The President’s Council of Advisors on Science and Technology, or PCAST, recently released a Report on “Realizing the Full Potential of Government-Held Spectrum to Spur Economic Growth.”  The recommendations contained in the Report were driven by the fact that mobile data volumes continue to grow at an astounding pace, and that responding to this demand curve is vital to continued U.S. economic growth, competitiveness and technology leadership.  On these points, we fully agree – there are few issues as pressing for the telecommunications industry as freeing up additional spectrum resources to meet demand and foster sustained economic growth in the wireless sector.

The Report’s core recommendations, however, have generated significant controversy.  The Report found that the new norm for spectrum use should be sharing, not exclusive licensing.  While we agree that sharing paradigms should be explored as another option for spectrum management, sharing technologies have been long promised but remain largely unproven.  The over-eager pursuit of unlicensed sharing models cannot turn a blind eye on the model proven to deliver investment, innovation, and jobs – exclusive licensing.  Industry and government alike must continue with the hard work of clearing and licensing under-utilized government spectrum where feasible.

On that point, we were heartened by statements made by Tom Power, White House Deputy Chief Technology Officer for Telecommunications, in the days following the Report, clarifying that the Administration has not given up on making parts of 1755-1850 MHz, which he called “this most appealing of spectrum,” available for exclusive commercial use.  As reported by Communications Daily, Mr. Power noted that NTIA has concluded that there are significant opportunities for clearing in that band within the next five years.  We were also happy to hear Mr. Power recommit to the Administration’s goal of reallocating a full 500 MHz of additional spectrum for commercial mobile use.

Similarly, we were encouraged when John Leibovitz, Deputy Chief of the FCC’s Wireless Telecommunications Bureau, noted earlier this week that the Commission will continue to follow three “parallel paths” to making more spectrum available for broadband:  removing obstacles to spectrum use; employing new tools to bring licensed allocations to market; all while keeping their eye on “new frontiers.”  This we can fully support.

The PCAST recommendations, on the other hand, were much more narrow in their vision.  Our concerns with the Report fall largely into three broad categories:

Investment:  The Report readily acknowledges the benefits that have flowed from the current exclusive licensing regime, yet gives little credit to the massive private investments that those licenses permitted – investments that are the foundation of U.S. wireless leadership today.  Licensed spectrum offers a critical cornerstone of certainty on which billions of dollars of capex have been and will continue to be committed.  The report’s preferred model – shared, secondary, unlicensed access over a small cell network – leaves unanswered significant questions about how that model will attract capital. 

It is true that carriers are investing in Wi-Fi networks today, but as a complement to their macro network deployments, permitting the offload of traffic to ease constraints and improve performance on their macro networks.  Small cell deployments by themselves are an expensive and incomplete solution, and an approach that does not support the type of full mobility and ubiquitous coverage that drive customer satisfaction.  A shared access system with limited licensing rights, no renewal expectancies and the prospect of service pre-emption by the primary government user creates a challenging environment for the commitment of investment dollars.

Unfortunately, the PCAST membership did not include a single wireless carrier, a single equipment manufacturer or a single chipset maker, and the Report’s recommendations surely would have been strengthened by perspectives from the companies that are currently investing billions to develop and deploy advanced wireless networks and technologies.

Technology:  The Report invests a lot of faith in sharing technologies, including dynamic spectrum access, the use of databases to define access rights and sensing technologies.  Few of these technologies have been proven in the marketplace.  In fact, the FCC has refused to rely on sensing technologies for access to TV white spaces even though that radio environment – with its fixed high power services – is ideal for that approach.

And while the Report cites developments in the white spaces as evidence that the technology is maturing, consumer products in that space have been long promised with limited actual delivery.  A white spaces database-driven network has been launched in Wilmington, N.C., but it has not yet been proven that such a network can scale or effectively deliver a robust mobile broadband service.  And recently the FCC’s OET acknowledged that the first mobile white spaces devices are “at least several years away.”

My argument is not that an unlicensed spectrum sharing paradigm can’t succeed, but the degree to which it can succeed is still largely unknown.  Spectrum sharing is certainly worthy of further exploration, particularly in bands ideal for unlicensed use such as the 5GHz range, and we support a targeted pilot program as recommended by the Report.  We also applaud the Report’s attempt to address the current lack of incentives for efficient federal government spectrum use.  But it is too early to permit aspirations for an unlicensed regime to supplant the time-proven approach of licensed spectrum allocations; and it is premature to declare spectrum clearing unsustainable.

Spectrum efficiency:  The Report argues that the “new spectrum superhighway” that will be created through the identification of 1,000 MHz of federal spectrum for sharing will increase data capacity by “1,000’s of times.”  But the Report fails to consider that efficiency gains in heterogeneous networks come from the coordination of small cells with the macro networks, not from the deployment of small cells in isolation.  Studies have demonstrated that tight integration of low power nodes with the macro network provides substantial gains over the uncoordinated approach inherent in an unlicensed system.  Indeed, Qualcomm is already investing heavily in LTE Advanced HetNet technologies, important advancements not properly considered in the Report.

And although the Report correctly criticizes the fragmentation of current licensed spectrum bands, the fragmentation problem is not driven by the fact that the spectrum is licensed, but rather by the manner in which the bands were originally made available.  Insightful band planning can remedy much of the prior ills, and the FCC’s recent Band Design Workshop is strong evidence that the fragmented band design mistakes of the past are understood and will not likely be repeated. 

The lion’s share of wireless spectrum suitable for commercial wireless use is currently licensed to government users.  We cannot and should not avoid the hard work of identifying which of those bands can be cleared and reallocated for licensed wireless use.  Even if the band cannot be fully cleared, we must explore exclusive licensing models that permit/protect government incumbent use in defined time, geography or frequency exclusions.  Granted, this task will not be easy, but we cannot afford to turn our back on the licensing model that has put the United States at the forefront of the wireless broadband revolution. The stakes are too high and the consequences of being wrong about the promise of an unproven unlicensed approach too extreme.

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