Batter Up! All Eyes on NTIA

As I was bemoaning another poor effort by the football team that I root for on Monday night (yes, the “Dream Team” Eagles) and simultaneously tinkering with this blog post, I began to long for spring training and the start of baseball season (at least the Phillies will make the playoffs. I hope.). So, as I worked to finish this blog, I quickly found myself looking at NTIA’s efforts to reallocate government spectrum in the context of a hitter stepping up to the plate. As with any pressure situation, you have to look at the count, understand the situation and know what is at stake – in this case, a critical input for not just the wireless ecosystem, but also for our economy.

In his landmark 2010 Executive Order, Unleashing the Wireless Broadband Revolution, President Obama nailed the pitch, hailing the importance of wireless to America’s future and making clear that a new era of U.S. technology leadership “will only happen if there is adequate spectrum available to support the forthcoming myriad of wireless devices, network and applications that can drive the new economy.” He directed NTIA to work with the FCC to find 500 MHz of spectrum suitable for mobile and fixed wireless broadband use over the next 10 years. CTIA commended the President’s leadership, and since then we’ve maintained a laser-like focus on two spectrum initiatives:  advancing voluntary incentive auction authority so the FCC can free up underutilized spectrum; and reallocating government spectrum for commercial mobile broadband use. We’re hopeful that Congress will take up these spectrum opportunities as part of its work this fall, as each represents both sound spectrum policy and billions of dollars in revenue for the U.S. Treasury.

In the meantime, we’re awaiting another key spectrum pronouncement: NTIA is expected to release a report soon on the prospects for repurposing an important spectrum band, 1755-1850 MHz, from government use to commercial mobile broadband. This is a decisive at-bat in my analogy. That is because the 1755-1780 MHz band is ideally suited for pairing with a 25 MHz block already in the pipeline (AWS-3 spectrum at 2155-2180 MHz), and industry considers this 1755-1780 MHz band the most promising government spectrum for reallocation. With this upcoming report, NTIA can deliver a much-needed shot in the arm for achieving the President’s call for 500 MHz of broadband spectrum.

I’ve met with NTIA staff on many occasions over the last year, and there is no doubt that the NTIA team has been working tirelessly. So, back to my baseball analogy, NTIA stepped to the plate. A year ago, NTIA issued a Ten-Year Plan and Timetable for spectrum and released a “fast track” report that identified an initial 115 MHz of government spectrum for wireless broadband in the next five years: the 1695-1710 MHz and 3550-3650 MHz bands. As CTIA noted at the time, this action reflected the Administration’s keen understanding of “the vital importance of spectrum to improving our economic competitiveness, public safety and the lives of all Americans.” However, we also raised some concern, stating that “the 15 MHz of spectrum that NTIA has identified below 3 GHz is just a start. We will continue to work to ensure that federal policymakers understand, and focus on, the importance of certain bands of spectrum, such as the 1755-1780 band, for delivering on the promise of robust mobile broadband.”

Basically, NTIA took a big swing, made solid contact with the ball, but hit a long, deep, foul ball. Indeed, while the “fast track” bands offered some possibilities, they do not represent the significant, near-term solutions we need for mobile broadband. And, they certainly don’t deliver on President Obama’s directive to indentify spectrum that can “support the forthcoming myriad of wireless devices, network and applications that can drive the new economy.”

First, the 100 MHz from 3550-3650 MHz is considered well above the 3GHz cut-off that has been identified by many parties for mobile services. Spectrum below 3 GHz is viewed as attractive for mobile allocations, because it has superior propagation characteristics, is more easily deployed and allows more throughput over larger areas, penetrates buildings more effectively and suffers less attenuation from trees, foliage and variations in topography. The 3550-3650 MHz band is thus less appealing for delivery of mobile broadband. Plus, this band has other shortcomings. The “fast track” report observed that ongoing government operations in the band would require significant exclusion zones with no commercial operations. Using U.S. Census Bureau data, it appears that between 50% and 70% of the U.S. population would be subject to an exclusion zone in this band.

Second, we’ve supported the government’s efforts to identify and repurpose the 1695-1710 MHz band, which has favorable propagation characteristics and is adjacent to the AWS-1 band, but certain drawbacks exist here as well. This band is not internationally harmonized for mobile broadband, resulting in greater risks and higher costs for equipment development. Pairing with AWS-3 spectrum, moreover, will require additional or modified network infrastructure (unlike the 1755-1780 MHz band). And, according to the fast track report, 12% of the U.S. population would be subject to exclusion zones, including portions of the major metro areas of Washington DC, Miami, San Francisco, Los Angeles, St. Louis and Honolulu.

NTIA knows that the wireless industry sees great value in the significant economies of scale and production that would be reaped by pairing 1755-1780 MHz with the 2155-2180 MHz band currently in the pipeline. Last January, NTIA announced that the whole 1755-1850 MHz band would be its priority band for review in 2011. Over the course of the agency’s review, Assistant Secretary Strickling has referenced the nature of government incumbents in 1755-1850 MHz and the challenges of reallocating the band. More recently, he has referenced a new era of shared use, noting that “the days of clearing spectrum bands of all government uses and then making them available for the exclusive use of commercial service providers are pretty much over…We are headed for an environment where commercial wireless broadband will need to co-exist in the same bands with federal operations.”

I am concerned that while much of the European Union (Germany, UK, Italy, France and Spain) and key countries in Asia (Japan and South Korea) have identified hundreds of megahertz of reallocation for commercial mobile use, we may be facing an environment where the federal government identifies little or no cleared spectrum for commercial use. Not only will that not “support the forthcoming myriad of wireless devices, network, and applications” that the President called for, it may in fact put at risk our world leadership of this incredibly dynamic ecosystem.

In summary, spectrum at 3550 MHz doesn’t support mobile broadband. A report that only delivers spectrum in the distant future will imperil our lead in this dynamic ecosystem. The future is bright, but only if we can purchase the underlying resource necessary for mobile broadband. It seems as if every other advanced country on the planet is planning for this bright future.

Now, NTIA is digging in for the second pitch. We hope that the Administration will find ways, at a minimum, to make the 1755-1780 MHz band available in the near term for repurposing and auction, and work to clear additional spectrum going forward. We certainly hope that the reports we have heard about the cost and timeline for making any government spectrum available for reallocation are not correct. Another strike will put the country in a very difficult position. As the President indicated, we need to act to identify and allocate more spectrum to accommodate the explosive growth in demand for mobile broadband services. Four members of the Super Committee recently urged the President “to put every effort into making available paired, internationally-harmonized spectrum below 3 GHz in sufficient block sizes to support mobile broadband services.” CTIA wholeheartedly agrees – and the immediate focus should be on the 1755-1780 MHz band.

So, we look forward to release of the report and the Administration’s roadmap for delivering on its goal of 500 MHz of spectrum for wireless services.

Will NTIA swing and miss, hit another foul ball or make solid contact?  Stay tuned…