Federal Communications Commission

You Can’t Coach Height: A Winning Spectrum Strategy

October 29th, 2009 by Blair Levin - Executive Director, Omnibus Broadband Initiative

Football analogies may be in poor form in Washington, D.C. these days as the Washington Redskins flounder.  But when I think about one of the biggest challenges we face in meeting the broadband needs of this nation - lack of available spectrum for mobile broadband --  I think of Doug Flutie.

Doug Flutie was a quarterback in both the Canadian and National Football Leagues.  Flutie was a great quarterback.  He had a lot of great attributes.

But he was 5' 10".  And while he had some great moments, let's face it, he was destined to be a star… in Canadian football.  He had a career very different from that of 6'2' Joe Montana, 6'4' Tom Brady, or 6'5' "Big Ben" Roethlisberger of Pittsburgh.

The point is this: Unless we get more spectrum, we as a country are destined to be the Doug Flutie of mobile broadband.

Spectrum is like height.  If you don't have it, it's pretty hard to be in the big leagues. As they say, you can't coach height.

Now it's not an exact analogy.  Technology and other capital inputs can help overcome the lack of spectrum.

But let's not kid ourselves.  Lack of spectrum will mean that our mobile service will be more expensive and of a poorer quality than if we had more of it.  And that's very bad news unless we figure out a way to solve that problem.

Why?  Mobile broadband is going to be the fastest growing segment in communications ecosystem. The 75,000 iPhone applications show us a huge pent up demand to do things to do things based on where you are, to do things no matter where you are.

And AT&T projects that by 2018 mobile data traffic expand by a factor of 250 to 600.

This is potentially a fantastic story for America.  It's the story of an America where citizens have access to information everywhere, and where entrepreneurs have the opportunity to reach consumers in ways never before possible, were no one has to be a prisoner of geography.

And, this story becomes even greater as we enter the era of pervasive computing, where devices and machines of every kind become "smart" by virtue of the wireless connections to the Internet.

But none of this can happen without spectrum.

The wireless industry says we need 800 Mhz more. How much is in the pipeline now?  50 MHz. And it's not very good spectrum for mobile broadband.

Moreover, it takes an average of 6 to 13 years to clear spectrum.  For example, in the Clinton years we sold about 198 Mhz. During the last administration, we sold about 276 MHz.

What does that mean?

A few years ago, the Congressional Research Service concluded that "American competitiveness in advanced wireless technology may be constrained by the limited amount of exploitable bandwidth that is available."

So the challenge over the next 110 days we have to develop a National Broadband Plan is to understand the tough trade-offs, come up with creative options, and produce a plan that can truly help deliver all the fantastic opportunities that mobile broadband can provide. Touchdown!

5 Responses to “You Can’t Coach Height: A Winning Spectrum Strategy”

  1. Ben Byrne says:

    I think the FCC ought to scrap its entire spectrum allocation system and start from scratch. Giving away free beachfront property to broadcasters than make a minimum effort to meet public interest standards - the stuff in their public files is a joke - doesn't make sense. Auctioning off huge swaths of spectrum to an ever-increasingly small number of incumbent wireless providers who then proceed to treat that spectrum as their own walled gardens (and not just something leased from the people) doesn't make sense either. While it was good to see the FCC reform the 700mhz analog tv band auction rules to level the bidding field a little bit, it didn't go far enough to introduce more competition and innovation (witness Google's backing out).

    If you're truly interested in coming up with creative options, it's worth revisiting the entire concept of spectrum scarcity in light of technological developments that allow for "smart" devices to dynamically alter their spectrum use (I think the New America Foundation has thought a lot about this). Given the innovation we've seen in current unlicensed spaces - 802.11n is amazingly fast - we ought to be opening up more than the crappy little sliver we have now (and the other sliver that was tossed the public interest community's way as a part of the 700mhz auction) for unlicensed use.

    And finally, I'd love to see the FCC/NTIA develop a better relationship with the military to see if maybe, just maybe, there isn't some spectrum allocated to our armed forces that could be put to more advantageous use by the private sector.

    In short, I believe the FCC desperately needs to really look at "big picture" goals without getting caught in the weeds of appeasing competing interest groups of varying shapes and sizes (NAB, wireless mic people, device makers, etc), and perform a radical overhaul of our spectrum management system. I know given the number of devices/users in the field that a true revamp isn't really possible (it was hard enough just to transition to DTV) but it is *sorely* needed.

    My two cents.

  2. Jim A says:

    There has got to be a number of ways to use the same channels by many users at the same time.. a version of mobile Ethernet..

  3. concerned says:

    Mr. Levin: Your post does not one time mention anything about the other uses spectrum is put to. You do not mention that it's used to operate radars that allow us to navigate aircraft safely around the country. It's used for other radars that allow us to spot incoming hostile objects like missiles. It's used by policemen, firemen, ambulance techs, and others that keep us safe. It's used by our military forces wherever they go (and during a disaster, they can operate HERE). It's used to distribute television and radio programs to stations and to users via satellite and terrestrially. It's used to control utility systems that deliver electricity, water, and natural gas, and remove sewage. There are dozens of other uses that have nothing to do with providing video games, or Twitter, or Facebook, but which have a whole lot to do with operating this society.

    Are you, Mr. Levin, advocating that the cost of all of those services provided by your government at all levels to go up because the government entities that do them now have to pay Verizon or AT&T or someone to use the spectrum they use today?

    You, of course, will hotly deny that that is your intention, but as has been said in the past, "The road to hell is paved with good intentions." You are going to need a lot more than good intentions to do this correctly.

    You also do not appear to understand, Mr. Levin, that this is primarily not an exercise in government, or in economics. Certainly those you answer to in Congress and industry don't understand this. Nevertheless, it is first and foremost an exercise in physics, because contrary to belief in so many government and industry circles, the laws of physics are not subject to Congressional oversight, Executive orders, or Judicial review. If the FCC fails to get the physics correct in their plans, it will not matter how much revenue is generated by the sale of spectrum, or the amount of new economic growth that the business community creates. All that and more will be required to fix the problems you create by ignoring the laws of physics in your rush to provide more spectrum for mobile broadband. In the limit, people may be killed by systems that don't function correctly any longer due to harmful interference from broadband emitters carrying Youtube videos. That's hardly the legacy you want to leave behind here, is it?

    How will you subject your plans to rigorous review by trained engineers that aren't under the FCC's wing (that IS how real science is done, by the way)? How can we possibly do a thorough engineering review of your plans and proposals in the 110 days you have left? Or are we just supposed to "trust you"?

    I must point out that your track record here is not encouraging. You failed to anticipate the problems that Nextel's operations in 800 MHz would cause to public-safety operations in nearby spectrum. You appear to have set the stage for the same thing to happen at 700 MHz. Your organization was reprimanded by a Federal court for deliberately withholding engineering information that supported a conclusion different from the one your organization desired to reach regarding Broadband over Power Lines. Given this evidence, how can we trust you to engineer correctly around those radars and other systems that we stake our lives and the survival and correct operation of this nation upon?

    It will probably take considerably longer than 110 days for you to do a complete, accurate, and relevant engineering analysis and subject it to outside peer review by other trained engineers. Does your organization have the courage to tell your masters that "it's just going to take longer"? Or will you buckle to them and put our lives and livelihoods at risk just to satisfy a political deadline?

  4. Brad Bowman says:

    As Comcast and Time Warner need a wireless strategy going forward they are starting to resell Clearwire's (CLEAR) WiMAX services( ). This represents a stepping stone towards the most immediate available solution to developing and deploying a viable and sustainable national broadband plan. This also can set the precedent for any changes the new FCC will make surrounding the 700MHz band ( ) [see subscript below]

    The new FCC is all about spectrum (or the lack there of) because of the growing demand for mobile broadband (internet access) and communications. As Comcast and Time Warner have abundant cash reserves they should be locking down wholesale agreements with Clearwire and coordinating with the States to provide a cohesive plan to work with all all the applicants they are now trying to shut down because of concerns that these applicants are stepping on their territory. ( ).

    Comcast/Time Warner/Clearwire could immediately create thousands of jobs by agreeing on concurrent build out of the 2.5GHz EBS (mobile) and 3.65GHz (fixed) WiMAX bands within their (our) markets. This would provide a robust, interoperable broadband network with ubiquitous wireless accounts for all individuals, households and businesses in all rural, metro, urban and suburban markets.

    3.65GHz Fixed WiMAX - local governments, school systems, libraries, colleges/universities, smart grid, public safety, workforce, non-profits, households, businesses.

    2.5GHz EBS Mobile WiMAX - mobile overlay for fixed, individuals, households, businesses.

    The FCC/NTIA/RUS need to step up and provide incentives for this type of plan as incumbent cable and telcom's are not going to go away and need to maintain ARPUs (average rate/revenue per user) and market share while building towards a national broadband plan.

    Please use the remaining $3.2 billion to provide incentives to make this plan happen.


    [Subscript] In 2004 the past FCC changed the rules on the 2.5GHz Instructional Television Fixed Service (ITFS) band which allowed Sprint & Clearwire to approach non-profits within our communities to lease this very valuable asset. These non-profits include state universities and university systems, public community and technical colleges, private universities and colleges, public elementary and secondary school districts, private schools (including Catholic school systems in a number of large metropolitan areas), public television and radio stations, hospitals and hospital associations, and private, non-profit educational entities.

    Ironically, these are the same agencies that now qualify for broadband stimulus funding but have signed away their rights to the asset they have maintained for decades. They must now wait on Clearwire (middle man) to launch within their respective communities/markets.

    Clearwire (CLEAR) now has rights to 85+ percent of this spectrum, nationwide. ( )


  5. Brett Glass says:

    The maxim that "you can't coach height" is very apt.

    Here in the United States, we have thousands of small, independent ISPs -- many of whom are eager to make use of spectrum in ways that would be tremendously beneficial to the public. And there are willing customers who would love to patronize them.

    Unfortunately, under the current auction regime, these companies' chances of obtaining spectrum with which to provide wireless broadband service is just about zero. They're small businesses, without millions of dollars of capital on hand... and you can't coach business size. (Nor would you want to, even if you could. One of the best things about these business is that they are small, local, and "hands-on.") They thus must survive by attempting to operate in the Part 15 unlicensed bands (also called the "junk" bands), in which a single pair of wireless headphones or a baby monitor can wipe out an ISP's service to tens of square miles.

    Coaching these ISPs to "get in there and bid" -- analogous to coaching a tiny athlete to "get in th ere and try harder" -- won't do a thing. The entire auction regime -- in which licenses must be paid for upfront rather than out of revenuesover time, large spectrum holders are allowed to accumulate more before using what they have, and deployment requirements are routinely waived at renewal time -- is irrevocably slanted toward large players.

    What's more, as any economist can readily demonstrate, the foreclosure value of spectrum (the value to an incumbent of buying it to keep competitors out) is much, much greater than its utility value (the value to a newcomer of buying it to put it to productive use).

    I, personally, once entered one of the auctions and attempted to bid on a small sliver of spectrum in my region. It wasn't enough spectrum to provide the sorts of speeds I really wanted to provide, and the area covered by the license was sparsely populated and extremely difficult to serve. Even at my maximum bid it was questionable whether I or any other bidder would get a positive return on my investment in the end.

    Yet, I was outbid by a factor of 50 by a nationwide cellular provider, which is sitting on the spectrum and doing nothing with it. (I could not have afforded to sit on it for a day; I would have started getting radios built and mounted on users' homes immediately.) To this day, that spectrum is still sitting fallow and unused, while I would have immediately put it to productive use. And neither that spectrum nor any like it is available on secondary markets, since the entire purpose for which it appears to have been obtained was not to deploy broadband but to shut out competition.

    Because current law makes it extremely difficult for the Commission NOT to auction spectrum, the Broadband Plan must include a recommendation to Congress that it change the law so that a small, local, or independent provider can obtain at least a small plot of ground to till. It doesn't need to be exclusively licensed -- in fact, it's better if the majority is not, because we don't want to lock out innovators who come along later. So long as spectrum etiquettes are mandated, the spectrum can be shared. But it's vitally important to broadband deployment that current practice not continue.

    In the meantime, I, as a WISP, face the constant challenge not only of deploying broadband to very remote rural areas but also of dealing with interference from consumer devices, competitors' equipment, and the wireless networking equipment of third parties. This interference makes me less productive (because I must spend time engineering around it), increases both my costs and my customers' costs, impacts the reliability with which my customers can communicate with my network, and in some cases precludes me from reaching distant areas at all.

    It's heartening to hear that the Broadband Plan team recognizes the need for more spectrum. But it's equally disheartening to read, above, that the success of spectrum deployment seems to be measured purely in terms of megahertz "sold" (it is licensed, not sold). A better measure would be megahertz x square miles in which it is actually put to productive use.

    What's more, the total above does not mention the unlicensed and nonexclusively licensed spectrum that was released during the same periods, as if that spectrum did not count.

    To ensure that the spectrum that is released is actually used to solve the problems of broadband deployment, penetration, and affordability, we must also make sure that it is released in such a way that it cannot be hoarded; that innovation and competition are not foreclosed; and that small businesses have every bit as much of a chance to use it to serve their communities as huge, nationwide carriers. We'll make more productive use of the spectrum than the big guys.

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