A Lesson on Spectrum: Study Up!
Today the NAB released yet another “study” in its frenetic, reality-defying campaign to prove that America is not facing a spectrum shortfall. We are tempted to again recite the facts on the exponential growth of wireless demand, the finite nature of spectrum supply and the inherent inefficiency of current broadcast spectrum use. Rather than restating the obvious, we make the following observations. First, every one of the spectrum efficiency techniques cited in the NAB “study” has been long known, long used or fully evaluated by wireless carriers. Americans will purchase more than 150 million new wireless devices (including more than 70 million smartphones) in 2011 alone, and every one of those devices needs spectrum to function. Meanwhile, the nation’s 1,600 or so commercial TV stations collectively hold vast stores of underused spectrum and, rather than allowing that spectrum to provide service to the 150 million new wireless devices consumers are adding this year, these TV stations are hoarding spectrum to instead serve fewer than 10 million American households. Second, the “study” ignores the fact that the underlying approach of the FCC and White House spectrum plan is to extend spectrum efficiency techniques to TV broadcasting — an industry populated by tall towers, high power and mileage separations that leaves spectrum unnecessarily idled. Efficient re-allocation of underused TV spectrum to alleviate the broadband spectrum shortage is logical and necessary. Finally, the NAB “study” ignores the most obvious and telling question -- if wireless providers could solve their spectrum needs cheaply or don’t have spectrum needs at all, why would they want to pay billions of dollars for such an unnecessary asset? Anyone who has studied not only projections, but also actual use of mobile networks knows that our wireless networks desperately need more capacity – wireless companies are seeking more spectrum for their networks because their customers demand it. The NAB document, authored by NAB-hired consultant Uzoma Onyeije and entitled “Solving the Capacity Crunch,” starts by saying that increasing the capacity of existing spectrum can help alleviate the need for spectrum. The paper then goes through a rather unremarkable recitation of all of the “tools” in the “toolbox” for wireless carriers to use. The NAB author does note in passing that these techniques have already resulted in a “sixteen hundred times improvement” in “spectral efficiency.” Other proposals — such as the use of Wi-Fi networks to offload capacity from carrier networks — have resulted in increased network load, not decreased traffic. And, the customer provided femtocells suggested by Onyeije are a good solution for signal fading issues, but have no benefit in increasing capacity. Thanks for the help, Mr. Onyeije, but the mobile industry employs tens of thousands of actual engineers and spectrum optimization experts. In stark contrast to the dynamic and ever-changing wireless ecosystem, the broadcast industry, which has undergone only one partially taxpayer-funded government-mandated infrastructure upgrade in the past 50 years, remains an infrastructure dinosaur. The essential television delivery architecture has remained unchanged for broadcasters (except for a government-mandated digital conversion) since the dawn of TV time. The wireless industry is committed to fulfilling the promise of mobile broadband for the nation. That means expanding output so that capacity limits are not the bottleneck for the applications and communications services and products that will fuel increased economic growth and development for the country. Historically, the cycle of innovation has meant that increased capacity has resulted in increasingly sophisticated and innovative uses and devices, which in turn have driven additional growth. As much as Onyeije now attempts to discount the potential growth of wireless data, the facts and data gathered by the FCC from innumerable sources contradict his lone — and self-interested — cry that mobile data demands will suddenly, and inexplicably, decrease. CTIA and CEA urge the FCC — in Onyeije’s own words—“to rely on data it has gathered and analyzed rather than slanted and unsupported ex parte filings.”