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The Record Is Clear: America Needs More Spectrum

April 8th, 2010 by Edward Lazarus - Chief of Staff

Many have noted recent comments by the CEO of Verizon Ivan Seidenberg casting doubt on the need to allocate additional spectrum for mobile broadband, a key recommendation in the National Broadband Plan.

The FCC based the spectrum recommendations in the National Broadband Plan on the public record generated by an unprecedented open and participatory process.

That’s why the recent statements by Verizon’s CEO are rather baffling. The fact is, Verizon played a major role in building an overwhelming record in support of more mobile broadband spectrum, consistently expressing its official view that the country faces a looming spectrum crisis that could undermine the country’s global competitiveness.

Verizon’s advocacy began as early as June 9, 2009, where their filing stated:

“Verizon Wireless believes it is vitally important for the federal government to identify spectrum bands that can be reallocated for future broadband use. Any policy or strategy to promote broadband access to acknowledge the need for more spectrum in order to meet the growing demand for wireless broadband.”

“The government has the responsibility to identify and license spectrum to serve the public interest.”

“Verizon Wireless believes that a more important goal of any spectrum inventory should be to identify any underused spectrum that can be repurposed to auction for broadband use.”

Verizon’s push for more mobile broadband spectrum continued in a September 30, 2009 filing, which notes:

“The Commission has identified only 50 megahertz of additional spectrum for next generation wireless growth. This total lags behind both the United States’ competitor nations as well as the ever increasing demand for mobile broadband services. Verizon Wireless therefore urges the Commission to undertake a targeted examination of spectrum to identify additional bands.”

“Recognizing that ‘the world is at the precipice of the full scale convergence of two powerful and sweeping forces: wireless mobility and broadband internet access,’ numerous studies have analyzed the growing market for mobile broadband and concluded that significant additional spectrum must be allocated in order to keep up with demand and changing technologies. These studies make clear the urgency with which the Commission must act to identify and allocate additional spectrum for wireless services in order to maintain and promote innovation.”

Indeed, the need for more spectrum is well documented in the many studies submitted into National Broadband Plan record. According to Cisco, North American wireless networks carried an amount of data equivalent to 1,700 Libraries of Congress. By 2014, Cisco projects wireless networks in North America will experience more than a 40-fold increase in data traffic.

Participating in a National Broadband Plan workshop on spectrum, Bill Stone, Executive Director of Network Strategy for Verizon Wireless noted that the company has recently experienced substantial data growth in its network and would need more spectrum in the coming years:

“I'll say in the five-plus year timeframe, I'd like to have north of -- I'd like to be in a position where I could acquire north of 100 megahertz.”

Even as recently December 2, 2009, Verizon Wireless, along with nearly 100 other leading companies from across the broadband ecosystem, sent a letter to Commission offering their help in pursuing more spectrum for mobile broadband:

“Our nation’s ability to lead the world in innovation and technology is threatened by the lack of sufficient spectrum for wireless broadband applications and services. As the chairman has said, there is a looming spectrum crisis. We applaud your candid acknowledgement of this fact and appreciate your efforts to close the spectrum gap.”

“Without more spectrum, America’s global leadership in innovation and technology is threatened. The undersigned urge you to allocate more spectrum for wireless broadband as soon as possible. Please let us know how we can help.”

Moreover, the wireless industry’s trade association (CTIA -- of which Verizon is a member) called for 800 Mhz of spectrum for mobile broadband -- 300 Mhz more spectrum more than the Plan recommended -- to address the looming spectrum crunch.

As the U.S. Department of Justice (DOJ) aptly summarized: "Given the potential of wireless services to reach underserved areas and to provide an alternative to wireline broadband providers in other areas, the Commission’s primary tool for promoting broadband competition should be freeing up spectrum."

The National Broadband Plan record contains widespread agreement and a solid foundation of factual evidence on the need for the FCC to pursue policies that would free up 500 Mhz for mobile broadband by 2020.

We hope to work with Verizon and other companies across the communications sector on ways to achieve the important goal of ensuring that the United States has world-leading mobile broadband infrastructure.

8 Responses to “The Record Is Clear: America Needs More Spectrum”

  1. Guest says:

    This is exactly why the FCC needs to be more data driven along with getting appropriate independent third party experts to validate the claims with reality. The FCC should be taking much of what each side has to say with a grain of salt.

  2. Keytarvillain says:

    This new era of consumer advocacy at the FCC is thrilling. I think the FCC should have full powers to regulate spectrum, to keep it out of control of the Telcom companies.

  3. Britt Burton says:

    Sir, I applaud the efforts of the FCC to meet the needs of the American People. Self-serving business interests, as represented by the CEO of Verizon to push some agenda to the detriment of the country, but to his companies profit, are not good for the Nation. In past the nation's telecom companies have routinely lobbied Congress for not only free and unfettered access to National Assets (such as spectrum, which I label as such because if Corporate America controls it, then the Public suffers) but also subsidies funded by the public to provide services upon which they then make an exhorbiatant profit.

    Please consider that this persons remarks are only intended to support his opinion that unless public policy is designed to line his pockets and force customers to pay more, he will continue to make up lies such as those recorded in his remarks.

  4. Brett Glass says:

    Please allow me to help explain Verizon's remarks.

    Verizon has, as it says, more than enough spectrum to serve its own needs for the foreseeable future. But in order to forestall competition, it needs to corner the market, buying up whatever remains so that innovators and would-be competitors cannot get any. It wants to secure this position as quickly as possible, and so is urging the Commission to auction it off under the existing rules -- which favor large incumbents such as Verizon.

    In other words: More spectrum is indeed needed, but not for the large hoarders of spectrum, such as Verizon and Sprint. Verizon's remarks are a strong argument for revision of the auction rules to give small, local, and competitive providers a chance to obtain spectrum, despite its high foreclosure value (see the DoJ's remarks to the Commission). Caps, stronger preferences for small businesses, revised rules, and more nonexclusively licensed spectrum (with rules similar to 3650 MHz, but with mandatory spectrum ettiquettes to ensure fair play) are all necessary.

  5. Guest says:

    How can there be a spectrum crisis because of the iPhone etc.. when AT&T hasn't even deployed 3G equipment on it's PCS holdings (EDGE only), and neither AT&T or VZ have used their spectrum in the AWS and WCS bands?

    If there was a crisis, why would they not have used all their spectrum? And why not use equipment that maximizes capacity?

    Why take spectrum away from broadcasters and the government when these two don't even use the spectrum they do have?

    Ivan is right, and the FCC is wrong about this.

  6. Cervantes says:

    Edward: Thanks for exposing Seidenberg's flimflammery.

  7. Dave Burstein says:

    Ivan is right and his lobbyists are wrong, at least for the better part of a decade at Verizon. Verizon lobbyists are among the best, under instructions not to lie. But they are all lawyers and the like who aren't technologists. Ivan's spent 30 years building networks and is a much more reliable source. They'd like more spectrum, of course, because in the long run it lowers the cost of building networks. Lobbyist hyperbole took over after that.

    If the FCC releases more spectrum - which I support - it might go to competitors. No incumbent wants that. Canada, Mexico, France and most other nations are reserving spectrum for new entrants. Personally, I like competition and think that would be a good thing. The economics of scale in telecom mean the spectrum may not be enough to make new entrants viable in the U.S., as AT&T and Verizon are already pulling away. It's hard to analyze.

    But Ivan's shareholders presumably don't want to face that risk.



  8. Guest says:

    Is there ANYONE left at the FCC who understands RF and signal propagation?

    Proposals to take away UHF spectrum for wireless broadband will leave the still-nascent MH service dead in its cradle. Who will want a mobile TV device with a 3-foot-long antenna to pick up MH from VHF TV stations?

    And where is this compelling need for wireless broadband? What about the millions of Americans whose only TV service comes from free, over-the-air TV? And who have little use for broadband? (Yes, they are still out there.) Who speaks for this group?

    Doe anyone at the FCC understand the limitations of shared bandwidth networks for delivering video and audio content, vs. fixed, high bit rate digital TV?

    What about the advantages of a decentralized TV distribution medium in times of emergencies, such as hurricanes, floods, and other severe weather? (Or in the case of man-made disasters?) Cell phone networks fold like a card table. Broadband speeds drop like a stone.

    But TV keeps chugging along, like it always has. Broadband is NOT the answer to everything. It is but one of many ways for people to communicate and get information. It should not become the predominant communications medium as the expense of other, time-tested outlets.

    If the United States government is so keen on using spectrum for wireless broadband, it should free up a chunk of the hundreds of megahertz it currently reserves for military and other uses. Don't pinch the broadcasters, who are just getting out of the gate with ATSC and MH services that are proving to be popular with cost-conscious viewers.

    In the interests of disclosure, I don't work for a TV station, or a network, or NAB, or MSTV. I just believe this policy of "broadband above all else" to be misinformed and technically flawed. And definitely NOT in the interests of Americans.

    But then again, perhaps I'm not that surprised this is happening, since it appears that Gen Xers are taking over the FCC.

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