The Only Ones Who Will Drop Dead Are Those Who Stand Still.
Given my enthusiasm for the PCAST report on, ‘Realizing the full potential of Government-held spectrum to spur economic growth’, I feel obliged to comment on the CNET article – ‘Feds to Mobile Users: Drop Dead’. I have to give the author marks for his title. It really succinctly summarises what he feels the PCAST report is saying – but that is all I can give him marks for.
From what I read, the main gripe in the CNET article is that Mobile Operators (i.e. Carriers) feel hard done by. They are desperate for spectrum. The hope was that some of their spectrum needs would be filled by cleared Federal spectrum and now these hopes are dashed because the PCAST report has more or less made it clear that this is not the way to go. It is all about sharing now. And the real point of talking ‘sharing’ is to stall anyone getting access to the Federal spectrum. So we the mobile users will all suffer as a result. Not as succinct as ‘Feds to Mobile Users: Drop Dead’ but I think it captures the main gist of the article.
My overwhelming reaction to the article is that when it comes to spectrum management we have the problems we have because we do not think long-term enough. And just so the CNET team are clear, thinking long-term does not mean simply using the word ‘long-term’ in the actual name of the technology.
Let me deal with a few points. The following statement is taken from the CNET article (the new approach referred to is that advocated in the PCAST report) –
“Adoption of this radical new approach to spectrum management would utterly change a system that has been in place since the sinking of the Titanic, and which has in recent decades generated billions of dollars through license auctions.”
When the Titanic sank it was claimed that boats nearer to the sinking liner did not get the call for help due to all the radio interference that occurred. What followed was a focus on safety at sea and the beginning of radio regulations as we have known them for decades. And that is the nub of the issue. The regulations were designed and crafted based on an understanding of the technologies as they functioned at that time and not an understanding of what the technologies could be. And ever since, except in some enlightened cases, we have been mired in technology specifics and the inputs to the system, rather than the behaviours we are seeking and the outputs we desire.
As a simple example from a European perspective, it took a long and drawn out battle to reallocate 2G spectrum to 3G technologies, even when it as becoming clear that 2G was being superseded by 3G. Why? The use of the 2G spectrum was tightly coupled with the use of 2G technologies. The spectrum usage was not defined in a technology- neutral way or in other words things had not changed since the Titanic! And as result many hurdles had to be overcome to allow the bands to be used for 3G.
How then can an industry that has already lost out to a Titanic world view shout in favour of this mindset?
The PCAST report captures, in my opinion, the essence of technology neutrality.
The focus on interference limits or spectrum usage rights is THE best way to truly issue licenses that do not burden a service with the specifics of the technology used to deliver it. They do not restrict the options of the service provider as technologies progress. They open up options. Interference limits are about desired outputs of a system and not about defined technical inputs. If an implementation of the PCAST proposals edges the adoption of interference limits or spectrum usage rights forward by a milimeter, it will be doing the world a favour.
And this point can be further strengthed by drawing on other observations made in the CNET article. As Downes points out –
“While PCAST is to be commended for its vision of future technologies and their ability to make dramatic improvements in the efficiency of spectrum allocation, use, and minimization of interference, the kinds of technologies PCAST foresees simply don’t exist yet. We don’t know when they will come, and how well they will work. There is far too much uncertainty in technologies that “will likely mature” in the next decade to justify a complete rewrite of spectrum policy.”
He is right – we don’t know what is coming. It is uncertain. But he is wrong to let this hold us back.
Of course there are a large number of outstanding technical issues which need to be addressed – at the regulator side and at the spectrum consumer side. And these are hugely challenging. But they should be. When regulating for the long-term it is important to allow the technical imagination go wild. It is important to speculate and conceive of things that are yet to come. Then it is essential to remove all traces of this future technical proposition from the picture.
And to my mind the PCAST report does that. In it, there is room for very static technologies that just use spectrum in certain bands when it is free and possibly stay in those bands for long durations. But there is also room for completely dynamic cognitive systems that get assignments of spectrum on-the-fly and move to the next assignment for the next session. In it there is room for traditional commons-like behaviour as we already know (i.e. power limited behaviour) as well as room for new spectrum etiquette and different flavours of light-touch regulation. There is room to pay for spectrum and room for free options. There is room for exclusivity and for inclusivity.
And while Downes states that
“Over the last two years, spectrum “sharing” has become code among federal authorities to stall for more time.”
I argue, that it is the sharing itself that is the scary thing and far from a stall tactic. It is the beginning of the end of what we know today for incumbents and legacy systems. It is the beginning of a true opening up of the spectrum and that means opening to many more than the traditional operators.
And while much of the article focuses on the huge data demand and the need for speedy access of spectrum, there is in my mind no evidence that clearing would be any faster. But more importantly it would involve a piecemeal approach (more of the same short-sightedness) and not the systematic rethinking advocated in the PCAST report.
I think it is very apt that the image of the Titanic was evoked in the article as to me the Mobile Operator or Carrier as we currently know and understand it is somewhat of a sinking ship. In many areas of the world current business models are unsustainable. But the Carrier who embraces the opportunity and who looks at the proposals as means of expanding its reach, thinking about new topologies, embracing new ownership models, understanding new modes of collaborative consumption will not go down. This is an additional opportunity – not a taking away.
Of course there are many challenges and loads to answer. But the PCAST report is about moving forward and it is only those who stand still that will drop dead!