TECHNOLOGY DEVELOPERS URGE FCC TO EXPAND UNLICENSED SPECTRUM

Of nearly 140 comments received in FCC’s docket so far, several highlighted tension between incumbent licensees that were concerned that too much flexibility might erode spectrum rights versus new technology developers who want more leeway to deploy new devices, especially for wireless data. For unlicensed spectrum for data networking, Cisco said FCC should create rules so devices used in those bands optimize frequency use. Not every unlicensed band necessarily has to be maximized for wireless networking, it said. “A more open, even if less efficient, regulatory regime may have the benefit of permitting greater experimentation,” company said. “But neither is it necessary, and surely it is not wise, to maximize every unlicensed band for experimentation. Some unlicensed bands should be maximized for service.” For spectrum set aside for data networking, rules should be crafted so that clients optimized frequency use, particularly as techniques such as dynamic frequency selection and transmit power control allow more efficient spectrum use, Cisco said. It said its engineers were working on new wireless applications that used power levels that could minimize self-interference and optimize frequency reuse.

“As power levels go down, radiation range diminishes to smaller spatial area and starts to correspond to traditional ‘property boundaries’ such as a residential lot or house walls, a corporate or university campus and so on,” Cisco said. “Reduced power levels generally empower users to mitigate interference based on their ability to regulate who enters their property without the need to regulate the nature of emissions or who emits.”

Microsoft advocated more than one “flavor” of unlicensed spectrum regulation. “In addition to the current approach typified by the 2.4 GHz band, the Commission might consider the creation of ‘unlicensed broadband spectrum’ for the evolution of technologies and business modes, such as wireless data networks, that could supplement cable and DSL services.” That version of unlicensed broadband spectrum could “jump-start the creation of competitive wireless broadband networks” in the U.S., company said. Microsoft urged FCC to: (1) Allocate additional spectrum below 2 GHz and in 5 GHz band for unlicensed broadband uses. (2) Require that devices in unlicensed broadband spectrum be capable of 2-way packet data communication and observe media access rules that minimized interference and maximized efficiency, “including perhaps receiver standards.” (3) Provide users of unlicensed services “degree of protection” from interference from licensed services. (4) Do its own testing to evaluate whether unlicensed underlay technologies could coexist with individually licensed services. Microsoft said one of most overlooked consequences of creation of unlicensed bands had been “tapping of an entirely new source of capital to build networks: The financial resources of the users themselves.”

Ultra-wideband developer XtremeSpectrum recommended FCC fine-tune its definition of harmful interference for unlicensed devices. Unlicensed devices under FCC rules may not cause harmful interference and must accept any interference received. XtremeSpectrum said definition of harmful interference as whatever seriously degrades, obstructs or repeatedly interrupts communications is “largely subjective.” Company advocated 3-step approach in which: (1) FCC would determine how much degradation or interruption given service “can reasonably be expected to tolerate.” For example, fixed microwave service carrying phone traffic with 99.999% reliability might be asked to tolerate “no more than several additional seconds of interruption per year” due to interference. CB channels, on other hand, would be entitled to little protection. (2) Commission would set permissible interference levels that particular service could receive. (3) Agency would translate those received levels into “maximum permissible emissions levels from the secondary (or unlicensed) device.”

Information Technology Industry Council (ITI) agreed FCC needs to identify additional spectrum for unlicensed wireless networks. Group is backing Wireless Internet Compatibility Alliance petition to FCC to allow unlicensed use of 5470-5725 MHz for wireless LANs. “This spectrum is in use in Europe today and would provide another 11 channels at 54 Mbps,” ITI said. “At current growth rates, even this bandwidth will quickly be consumed in more congested metropolitan areas,” filing said. “It’s important that we find additional spectrum now to prepare for this anticipated growth.” In area of 3G spectrum, ITI said that more than 120 MHz would be needed to meet growing demand for wireless services, particularly as new data and multimedia services were launched. ITI said it backed relocation fund proposed by Bush Administration that would earmark auction funds for relocation and modernization of incumbent govt. spectrum users that moved to make way for new services.

Part 15 Organization, which represents wireless ISPs, said more unlicensed spectrum was needed below 6 GHz for broadband wireless access (BWA), in part to overcome line-of- sight requirements needed above 1 GHz. “Additional 900 MHz, 2.4 GHz and 5 GHz unlicensed spectrums could be the determining factor of whether BWA is available to much of the nation and is especially important in urban and rural areas,” it said. Group recommended that Commission consider changing current rules to make distinction between use of indoor and outdoor equipment. Some wireless ISPs have found that unlicensed indoor devices have capability to transmit up to one mile away, range that isn’t needed for indoor applications, group said. Restrictions on indoor equipment could include decrease in power or limitations on use of certain antennas, filing said. New rules for outdoor use could require coverage of interference issues and higher power levels “if applied in such a fashion as not to cause ’significant’ interference with other uses in the unlicensed spectrum,” filing said.

As for how FCC could measure spectrum efficiency, ArrayComm suggested benchmarks based on bits per second per Hz per cell or subscribers per Hz. In international arena, company said U.S. had been “out of kilter with the spectrum allocations of much of the rest of the world.” When U.S. economy is growing, there may be few economic consequences to that approach, ArrayComm said, but if that economy lags behind western Europe and Asia, domestic manufacturers could face competitive disadvantage. “Either way, we pay a price politically,” it said. “Support from Canada and Mexico has eroded. With our leadership and their support, we used to dominate Region 2 spectrum policy decisions.” That region of ITU policymaking, which includes the Americas, has found it increasingly difficult to give the U.S. “the unqualified backing that they did in previous years.” At World Radio Conference meetings, trend is to follow regional proposals before giving consideration to national ones, ArrayComm said, meaning U.S. needs support of neighboring countries. “By expressing reservations to various WRC decisions and recommendations, and thereby failing to implement them, we may be able to satisfy our internal interests, but there is an inevitable erosion of our influence abroad,” ArrayComm said.

CTIA told FCC its spectrum auction assignment policies generally had worked well and didn’t need major overhauls. Group said Commission should implement trust fund tool for relocating govt. users if Congress provided authorization to do so. CTIA also called for type of zoning model that would allow FCC to determine what was and what wasn’t acceptable interference. “Going forward, for new spectrum being made available (typically through auction), the FCC should more precisely define the ‘zoning’ rights and obligations of licensees before licensing,” CTIA said. “For spectrum that has already been licensed, the FCC should ensure that incumbents have the exclusive right to provide services in their licensed spectrum, subject to ‘zoning’ service rules. Those identified rights should not be undermined after licensing.”

Spectrum Policy Task Force, which plans to present recommendations on spectrum policy to FCC in Oct., on Wed. set dates for 4 public workshops: (1) Aug. 1, experimental licenses and unlicensed spectrum. (2) Aug. 2, interference protection. (3) Aug. 5, spectrum efficiency. (4) Aug. 9, spectrum rights and responsibilities. All workshops will be 9 a.m.-3 p.m. in FCC meeting room.