We Need a Course Correction on Federal Spectrum

April 28, 2013

Go into any workplace, restaurant, school, or home today and it is easy to see why the wireless industry is a significant component of our country’s economic recovery.  A recent report by CTIA reveals that Americans used more than1.1 trillion megabytes of data from July 2011-June 2012, which was an increase of 104 percent over the previous year. Cisco predicts this growth will continue, with global mobile data traffic expected to increase 13-fold between 2012 and 2017 at a compound annual growth rate of 66 percent. Today, the wireless industry supports 3.8 million jobs and contributes $195.5 billion to the U.S. gross domestic product.

Without doubt, this growth is a good thing for the economy, consumers, and wireless providers, but it cannot be sustained without additional spectrum for commercial wireless services.  The industry first identified a looming spectrum crisis in 2009 and urged U.S. policymakers to identify and allocate bands to meet the demands of consumers and businesses that were, and still are, increasingly dependent on “wherever, whenever” access.  For their part, carriers continue to develop and deploy advanced technologies to squeeze the most out of their existing spectrum, but those efforts simply are not enough.  Carriers must have access to additional licensed spectrum to keep up with burgeoning consumer demand. 
The sources of future additional spectrum are limited today to already-occupied bands, and while the Federal Communications Commission (FCC) and Congress have taken aggressive measures to free up bands currently held by commercial broadcasters, significant work still needs to be done to reallocate Federal spectrum.  Clearly, spectrum plays an essential role for government users, but in this environment, the Federal government must evaluate the use of its spectrum, ensure it is using it efficiently, and convert it to commercial use when appropriate.

We appreciate the steps the government has taken to study the possibility of reallocating 1755-1850 MHz and other bands.  Current efforts, however, are insufficient to yield timely results and unnecessarily delay consideration of reallocation of the 1755-1780 MHz portion of the band by first requiring a complete solution for the entire 1755-1850 MHz band.  Rather than attempt to develop relocation plans and cost estimates for the entire 95 MHz, the government should focus on the 1755-1780 MHz portion of the band that is of primary interest to the wireless industry.

The 25 MHz sub-band at 1755-1780 MHz is uniquely valuable given its international alignment and the readily available spectrum at 2155-2180 MHz with which to pair it.  By contrast, without being paired with an available downlink, the 1780-1850 MHz portion of the band is of much lesser value and fails to meet the greatest demand for broadband capacity, which is on the downlink – bringing data from the network to the user.  Furthermore, the clock is ticking on 2155-2180 MHz.  Congress has already mandated this band be auctioned and licensed by the FCC by February 2015, and time is quickly running out.

Although sharing or relocation studies for the remaining 70 MHz should continue, a near-term auction of the 1755-1780 MHz band paired with 2155-2180 MHz, as proposed by the FCC, will help relieve the growing pressure for additional spectrum, while allowing federal agencies reliable, exclusive access to 1780-1850 MHz for a significant period, likely at least ten years.  This will provide the time necessary to resolve problems with the current planning process and to study options for meeting both Federal and commercial needs, including an overall assessment that includes potential relocation bands and sharing where it makes sense.  In a recent letter, the wireless industry demonstrated consensus in an approach that prioritizes 1755-1780 MHz for commercial use, while providing continued exclusive Federal access to the remaining 1780-1850 MHz band as long as a long-term assessment of how to best meet the needs of both Federal and commercial requirements continues. 

For a variety of reasons, current efforts among industry, the Defense Department and other Federal entities are insufficient to make the 1755-1780 MHz band available for commercial operations in the timeframe necessary.  The current government-industry efforts are mired in worst case analysis, analysis for systems where it’s clear that sharing is not possible, and a general lack of willingness to share information or collaborate.  We must change from the current course to one that attacks the problem in a more goal-oriented and collaborative manner.  

If we continue along the current path, we will miss the opportunity to auction 1755-1780 MHz paired with 2155-2180 MHz.  Foreclosing on this opportunity will reduce auction revenues and deny American consumers greater access to broadband. A course correction is needed immediately to ensure the wireless industry continues to grow and contribute to the U.S. economy.  We need all hands on deck and a truly collaborative environment to move forward. 

Steve Sharkey is Director, Chief Engineering and Technology Policy in T-Mobile's Government Affairs office in Washington DC. He has overall responsibility for technical policy agenda and manages a team of technical experts to achieve the company's policy goals.