More Bands Found for Fast Track Clearance, CSMAC Meeting Told

Nebbia said 1755-1780 MHz and 1675-1710 MHz looked like possible bands for pairing with AWS-3 spectrum. The agency’s primary focus now is on 1675-1710, he said. “The other two bands are others that we saw holding some possibility for rapid action,” he said. “For the past few months we have been meeting and discussing these.” The 1755-1780 MHz band has been the primary focus of carriers and is mentioned in the broadband plan for possible pairing with AWS-3 spectrum.

That band is still being looked at to see if the Department of Defense and other users can be relocated elsewhere, Nebbia said. Clearing that band would take considerable time, he said. “Certainly that band is going to be part of the broader work,” he said. “There will be certainly further discussions as we finish off the fast track work. … We do certainly recognize the place that it has in international agreements that already exist and what’s being done in other counties."

Nebbia said the 1675-1710 MHz band offers more potential for quick clearance, saying most users today are unregistered and unlicensed. “We are concerned about the people who are there,” he said. “There are issues that are going to have to be looked at in terms of obviously groups that have invested in what’s there. But in the long run we feel that our job is to locate opportunities and to move forward as aggressively as we can.” For these users of weather satellite data, “there are potentially other opportunities for them to get the data that they really need,” Nebbia said. “We're not doubting that they need the data."

The 3500-3650 MHz band is mostly a military radar band containing high-power air and ship-borne radar systems, Nebbia said. “We're looking at that very closely, mostly from the perspective of whether in certain portions of the band that most of the systems are out to sea we might get significant opportunities on the land side.” The 4200-4220 and 4380-4400 MHz band is on the “edges” of a radar altimeter band, Nebbia said. “The struggle there is that that band is committed internationally,” he said. “To turn that around to get a conclusive answer by Oct. 1 also from our standpoint has put that on the back burner."

As the demand for spectrum increases, there will be increased pressure on policy makers to develop new approaches to sharing spectrum, said David Donovan, president of the Association of Maximum Service TV, a member of the subcommittee on spectrum access. In many respects, the interference polices will have a significant impact on the development of new spectrum technologies, he said. These policies will also affect investment incentives in spectrum-based communications services, he said. The subcommittee encourages the Department of Commerce and NTIA to make significant investments to allow more spectrum sharing without causing interference to incumbent services.

The NTIA, FCC and other government spectrum managers should devote substantial resources to establish a wide-ranging evaluation process for new devices that use spectrum to transmit or receive signals, said the subcommittee’s report. Agencies with spectrum management responsibilities need to shift from an interference prevention-only approach to both prevention and enforcement as sharing opportunities become an important aspect of making more spectrum available to meet growing demands and introduce new spectrum-dependant applications, it said.

The subcommittee outlined principles that could guide NTIA and other government entities employing guardbands in spectrum policy. For new services, the spectrum used for such a guardband should come from a new service commencing operations and not an incumbent service. If an incumbent service makes changes to its system’s architecture or modulation technique that results in new interference, then the spectrum to be used to establish any guardband protections should be provided by the service making such changes. When allocating spectrum for new services, guardbands should not simply reflect current OOBE (out-of-band emissions) rules. A realistic assessment of the potential for OOBE interference should be analyzed to ensure the size of the guardband is appropriate.

NTIA, FCC and other agencies responsible for spectrum management should move forward with a complete spectrum inventory, recognize that frequency coordination becomes more complex when sharing spectrum with unlicensed devices, and coordination may be impossible if such devices are “untethered” or not connected to an accurate spectrum database or other management control system, the report said. The agencies should also use private market mechanisms like negotiated interference solutions to facilitate frequency coordination, it said. The creation of a spectrum database generally is essential to provide spectrum managers with information necessary for future spectrum planning, it said. The subcommittee supports current legislative and government efforts to inventory spectrum use by commercial and government entities.

While the CSMAC Incentive Subcommittee reached no consensus on spectrum fees, it’s putting forward an initial recommendation on rewriting OMB Circular A-11 and on creating a Spectrum Innovation Fund, said Vice President Michael Calabrese of the New America Foundation. The subcommittee will also be moving on to consider secondary market and spectrum leasing incentives, he said. The goal is an initial draft report by the next general CSMAC meeting. There was some support for the concept of a low, flat fee on all spectrum, which could be implemented more easily than a market-rate fee that would be more difficult and controversial to implement. There was substantial criticism of that approach from subcommittee members who contend that phasing in a more market-based pricing scheme is needed to internalize true opportunity cost.

Spectrum fees in the federal sector will have little or no impact on “the behavior we are seeking to impact, and/or are inappropriate considering the societal importance of the federal mission at stake, particularly among national security and public safety agencies that tend to occupy the largest quantities of spectrum,” Calabrese said. The Incentives Subcommittee will revisit this issue one more time.

The Incentive Subcommittee hasn’t reached consensus on the issue of a spectrum innovation fund. There is general agreement that federal spectrum use enables effective national security, transportation safety and other vital government functions that must be preserved while agencies promote continued innovation in spectrum use, Calabrese said. There has been little in terms of resources made available by Congress or NTIA to support such proposals, let alone support any such initiatives from a federal agency, he said. For fundamental shifts in domestic spectrum policy to be successful -- including the promotion of innovation in spectrum management -- new strategies and processes based upon technical, regulatory and policy studies are needed, the Incentive Subcommittee report said.

Some members of the Spectrum Sharing Subcommittee stressed issues like the need to create a document that explains the concept of spectrum sharing and lists various methods for sharing used in the past and proposed for the future, said SkyTerra Executive Vice President Gary Epstein. Members also stressed the need to address technical matters like the frequency range, which determines propagation characteristics, types of services, such as the fixed-satellite service sharing with a terrestrial mobile service, and the top-level regulatory framework for those services must be addressed to determine the general prospects for sharing.

To offer a comprehensive review of current and proposed unlicensed usage, the CSMAC Unlicensed Subcommittee will evaluate existing unlicensed technologies and deployments, ongoing FCC proceedings like the broadband plan, extending white space geolocation database to other spectrum bands and efforts to generate a spectrum inventory, said Clearwire Executive Vice President Gerry Salemme. Ultimately, he said, the subcommittee’s report will provide a detailed assessment of where the unlicensed spectrum industry now stands and what opportunities it may provide in the future.