[IP] CD's summary of comments filed on FCC SPTF Docket 02-135

[Dave Farber <dave@farber.net>]

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From: Dewayne Hendricks <dewayne@warpspeed.com>

[Note:  Here's an advanced look at some of the comments that were
filed on the FCC's Spectrum Policy Task Force's final report that
will be published in 'Communications Daily' tomorrow.  Let the
spectrum wars begin!  DLH]

COMMUNICATIONS DAILY WEDNESDAY, JANUARY 29, 2003

Microsoft: Be Bold
SOME URGE CAUTION ON SPECTRUM TASK FORCE RECOMMENDATIONS

Wireless carriers raised concerns to FCC late Mon. that "interference
temperature" touted by agency's Spectrum Policy Task Force report
wasn't yet backed up by real-world information, such as noise floor
data. Responding to task force recommendation, several commenters
cautioned Commission against basing spectrum allocation and policy
decisions on technology advancements that hadn't yet materialized.
Among common themes that emerged in comments this week was need for
more unlicensed spectrum, requirement for additional public safety
bands, concern over auctioning of satellite spectrum. Task Force's
recommendations in Nov. for updating FCC's spectrum management regime
concluded access to spectrum was larger problem than was scarcity. It
recommended that Commission increase access to spectrum for both
licensed and unlicensed operators through more flexible user rights.
Industries from broadcasters to unlicensed spectrum developers to
satellite companies have been closely watching recommendations for
clues as to how FCC would strike balance between allowing more
flexible use of new technologies versus protecting incumbents.
Several carriers and groups expressed concern about using
interference temperature before FCC had more data. Point of concept
would be to place ceiling on noise environment in which receivers
would be required to operate. To extent "temperature" in particular
band isn't reached, user that emits energy below that threshold could
operate more flexibly. That temperature would put cap on potential
radiofrequency (RF) energy that could be put into particular band.

That concept "places complete faith in the Commission's ability to
set permissible levels of increased interference for all interference
environments and declares that futuristic unlicensed devices will be
able to gauge the interference temperature and only operate below the
cap," AT&T Wireless said: "There is no basis to conclude that this
approach is practical, technically feasible in any meaningful time
frame or enforceable." Carrier said follow-up information Commission
should gather before putting idea into force should include: (1)
Noise floor variations among different environments and "how the
noise floor is expected to evolve." (2) Various interference sources,
including out-of-band emissions, spurious emissions. (3) Impact of
interference on system design, including cell size, power levels,
handset capabilities. Motorola said interference temperature offered
potential benefits in "long term" to apply more of quantitative
approach to interference management. But company stressed short-term
technical challenges: "The interference temperature theory envisions
the dynamic ability of unlicensed transmitters to detect
communications traffic within licensed spectrum bands." Motorola said
task of controlling influence of transmitter's emissions on remotely
located receiver was very complex. It listed "technical hurdles" that
had to be overcome before interference temperature could be used.

Company said idea was "a long way from being ready for routine
deployment in the real world as a reliable spectrum management tool."
Motorola also: (1) Urged caution on report's consideration of
exploiting "time dimension" of spectrum management. Report
recommended FCC increasingly take into account time dimension of
spectrum management, instead of just geographic or frequency-based
licensing. Example would be allowing more dynamic allocations of
spectrum rights or allowing services such as public safety to lease
excess capacity to nonrelated users during periods when band
otherwise would be unused. "Considerable work remains to be done to
fully understand how the time dimension can be exploited," Motorola
said. While such arrangements may help in some cases, they aren't
"adequate substitute for spectrum allocation and management." (2)
Warned that generic receiver standards would be inappropriate because
such performance specifications were system dependent. It said
industry developed receiver specifications could help in particular
cases to resolve spectrum incompatibilities.

Public Safety Needs Stressed

Several commenters took report to task for not going far enough in
recommendations on public safety. Motorola said report implied no
further allocations of dedicated spectrum for public safety were
needed. "None of the alternatives to dedicating spectrum for public
safety use that the task force suggests -acquisition of public safety
spectrum in public auctions, or access to commercial spectrum via
easement or 'priority access' mechanisms -are viable at the present
time or at any time in the foreseeable future," it said. Assn. of
Public Safety Communications Officials International (APCO) cited
1996 Public Safety Wireless Advisory Committee (PSWAC) report that
said public safety users would continue to require additional
spectrum. "Since September 11, 2001, those demands have only
increased," APCO said. While some new public safety allocations have
been made since 1996, much of spectrum is unusable until DTV
transition is completed, it said. Task force suggested leasing option
should be available to public safety users during down times, with
mechanism for taking back capacity immediately when needed. "While
this approach may have some theoretical appeal, it would face major
technical, legal and practical impediments," APCO said. Group said
that for many public safety agencies, radio use was virtually
constant and data communications were putting new demands on
capac-ity. "Thus, the potential for leasing public safety spectrum
capacity is probably much less than the Task Force may perceive,"
APCO said. Another task force proposal was to reassess Orbit Act to
consider permitting, but not requiring, FCC to use competitive
bidding for spectrum for international satellite services. Satellite
Industry Assn. (SIA) said it strongly opposed any effort to do away
with act's no auction provisions. To provide more flexibility in
licensing satellite spectrum, task force suggested FCC consider
floating statutory proposal that would reexamine Sec. 647 of Orbit
Act to weigh permitting, but not mandating, competitive bidding to
resolve mutually exclusive applications. "The Task Force report
neither dis-cusses, nor even recognizes, the rationale behind the
statutory prohibition," SIA said: "It makes no effort to acknowledge
the complexity or danger of auctions for international or global
satellite systems, opting instead simply to note that auctions might
be useful for increasing flexibility." SIA said report didn't spell
out how auctions would advance flexibility or "why this goal is worth
risking significant and unpredictable financial damage of a vital
U.S. industry." Group said task force's recommendation was based on
"purely theoretical assumption" that satellite industry was
interested in obtaining licenses that provide for full, flexible
spectrum use. "There is no indication that there is any such interest
in full flexible use," SIA said. On spectrum for unlicensed uses,
Microsoft said task force indicated more should be allocated for
primary use of unlicensed devices. "Unfortunately, with respect to
where that spectrum should be located, the report is perhaps too
timid," company said. It noted report recommended that new unlicensed
spectrum generally should be found above 50 GHz, while in bands below
5 GHz FCC should focus primarily on using exclusive licensing.
"Because only lower bands permit longer range propagation, limiting
primary unlicensed operation to the upper bands necessarily means
fewer unlicensed broadband networks that are available for easy
consumer access," Microsoft said. That would curtail applications
that had potential for greatest public benefits, it said. Company
urged FCC to be "bolder" in approaching rules on primary allocations
for unlicensed services. Spectrum set aside for primary use of
unlicensed services should incorporate some interference protection
for those services, Microsoft said. Nature of unlicensed devices is
that they don't receive interference protection from one another.
"There is no reason why users of unlicensed devices in any band
allocated primarily for the unlicensed services should not be
entitled to reasonable protection from out-of-band interference, as
well as from later approved licensed services," Microsoft said. NAB
and MSTV encouraged Commission to "commit itself to successful
completion of digital transition" before considering additional
policy changes affecting broadcast spectrum, and to address
interference that could result from some spectrum sharing ideas
outlined by task force. If FCC wants to conduct experiment with such
ideas, it should use spectrum other than that assigned to TV, they
said: "Injecting additional uses of already crowded broadcast
spectrum will obstruct and burden the transition, draining its
momentum." NAB and MSTV said FCC priorities should include preserving
of benefits of analog broadcasting and future benefits of digital
broadcasting, relying on actual interference levels and committing to
remedy existing interference problems caused by incorrect
predictions. Some wireless carriers showed strong resistance to idea
of authorized "underlay" operations in licensed spectrum. CTIA
reiterated concerns that "unbridled" additional service flexibility
not involve incumbent licensees. "A grant of 'retroactive'
flexibility to an incumbent licensee not subject to market incentives
for an entirely different service than contemplated in the original
allocation and licensing scheme, for example, may result in spectrum
inefficiency, raise interference concerns and create inequities that
will harm competition" CTIA said. Retroactive flexibility could
create distortions for competitive bidding process, group said. It
supported general idea of "threshold" to set maximum per-missible
interference levels, but said precise meaning of task force's
interference temperature wasn't clear: "CTIA cannot support the
concept without understanding how the theory would be rendered into
practice." Cingular Wireless said some task force proposals "would
seriously undermine the stability and vibrancy of the
telecommunications marketplace." Carrier urged FCC to reject proposal
to address spectrum scarcity issues by creating easements or
underlays in spectrum awarded under exclusive licenses. "Most of the
'commercial' spectrum below 5 GHz is extremely congested," Cingular
said. "Creating easements or underlays in this spectrum would merely
create additional technical problems for incumbent licensees who are
already struggling to satisfy demand." Cingular said Secs. 301 and
307 of Communications Act specified spectrum usage be permitted only
with license, except in limited cases. "The Commission cannot permit
unlicensed use that in any way undermines or diminishes the rights of
licensees using spectrum awarded pursuant to Section 301," it said.
Sprint raised similar concerns about interest of licensees,
"particularly as to spectrum won at auction." It urged FCC to not
impose underlays or easements in licensed spectrum. "These proposals
will jeopardize spectrum efficiency and compromise licensees'
rights," Sprint said. While better understanding of noise floor would
be helpful to protect incumbents' rights, those data didn't exist now
and "difficult methodological questions must first be resolved,"
Sprint said. It said FCC should turn to Technological Advisory
Council to develop proposed testing methodology for Commission
consideration and public comment. Several commenters said some of
technologies on which task force based proposed spectrum changes
weren't yet widely available. TIA said it supported ideas such as
better use of so called spectrum "white spaces." But it said some
technologies, such as software defined radios that were "completely
agile" in moving between operating frequencies, bandwidths and
modulation formats, were "not likely to be ready for commercial
availability for some time." Other factors, such as interference
temperature, are "unproven and undefined," TIA said. "Allocations
based on anticipated advances in technology are dangerous, and should
await the demonstrable existence of such technology at reasonable
costs for widespread deployment." -Mary Greczyn

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