IIC Gets NTIA Push, Faces Challenges

Incumbent informing capability, a new and sophisticated sharing technology that makes use of AI and machine learning, is a major NTIA focus, but the agency doesn’t have the congressional funding it needs to put IIC in place, experts told us. IIC would be the next generation of sharing, a more sophisticated version of what's being done in the citizens broadband radio service, replacing the environmental sensing capability (ESC) used in that band.

NTIA acting Administrator Evelyn Remaley at a recent conference emphasized the role IIC could play (see 2110130066). IIC could be used in many bands and NTIA would want all federal agencies to use the technology, she said. NTIA is hopeful Congress will fund IIC development but warned it could take five years to fully develop.

"Spectrum sharing is a reality right now, and it’s a big reason why the United States is leading the world in allocating mid-band spectrum for 5G," an NTIA spokesperson emailed: "Having mechanisms like the IIC in place will help accelerate future repurposing efforts and further cement America’s wireless leadership."

In a February paper (see 2102220050), NTIA described IIC as “a long-term project with iterations that will ultimately allow federal agencies to populate and update in realtime a database with frequency, location, and time-of-use information for systems they deploy.” Rep. Brett Guthrie, R-Ky., recently filed the Simplifying Management, Reallocation and Transfer of Spectrum Act (HR-5486), which would require NTIA to develop and implement a standardized framework for facilitating spectrum sharing, though the bill doesn’t use the term IIC (see 2110060073).

NTIA doesn’t have industry “buy-in” and “they’re not going to get any resources to do their dream wish,” former FCC Commissioner Mike O’Rielly told us: “Sharing has a place. It’s not the be-all, end-all. We’re still going to have the fights over the need for exclusive licenses. We’re not going to move to a completely sharing model. … That’s maybe 20 years away.”

IIC would be “a move towards a comprehensive sharing regime that also includes necessary security procedures in order to protect Defense and other public safety uses,” Commissioner Nathan Simington said Thursday during a Cooley webinar (see 2110210072). The federal table of frequency allocations “is incredibly detailed, incredibly ornate, and reflects ... the realities of spectrum allocation up to this point,” he said. The table “also creates stickiness,” he said: “It makes it difficult to change and revise services. Some have said it creates a strong incumbent basis and discourages entrepreneurial activity and flexibility, and I’m open to those arguments.”

Simington understands “the appeal” of more dynamic sharing. “There are a lot of conversations to be had about loosening up specific spectral allotments,” he said: “There’s a lot of spectrum that’s fallow at any given moment and technology such as IIC shows … significant potential for allowing for much more pervasive and effective use.”

Think Piece

IIC is “a wonderful think piece, but how are they going to get from here to there and do they have the budget?” asked Michael Marcus, former FCC engineer. The FCC and NTIA are both “woefully underfunded” on spectrum with “virtually no contract money,” he said. Marcus said more-sophisticated sharing tools are likely needed only in a few markets. Other than in San Diego, with its naval base, military use of spectrum rarely overlaps with commercial use in big cities that have the most need for spectrum, he said.

One handicap is NTIA hasn’t had permanent political leadership for years, Marcus noted: “Since 1978, it has been very unclear, does IRAC [the Interdepartment Radio Advisory Committee] control spectrum and NTIA puts decisions on its letterhead or is NTIA in charge?”

“It’s hard to object to funding small government experiments with new technology, but NTIA has little to show for its 30 years of studies, experiments, and inquiries in this area,” said Brent Skorup of George Mason University’s Mercatus Center. There will be “little progress until Congress gives agencies a cut of spectrum auction proceeds for relinquishing spectrum,” he said: “Sharing spectrum with other users in real time represents a headache and as for fully functional IIC in five years, I’ll believe it when I see it.”

Others think IIC is the future. In comments on sharing in 3.1-3.45 GHz, Google said IIC will address problems seen with CBRS-style sharing. “The primary deficiency of sensing networks is that the need to protect the sensors from interference prevents nearby utilization of the very band that the networks are designed to support,” it wrote in FCC docket 19-348: “This is especially problematic if an ESC network operator is not rigorous in its choice of sensor deployment locations, and puts them in areas with strong commercial demand.”

"With any sharing regime, rules and the technology must allow for incumbents and new entrants to maximize the value of their rights, despite the inherent limitations of sharing,” said Jeffrey Westling, R Street Institute technology and innovation policy fellow. In CBRS, “the ESC rules limit the value of priority access licenses by restricting CBRS operations in certain areas to prevent harmful interference to the sensors designed to facilitate sharing,” he said: “Extending similar restrictions into other bands would serve as a major barrier to network deployment, but at the same time industry continues to need additional bandwidth.” Westling would prefer to see the DOD shift operations out of these bands into their other existing allocations, but that isn't always a possibility.”

The lack of permanent leadership at NTIA “is always a problem, but I don't doubt that career staff at the agency will continue to drive these efforts behind the scenes,” Westling said.

IIC “can greatly expand access to unused federal spectrum in underutilized bands and could also improve efficient sharing among federal agencies that share bands,” said Michael Calabrese, director of the Wireless Future Program at New America. “It’s very important that any IIC is built to promote dynamic sharing on both a licensed and unlicensed basis,” he said: “An IIC must be able to interface with spectrum sharing databases certified by the FCC, such as the spectrum access systems that currently protect Navy radar spectrum in the CBRS band, yet also be able to obscure classified information, as the NTIA database does today to coordinate sharing in the 70, 80 and 90 GHz bands.”