Hello readers, my name is Benjamin Lennett, and I work with Sascha at the New America Foundation's Wireless Future Program as well as contribute to the foundation's Open Technology Initiative (OTI).

Last week, OTI, along with Iarla Flynn, European Policy Manager for Google, submitted a filing to Ireland's Spectrum Policy Consultation . The document, A Technology Driven Spectrum Policy, lays out a new vision for Ireland's Spectrum Policy in the 21st Century. The document focuses on encouraging unlicensed access and cognitive radio technology to promote a more efficient, flexible, open, and inclusive approach to spectrum management.

The following is a summary of the filing:

A Unique Opportunity for Ireland

Ireland is in a unique and enviable position. Its geographic locations and relative lack of congestion in most spectrum bands, provide Ireland with the flexibility and freedom to become a policy innovator in spectrum management, allowing it to quickly reallocate valuable spectrum to further advanced wireless telecommunications and broadband, while also encouraging technological innovation and experimentation.

Spectrum policy has largely developed under an assumption of scarcity, and therefore the need to ration spectrum access as means to prevent interference among users. This has resulted in a policy framework that placed state authorities in Ireland and elsewhere in the role of hands-on managers of national spectrum resources.

But, the reality is that spectrum under current management frameworks is substantially underutilized. An independent analysis of usage in the centre of Dublin (in 2007) highlights that average use across the primary spectrum bands was less than 14 percent. In addition, technological advancements in wireless communications are fundamentally changing how we can manage access to spectrum, providing for more equitable and efficient use of this public resource. "Smart" or "cognitive radio" technologies and the shift from analog to digital for various services (e.g. terrestrial TV and public safety services) provide a timely opportunity to reallocate significant blocks of spectrum for new uses and services.

The switch over to Digital Television (DTT) provides a tremendous opportunity for Ireland to re-envision its spectrum policies and reallocate valuable spectrum for advanced communication uses and technologies. The challenge for Ireland is to develop a broad-based spectrum policy that ensures all Irish citizens can access the benefits of this public communications resource.

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Yesterday will go down in history as a bellwether moment. Few among us will soon forget the excitement of Obama's election. But there was an equally historic vote yesterday that for geeks, policy analysts, and technologists represents an entirely new trajectory in telecommunications. In essence, the FCC has begun the transition from command-and-control, single-user spectrum licensure to a more distributed system that holds the potential to eliminate the artificial scarcity that prevented widespread access to the public airwaves since 1927.

Yesterday, the FCC ruled that unlicensed white space devices would be allowed to operate on unused television channels -- allowing an entirely new generation of technological innovation to begin. While the official order has not been release, here's the information that's been gleaned thus far (please note that this is tentative information and until the official Report and Order is issued by the FCC, while unlikely, is subject to change):

• Both fixed and personal portable devices will be allowed. So look for base stations on cell towers as well as next generation PDAs and multi-media devices.
• Personal portable devices will be allowed to operate at power levels up to 40mW.
• On non-adjacent channels (i.e., where you have three unoccupied TV channels in a row, this would be the middle channel), higher power levels will be allowed (up to 100mW -- though I've also heard that up to 4-5W may be possible).
• Unlicensed wireless microphones will not receive priority status except, potentially, on channels 2-4. On all other channels (through to channel 51), all devices will share secondary status to primary broadcasters (e.g., television stations and licensed microphones).
• A geolocational database will back up spectrum sensing capabilities to ensure WSDs do not operate in restricted areas. Left unclear is whether licensed wireless microphone users will be allowed to exempt their venue from WSD use and whether this would also allow for unlicensed wireless microphone users to do likewise.
• A Notice of Inquiry will be launched by the FCC to investigate higher-powered use as an additional service in areas with few digital TV stations. This would facilitate backhaul capabilities for WISPs and other service providers.

I first started working on this proceeding back in 2004. After years of work, and an ever-increasing amount of time and energy spent on this battle, I can honestly say that I'm amazed by how successful this work has proven. At the same time, much like the presidential election, this win provides only the opportunity for amazing new innovations and services and much work remains. We need to work with performing arts groups to ensure that they have access to the technologies they need to carry out their work. And we need to work with wireless ISPs and allied organizations to ensure that they have the resources they need to continue spreading connectivity to underserved communities across the country. Finally, though the foundation has been set, the most important battle is yet to come -- opening up all underutilized bands for opportunistic spectrum reuse.

I expect a multi-pronged approach to what lies ahead. I've already begun talks with WISP allies to follow up on the FCC's announced NOI. Likewise, I'm hopeful that folks I've been talking with for months within the performing arts community will see the FCC's decision as a good reason to collaborate on future joint efforts. In the interim, I am working with my colleague, Victor Pickard, on opening up debate on opportunistic spectrum reuse -- starting with government spectrum. Our revamped working paper should be out in the near future, laying out a policy agenda for what needs to be done at the down of the age of opportunistic spectrum reuse.

Here's the FCC's press release as well as Commissionerss statements:

11/4/08

FCC Adopts Rules For Unlicensed Use of Television White Spaces.
News Release: Word | Acrobat
Martin Statement: Word | Acrobat
Copps Statement: Word | Acrobat
Adelstein Statement: Word | Acrobat
Tate Statement: Word | Acrobat
McDowell Statement: Word | Acrobat

For long-time readers, you know that I've been working on the 3650-3700 MHz FCC proceedings for a few years nowthe FCC created a rather unique quasi-(un)licensing rule for the band, allowing community networkers, WISPs, and other interested parties to access this resource. By 2007 we began to see the widespread availability of 3650-3700 MHz equipment.

I've begun to collect data on real-world use of 3650-3700 MHz equipment (yes, it's already being implemented in networks across the country):

WISPs have been leading the charge and people are reporting 15km non-line-of-sight (NLOS) connectivity with 3650-3700 MHz (operating at 10W) -- which is a huge boost over 802.11. Meanwhile, capacity seems to be hovering around 15 Mb per 7.5 MHz (or 20Mb per 10MHz) -- so 100Mb connections over 15km without line of sight are quite feasible using this band. All in all, that's pretty impressive for first-generation equipment. The equipment vendor Aperto is claiming that their new equipment will get 20Mb per 7MHz (so you can see the development curve is already fairly steep).

To give you a feel for the real-world implications, folks testing things out reported, "6mb/s indoor at 2 miles NLOS. The base station was a 1 sector install using diversity at approximately 50ft up on tower using 120 degree sectors" -- try to get that with an 802.11 access point.

Sooner or later metro wireless folks will figure it out (at which point they're deploy like crazy before realizing the capacity limits given population/user density). Meanwhile, I think it's fairly clear vindication as to the import and utility of the band. Hopefully, municipal networkers will check with objective experts before jumping onto what is sure to be a 3650-3700 MHz bandwagon, but all in all, this is great news for wireless networkers everywhere.

"Smart" wireless devices can use the unassigned frequencies between broadcast TV channels to offer wireless broadband and other innovative services. A rulemaking is pending at the FCC (docket 04-186) to permit unlicensed access to this currently wasted spectrum, subject to technical requirements that will protect television reception from interference. Access to the vacant TV channels in each market has been the subject of intense lobbying, yet far too many of the arguments against "white space" devices rely upon misinformation about the technologies and the FCC process that will prevent harmful interference to DTV reception and other incumbent services.

This policy backgrounder offers a summary analysis, and is an effort to help policymakers strike the appropriate balance between protecting existing services from interference while making the benefits of mobile broadband services available and affordable for all consumers. It provides policymakers with:

1. a brief historical background to the current FCC proceedings;
2. a description of White Space Device (WSD) technologies;
3. a “Myths vs. Facts” section addressing the key concerns raised about WSDs;
4. an overview of the public benefits of WSDs; and
5. a concise summary of where we are in the multi-phase process of adopting WSD technologies for consumer use.

For the full document, please click here.

The political tides are beginning to turn when it comes to opening up vast quantities of new spectrum to unlicensed devices. Strangely enough, it's not the FCC that's the driving force behind these new initiatives, but Congress. Congressional members, tired of a stagnant broadband rollout across the United States are, more and more, taking matters into their own hands.

There's been a ton of news of late, but here's the last blurb to come across my desk (from the Benton Headlines):

WIRELESS ENTREPRENEURS: CAN YOU HEAR US NOW?

[SOURCE: Broadcasting&Cable, AUTHOR: John Eggerton]

Republicans and Democrats on the Senate Commerce Committee remain pretty much in agreement that some legislation is needed to open up spectrum to wireless devices, likely including some in the spaces between broadcast channels. Driving the concern is the rollout of broadband service to rural and other underserved areas. At a hearing on the issue in the committee Tuesday, John Kneuer, of the National Telecommunications and Information Administration, pointed out that, starting in 2005, the Office of Management and Budget said spectrum policy has to be looked at in terms of conserving and efficiently using spectrum. Thomas Walsh, of the rural Cellular Association, argued that it is technologically feasible to open up the broadcast band to unlicensed devices "with no danger" to existing broadcast channels, and said there is a clear benefit to doing so. Sen Kerry called broadcasters' fears of interference from the new unlicensed devices a "false argument."

www.broadcastingcable.com
(free access for Benton's Headlines subscribers)

* Intel urges lawmakers to free up U.S. airwaves