiercely, opposing certain rule changes.  These rules now enable most of the cordless phones these manufacturers now sell.  The closing keynote, Dewayne Hendrix pointed out how spectrum policy the cognitive dissidence spectrum policy faces in affording interference rights.  We allow licensees to “whine” about interference when they use decades old technologies which do not have the ability to reject unwanted signals which more modern gear does.

Insight: In the US, there is no such thing as unlicensed spectrum.  Rather, and this is an important distinction, the FCC allows low power operation on a sufferance basis, proved the devices cause no harmful interference and accept all received by them.  Operators have a right, but not a vested right to continued operation.  The FCC has historically viewed the radio energy emission from these devices as not rising to a level sufficient to call “spectrum”.  This has left me wondering if there is no such thing as spectrum at all.  Spectrum is a legal and engineering construct to control for an immutable fundamental physical property.  When multiple electromagnetic waves, used as carrier waves to transmit information are incident in time, harmonic in frequency, and alight on the same reception antenna, they degrade one another’s ability to transmit information.  Next generation radio policy will focus more on solving the coordination/congestion problem, and not on “spectrum” per se.  (I also gave a really cool PowerPoint.  (Click to start, click to advance each slide after the animation stops).

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.

Safety First: Reinvesting the Digital Dividend

Sunday, May 4th, 2008

My report on Public Safety and Security spectrum use in Europe publishes today. In the report, we marshal the policy and technological arguments for a reallocation of further dedicated spectrum for mission critical PSS communication from the transition to digital terrestrial television, the so called Digital Dividend. The website for the study is: http://www.public-safety-first.eu/. For the first time since I served on the FCC’s Hurricane Katrina response team, I have felt that my work has served a critical societal need. Yet, as an American who is used to being constantly bombarded with the need for homeland security, it was a bit surprising to me that PSS communications has received little attention in the discussion regarding how to redistribute this radio spectrum. So, it has been personally rewarding to influence the debate in at least some small way.

Insight: PSS service responders provide us with indispensable police, fire and other emergency services and the provision of emergency services extends beyond the social contract and invokes a moral obligation to protect life, welfare, and property. In order to enable the necessary broadband communications for next generation PSS communications, they will require two additional 15 MHz-wide blocks in the Digital Dividend bands. This allocation is on par with the 24 MHz which the US is reallocating from its DTV transition. A reallocation to PSS use cannot come soon enough since it may take more than ten years, to plan and deploy these networks.