Commenters at Odds on Need for FCC Spectrum Occupancy Measurements
Commenters disagreed sharply on what the FCC should do in response to an August notice of inquiry on understanding nonfederal spectrum use. Some observers have questioned how much will be gained by the inquiry, especially because it doesn’t ask about federal use (see 2308020054). Comments were posted Wednesday in docket 23-232.
The NOI seeks comment on the “capabilities and limitations” of existing commission practices on real-time spectrum usage (see 2307130065). It seeks “feedback on what definitions appropriately capture the extent to which a set of frequencies is being utilized” and on “band-specific considerations” for examining spectrum usage.
The Association of Federal Communications Consulting Engineers (AFCCE) said data needs to be collected in a variety of ways to gain a complete picture of spectrum usage. “Fixed point-to-point services are generally well-defined by the parameters required for FCC licensing a facility in these bands,” AFCCE said. “Spectrum usage can be analyzed from the geographic routes, bandwidth, power and modulation types in use,” but “time-of-use may require collecting information by survey from the operators,” the group said: “Fixed-to-multipoint services illustrate a different case in which usage can vary dynamically by end-point locations and duty cycle of usage. Remote monitoring of network usage is a cumbersome task, but could be used to verify system information collected by operators.”
“While non-federal spectrum is allocated by the Commission for various services, actual utilization and occupancy is not currently tracked in a scalable fashion over space and time,” said Monisha Ghosh, engineering professor at University of Notre Dame and former FCC chief technologist: “One cannot control or manage what is not measured: hence, long term spectrum planning requires measurements and data on actual spectrum usage beyond mere spectrum allocations.”
Ghosh provided technical advice based on work being done at Notre Dame, the home of SpectrumX, which studies spectrum. “Careful thought needs to be put into how to define spectrum occupancy, what should be measured and how, managing the volume of data that will result from measurement campaigns and how such measurements can be used in crafting effective spectrum policy,” she said.
“No single approach is feasible to measure spectrum occupancy,” said the Society of Broadcast Engineers: “Different frequency bands and services have unique characteristics, and the methods used to assess occupancy must vary accordingly. This is a complex and challenging task, but it is essential if the Commission is to effectively manage the non-Federal spectrum bands.” Broadcasters use spectrum in a variety of ways, SBE said. “Some usage is fixed and continuous, like many television and radio broadcast streams” and “other operations are intermittent and/or mobile, like mobile electronic newsgathering,” the group said.
Industry Concerns
The FCC should focus on bands without “competitive incentives such as shared/unlicensed spectrum bands and bands where licensing is done outside of competitive bidding,” said CTIA. The FCC already has databases to look at, including in the citizens broadband radio service band and in the international communications filing system, which “can be explored prior to suggesting new data collections for Commission licensees,” CTIA said. The group urged the commission to work with the NTIA to gather data on federal spectrum use.
Wireless carriers “have built-in incentives to ensure spectrum is used efficiently,” Verizon said, noting U.S. providers have spent more than $230 billion in spectrum auctions in the past 30 years: Carriers have also handled a “massive growth in demand despite only modest growth in spectrum access.” The carrier also urged a focus on federal use. “Efforts across government are necessary to ensure that finite spectrum resources -- allocated for federal or non-federal purposes -- are efficiently used and that all spectrum users are good stewards of the airwaves,” Verizon said.
The FCC should articulate its goals before starting any new data collections, said AT&T. “Gathering data without a broader policy framework on how the data is to be used is not only potentially burdensome, but also fraught with potential dangers both at a personal privacy level and at a more global spectrum policy level,” AT&T said.
Lockheed Martin counseled against a focus on efficiency of spectrum use. Efficiency is “too relative a term and not the right metric; instead, spectrum use should be measured consistent with the goal of establishing an effectively and maximally shared spectral environment, as the predicate to a spectrum coexistence framework,” the company said.
SpaceX said the FCC should focus on terrestrial and satellite usage. “Assessing satellite spectrum usage is particularly important in lower-frequency bands, where satellites will interweave with and complement terrestrial networks through both standalone mobile-satellite service and supplemental coverage capabilities,” SpaceX said.
Qualitative evaluations of spectrum use are “unavoidable,” the Satellite Industry Association commented “Critical safety of life services may be perceived as quantitatively ‘less used’ than other services, though they must remain highly available for when other communications infrastructure becomes inoperable,” SIA said: “The public good derived from provisioning services to rural and underserved communities from space cannot easily be distilled down to a quantifiable technical metric to determine use.”