Counting Spectrum in an Age of Sharing

Mike Marcus’s recent blog post Dueling Spectrum Charts - Part 2 is a nice reminder (not that anyone who reads his blog needs it) that spectrum isn’t just MHz. The current focus on “spectrum sharing” underlines the fact that one has to think of space and time as well as frequency. A more accurate (but also much more geeky) metric would divide MHz by percentage of population covered, and percentage of time allocated.

Using an auction to decide the number of 3.5 GHz spectrum access administrators

The FCC faces a choice of whether to authorize one database administrator or many to run the spectrum access system (SAS) that will manage small cell operation in the 3.5 GHz band. This resembles the choice between an exclusive-use licensing or unlicensed regime. The FCC could use an auction to let the market decide by using a simplified version of the 2008 Bykowsky, Olson and Sharkey proposal.

Harm claim thresholds could help sharing in the 3.5 GHz band

I have filed comments on the FCC's proposed new rules for the 3550-3650 MHz band (proceeding 12-354).

Harm claim thresholds for satellite earth stations

I'm reasonably confident at this point about deriving harm claim thresholds for cellular neighbors and TV receivers (see e.g. the TPRC 2012 paper http://ssrn.com/abstract=2018080). Here's a first cut (a few months old, but I'm behind on blogging...) at thresholds for satellite earth stations.

TV/cellular guard bands - second thoughts

In a recent post ("The FCC's TV/cellular guard bands don't compute") I wondered whether the guard bands between TV and cellular service that the FCC proposed in its Incentive Auction NPRM (pdf) had been designed to make room for more unlicensed in the TV bands. Having spoken to some experts, I’ve concluded that I was probably wrong about that: my new best guess is that they’re a benefit for the cellular industry.

800 MHz receiver criteria as harm claim thresholds

Bob Pavlak at the FCC prompted me to read the 800 MHz “unacceptable interference” rules in the context of an interference limits approach (root post).

The 2004 Report & Order (pdf) introduced the concept of unacceptable interference, “a term of art adopted for the limited purposes of this proceeding … that defines a bright-line test for interference protection that takes into account, among other factors, the strength of the desired signal and the characteristics of the receiver being employed” (Report & Order, footnote 8). While this sounds like a receiver performance requirement, I think it actually amounts to an interference limit or harm claim threshold. In fact, if it is reformulated as a harm claim threshold, it becomes more powerful because it does not enshrine a particular set of receiver performance parameters in the rules, leaving manufacturers and system operator with more flexibility.

Receiver Interference Tolerance: The Tent Analogy

A postcript to my testimony (see previous post) at the House sub-committee on Communications and Technology hearing on receivers: It sounded like Rep. Walden, who chairs the sub-committee, hoped my oral presentation would've mentioned the tent analogy I included in the written testimony. So since at least one person liked it, here it is:

Testimony: Harm Claim Thresholds

I was privileged to testify yesterday at the House Committee on Energy and Commerce’s sub-committee on Communications and Technology hearing on the topic “The Role of Receivers in a Spectrum Scarce World.”

My testimony (pdf; my oral testimony at time code 0:17:23 in the YouTube video on the hearing web page; the members' questions start at 0:27:00; some press here and here) tried to make four points:

1. We need to improve the ability of radio systems in one frequency band to tolerate reasonable signals in adjacent bands. 
2. Receiving system operators must bear some of the responsibility, but need to know what those responsibilities are.
3. Regulators can bring receiving systems into the mix by setting harm claim thresholds (aka interference limits or receiver protection limits), i.e. the interference levels that a service needs to tolerate without being able to bring a harmful interference claim.
4. Congress can play a role by keeping up the pressure, allowing the FCC to move ahead, and funding FCC technical investigations.

The FCC's TV/cellular guard bands don't compute

The FCC incentive auction NPRM [1] proposes 6 MHz guard bands between cellular and TV services (actually 6-11 MHz, depending on how the auction works out). The number is arbitrary, and could well have been chosen on political grounds to make room for more unlicensed in the TV bands.

The impact on interference from cellular systems into TV receivers is much the same whether the guard band is 1 or 20 MHz: most receivers will be unaffected, and for the small but significant number that suffer harm (0.5-5%?), only receiver filters will really help. The real question is: who's responsible for buying and installing those filters - the consumer or the cellular companies?

TV whitespace vs. cellular power limit anomalies

In the previous post, I considered interference between cellular base stations and TV receivers. What about interference between cellular handsets and TV? Considering this case highlights striking contradictions between the low power allowed for TV whitespace devices and the high power the FCC proposes for cellular operation: 20 dBm for whitespace personal devices but 37 dBm for cellphones, in both cases with a 6MHz guard band.

Post-auction cellular interference into TVs?

How many TV receivers will be affected by interference from cellular services as a result of the FCC’s "incentive auction" plan?  The FCC’s proposal doesn’t venture an answer; I don't think it even asks the question. Ofcom’s technical analysis in the UK’s rearrangement of the TV bands to accommodate more cellular service suggests that the number will be small, but not negligible. Ofcom therefore decided to require cellular operators to install filters on TV sets where there is a problem; the FCC has not raised this possibility.

In summary, the UK modeling suggests that TV reception will be affected in about 5% of  homes if there's a 11 MHz guard band between TV and cellular channels; the FCC's proposed guard band will be 6 - 11 MHz, depending on auction outcomes. By far the most effective way to mitigate this interference is by installing a TV receiver filter in affected homes.

Receiver regulation: Why no progress?

(Written with Madelaine Maior, Silicon Flatirons research fellow)

There’s an emerging consensus that the role receivers play in interference should be recognized in wireless regulation. But why has it taken so long to come to a conclusion about the performance of receivers?

Spectrum sharing is not a partisan issue – NOT

After his keynote at Dyspan yesterday, PCAST member Mark Gorenberg and his podium guests (and spectrum report co-authors) Dennis Roberson and Michael Calabrese were asked about the political prospects for the PCAST spectrum sharing recommendations (pdf). I can’t remember exactly who said what, but the message was that spectrum sharing wasn’t a partisan issue. Not so.

Three meanings of "spectrum efficiency"

“Efficiency” is a word of power, chanted when someone wants to bewitch an audience with the potency of economics. It’s often used in wireless policy, and I’ve realized that even when “spectrum efficiency” isn’t purely a fetish and is used to refer a ratio of input divided by output, the amounts compared depend on whether the speaker is an engineer or economist.

PCAST Report endorses receiver interference limits

The President's Council of Advisors on Science and Technology (PCAST) released its report Realizing the Full Potential of Government-Held Spectrum to Spur Economic Growth today (PDF, Administration’s blog post, webcast).

The main thrust of the report is the need for a shift from clearing and reallocating federal spectrum to dynamic sharing. As part of implementation, the report recommends that interference limits are used to include receiver considerations in spectrum management. (I was an advisor to the PCAST committee that wrote this report.)

Recommendation 3.1: The Secretary of Commerce working through the National Telecommunications and Information Administration (NTIA), in cooperation with the Federal Communications Commission (FCC), should establish methodologies for spectrum management that consider both transmitter and receiver characteristics to enable flexible sharing of spectrum. To safeguard primary Federal users, FCC should require that future non-Federal devices will be permitted to share government spectrum as Secondary Access users only if they are certified to operate within the stated interference limits for the band of interest. Initial specification of protection should be reviewed such that they safeguard new FCC assignments against harmful interference while grandfathering in existing devices and operations.

The report recommends that “[i]n order to facilitate more intensive and efficient sharing among Federal users, the NTIA should set and publish receiver interference limits using a transparent process for government assignments” It also recommends that “in the immediate timeframe, the FCC should begin the Notice and Comment cycle on implementing receiver interference limits as part of license terms for new allocations, updating old licenses to include receiver interference limits, and ex ante enforcement mechanism for non-Federal devices sharing with Federal users.” (Section 7.3, p. 77-78)

A detailed discussion of interference limits is given in Appendix D (p. 107 ff.).