FCC Technical Paper to Offer More Detail on Analysis on Wireless Industry Spectrum Needs

With the National Broadband Plan on the street and plans underway to try to find an additional 500 MHz of spectrum over the 10 years, questions remain about the actual spectrum needs of carriers. The broadband plan offered relatively little analysis on this critical issue. FCC officials said more is to come and the agency will release a technical paper offering more detail on the number crunching behind the plan’s spectrum chapter.

"3G network services are in full bloom. Data traffic on AT&T’s mobile network, driven in part by iPhone usage, is up 5,000 percent over the past 3 years, a compound annual growth rate of 268 percent,” the report said in its analysis of carrier spectrum needs. “Verizon Wireless says it, too, has recently experienced substantial data growth in its network. According to Cisco, North American wireless networks carried approximately 17 petabytes per month in 2009, an amount of data equivalent to 1,700 Libraries of Congress. By 2014, Cisco projects wireless networks in North America will carry some 740 petabytes per month, a greater than 40-fold increase.”

"I think they embrace and accept what CTIA has said about the pace of data broadband adoption,” a wireless industry attorney said of the FCC. “They see what has happened with the iPhone for example and what that has done to AT&T’s network. They also kind of accept the notion that wireless is an important contributor to economic growth.” The attorney said the FCC might not accept that the industry needs 800 MHz -- CTIA’s forecast based on an ITU analysis. “Do [FCC officials] buy that they need to make 800 MHz available?” the attorney asked. “I think over time improvements in radio technology, femtocells, the use of better receivers, more spectrum efficient equipment -- they hope that those developments will cut back on the needs for some of that 800 MHz."

The commission will publish technical follow-on papers that go beyond the plan, said an agency official. The broadband team did some crunching, though that was not explicitly discussed in the plan.

CTIA will offer a number of papers of its own on carrier spectrum needs. The association has not offered analysis that goes beyond the ITU projections. “The next piece is we have a paper coming up on the implications and impact of not releasing the spectrum,” said Chris Guttman-McCabe, CTIA regulatory vice president. “It doesn’t offer more detailed modeling, but it’s sort of an analysis of what will happen from an innovation perspective without more spectrum being brought to market.” CTIA will also offer a paper on the technical elements of the efficient use of spectrum “and how efficient the U.S. wireless industry is in its use of spectrum,” he said. The first paper is to be ready this week.

"Everything we have seen projects tremendous demand for wireless broadband services and, as a result, tremendous straining of current spectrum resources,” Guttman-McCabe said. “That could be the basis on our advocacy. But then when you look around the rest of the world, you have Japan announcing that it’s going to bring several hundred MHz to market. You've got Germany that has 350 MHz in the pipeline in the next year or two. You've got the U.K. None of those countries have as many providers to split the spectrum across."

Broadcasters and public interest groups question whether the wireless industry has provided adequate evidence to justify auctions that would provide carriers several hundred more MHz in licensed spectrum. “Broadcasters support the goal of promoting access to broadband services but still question the conclusion that limiting free and local television station is either necessary or desirable,” said NAB spokesman Dennis Wharton. “There is very limited documentation in this 376 page report to support claims of a spectrum crisis. Moreover, it’s noteworthy that the FCC’s own recommendation to take 120 MHz away from broadcasters is premised on a conclusion from a footnote in the report that cites a study that is ‘forthcoming.'"

The team that wrote the broadband plan offers little in the way of evidence on carrier spectrum needs, said Association for Maximum Service Television President David Donovan. “Apparently, the Task Force has no question about wireless carrier’s spectrum needs since they did no studies or work to address this issue,” he said. “The report contains no analysis of spectrum use or efficiency across carriers. What is the relationship between spectrum holdings by the four major carriers and the number of customers? There is no analysis regarding the number of cell sites deployed in any market, nor is there any indication that the spectrum is being used efficiently. Moreover the NBP never responded to or addressed any of the criticisms regarding the exaggerated predictions in the ITU study."

"The evidence presented to the FCC is, in fact, fairly simplistic. It assumes that everything remains the same and that smartphone growth will continue on the same exponential curve,” said Public Knowledge Legal Director Harold Feld. Feld said the FCC can’t have a “drill, baby, drill” mentality for bringing spectrum online through future auctions. “It would have been nice to see projections on whether more efficient receiver standards and other ways to promote efficiency among existing operators would better address spectrum needs in the short term,” he said. “To compare to the energy crisis, the FCC seems to have chosen offshore drilling rather than looking at making cars more fuel efficient."

The Public Interest Spectrum Coalition questioned carrier needs in a November filing in response to the broadband plan’s wireless innovation notice of inquiry, said Michael Calabrese, vice president of the New America Foundation. “We argued that attempting to meet exploding mobile data demand only with more licensed spectrum is both impractical and potentially harmful for consumers and innovation.”