“[S]tatistics can lie. But cast as ‘studies’ by commentors, they take on the weight that a decision maker chooses to make of them.”

– Daniel Brenner

As a follow-on to its National Broadband Plan, the FCC last year released a Technical Paper intended to validate the Plan’s prediction of a 300 MHz mobile-broadband spectrum deficit by 2014. The Paper describes a spectrum requirements model that totals current spectrum assigned to mobile broadband and applies a multiplier based on expected demand, taking into account expected increased tower density and improvements in air-interface spectrum efficiency. The model’s result is a predicted deficit of 275 MHz in 2014, which rounds to 300 MHz. On the way toward that result, however, the analysis uses just a few of the available data forecasts, ignores offloading of macrocell data to Wi-Fi and femtocells, and assumes the continuation of flat-rate plans for consumers. Some of these oddities I noted in a post at the time. I had hoped the FCC would make the Paper a subject of public comment. That hasn’t happened. So, I’ve looked at the Paper in more detail. I find that when looking at the above factors in a more realistic manner, predicted spectrum requirements go down significantly.

INVALID ASSUMPTION #1: THREE ARBITRARILY-PICKED FORECASTS ARE REPRESENTATIVE

To estimate spectrum requirements in 2014, the FCC’s model uses a multiplier based on an average of three forecasts of mobile-broadband data demand. These are by Cisco, Coda Research, and Yankee Group. From 2009 to 2014, they predict mobile broadband data growth of 4722%, 3464%, and 2332%, respectively, for an average of 3506% (or, if you prefer, 35x).

The FCC characterizes these as “industry analyst mobile data demand forecasts” when in fact only two are from industry analysts. Cisco is an equipment vendor. The preparation of its forecast is managed by a member of Cisco’s marketing team. The Cisco forecast is used to promote the sale of Cisco’s core-network hardware that can be used to help address the increased data demand the forecast predicts. The Technical Paper gives no indication as to why these three forecasts were chosen and others rejected. It would be as if the FDA looked at clinical trial data, ignored the statistics, and made decisions based on its favorite data points.

The decision to use Cisco’s forecast, and not those of other equipment vendors, is odd. Forecasts are also available from Alcatel-Lucent, Ericsson, and Nokia Siemens Networks (NSN), among others. Unlike Cisco, these companies have core competency in the 3G/4G radio air-interface that is the most challenging bottleneck when it comes to mobile capacity, so it would seem useful to include their findings. For the same time frame looked at by the FCC, 2009-2014, Alcatel-Lucent, Ericsson, and NSN predict data growth of 3893%, 2541%, and 811%, respectively. The 811% looks very low, but is consistent with recent forecasts predicting data increases in the 8x-10x range over the next several years; these lower estimates may be an indication of large-cell model of cellular hitting an inflection on a technology-maturation S-curve.

When the forecasts are considered with those of Cisco, Coda Research, and Yankee Group, the six-forecast average is 2961%, or 15.5% less than the FCC’s estimate of 3506%. What does this do to spectrum requirements? From the FCC’s own sensitivity analysis in the Paper (p. 22), this reduces the 2014 shortfall from 275 MHz to approximately 165 MHz.

INVALID ASSUMPTION #2: OFFLOADING IS AN ABSTRACT CONCEPT

Today’s typical macrocell (large cell) wireless systems have always expended disproportional resources trying to overcome building attenuation and reach user devices indoors; it’s been an outside-in approach. Adding to the challenge, we’re inside 70% of the time, and will be inside even more as time goes on, according to Informa estimates. Building attenuation is not the only indoor problem; signals indoors weaken as the distance to base stations increases. Furthermore, capacity available to a user goes down as more users join the cell.

At the same time, our indoors increasingly have fixed broadband service. This can be used in conjunction with small cells, such as Wi-Fi access points or femtocells, to offload data from the macrocell. When the user is close to small cells, a lot of good things happen, things beyond the ability of additional spectrum to provide. Building attenuation goes down because we’re not punching through as many walls. Signal strength increases because of the shorter distance. Throughput to the user goes up because capacity is no longer shared with several dozen others. (Throughput to those still on macrocells goes up, too, because they’re no longer competing with the small cell users.) As an added benefit, since the user is close to the cell, not as much power is needed on the uplink; handset transmit power goes down, increasing battery life. Taking all these factors into account, data rates available to a user can go up 80x or more using small cells depending on the deployment scenario.  In contrast, doubling available spectrum increases throughput only 2x. Allocating the entire 300-3000 MHz band to mobile broadband would increase throughput only 7x, were that a practical option.

The outside-in approach of macrocells is turning inside-out, bring the user closer to the base station. This offloading concept is consistent with the ITU’s 2003 vision of heterogeneous networks; each wireless access technology excels in certain circumstances, and shouldn’t be force-fit into others. It’s hopeless to reach the capacity increases that can be achieved through small cells by the use of additional spectrum. Qualcomm, a longtime advocate of more spectrum for mobile broadband, recently said that “the next performance and capacity leap will come from network topology evolution by using a mix of macro cells and small cells – also referred to as a Heterogeneous Network (HetNet) – effectively bringing the network closer to the user.” The same improvements in electronics technology that enable smartphones, and their increased data requirements, likewise enable new small-cell technology that can address the demand. Wireless innovation is not only on the user-device side.

Despite this progress in small cells, the Technical Paper inexplicably dismisses offloading:

“Since this paper is focused on mobile data traffic, strategies to offload traffic to femto‐cells and WiFi is [sic] not directly considered. In addition, the rollout of such network architecture strategies has been slow to date, and its effects are unclear.”

First, mobile broadband data traffic and offloading go hand in hand and thus must be considered; the more data offloaded, the less carried by the mobile broadband network, and the less spectrum required for that network. Second, offloading strategies are ramping up quickly. The “effects” are clear. Less data is carried on the macrocell, reducing the need for new spectrum.

If the Technical Paper does not directly consider the effects of offloading, perhaps the input forecasts from Yankee Group, Coda, and Cisco do. It’s not clear, from information provided in the Paper, to what extent the three forecasts take offloading into account. Looking at the Cisco forecast separately, we can see it estimates that in 2014, 23% of wireless data in the U.S. will be offloaded to Wi-Fi and femtocells. More recent observations and forecasts, however, are substantially higher than Cisco’s. Commenting on the issue in its latest wireless competition report, the FCC said “AT&T has experienced significant growth in hot spot usage in the first half of 2010, with an estimated 40 percent of iPhone traffic in the United States being transmitted over a Wi-Fi connection.” Independent analysts ABI Research and Juniper Research predict worldwide offloading rates of 48% and 63%, respectively, in 2015. ComScore estimates that in August 2011, 37.2% of mobile phone data was sent using a WiFi connection, a percentage that grew almost 3 points in just the preceding three months.  For 2014, Juniper Research predicts North American offloading will reach 76.9%. Cisco’s underestimation of offloading contributes to its forecast usually being the highest of the bunch, making it the go-to forecast for spectrum crisis adherents.

The FCC didn’t directly consider offloading, but we can. For the purposes of this post, let’s average the low and high offload estimates, from Cisco and Juniper Research. That gives us 50% as an offload factor. Adjusting Cisco’s forecast using the 50% offload factor instead of 23%, one gets a Cisco 2014 data growth relative to 2009 of 3066%. This lowers the six-forecast average to 2685%, which is 23.4% less than the FCC’s estimate. Returning to the sensitivity analysis, the revised spectrum shortfall is approximately 115 MHz instead of 275 MHz.

INVALID ASSUMPTION #3 – FLAT-RATES RULE

Most U.S. operators have gone from flat-rate “all you can eat” rate plans to usage-based plans where the consumer is charged based on the amount of data used. AT&T made the change in June 2010, T-Mobile in April 2011, and Verizon Wireless in July 2011. (Sprint is the only major operator with an unlimited plan today, on its 3G network for the iPhone.) These new rate plans will further encourage users to offload data. The Technical Paper, again inexplicably, does not take this into account:

“The projections of mobile data demand used in this analysis are based in part on historic market dynamics, such as “all you can eat” pricing for data. The effect of new pricing strategies on consumer data demand is not yet known, but has the potential to impact data traffic projections if widely adopted in the market.”

I expect the effect of these new pricing strategies will be that consumers moderate their less essential use of mobile broadband. This will be especially so for the data hogs, a few of whom consume the bulk of mobile broadband data in each cell. There is not much public information yet on consumer response to these new pricing plans, but it’s something to watch out for, and then we can make a further correction to the spectrum deficit estimate.

The effects of usage based plans on data consumption will be far reaching. With the cost of bits more aligned with what it costs the operator to supply them, the consumer has more price signals on which to act upon. These signals, in turn, will be felt by the rest of the wireless ecosystem. Under flat-rate plans there was little incentive for consumers to be conscious about how efficiently-coded the phone’s operating system or applications were. Under newer plans that charge by use, consumers will have a heightened awareness of how much data they’re using, and for what purpose. Software will increasingly compete on efficiency. On the application side, operators know where every bit goes, and which applications consume the most data. There is no such awareness on the consumer side. Perhaps the industry will provide greater granularity in data metering, to the application level, so users can better prioritize usage of their data plans. Once this happens, developer sensitization to the issue will increase.

Some of this software-based improvement is nearly “free,” requiring only improved programming practices. Last year, the World Wide Web Consortium adopted a recommendation for best practices in mobile web application development.  As one example in the recommendation, mobile web applications often use several static images to represent buttons. Each image that is sent uses a separate HTML request. HTML requests can be reduced to one by combining the buttons into one static image, sending that image, and cutting the buttons from the image. That saves data. Under flat-rate plans, why bother?

On the operating system side, different phones can vary greatly as to the amount of data needed to perform the same function. One analysis, sponsored in part by Research in Motion, finds that across multiple applications and for the particular smartphones studied, the BlackBerry used much less data than the iPhone or Android phones. For web browsing, the Blackberry was 2.1 times more efficient (i.e., used 2.1 times less data) than iPhone iOS or Android. For e-mail, the Blackberry was 4.5 times more efficient than Android and 11.4 times more efficient than iPhone iOS. As users become more aware of what data they’re getting for their money, competitive pressures will lead the less efficient operating systems to become more so.

FURTHER ADJUSTMENTS TO THE ESTIMATED SPECTRUM DEFICIT

We’ve looked at the estimated spectrum deficit from the basis of demand and the FCC’s model. Before we finish, let’s take a quick look at where we are today on the supply side. The following efforts show promise for making more spectrum available for mobile broadband within the 2014 timeframe:

• LightSquared is seeking approval to use 40 MHz of spectrum near 1500 MHz for terrestrial mobile broadband. Such use is pending resolution of GPS interference issues.

• The FCC has an open proceeding looking at maximizing the mobile broadband potential of a total 75 MHz of spectrum around 2 GHz. Some 40 MHz of that belongs to Dish Network, which recently asked the FCC for permission to deploy a hybrid satellite and terrestrial mobile and fixed broadband network. Qualcomm, Dish, and others have various smaller pieces of the 700 MHz band, which might be practical for use with LTE in a TDD mode using unpaired spectrum.

• NTIA has issued a plan and timetable identifying over 2200 MHz of Federal and non-Federal spectrum that might provide opportunities for wireless broadband use. For mobile use, the most promising band in the near term is 1755-1850 MHz. NTIA is finishing a detailed review of the band to determine to what extent it can be made available for commercial broadband use. The review was supposed to be completed by September 30, 2011 but is running late; perhaps we’ll see the results by the end of the year. I hoping at least 40-50 MHz becomes available from this band.

An accurate and current inventory of frequency assignments and usage would help identify new mobile spectrum, but such an inventory doesn’t exist. The preliminary steps the FCC has taken so far are so laden with disclaimers they can’t be relied upon. On the Federal side, the Government Accountability office (GAO) recently reported that “NTIA’s data management system lacks transparency and data validation processes,  making it uncertain if spectrum management decisions are based on accurate and complete data.” The U.S. should conduct a thorough spectrum inventory, informed by measurements.

CLOSING THOUGHTS

We’ve seen that reasonable updating of the FCC’s spectrum deficit model significantly reduces the short-term forecast deficit for 2014. As adjusted, the Technical Paper doesn’t support the National Broadband Plan’s mobile broadband spectrum recommendations, as was its intent.

We might step back and ask why the FCC is forecasting spectrum demand at all. If the U.S. moves more toward a property-rights and marketplace regime for spectrum use, as it may with the incentive auction approach, the Technical Paper estimates and National Broadband Plan recommendations become less important as the market will tend to allocate spectrum resources efficiently. To the extent it does not, and fails to meet a public policy goal, policymakers can change the market outcome.

If a forecast is to be maintained, the FCC should reconcile the National Broadband Plan with an updated forecast spectrum deficit, openly prepared with broad input and using the latest data. Part of that examination should be the validity of other methodology used the Technical Paper. The work should be thorough enough that the FCC Chairman no longer feels the need to cite Cisco’s forecast in speeches, and can instead cite the work of the FCC’s own staff — with authority.

• Amateur Radio operator Juan Granados filed an application with exhibit for experimental license to test CW, LSB, RTTY, and digital modes such as BPSK on 130-140 kHz and 495-505 kHz. The testing will take place in Miami, Florida and involve communication with amateurs in other parts of the world.

• Cognitive Data Dispatch (CDD) filed an application with exhibits for experimental license to “explore the possibility of a cognitive type of radio architecture in transmitting very brief time duration data transmissions over a HF radio channel.” “CDD is seeking authority to transmit data in a point-to-point mode using a minimal spectral footprint (utilizing a channel for less than 10 milliseconds at a time, not to exceed 250 milliseconds of total occupation during any 24 hour period) on pre-coordinated HF frequencies using fixed transmit and receive locations. These extremely brief time duty duration transmissions will ensure no harmful interference will occur to any licensed users of these channels. As part of the channel selection process, CDD transmissions will employ cognitive radio features to ensure the optimum transmission channel and minimal opportunity for interference.” Operation will be from sites in Aurora, Illinois; Washington, DC; and East Rutherford, New Jersey on various frequencies from 2.2890 MHz to 7.6971 MHz.

• RIIMIC LLC, d.b.a. Sunair Electronics filed an application with exhibit for experimental license to conduct testing of single-sideband communications equipment in Ft. Lauderdale, Florida on 5.888-23.1465 MHz.

• Lockheed Martin filed an application with exhibit for experimental license for control operation of the AN/WLD-1(V) Remote Multi-Mission Vehicle (RMMV) in support of the US Navy’s Remote Minehunting System (RMS) and Multi-Vehicle Communication System (MVCS) programs. This experiment is said to be necessary for development and integration of the radio communication link between the control and remote stations. Operation will be in West Palm Beach, Florida on various frequencies between 30-40 MHz and 1708-2297 MHz.

• Signal Systems Corporation filed an application with exhibits (several confidential) for special temporary authority to test the utility of short duration messaging in the VHF band using meteor burst communications). Data rates will be up to 9600 bps. Operation will be in Ridgley, Maryland and Blacksburg, South Carolina on 40.75 and 49.8 MHz.

• Live2Media filed an application with exhibit for special temporary authority to test “media broadcast” at an auto race event. The broadcast will consist of messages from the pit crew to the race car, along with announcements. Operation will take place in Laguna Seca, California on several frequencies between 64.0 MHz and 68.2 MHz.

• Garmin filed an application with exhibits for experimental license to test the interoperability of its avionic data link system and data link radio (GDR 66) with an ARINC ground station. The link is characterized by 8-DPSK modulation, 25 kHz channel spacing, a raw data rate of 31.5 kbps, and a carrier-sense multiple-access technique for operation on a shared channel. Operation will be in Olathe, Kansas on 136.975 MHz.

• Adaptrum filed an application with exhibit for special temporary authority to experiment with prototype TV white-space equipment. The equipment is to be fully compliant with the new white space rules except for equipment authorization. Operation will be in San Jose and Mountain View, California on 174-216 MHz, 470-608 MHz, and 614-698 MHz.

• The Rappahannock Electric Cooperative (REC) filed an application with exhibit for experimental license to test the usefulness of TV white-space frequencies in, as the applicant states, “supporting smart grid fixed and mobile data connectivity. Fixed applications include long range point to multipoint backhaul of internal utility traffic including supervisory control and data acquisition (SCADA) traffic and automatic metering infrastructure (AMI) traffic, both located at REC’s electric utility substations. The AMI system also enables real-time load management thereby improving system reliability and reducing peak demand, all of which further the nation’s goal for greater energy independence and reduced carbon emissions. In terms of mobile data connectivity, REC plans to leverage this technology to test the efficacy of these frequencies for mobile workforce management applications in the utility service vehicles including processing work orders – new connects, disconnects, reconnects, and outage orders. REC also has a need to test automatic vehicle location (AVL) to optimize routing of service vehicles in real time.” Operation will be in several Virginia communities on 174-216 MHz.

• The Avionics Engineering Center at Ohio University filed an application with exhibits for experimental license to operate in support of research on the Joint Precision Approach and Landing System (JPALS). The system is intended to provide fixed and mobile precision approach and landing systems that will support a 200 feet decision height and 0.5 statute mile visibility while operating in military or civil modes. The system will also support auto-land capability for suitably equipped aircraft (to include Army, Navy, Marine Corps, and Air Force aircraft) and operate in a GPS-jamming-threat environment. Operation will be in Albany, Ohio on 240.650 MHz and 280.975 MHz.

• Lockheed Martin filed an application with exhibits for experimental license to “perform testing on a Low Frequency Sensor (LFS) radar that will be used for long range detection. The testing will evaluate the sensor detection performance and antenna characterization of the radar.” The test antenna will be log periodic with a gain of 6 dBi and beamwidth of 103 degrees. ERP will be variable up to 10 watts. Operation will be in Syracuse, New York on 420-450 MHz.

• KTS Wireless filed an application with exhibit for experimental license to test a TV white-space system in an orange grove located southwest of Clewiston, Florida. The intent is to apply TV white spaces to the problem of enabling automation for sustainable specialty crop farming. “The current implementation requires a multi-radio solution in several bands with multiple repeaters which is problematic in an industrial environment.” The white-space method is intended to allow a single base-station solution. Operation will be on 470-608 MHz and 614-698 MHz.

• Google filed an application with exhibit for experimental license to operate in support of experiments in TV white spaces in the bands 512-602 MHz and 620-698 MHz. “Google will conduct research and experiments of fixed and personal/portable devices within the white spaces to determine the potential utility and feasibility of such operations and technology. Google requests authorization within the geographic coordinates of its Mountain View, California campus. Google plans to operate up to three fixed base stations at 4 W per 6 MHz channel available, with a radius of operation of 5 miles (8.05 km), and up to 50 mobile stations at 100 mW per 6 MHz channel available.”

• Quantum5x Systems filed an application for special temporary authority to test a “new type of wireless microphone with a rubberized housing and internal antenna, as well as addressing de-sense and intermodulation correction technology.” Operation will in New York, New York on 600-608 MHz and 614-689 MHz.

• Lockheed Martin filed an application with exhibits for special temporary authority to test its “MONAX Cellular solution along the southwest border of Texas. This operation will be supporting evaluation by local and state authorities of the MONAX solution for utilization in securing the border with Mexico.” “MONAX is a powerful, new communications system that combines the convenience of smartphone technology with the power and flexibility of a secure, highly portable infrastructure.” “The 4G wireless system, consists of a unique portable MONAX Lynx sleeve that connects touch-screen COTS [commercial off-the-shelf] smartphones [which look similar to iPhones] to the MONAX XG Base Station infrastructure on the ground or in airborne platforms, offering uninterrupted service to warfighters in the field.” “MONAX offers a rich set of applications and governance, leveraging commercial smartphone application development and application store model. Applications can be easily written or re-hosted on a smartphone, reviewed/approved for mission effectiveness, hosted in a 24×7 app store and made available to the warfighter.” Operation will be near Finlay, Texas on 758-763 MHz and 788-793 MHz.

• Vodafone filed an application with exhibit for experimental license to “test and demonstrate advanced Internet services in . . . GSM, HSPA and LTE environments, such as GPRS (general packet radio system), location-based services, transcoding between email, SMS, and WAP, and secure position/mobile-commerce services.” Operation will be in Redwood City, California on 842-850 MHz, 890-893 MHz, 935-938 MHz, 1920-1936 MHz, 2110-2126 MHz, 2500-2520 MHz, and 2620-2640 MHz.

• Western DataCom filed an application with exhibit for experimental license to test UMTS wireless devices used by the Intelligence & Information Warfare Directorate of the US Army Communications Electronics Research, Development, and Engineering Center. The system is to be used for transmission and reception of voice and data within a single network; it does not connect to any other provider’s network. Operation will at Fort Dix and Lakehurst, New Jersey, on 900-915 MHz, 945-960 MHz, 1755 MHz, 1850 MHz, 1972.4-1977.4 MHz, and 2162.4-2167.4 MHz.

• General Dynamics filed an application with exhibits for experimental license to conduct testing in support of its Labrador program, which is intended to develop methods for locating and identifying radio frequency signals using a variety of devices. The project requires communication between collaborating software-defined radios. Operation will be in Ypsilanti, Michigan; Bloomington, Minnesota; Tucson, Arizona; and Austin, Texas on 902-928 MHz, 1350-1390 MHz, and 1755-1850 MHz.

• Wal-Mart Stores filed an application with exhibits for experimental license to conduct RFID research at its lab in Fayetteville, Arkansas. This research relates, in part, to optimal placement of RFID tags on cases, pallets and assets. “The experimentation will include RFID tagged cases going through a simulated supply chain. This will include testing in a dense reader mode environment. Additional testing will be conducted using RFID enabled handhelds for inventory collection, product locating and product receiving in a simulated store environment. RFID readers fixed to mobile assets (forklifts, carts, wearable devices) will be tested using this site license to ensure that solutions developed using RFID readers in the United States will meet the given performance criteria across all other regions worldwide within which Wal-Mart operates.” Operation will be on 902-928 MHz.

• General Electric Global Research filed an application with exhibits for special temporary authority to test a microwave imaging system for non-destructive testing of in-service wind turbine blades. Operation will take place in Schenectady, New York. The signal will be a broadband linear chirp swept from 1 GHz to 18 GHz up to 10 times per second.

• Rockwell Collins filed an application with exhibit for special temporary authority to develop and test equipment used in the Aeronautical Mobile Satellite Service. Four Inmarsat geostationary satellites will be used. Operation will be nationwide on 1626.5-1660.5 MHz.

• BAE Systems filed an application with exhibit for special temporary authority to conduct proof-of-concept tests for the next generation of communication-intelligence unmanned aerial vehicles (UAVs). Operation will take place in Hudson, New Hampshire on 1760-1840 MHz, 2365-2445 MHz, and 10.25 GHz.

• Ericsson filed an application and exhibit for experimental license to conduct tests related to 3G and LTE application performance. “This investigation will examine a new aspect of network performance and will contribute to expansion of the mobile ecosystem. Historically, the wireless industry has relied solely on bandwidth or transmission rates to assess performance. However, the expanding variety of applications that will run over networks indicates that network performance should also be investigated through the lens of application performance. The uniqueness of the planned experiment is to understand the performance of new, varied applications and services on mobile networks.” Operation will take place in San Jose, California on 1920-1930 MHz, 2110-2120 MHz, 2500-2520 MHz, and 2620-2640 MHz.

• Space Exploration Technologies filed an application with exhibits for experimental license to operate in support of R&D for a Vertical Takeoff, Vertical Landing (VTVL) vehicle on its test site in McGregor, Texas. The vehicle is to take off, ascend vertically to a low altitude, and then descend back to its original landing spot. “The tests themselves are divided into low‐altitude and higher‐altitude tests. The low‐altitude tests stay below 215 meters in altitude and last approximately 45 seconds. These tests will be run approximately three times per week during the initial portion of the program. The higher‐altitude tests can go as high as 3.5 km and will occur approximately once per week. These tests last approximately 3 minutes.” A downlink is used so operating parameters can be viewed in real time. An uplink is used in case of an anomaly, so the vehicle can be commanded into a safe state. Operation will be on 2040.5675 MHz, 2221.5 MHz, and 2273.5 MHz.

• Space Exploration Technologies filed an application with exhibit for special temporary authority for “telemetry and video transmissions during launch (and pre-launch checks) for an orbital test flight of the Falcon 9 launch vehicle from Cape Canaveral, pursuant to the Commercial Orbital Transportation Services (COTS) Demonstrations agreement with NASA. The launch date is currently scheduled for November 30, 2011.” “The purpose of the operation (the Demo C2/3 mission) is to demonstrate the capability to launch a capsule that can dock with the International Space Station.” “[S]pectrum support for the capsule is already being handled by NTIA (via NASA). Accordingly, STA will only cover the launch vehicle stages (first stage and second stage), during launch, as well as pre-launch checks.” Operation will be on 2213.5 MHz, 2221.5 MHz, 2251.5 MHz, 2273.5 MHz, and 5765 MHz at Cape Canaveral, Florida.

• Panasonic Avionics Corporation filed an application with exhibits for special temporary authority to conduct ground testing of potential interference from portable electronic devices (PEDs) in aircraft. This is in support of Panasonic’s Global Communications Suite (“GCS”) featuring the “eXConnect” Ku-band aeronautical mobile-satellite service system providing broadband connectivity on the aircraft during flight. Testing will be in Everett, Washington on 2386-2505 MHz, 5150-5350 MHz, and 5715-5835 MHz.

• Gibbons Systems Inc. (GSI) filed an application with exhibit for special temporary authority to test a new air-to-air ranging system as part of a contract with Wright-Patterson Air Force Base. The applicant is developing the system to “fundamentally improve radio ranging among the C-130 fleet deployed by the United States Air Force. Currently, the C-130 fleet utilizes high powered radio transmissions, similar to radar, for maintaining formation, which nonetheless render the formation highly detectable and, thus, vulnerable to enemy monitoring. The GSI RF technology employs several techniques (including low duty cycle, low total signal energy, and high bandwidth) to render the signals difficult to detect, i.e. ‘low probability of detection’ (‘LPD’). “Operation will be in Redwood City, California on 2500 MHz.

• Aurora Flight Sciences filed an application with exhibit for experimental license to operate in support of the development of an Unmanned Aircraft System (UAS). The applicant says existing data-link systems don’t provide the necessary data rate of 10 Mbps. An auto-tracking antenna, designed for use with this system, combines a high gain directional dish, a low-gain omni-directional antenna, and associated auto-tracking hardware. The omni-directional antenna is for close-in operation of the aircraft, such as during takeoff and landing, where the angular velocity of the aircraft relative to the antenna is too great to track. The high-gain antenna is for long-range operation. “The auto-tracking antenna is provided with the GPS position of the aircraft. Tracking is accomplished using a combination of GPS and signal strength. Signal strength is used to find the aircraft when the tracking is not locked, and GPS is used to follow it thereafter.” Operation will be in Warrenton, Virginia on 4.4-4.8 GHz.

• Motorola Solutions filed an application with exhibits for experimental license to test the outdoor link performance of its RDB350 point-to-multipoint data transceiver. The intent is to test fixed and mobile outdoor data transmission for federal users. The system is based on the IEEE 802.16e standard. Operation will be in Schaumberg, Illinois on 4600-4800 MHz.

• Raytheon Network Centric Systems filed an application with exhibit for special temporary authority to test a mobile surveillance system based on commercial off-the-shelf radar, electro-optical/ Infrared cameras, and microwave communications (i.e., the Motorola PTP 48600 wireless Ethernet bridge). The system is intended to “monitor international borders.” Operation will be near Las Cruces, New Mexico on 4720-4990 MHz. A similar application was filed for operation near McKinney, Texas.

• Miltec Corporation filed an application with exhibit for experimental license to conduct tests, as part of a U.S. Army contract, in support of the Innovative Waterside Wide-Area Tactical Coverage and Homing Sensors (IWWS) program intended to detect, track, and classify people and vessels in a maritime environment above and below the surface of the water. Operation will be in Kingsport, Tennessee and Guntersville, Alabama on 9.38-9.44 GHz.

• SAIC filed an application with exhibit for special temporary authority to test“low-power land radar” on 10.25-10.50 GHz. The system uses the ELTA model EL/M 2112 radar, and might be used by the Department of Homeland Security. Testing will take place around the perimeter of Lake Moultrie in South Carolina.

• L-3 Communications filed an application and exhibit for special temporary authority to test a prototype high-capacity airborne networking system. The data links will be between a ground station and an aircraft, and between two aircraft. Operation will be in the vicinity of Monterey, California on 14.50-14.83 GHz and 15.15-15.35 GHz. “The RF transmissions will utilize root raised-cosine (RRC) shaped offset QPSK modulation, at various symbol rates, with shaping factor (alpha) of 0.33. All transmitted data will be encoded with a rate-7/8 turbo product code prior to transmission.” “All transmissions will use identical 9.5” parabolic dish antennas.”

• Raytheon Network Centric Systems filed an application with exhibit for special temporary authority to “develop and demonstrate a mobile surveillance system based on commercial-off-the-shelf radar (SR Hawk Radar SRC-2362) and electro-optical/infrared cameras to monitor international borders.” Operation will be near McKinney, Texas on 16.21-16.50 GHz.

• Raytheon Network Centric Systems filed an application with exhibit for special temporary authority to “develop and demonstrate a mobile surveillance system based on commercial-off-the-shelf radar (DRS Manportable Surveillance and Target Acquisition Radar (MSTAR)) and electro-optical/infrared cameras to monitor international borders.” Operation will be near Las Cruces, New Mexico on 16.75-17.25 GHz.

• Samsung filed an application with exhibit for experimental license to “[f]ully characterize the radio channel at mmWave frequencies for mobile, outdoor environments to understand path loss, angular spread, delay spread, NLOS beamforming and blocking issues.” “This will help design mmWave communication systems, providing multi-Gbps data rates for wireless mobile services within new spectrum bandwidth and therefore meeting the challenges raised by the on-going mobile data explosion.” Operation will be on 27.925 GHz in Richardson, Texas.

• L-3 Communications Datron filed an application with exhibits for experimental license to conduct testing of Iridium satellite system feeder-link-terminals (FLTs) related to retrofit work.” The applicant “will retrofit the current 27 FLTs to address obsolescence and maintenance issues as well as modernizing hardware and software interfaces. As many as 12 new FLTs will also be built in the future to support the latest generation of Iridium NEXT satellites currently being planned and designed.” Operation will be in Simi Valley, California on 29.1-29.3 GHz.

• Google filed an application for special temporary authority to conduct “experiments using test vehicles equipped with automatic cruise control radars in a manner that extends the sensing range of the radars when a vehicle is not in motion.” “Each Google test vehicle contains several off-the-shelf automatic cruise control (ACC) radars certified for use in the 76.0-77.0 GHz band.” “Several ACC radars will be mounted on test vehicles and the vehicles will be driven through a variety of traffic situations, including along freeways and urban surface streets and through complex intersections. The radars will operate at a radiated power of 60 uW/cm² at 3 m (i.e., the current in-motion criterion) both while the vehicles are in motion and stationary. Because the power will not exceed the current in-motion criterion, Google believes the experiments will not increase the likelihood of harmful interference to any user.” Operation will be in the San Francisco Bay area. (The FCC has separate in-motion and not-in-motion emission limits for these vehicle radars to prevent prolonged human exposure to RF energy while the vehicle is stopped. I thus find it odd that Google links the in-motion criterion to “interference.”)

• Sierra Nevada Corporation filed an application with exhibit for experimental license to conduct ground testing of an Autonomous Landing Guidance (ALG) radar system. This is intended to allow “a fixed wing aircraft pilot to safely execute takeoff, approach, and landing maneuvers in low visibility conditions such as that caused by thick fog or blowing sand and dust.” “The ALG system is a derivative of other Sierra Nevada Corporation (SNC) products currently in evaluation programs that provide similar landing situational awareness for rotor wing aircraft pilots. ALG is a millimeter wave (MMW) frequency-modulated continuous wave (FMCW) radar with a narrow 1.0 beamwidth that is scanned over a 25° by 10° field of regard twice per second. During the scan the radar return data is processed by computer to extract the amplitude and the range to the ground. The computer accumulates all of the range and amplitude data over the field of regard and displays a three-dimensional representation of the ground to the pilot on a flight deck display.” This ground testing is a prelude to flight testing, at which time Sierra Nevada will apply to modify its experimental license. Operation will be at several California and Nevada locations on 94 GHz.

For the TV broadcasting spectrum, voluntary incentive auctions have long been on the horizon. Many broadcasters aren’t opposed to the idea in principle, but want assurances that existing or equivalent coverage is maintained during any channel repacking. For all they know now, it could be cut in half. This anxiety is heighted because the FCC refuses to make available for inspection pre-release versions of the software used to calculate a repacked channel plan.

This refusal follows the FCC dismissing a noteworthy study prepared by the NAB on the wireless capacity crunch, and rejecting an attempt by broadcaster to try to innovate and experiment with new broadband technologies. Add to that the FCC Chairman being associated with a policy of marginalizing the broadcast industry, some broadcasters may rather take their chances on the next FCC.

I think there may be another way forward. The Advanced Television Systems Committee (ATSC) is starting a process to develop a next-generation TV standard, ATSC 3.0. That new standard doesn’t have to be backward-compatible with current TVs. I suggest that as part of this standardization process the ATSC look at cellularization as a new architecture. Others have done this before, and the main objection has been it’s too expensive compared to the current single-transmitter model. It’s time to look at cellularization again, in light of less expensive cell site equipment and published work suggesting such a system for all broadcasters could occupy less than 100 MHz of spectrum, perhaps freeing up more than the planned 120 MHz. TV broadcasting could enter, and perhaps influence, the global LTE standards ecosystem with its economies of scale, its interoperability, and, crucially, its evolution. There’s also the potential for a return path. Looking at cellularization now might help avoid repacking the TV channels twice in a short time frame:  following a spectrum auction and then again for ATSC 3.0. If such a cellularization scheme is seen as becoming practical, it could simultaneously result in a more durable strategic advantage for broadcasters, and more than 120 MHz for mobile broadband. There’s also the potential for a return path. Looking at cellularization now might help avoid repacking the TV channels twice in a short time frame:  following a spectrum auction and then again for ATSC 3.0. If such a cellularization scheme is seen as becoming practical, it could result in a more durable strategic advantage for broadcasters, and more than 120 MHz for mobile broadband.

Continuing our spectrum survey, the LightSquared proceeding will likely result in at least some of 59 MHz of spectrum around 1500 MHz becoming available, with the rest available once issues with potential interference to precision applications of GPS are resolved.

The FCC has an open proceeding looking at maximizing the mobile broadband potential of a total 75 MHz of spectrum around 2 GHz. Some 40 MHz of that belongs to Dish Network, which recently asked the FCC for permission to deploy a hybrid satellite and terrestrial mobile and fixed broadband network.  Qualcomm, Dish, and others have various smaller pieces of the 700 MHz band, some of which are in play now.

An accurate and current inventory of frequency assignments and usage (based on measurements) would help identify new mobile spectrum, but the preliminary steps the FCC has taken so far are so laden with disclaimers they can’t be relied upon.

Then we have the Federal spectrum. NTIA has issued a plan and timetable identifying over 2200 MHz of Federal and non-Federal spectrum that might provide opportunities for wireless broadband use.  I wouldn’t call any of that “pipeline” at this point. NTIA is, however, finishing a detailed review of the 1755-1850 MHz band to determine to what extent it can be made available for commercial broadband use. This review should be completed by September 30. Since this band might be considered a best-case for repurposing Federal spectrum, the results of this review may give us a sense on how we’ll fare with other Federal bands.

Anecdotal evidence suggests there is more Federal spectrum available. Below is a figure from a report prepared by Shared Spectrum Company, which conducted spectrum occupancy measurements at its suburban Washington, D.C. office.

Shared Spectrum notes that, because of its methodology, some of these bands may be utilized but hard to measure, such as GPS satellite signals in the 1575 MHz region. Other fallow spectrum may be in a pipeline, but for services other than mobile broadband. One field test is not the basis for spectrum planning. These general results, however, have been replicated by Shared Spectrum elsewhere, and by NTIA at various locations.

In addition to measuring what’s out there, one might think to examine the NTIA’s database of Federal frequency use to see what’s open. Unfortunately, the Government Accountability Office (GAO) recently reported that “NTIA’s data management system lacks transparency and data validation processes, making it transparency and data validation processes, making it uncertain if spectrum management decisions are based on accurate and complete data.” A new, improved database system is in the works but isn’t scheduled to be online until 2018 (not a typo).

Other problems with the current Federal spectrum management process, as found by the GAO, include heavy reliance on agencies to self-evaluate and report their current and future spectrum needs, lack of specific spectrum management requirements for federal agencies, and limited assurance that federal agencies are recording accurate data. In a recent review of a sample of Federal spectrum assignments for one agency in the Detroit area, approximately half of that agency’s assignment records were inaccurate. There’s also a spectrum warehousing issue: some federal agencies are concerned that if they say they are no longer using an assignment, it will be deleted and they will not be able to get it back if needed later.

The NTIA database problems point to another reason why a spectrum inventory, of Federal and non-Federal bands, should be informed by measurements. Repurposing existing databases known to contain errors, under layers of disclaimers, is not a spectrum inventory.

Though not one of the usual spectrum candidates, it might be time to look again at the 1435-1525 MHz flight test telemetry band. This have been tried at least a couple of times before, by satellite radio and by land-mobile proponents. Both attempts didn’t get anywhere. This time I’d suggest looking at it with more of a goal toward sharing. I can’t help but notice that, today, the band is routinely shared under special temporary authority by video production entities looking for bandwidth to relay video during special events. One application was recently approved for an event in the middle of Washington, DC. If a hole is there why not use it for mobile broadband as well? I’d think . . . hope . . . that most flight testing is not done over major cities where the capacity crunch is the greatest. Flight test links are usually air-to-air or between air and ground, not ground-to-ground, so I’d expect considerable antenna discrimination that would reduce the potential for interference with other services.

By the time we reach the National Broadband Plan’s 10 year deadline for 500 MHz of new broadband spectrum (for fixed and mobile), many promising technologies and techniques found in the record of the FCC’s proceeding on dynamic spectrum access will become a reality, increasing the capacity of existing spectrum. These will make it easier to implement shared spectrum use using cognitive radio techniques.

Moreover, moves toward a property-rights regime for spectrum use and creation of markets for licenses, recognizing that government can improve market outcomes, would remove some of the headaches inherent in sorting out the above. We wouldn’t have to worry as much about filling the pipeline. It would fill itself.

Looking at the chart, we see the U.S. has the most subscribers of the countries chosen for comparison (China and India each have about three times as many subscribers as the U.S.).  Then we see that the U.S. average revenue per voice minute, which can be considered a proxy for subscriber cost, is 4 cents, the lowest of all countries compared. Very impressive. I’ve seen criticism that this figure may be lower than actual because of a possible assumption that the consumer uses all, and no more of, plan-minutes per month. Even with further adjustments I’d expect the comparison to be favorable. With the growing role of mobile data services, data costs would be a useful to see as well; such a comparison is conspicuous by its absence.

CTIA then positions the U.S. as a leader in efficient use of spectrum, by a factor of two-to-one or more, using “Subscribers Served per MHz of Spectrum Allocated.” Here, they lose me. Cellular spectrum is reused. We are not partitioning the spectrum allocations such that each subscriber has a unique fraction. Though there are many ways to measure spectrum efficiency, and new ones can be created, I don’t see how this qualifies.

We’re back on track with the last two lines showing spectrum allocations and new spectrum in the pipeline.  I’m concerned that they are based in part on “regulatory and company websites and press reports.”  As we have seen, some press reports are more reliable than others. I’d like to see the specific reference for each figure.

I find it noteworthy that Japan and South Korea, nations with very progressive wireless industries, make do with less spectrum than the U.S. It may be no coincidence that South Korea has one of the smallest spectrum allocations, one of the smallest amounts of spectrum in the pipeline, and has operators that are aggressively deploying Wi-Fi offloading and six-sector base-station antennas, which nominally double spectrum capacity compared to the more-common three sector antennas.

The 50 MHz pipeline figure apparently comes from the National Broadband Plan. There’s been a lot of spectrum policy activity since then, but we’re agreed that there’s little in the pipeline now. In my next post I’ll try to take a snapshot of where we stand with the usual spectrum candidates, and suggest one or two others. Later I plan to review where we are with offloading and other technologies, along with tiered rate plans, that can reduce, but not eliminate, the need for new mobile broadband spectrum.

Gerald Whitney filed an application with exhibits for experimental license to test a prototype AM broadcast transmitter system covering 2-16 MHz at a carrier power of 1 kW. The system, part of a U.S. Department of Defense project, includes a frequency-agile transmitter, antenna tuning unit, and antenna. Testing will be done in Victor, New York.

Curtis-Wright Controls filed an application with exhibit for special temporary authority to demonstrate its 3d-Radar brand of ultra-wideband ground penetrating radar (GPR) for prospective non-federal customers as it awaits expected FCC grant of its Part 15 waiver request for the device. Operation will take place at various locations in the U.S. on 140-3000 MHz, with frequency notching to preclude transmissions in the bands 608-614 MHz, 1400-1427 MHz, 1660.5-1668.4 MHz, and 2690-2700 MHz, in accordance with an NTIA authorization. The company filed its Part 15 waiver request with the FCC in June 2010 seeking authorization to operate the device for non-federal use (ET Doc. No. 10-167). The company understands the FCC’s Office of Engineering and Technology is working on an order that would permit non-federal use of the device. The company notes that NTIA, with FCC coordination, has already approved the use of the device for federal use on a nationwide basis.

Carlson Wireless Technologies filed an application with exhibit for special temporary authority to test voice and data connections among multiple Chevron Oil oil-field facilities using TV white space frequencies. Test results will be compared to the performance of a current 900 MHz system. Operation will be at several California locations in the 174-216 MHz and 470-698 MHz bands.

Southern Methodist University filed an application with exhibits for experimental license to operate a cognitive radio testbed. The testbed is backed by a National Science Foundation grant.  Operation will be on several frequency bands between 400 MHz and 6100 MHz in the Dallas area. The testbed will be used to study wireless performance in mobile and stationary environments. Featured in the testbed is real-time multi-band operation, which can be used to aid design of context-aware and cognitive algorithms that use multiple frequency bands to adapt to dynamic environmental conditions. One goal of the research is to develop an open-access database of wireless performance in multiple scenarios.

L3 Nova Engineering filed an application with exhibits for experimental license to demonstrate a seismic activity sensor network. Testing will take place in Great Falls, Virginia on 420-440 MHz.

Sierra Nevada Corp. filed an application for special temporary authority to test equipment that will facilitate formation flight between two aircraft. This supports DARPA’s Global Hawk autonomous aerial refueling demonstration program that is intended to accomplish the first-ever fully autonomous rendezvous, refueling, and formation flying of two unmanned aircraft. Each node of the system consists of a GPS receiver, processor, and other equipment including the UHF data link that is the subject of this application; one node would transmit data to the other such that the receiving node would be able to calculate its position and orientation relative to the transmitting node. The testing will take place in Salt Lake City, Utah on 420.25-426.60 MHz.

Raytheon BBN Technologies filed an application for special temporary authority test distributed-transmit beamforming using RF modules developed under DARPA’s Precision Electronic Warfare (PREW) program. “Specifically, BBN Technologies seeks to demonstrate the capability to synchronize clocks from up to 10 RF modules remotely using UHF band frequencies, and project RF energy at specified frequencies that results in the coherent combining of focused power within a small geographic area of interest using the these radios to enable high data rate transmissions and longer ranges.” According to DARPA, “the goal of the Precision Electronic Warfare (PREW) program is to demonstrate technologies and a prototype system that will enable the fielding of an ad hoc sparse array consisting of multiple airborne and/or ground nodes that can perform surgical jamming. The PREW system should be able to project RF energy that results in the coherent combining of focused power within a small geographic area of interest (AOI). When operating outside the AOI, the system must minimize the coherency of the RF energy to limit the impact to collateral systems.” Testing will occur at Sky Meadow State Park, Delaplane, Virginia on 437-493 MHz, 877-953 MHz, and 2400-2480 MHz.

Airvana filed an application with exhibit for experimental license to develop and test prototype LTE infrastructure equipment on 698-716 MHz, 728-757 MHz, 776-787 MHz, 806-824, MHz, 851-869 MHz, 1910-1915 MHz, and 1990-1995 MHz. Airvana says it will evaluate handoff performance among sectors, network capacity, quality of service, multi-path performance, average data rates, and interference performance. The testing is to take place nationwide.

Lockheed Martin filed an application with exhibits for experimental license to conduct testing in support of the Extended Area Protection System (EAPS) missile test program under sponsorship of the U.S. Army. The EAPS interceptor is a small ground-launched missile system under development as a performance demonstration program of hit-to-kill technology. The hardware requiring licensing consists of two systems. The first is the telemetry system providing downlink of flight telemetry data from the interceptor to a launch control trailer. The second is the unmanned ground system that provides uplink of flight control data from the launcher control trailer to the interceptor. Testing will take place in Texas on 2270.5, 2280.5, 2281.5, 4401.5, 4410.5, and 4411.5 MHz.

Bell Helicopter Textron filed an application with exhibits for experimental license to conduct testing and development in support of eventual unmanned helicopter flights. Testing will take place in the vicinity of Arlington, Texas on 2282.50 MHz.

Teletronics Technology Corp. filed an application with exhibits for special temporary authority to test a new transceiver with both OFDM and burst-mode shaped-offset QPSK (SOQPSK). The transceivers are said to provide “maximum transmission and reception distance under harsh environmental conditions.” Operation will be in the vicinity of Newtown, Pennsylvania on 2360-2390 MHz.

North American Eagle, a project testing the capability of a land-based vehicle to safely transition through supersonic speed, filed an application and exhibits for experimental license to operate a Wi-Fi network consisting of five Tropos model 7320 mesh routers mounted on eight-meter towers and one Tropos model 4310 mobile-mesh router mounted in the vehicle’s nose cone. Video and vehicle operational data will be sent to the base stations. Operation is to take place on dry lake beds near Black Rock, Nevada and Diamond Valley, Nevada on 2400-2483MHz (for data) and 5725-5850 MHz (for video). Transmitter output power will be 30 watts. (Wi-Fi at 800 MPH will be a challenge.)

Raytheon filed an application with exhibit for special temporary authority to test a critical-infrastructure-protection radars system. The system uses a p0-degree-quadrant staring radar with moving target indication designed for perimeter intrusion detection applications around secure facilities such as airports, seaports, utilities and other critical infrastructure. The system is based on Raytheon’s SR1500 Short-Range radar, which is under development. The plan is to deploy a network of low-power, short range (1.5 km) radars at fixed locations around critical infrastructure sites of the Port Authority for New York and New Jersey to provide perimeter security. An Ethernet-based network provides communication between multiple radar and electro-optic sensors. Testing will take place at various locations around New York City on 3100-3500 MHz.

L3 Communications filed an application and exhibits for special temporary authority to test a SONAR telemetry transmission system for military use. The system would send SONAR data from a small boat at a rate of 10 Mbps. The link will also carry video from cameras on the boat to allow operators to confirm normal operation of the hardware. The SONAR data and video will be transmitted to a larger manned ship at a range of a few miles. Testing will take place on the Pacific Ocean, between San Pedro and Catalina Island, in the bands 5200-5679 MHz and 5689-5800 MHz.

Laufer Wind Group filed an application with exhibits for experimental license to conduct tests in connection with the development of a radar-activated FAA obstruction lighting system for wind farms. Testing will take place in New York and New Hampshire on 9380-9440 MHz.

Lockheed Martin filed an application with exhibits for special temporary authority to evaluate Ku-band satellite technology for high-data-rate communication to helicopters. It intends to test ViaSat’s proprietary technology said to maintain the flow of data transmission in the presence of momentary path blockage from rotor blades. Test antennas will be mounted on stands underneath the rotor blades. Testing will be in Owego, New York on 14.0-14.5 GHz.

Raytheon filed an application with exhibit for special temporary authority to test a radar system for mobile surveillance system based on the DRS MSTAR commercial-off-the-shelf radar. The radar, in conjunction with electro-optical/infrared cameras, is intended for use in monitoring international borders. Testing will take place near McKinney, Texas on 16.75-17.25 GHz.

General Dynamics filed an application with exhibit for experimental license to operate an airborne radar system in support of ground imaging research using synthetic aperture radar techniques. Separate transmit and receive antennas would be mounted to a rotational pedestal on the underside of an aircraft. The gain of the antennas is 40 dB at 94 GHz, and they have a 1.5 degree half-power beamwidth in both the azimuth and elevation planes. The radar will use a pulsed linear-FM chirp waveform, centered at 94 GHz with a bandwidth of 600 MHz. The width of the waveform pulse will be approximately 20 microseconds and operate at a pulse repetition frequency of approximately 10 kHz. Peak ERP will be 5,000 Watts. Operation will be in the vicinity of Ypsilanti, Michigan.

Ducommun LaBarge Technologies filed an application with exhibits for experimental license to test its model SG-DDR50 security system, a directed-energy weapon that uses millimeter-wavelength energy to “stop, deter, turn back, and otherwise discourage a trespasser, thief, or belligerent and threatening person at relatively long distances.” “The system consists of an electrical power source, a device producing millimeter wavelength electromagnetic energy, an energy director projecting a narrow energy beam towards a target, and mounting and connecting equipment.” “The SG-DDR50 uses the susceptibility of skin nerve endings to millimeter-wavelength electromagnetic energy to report a sensation of intense undesirable heat on the skin of the person in the energy beam, all while doing no harm.” “The purpose of the experimental license is to align the system to operational specifications using infrared imaging of patterns on a sensitive carbon impregnated teflon [sic] target . . ..” Testing will occur in Huntsville, Arkansas on 94.5-95.0 GHz. Transmitter power and ERP are both specified as 800 Watts on the FCC application form. According to the applicant, “[t]he nature of this test configuration does not lend itself to be characterized by traditional measures, such as ERP, ERIP, Peak Power, and the like.”

The due date for comments was July 25; reply comments are due August 24. (You can look at the comments and submit a reply through the first link above.) Comments and reply comments were originally due 30 days earlier; the FCC granted a request for deadline extension filed jointly by Verizon Wireless and Wilson Electronics (a booster vendor), who cited progress toward a solution that could benefit both manufacturers and carriers. They’ve submitted a joint proposal and I’ll spend most of this article looking at that.

As to the other comments, there are booster vendors naturally arguing for flexibility in design and operation. The in-building distributed antenna system folks are fine with boosters but don’t want any new rules to harm them. Public interest groups don’t want boosters tied to any one carrier, and want simple designs to keep the cost down. A company called Smart Booster brings concepts from dynamic spectrum access to boosters – intelligent units that know when and where to amplify or not. As noted above, the rulemaking proceeding also deals with Part 90 and Part 95 services; APCO addresses concerns about interference and unauthorized use in Part 90, and WCAI discusses various issues related to Part 90 and Part 95.

Most noteworthy, in my view, is the joint agreement among Verizon Wireless, its wireless engineering consultant V-COMM, and Wilson Electronics, that specifies requirements for the design, operation, and installation of boosters to help avoid harmful interference. This is a significant achievement for parties who are traditionally adversaries. The agreement provides for three categories of signal boosters: Carrier Installed Boosters, Certified Engineered and Operated Boosters, and Consumer Boosters. I’ll briefly discuss the first two, and spend some more time on the third.

The Carrier Installed Boosters would be installed by FCC licensees to operate exclusively on the licensees’ frequencies. The agreement doesn’t say much else about this, but there’s not much to say. Carriers have long been free to do pretty much what they want within the broad parameters of their license, and the agreement would not change this. They’re motivated to implement hardware that won’t interfere with themselves.

The Certified Engineered and Operated Boosters would be for large areas, such as campuses or large offices (CEO – get it?), and would require professional installation and close carrier coordination. The joint proposal provides a framework for these boosters, with technical standards yet to be developed.  They would be operated under the wireless licensee’s authority.

Then we have the Consumer Boosters. Under the joint proposal, these could be purchased only by wireless service customers. They would basically be bi-directional RF amplifiers with antenna systems that transmit and receive signals using an outdoor antenna for transmission and reception to a CMRS base station, and an indoor (or in-vehicle) antenna (or direct connection to the mobile device). V-COMM provides a set of specifications for these. They’re technology neutral and intended to provide protection to all CMRS network technologies on all relevant bands. Among other things, the specifications include requirements for automatic gain control to protect against out-of-tolerance operation in instances of overload, anti-oscillation protection to limit power when the inside and outdoor antenna are too close, and limits on uplink and downlink EIRP of 1 Watt and 0.05 Watt, respectively. The uplink transmitter has to turn off if no signal is received from the mobile device in 15 minutes. Noise limits are specified.

Also part of the specifications, Consumer Boosters must be registered with the licensed carrier, either manually or through a Bluetooth connection. In the Bluetooth registration method, the booster operates as an extension to the mobile device and is controlled by it. The manual registration process provides for the customer to give their address, phone number, and other information to the carrier so  it will know whom to contact if it suspects a particular booster is a source of interference; the customer would then be expected to turn it off.

An issue with the manual method is that it requires good faith on the part of the customer.  Others commenting, including T-Mobile and CTIA, prefer that the booster be under some form of direct control by the licensee, so it can be turned off in the event of interference. Without direct control, the manual process is rather open ended. There isn’t much of an incentive for the customer to complete the registration process, registration information that is given will fall out of date, and boosters will be sold second-hand and no longer be linked to the original phone of record. WCAI goes into some of these issues in depth.

I’m surprised to see this manual approach in light of V-COMM’s position in the FCC’s experimental license proceeding (ET Docket No. 10-236), in which it opposed any experimentation by third parties in the CMRS bands due to interference concerns. As a carrier concerned about interference, I’d be less worried by Part 5 experiments than by many more boosters that are out of my direct control. But I’d also realize that many applications for boosters are now inside buildings, and deployments of Wi-Fi and femtocells will gradually displace boosters to some extent, while providing better performance. In addition, the operator may be able to tell which wireless device the malfunctioning booster is associated with and disable the device, thus disabling the booster indirectly once it times out.Still, I’m used to CMRS operators being able to control dozens of parameters on a cellphone, including those related to power control. It’s hard for me to not want control of one parameter on a booster – whether it’s on or off.

To your point, I don’t see LTE being competitive with wired in terms of speed or reliability today or in the future. You take the hit there for the convenience of mobile or portable operation. There’s a notion that if we just add enough base stations and repurpose enough spectrum to LTE, we can replicate the home wired experience in the mobile environment, but I don’t think that’s practical. The throughput from an LTE sector is divided among all users in the sector. If everyone wants to watch the Super Bowl at once on LTE, forget it (unless the LTE broadcasting standard is implemented, which let’s everyone watch the same channel like today’s TV (cough)). On FIOS or cable, the Super Bowl is no problem.

Moreover, video streaming on LTE is and will be a pain because of the need to maintain a relatively constant bit rate in a fading radio environment. An inordinate amount of system resources go into doing that, and the tiered rate plans we are seeing being adopted are in part a response to discourage that.

A twist is Wi-Fi, which can exceed wired data rates (or, at least somewhat match the speed of the wire it’s connected to). Many smartphones have Wi-Fi and, again, the tiered plans are to encourage you to use Wi-Fi whenever possible. In a year or two I think there will be more deployment of 3GPP’s Generic Access Network standard, that allows seamless switching of the phone between LTE and Wi-Fi — the core network can’t tell, and doesn’t care, which one it’s using. When you stream Netflix, it will switch to Wi-Fi by itself if available. With most smartphone use indoors, I think most smartphone access to the operator could one day be through Wi-Fi, with LTE as a backup for when on the move.

Elite Electronic Engineering filed an application for special temporary authority to conduct radiated radio-frequency susceptibility testing on a cotton harvesting machine. The testing is intended to determine the ability of the vehicle to operate safely in its electromagnetic environment without any change in state, function, or performance. Testing is to take place near Kimballton, Iowa on various frequencies in the 20 MHz – 2.5 GHz range. The tests are to be done outdoors because a sufficiently-large indoor shielded test chamber could not be found. Sirius XM Radio objects to the proposed tests out of concern for potential harmful interference to its operations.

Alcatel-Lucent filed an application and exhibits for experimental license to study white-space communications implemented using existing air interfaces such as LTE along with cognitive radio sensing and dynamic spectrum management overlays. The fixed and mobile equipment will utilize a software-defined wideband digital radio (WDR) from Rutgers WINLAB. Operation will be on various TV channels in the 174-698 MHz band around Murray Hill, New Jersey.

Carlson Wireless filed several applications for temporary TV white space operation, including in Cordova, Alaska to test the use of TV white space in supporting remote telephony connections. Operation will be in TV bands 174-216 MHz and 470-680 MHz.

Niitek, Inc. filed an application and exhibits for special temporary authority to test ground penetrating radar (GPR) in Dulles and Charlottesville, Virginia on 200-7,000 MHz. The radar uses ultra-wideband (UWB) technology. The GPR is for use in a landmine detection system that has been procured by the U.S. Army for use in the Middle East. A variety of shielding and power control measures will be used to reduce the potential for interference to other radio services.

Lilee Systems filed an application and exhibits for experimental license to test a positive train control system consisting of three components: locomotive radio, wayside radio, and base-station radio. The company is developing a product family supporting the positive train control effort mandated by the Federal Railroad Administration. Operation will be in New York, New York on 217-222 MHz.

Chevron USA filed an application and exhibit for special temporary authority to test an experimental fixed-link communications system connecting offshore platforms in the Gulf of Mexico. In 2008, Chevron participated in FCC Auction No. 73 and was the high bidder for the 700 MHz band A (698-704/728-734MHz), B (704-710/734-740MHz), and E (722-728MHz) blocks covering the Gulf of Mexico.  The tests will be on 703.55-704.45 MHz and 733.55-734.45 MHz. The equipment that Chevron proposes to test has been certified internationally, but not for the lower 700 MHz band in the United States. If the tests are successful, the equipment manufacturer will seek certification from the FCC.  Chevron plans to use this equipment to enhance the capabilities of its point-to-multipoint WiMAX network and provide high-speed network connections to existing and future production platforms.

The Aerospace Corporation filed an application and exhibits for special temporary authority to operate a satellite link in support of research into the space application of microelectromechanical systems (MEMS) components and related microelectronics technologies. The test includes a demonstration of principles of the physics of the low-earth-orbit space environment and its effects on MEMS microelectronics. The satellite weighs 11 pounds and its dimensions are 5x5x10 inches. It’s to be deployed during the last space shuttle mission, STS-135, which is now scheduled to launch July 12. The satellite has two radios for redundancy, both operating on 914.7 MHz, and both using an omni-directional patch antenna.

The Maryland Department of the Environment filed an application and exhibits for experimental license to use wind-profiling radar to study the transport of air pollutants such as ground-level ozone. The radar is a boundary-layer profiler, and depends on the scattering of a transmitted signal by irregularities in the index of refraction of the air caused by turbulent eddies in the wind. By receiving the scattered signal and determining the Doppler frequency, the speed of the wind can be determined. The radar consists of a vertically-looking antenna subsystem, a transmitter subsystem capable of unmodulated and phase-modulated pulses, a receiver subsystem, a signal processing subsystem performing target parameter extraction and identification, and a data processing/communication subsystem for charting, recording, and transmitting results.  Operation will be on 915 MHz at Cambridge, Maryland.

BAE Systems filed an application with exhibit for experimental license to operate on 1370-1390 MHz in Tucson, Arizona to test a new radio modem, transmitter, and receiver on the Silver Fox unmanned aerial vehicle (UAV) as part of a U.S. military project.

LightSquared filed an application and exhibits for special temporary authority to conduct testing to determine the effects of L-band LTE signals on GPS devices in a live field-test environment. The testing is an outgrowth of the requirements established in FCC Order DA 11-133 granting LightSquared, a Mobile Satellite Service (MSS) licensee in the L-Band, a conditional waiver of the Ancillary Terrestrial Component (ATC) “integrated service” rule. The requested frequency bands include 1526-1536 MHz and 1545.2-1555.2 MHz.

Qualcomm filed an application and exhibits for experimental license to test time-division duplex (TDD) technology in San Diego, California and Bridgewater, New Jersey. Operation will be on 1,915-1,920 MHz. A single fixed transmitter will be installed and operated at each location. Mobile units will operate within a 5 mile radius of the fixed sites.

Western DataCom filed an application and exhibit for special temporary authority to test the range and throughput of a UMTS cellular-based system mounted to an aerostat. Operation will be at South Boston, Virginia on 1972.5 MHz and 2162.5 MHz, with the antenna about 800 meters above ground.

Powerwave Technologies filed an application and exhibits for experimental license to operate a small network to test LTE picocell technology, including aspects related to handover, QoS, power control, and resource scheduling. The test will take place in Santa Ana, California on 1,710-1,755 MHz and 2,110-2,155 MHz.

ETS Technologies filed an application and exhibits for experimental license to test non-line-of-sight wireless backhaul technology for 4G systems. Operation will be in San Jose, California on 3,700-4,200 MHz.

Qualcomm filed an application and exhibit for experimental license to test IEEE 802.11p Dedicated Short Range Communications (DRSC) mobile devices in Bridgewater, New Jersey and New York, New York. Operation will be on 5,850-5,925 MHz. DRSC is a short-range communications service for roadside-to-vehicle and vehicle-to-vehicle links that are part of the Intelligent Transportation System (ITS).  Compared to 3G or 4G mobile broadband, DSRC acts as a complement with higher data rates and lower latency over a small area. In addition to the DRSC tests, Qualcomm will evaluate new proprietary OFDM technology operating within the same DRSC channel bandwidths.

Lockheed Martin filed an application and exhibits for special temporary authority to test enhancements to an existing AN/APY-12 modular Ground Moving Target Indication (GMTI)/Synthetic Aperture Radar (SAR). The enhancements are brought about by changes in operational requirements by the U.S. Army in Korea. This testing is required prior to integration and deployment of the radar system in an Airborne Reconnaissance Low (ARL) aircraft. The testing will involve detection and analysis of moving and fixed targets in open and urban settings. Testing will be on 9.297-9.903 GHz in Goodyear, Arizona and Hagerstown, Maryland.

Raytheon filed an application and exhibit for special temporary authority to conduct ground and airborne test and evaluation of design modifications and mode implementations to the APY-10 Radar. This product is for a direct commercial sale between Raytheon and Boeing, for a user in India. The modifications, required in part due to export restructions, reduce the accuracy of the radar by removing accumulated carrier phase measurement, removing 1 and 3 foot-resolution synthetic aperture radar (SAR) capability, and limiting performance to meet 30 meter SAR geo-location accuracy. Operation will be within 200 miles of Sherman, Texas on 9.350-10.150 GHz.

Niitek, Inc. filed an application and exhibits for special temporary authority to test a ground radio link intended to enhance the capability of the company’s landmine detection system. The system has been procured by the U.S. Army for use in Afghanistan. The enhancements provide data communication between a primary landmine detection vehicle and a second route-clearance vehicle. Operation will be on 14.7145-15.1365 MHz and on 15.1900 MHz.

A 3G feature phone on Verizon’s network uses about 1.25 MHz of spectrum. Using the above multipliers, a smartphone would need 30 MHz and a tablet 150 MHz, more than the total spectrum inventory of some carriers. In reality, smartphones and tablets use the same 1.25 MHz. What’s going on?

I assume the numbers Mobile Future cites come from the latest Cisco forecast (p7), but those are for increases in data traffic, not spectrum. Mobile Future seemingly equates the two, but they’re different. Data traffic increases with smartphones and tablets, but that data takes up capacity in existing spectrum. At some point, that spectrum runs out of capacity. More spectrum, along with other techniques, can be used to add capacity.

I sense the hand of a PR firm in this, which means it wasn’t cheap. Fortunately, the error seems confined to the voiceover, which can be redone relatively easily. To be breezy about it, for the sake of a two-minute video, the revised message might be that spectrum capacity is limited, smartphones and tablets use much more, when we run low performance suffers, more spectrum adds capacity improving performance.

Wireless service rationing? Millions of new jobs? Hey, it’s an advocacy video. I’d be very pleased if this video drew more attention to spectrum issues, and did not contribute to the myths.

NAB – Shortages of Capacity, Not Spectrum

The NAB report is prepared by Uzoma Onyeije, a consultant who was once Broadband Legal Advisor to the Chief of the FCC’s Wireless Telecommunications Bureau. The main claims are that there is no need for an urgent and massive reallocation of spectrum, that there are numerous alternatives to spectrum that can boost network capacity, and that sources of spectrum other than TV are more readily available.

It starts by noting there wasn’t a “spectrum crisis” until the American Recovery and Reinvestment Act of 2009, which required the FCC to promote broadband access. The National Broadband Plan followed calling for 500 MHz of spectrum to be made available for broadband within 10 years, with 300 MHz of that for mobile within five years, and 120 MHz of that to come from television broadcasting. Seven months after concluding that 300 MHz was needed in the short term, the FCC released a Technical Paper intended to support the 300 MHz figure. In November I wrote on that Paper, pointing out several factors not considered that, had they been, would have acted to reduce the estimate of short-term spectrum requirements. Later, I questioned the appropriateness of the FCC relying on a forecast prepared by the marketing department of an equipment vendor, without critically and openly examining the assumptions that went into the forecast. Onyeije shares some of the concerns I had, and still do, with that Paper.

I expect the American Recovery and Reinvestment Act turned some spectrum wants into needs, but by all accounts mobile network data volumes are increasing significantly, fed by a volatile mixture of old flat-rate plans and new bandwidth-hungry devices, though the growth rate of those data volumes is decreasing. Getting additional spectrum is a natural option to consider for more capacity. Onyeije provides a list of non-spectrum options. Some have been mentioned here before – offloading to Wi-Fi and other technologies, adjusting rate plans so largest data users pay more, tighter software coding of applications and operating systems. I don’t think I’ve discussed channel bonding, which is a technique that uses non-contiguous spectrum – combining a sliver here and a sliver there. Support for this will be appearing in LTE-Advanced, going on the air in a few years. Backhaul is also something I haven’t focused on; how much of the current spectrum crunch is really due to backhaul bottlenecks?

Another capacity-increasing technique mentioned is sectorization – changing a non-directional transmission system to a directional one using two or more sectors at the same cell site. In the most congested urban areas in the US, antenna systems are generally configured with three sectors, with each sector 120 degrees wide. You don’t see many six-sector configurations, in which each sector is 60 degrees wide. Theoretically, that doubles capacity from the same tower. A long time ago there was more activity in six-sector antenna systems, but the sense then was it wasn’t too practical; you might end up with just a 70% capacity increase because of real-world issues such as imperfect antenna patterns. It was hard to justify the expense. These days, however, with better transmission technology, it should be looked at again. I note SK Telecom in Korea is deploying 500 six-sector sites, after good results with 20 test sites.

Onyeije looks at the spectrum warehousing issue. If an operator has spectrum that isn’t being used, but is on track to build it out, I’m fine if it is fallow for a year or so. Maybe longer if the delay is to wait for much more efficient transmission technology that is on track in the standards process. If it is just sitting there with no build-out requirement and no prospect for utilization, I’d think the operator’s investors would create pressure to sell it. If a spectrum holder has “no plans to sell, lease or use” its spectrum, to quote one in Onyeije’s report, I’m more concerned.

Aside from the warehousing issue, Onyeije identifies a few bands that have been languishing at the FCC for years and makes the point that, since they have been idle for so long, the spectrum crisis must not be so great. These are the AWS-3 spectrum at 2155-2175 MHz, H block spectrum at 1915-1920 MHz and 1995-2000 MHz and J block spectrum at 2020-2025 MHz and 2175-2180 MHz, 700 MHz D block at 758-763 MHz and 788-793 MHz. What’s the story there?

Onyeije suggests mandatory receiver standards. Receivers are already very good in mobile broadband because of vendor competition and the need to operate in a congested environment. Receiver design is proprietary and an important source of differentiation among vendors. I’d think continued improvement of receiver performance in the marketplace, in the long run, would achieve greater capacity benefit than imposed government standards.

The report calls on the FCC to complete and publicly release a comprehensive spectrum inventory, along the lines of the Snowe-Kerry RADIOS Act, which includes measurements. The FCC has made available several spectrum tools online, including LicenseView and the Spectrum Dashboard, which it says is its inventory. According to their disclaimers however, LicenseView “is not intended for analysis of spectrum utilization or spectrum holdings of licensees” and “the FCC makes no representations regarding the accuracy or completeness of the information maintained in the Spectrum Dashboard.” Regarding federal spectrum, I’d add that an inventory becomes more important in light of GAO’s report on NTIA processes that said “NTIA cannot ensure that spectrum is being used efficiently by federal agencies” in part because “NTIA’s data collection processes lack accuracy controls and do not provide assurance that data are being accurately reported by agencies.” Thus, “it is unclear whether important decisions regarding current and future spectrum needs are based on reliable data.”

CTIA , CEA, and WCAI dismiss the NAB report, saying it’s a stalling tactic and they know these things already. One of Onyeije’s points, however, is that it’s the Commission that needs to know these things, and fully investigate and quantify the impact of all capacity-generating alternatives. It has not. It tried with the Technical Report, but inadequately.

CTIA Establishes the Efficient Properties of Cellularization

The CTIA report is intended to demonstrate that US mobile wireless providers are “extremely efficient” in their use of spectrum. The report was prepared by Peter Rysavy, a consultant known in wireless circles for his series of technical reports, with many pertaining to spectrum, air-interface, and mobile device issues.

This report seems to be a response to an NAB claim, some time back, that broadcasting is a more efficient user of spectrum than wireless. I presume NAB’s claim is based on broadcasters’ DTV system transmitting about 19 Mbps in a 6 MHz bandwidth, while the wireless operators are sending about 10 Mbps in 10 MHz bandwidth. (So, TV has more bits per Hertz.) This is kind of an apples and oranges comparison, but the comparison has been made and we have this report in response. Having spent a lot of time in 3G and 4G standards battles, I have no doubt that those participating are trying wring out all the efficiency that is both possible and practical. Wireless standards groups sweat to get another tenth of a dB improvement. Of course, part of efficiency is an implementation issue and not covered by standards. I agree cellular services are more efficient at delivering unicast traffic. Broadcasters, however, can be more efficient in another way. The efficiency debate occurs in part because we have not agreed on a definition of efficiency. More on this below.

The CTIA paper starts with a section on spectral efficiency. It discusses its fundamental measures and technologies that have been used to continually improve it, including adaptive modulation and coding. (Rysavy says his list of technologies is not exhaustive, but to his list I’d add Hybrid Automatic Repeat Request as a key enabler.)

Rysavy observes that the industry’s technologies are operating close to the Shannon Bound, the theoretical limit on the spectrum efficiency that can be had for a given signal-to-noise ratio. Capacity improvements thus must come from advanced antenna techniques (such as MIMO) and topology evolution (e.g., adding picocells to a macrocell).

The report is hopeful on the prospects for Wi-Fi and femtocells to relieve traffic on the macro-cellular network. I’m somewhat more cautious on the potential of femtocells to relieve the capacity crunch.  For various reasons, including interference management, what I think may happen with femtocells is that they get pulled out of the home and put up in neighborhoods using existing structures for support. (The more-favorable pole-attachment rules recently adopted by the FCC are timely.) There are many small-cell trials underway but I haven’t seen much in the way of results.

Network evolution is discussed in a larger sense, focusing on developments in heterogeneous networks, but Rysavy says that’s not enough and that more spectrum is needed, too.

Back to the efficiency issue, the efficiency of cellular systems is compared to that of broadcast television. The point made is that if you take many small cells and place them within a larger area  covered by one transmitter (e.g., one for TV), the cellular system can deliver many times the unique bits in that area. This is true, if that is the definition of efficiency. Let’s look at it another way and compare the maximum number of users served by each scheme. As a best-case scenario, assume the cellular users are using a low-bit-rate application such as LTE VoIP. In 10 MHz we can support about 400 users. That times 3 sectors is 1,200 users per cell. That times 30 cells (as per the example in the paper) is 36,000 users that can be supported at once. In contrast, a TV  station covering the same area can support an unlimited number of users, albeit one-way, since it isn’t limited by uplink capacity nor MAC addresses. Is it a fair comparison? No. One is broadcasting and the other is cellular. Can’t cellular broadcast also? Yes, but to the extent it does the unique-bits argument becomes weaker. We can go around and around. The television example is used, along with other analysis in that section, in an attempt to persuade the reader that “cellular architectures represent a configuration that is capable of providing tremendous service capacity to its users.” I’m convinced, but I was before reading the report.

Rysavy depicts how voice minutes, message volume, and data volume have increased on cellular networks over the years. Yesm growth has been dramatic, but the growth rate is slowing.

Epilogue

Concurrent with this debate, ATSC is in the early stages of planning and developing the second DTV standard to replace the current one that’s been around for about 15 years. LTE specifications support broadcasting, which can be done in a cellular manner on the same frequency. Transmissions are synchronized so the terminal can combine energy from multiple sites. The broadcasters looked at cellularization a year ago assuming use of the current ATSC DTV standard, and rightly found it was not practical. It just wasn’t designed for that purpose. With the new LTE standards, it’s time to look at TV cellularization again but with LTE as a core technology. There could be a return path, inexpensive chips for receivers, and it might  be able to be done in less than 100 MHz, making over 200 MHz available for auction. With DTV, the broadcasters found significant deployment and operating costs with cellularization, but with LTE infrastructure would be shared; it remains to be determined if it’s a business. The technology is there; it just has to be architected by broadcasters and infrastructure vendors into suitable form.

UPDATE 5/20/2011

The FCC issued a Public Notice today seeking comment on using the 2 GHz bands identified as “languishing” by NAB. Some are listed above. 75 MHz total.