Improving Federal Spectrum Systems
Last Friday, the Information Economy Project (a project of the George Mason University School of Law and Clemson University) held the best little spectrum conference Washington has seen this year. The discussion, Spectrum Beyond Incentive Auctions, featured a keynote by Blair Levin, architect of the National Broadband Plan, assessment of spectrum allocations since 2010 by Robert Kaminski, and a panel discussion on spectrum issues and the FCC featuring host Tom Hazlett, former FCC commissioner Harold Furchgott-Roth, former FCC staffer and Wi-Fi enabler Mike Marcus, and yours truly. I was the only panelist who has never worked at the FCC, as it turns out.
I discussed a paper I’m writing about how to free up the radio spectrum that’s currently assigned to the federal government for use by the people and the firms that serve our communication needs. As things currently stand, the government has control of more spectrum in the sub-3 GHz frequency bands that are vital for mobile networks (AKA “cellular”) and Wi-Fi than we do: 1200 to 1500 MHz for the government, depending on how you measure it, to 500 – 700 MHz for licensed mobile, 2.4 GHz Wi-Fi, and Sprint’s Clearwire bands.
As Levin pointed out, the discussion about how to motivate government users to slim down their spectrum holdings has failed to achieve meaningful results because it has focused on half-measures such as the PCAST Report’s sharing and “spectrum currency” recommendations when government only responds to actual orders. Government is good at following orders and not so good at exercising ingenuity and creativity, and that’s by design.
The PCAST Report isn’t the worst thing the federal government has ever done with spectrum; the Defense Department’s Joint Tactical Radio System probably holds that honor. The JTRS project wasted $6 Billion over a 15 year span on some cognitive radio technology that will never be ready for prime time. JTRS radios took ten minutes to boot up and ran out of battery power in 30; while the project was being developed, the DoD “spent $11 billion more on “legacy” radios based on technology from the Cold War.” The PCAST Report was reluctant to see this project for the failure it was for some rather personal reasons. I’d like to avoid boondoggles like this in the future.
I’m developing the idea of creating a Federal Spectrum Service, a government chartered for-profit corporation, to serve as the owner of all federal spectrum. The FSS would control all federal use of spectrum, and manage it according to a ten-year plan for reducing the federal spectrum footprint in two stages. In the first stage, the FSS would be required to reduce the federal spectrum footprint by 50%, and in the second stage it would be required to reduce it by 50% once again. The spectrum thus liberated would be auctioned for public use. Once this mission is accomplished, the FSS would cease to exist unless Congress explicitly re-authorized it to continue in some form.
The FSS would have the power to meet this mandate, as it would assume immediate ownership and control of all federal systems that use spectrum directly, either as transmitters or receivers. Therefore the FSS would be able to replace current systems with new ones that would use spectrum more efficiently and to auction the spectrum it frees up for public uses.
As a single entity with control of federal spectrum use, the FSS would not be affected by agency infighting and the fragmentation of spectrum expertise across the panoply of agencies. If the FSS finds the PCAST Report’s sharing recommendations sensible, it would be able to test them by having agencies share spectrum with each other.
While all of the liberated spectrum would be auctioned, it wouldn’t all necessarily go to the highest bidder. There is a continuing role for what we have come to know as “unlicensed” spectrum, but it needs more constraints than it currently has. It’s better to assign the Wi-Fi spectrum to an organization like the Wi-Fi Alliance than to simply open it up to use by any device meeting the FCC’s current transmit power limits. The 2.4 GHz band chiefly used by Wi-Fi today is also used by obsolete, legacy devices such as analog baby monitors and legacy versions of Wi-Fi such as the original 802.11 standard (with no letter) and by 802.11b. If the Alliance wants to rid the airwaves of these devices, it should be able to do so.
The proceeds from auctioning federal spectrum would easily pay for the equipment upgrades that would have even more spectrum available. The logic for the FSS follow the first of the ten principles I outlined in my TPRC paper last year: Upgrade and Repack. This method follows Cooper’s Law, the rule of thumb that bits/second/hertz/user spectrum efficiency doubles every 30 months. By allowing the feds 60 months to reduce its footprint by 50%, I allow for the development of new functions side-by-side with current ones.
I sent a copy of this paper to the House Energy and Commerce Committee along with answers to their 10 questions about spectrum policy. I still have more work to do on spectrum policy, so I’ll be expanding this theme for the rest of the year.