Freeing Federal Spectrum

The NTIA released its report on clearing the 1755 - 1850 MHz spectrum of government allocations today, and it’s good news and bad news. The good news is that some government agencies are playing ball, taking the exercise seriously and doing their best to increase the amount of spectrum available for general-purpose commercial networks.  The NTIA says the entire band can be made available within ten years, and significant portions of it much earlier. They caution that some sharing is going to be necessary for quite some time in a few areas, but they’re hoping that the sharing is something both the commercial sector and the government can live with. The bad news is that DOD and the FBI still insist they have applications of such importance that they can’t live without the allocations of spectrum they currently have. I’d like to have been a fly on the wall during the negotiations between the agencies and the NTIA in order to confirm the suspicion that I get from the report that the civilian agencies sent spectrum experts to talk to NTIA’s people while DOD and DOJ sent bureaucrats. That’s what the report seems to indicate.

The primary issue in reallocating spectrum from government use is whether the allocation makes sense any more, and the secondary issue is where in the spectrum map the government’s assignments should be. The 1755-1850 spectrum band is important because it’s been assigned internationally for mobile broadband, so there are tremendous benefits to U. S. firms and consumers if we can use it for that purpose.  While the NTIA appears to have dragged DOD kicking and screaming into the discussion about relocating some of its vital systems to other bands, they don’t seem to have made much progress toward getting them to consider alternate ways of performing their mission that don’t require 300 MHz more bandwidth than our European allies have dedicated to their military establishments. Maybe that’s too much to ask just yet.  And of course the estimated relocation costs provided by DOJ and DOD are outrageous, considering that all the equipment they’ve currently got should be replaced within five to ten years as a matter of course anyway, and this exercise has already been ongoing for ten years.

The executive summary declares: “In conducting the analysis, NTIA and the federal agencies endeavored to protect critical federal operations from disruption and to reach comparable capability via other spectrum, commercial services, or means that do not utilize spectrum, where appropriate” but this isn’t totally reflected in the body of the report. What we see is a desire to preserve the current set of government applications with as little disruption as possible and very little attention to developing alternatives to the current application-based allocation scheme that was the 20^th century’s method of handling spectrum.

Here’s a summary of the number of allocations to government users in the band. The total number is 3183 discrete allocations for particular purposes.

Source: NTIA Report, page 6.

Let’s go through the categories one by one and see what’s going on.

Fixed Point-to-Point Microwave

The first application, fixed point-to-point microwave, should raise a red flag immediately because nearly all its 360 allocations can be probably be replaced by a wireline or commercial alternative. Point-to-point microwave is a virtual wire whose history pre-dates fiber optics and it’s a laggard in terms of performance and quality.

The report excuses these allocations as being cheaper or higher quality than commercial or wireline alternatives, but that analysis only works if you value the spectrum at zero. Replacing 95% of these allocations with fiber backhaul could end up being a net positive for the government because they could over-provision and lease dark fiber to the commercial sector. The only rational application for fixed point-to-point microwave these days is connecting mountain tops in rural areas where there’s no plausible case for fiber and I doubt that’s the government’s typical use case.

Military Tactical Radio Relay

Per the report, “Tactical Radio Relay is a generic term for a class of transportable fixed microwave systems that support Army, Navy, and Marine Corps training at a number of sites and on tactical operational missions.” These systems probably have a stronger use case that fixed microwave, but probably not much of one. The purpose of these allocations should be to connect a training network to a fiber terminal, and I’d be very surprised if DOD needs 579 separate allocations to do this for active training missions. Even if they had hundreds of training missions going on at the same time, they’re not in the same place so there’s no practical reason they need that many allocations. This is another category of microwave, and there are commercial systems and higher frequencies available to support it that aren’t appealing to mobile networks. In fact many of these systems are indistinguishable from commercial mobile broadband systems in function and purpose. Most of these 579 allocations duplicate commercial systems.

Air Combat Training System

The report describe this application as one that “provides, via ground-based and airborne components, real-time monitoring of air combat training including gun-scoring; no-drop bombing; evasion and intercept tactics, techniques, procedures; and electronic warfare.” It seems that the major problem with these allocations is systems that require specific frequencies on which to operate. Combat systems have to be capable of operating overseas, in countries that have not made specific allocations of spectrum to invading armed forces, so you’d want to have some flexibility in them. And in fact they are designed that way, with the ability to operate on a number of frequencies (just like a car radio.) See the following table for some options.

Source: NTIA report, page 16.

The DOD is the prime developer of “software-defined radios” that operate at a wide range of frequencies, and these should be used in all military and law enforcement systems within the next five years in the course of normal replacement of obsolete equipment. The instances in which a particular frequency is needed for testing are rare, but they do exist. They can be accommodated, however, by short term use of the test frequency in a specific area rather than permanent assignment. Test conditions should resemble real-world conditions, after all. 707 allocations are at stake here, as well as the flexibility and utility of real combat systems.

Precision Guided Munitions

These systems “provide critical tactical communications between launched weapons and controlling platforms, allowing for precise and effective targeting.” Like other air combat training systems, they need to function in real-world settings that don’t provide them with a dedicated band and the ability to share and adapt to such conditions. They can be re-assigned to the same bands as air combat training systems.

Tracking, Telemetry, and Commanding

Here’s an application that makes some sense: “DOD satellites provide communications, navigation, surveillance, missile early warning, weather monitoring, and research and development support.” This application needs some specific spectrum assignments because it’s doing things that aren’t generic and don’t have to co-exist with generic systems. These systems have some general utility, and aren’t going to be usurped by commercial systems. Unfortunately, DOD has not build spectrum flexibility into satellites in the past, so they’re less functional than car radios in this respect. They propose to make a minimal change to allow the use of two bands in future satellites (the current “L” band and the future “S” band) but no more. This seems a bit uncooperative given that the “S” band at 2025-2110 MHz is pretty juicy for mobile broadband and there’s a lot of spectrum available above 3 GHz that doesn’t appeal to mobile.

I’d like to see a general principle in place to the effect that we don’t launch billion dollar systems into space that are hard-coded for one or two frequencies.

Aeronautical Mobile Telemetry 

The report says it all: “Aeronautical mobile telemetry systems operate from manned aircraft, unmanned vehicles, aerostats, missiles, or other platforms to provide real-time flight characteristics from the airborne vehicles to the ground, real-time video of cockpit or project information, real-time monitoring of flight research/test parameters, and real-time command and control of the vehicle.

“NASA determined that it can vacate its aeronautical mobile telemetry operations from the entire 1755-1850 MHz band in less than five years. Relocation to the 2025-2110 MHz and 5091-5150 MHz band requires a primary federal allocation for the aeronautical mobile service.” But DOD takes longer and wants more spectrum in return.

Video Surveillance

Of all the applications in the NTIA report, this is the most mind-boggling to me. The report declares: “DHS, DOJ, and the Treasury state they need to retain up to 30 megahertz of contiguous spectrum for surveillance in the 1780-1850 MHz band pending the successful development of new technology and the availability of spectrum in the comparable bands.” Granted, keeping the people safe from terrorists, criminals, and tax evaders is a noble cause, but since when are video bits so special that they need their own network? Commercial networks can easily accommodate the needs of law enforcement for transporting video bits just as they must do the very same job for consumers today and in the future.  There is no justification for putting 30 MHz of contiguous spectrum on hold just after allocating the D Block to the nation-wide public safety network that’s about to be built. The NTIA needs to say “no” to this application, resoundingly.

Unmanned Aerial Systems

The report advises that “The use of unmanned aerial systems has grown significantly with deployment of more sophisticated payloads for expanded functions of electronic attack, communications relay, firefighting, science observation, and search and rescue” and asks for the 2025-2110 MHz band to support this app, gulp. That’s twice as much spectrum as T-Mobile has today. This is a terrestrial application that seems to have most relevance for temporary uses within U. S. borders. Hence it’s difficult to justify such a huge allocation for it.

Conclusions

It seems that the ice is beginning to melt around federal spectrum allocations in the 1755-1850 MHz band. Civilian agencies are generally working in the right spirit toward the national goal, and military and law enforcement agencies are beginning to recognize that their extravagant historical claims on spectrum rights need to be scaled back, even if they’re not entirely happy about it.

This exercise can be judged effective only if the total amount of government spectrum is sharply reduced; simply moving government agencies from one prime spot below 3 GHz to another is actually a failure. Agencies should also realize that they serve the public by performing their roles to the best of their abilities, and these roles do not generally include network operations. The DOD is strangely lacking in enthusiasm for the software-defined radio technology it pioneered. There’s a story there that needs to be told, I fear.

 

Feature image: Source: “An Assessment of the Viability of Accommodating Wireless Broadband in the 1755 – 1850 MHz Band,” NTIA, March 2012, (NTIA Report) page 6.