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Spectrum Success Requires Smart Studies

Spectrum Success Requires Smart Studies

February 29, 2024

Our lives are more wireless than ever, but the spectrum your wireless devices use to send and receive data is getting overcrowded for consumer-level uses. The federal government, on the other hand, controls vast amounts of spectrum, and there’s good reason to think it has room for greater efficiency. We need federal agencies to be more efficient so that there’s more spectrum for consumers.

That’s why the National Telecommunications and Information Administration (NTIA) will soon unveil the implementation plan for the National Spectrum Strategy (NSS). The NSS is a long-awaited effort to repurpose some of the federal government’s spectrum for commercial uses. The implementation plan must, therefore, detail the process for determining what bands can be opened to commercial applications and under what legal and technical rules.

Technical studies will be the backbone of this process, so much depends on their quality and thoroughness. ITIF found that inconsistent or unrealistic studies caused some of the drama surrounding the aviation industry’s attempt to block mobile wireless use of the C band. As part of the NSS, NTIA itself is now seeking a redo of a study of the lower 3 GHz band, apparently unsatisfied with the Department of Defense’s (DOD) work the first time around.

Missteps on spectrum studies cost years of delay and risk missing out on value Americans could get from the airwaves. Therefore, we’ve distilled some best practices that should guide NTIA and all federal agencies as they implement the NSS.

Don’t let incumbent users control the study

Federal agencies have jobs that require spectrum, but they also have incentives to overstate their need for it and understate the possibilities for repurposing it. If you ask the guy holding the cookie jar, he’ll always say he needs all those cookies. Therefore, while NTIA should collaborate with federal agencies, it shouldn’t let them be the judge and jury in determining what spectrum they can give up. This is true even for agencies with sensitive uses, like DOD. National security is an essential interest that NTIA will account for, but it must not be used as a trump card to undermine more efficient spectrum use.

NTIA is also the ideal agency to lead these efforts because it houses the Institute for Telecommunication Sciences (ITS), a world-leading lab that can run robust tests and make unbiased findings. Congress should ensure ITS has the money and personnel it needs to play this role and work through studies in a timely manner.

Consider all the options

There are lots of different ways to open federal spectrum to commercial use. Of course, the cleanest option is for the federal users to simply clear out of the band and carry out their missions using another band or another technology altogether. However, federal agency incumbents all too often fall back on the excuse that clearing is not technically possible and that sharing is the only answer, even when clearing is technically feasible. Clearing also provides regulators with the most flexibility in deciding what the access regime for commercial use should be. Therefore, studies should always consider clearing a band to be the first resort. But when clearing isn’t possible, spectrum access can be divided by:

  • Geography: If the federal government needs a certain band around certain military bases, for example, studies should identify the minimum necessary protection zone and allow commercial users everywhere else.
  • Channels: Even if the federal agency can’t clear out of a band entirely, studies should consider whether its uses could be packed into a smaller set of frequencies in the same band, allowing commercial users to access the other channels.
  • Dynamic sharing: the flagship example of CBRS showcases a centralized system in which commercial devices are allowed to use a band until the federal incumbent needs it and are then kicked off until the federal user is done. There are many different types of systems that could fall under the label “dynamic sharing,” and studies should consider their benefits and costs relative to other options.
  • Time: A federal and commercial user can share the same frequencies in the same place if they transmit at different times. Time sharing could include splitting up use between day and night or more advanced techniques that can divide access down to fractions of a second.

There are many more sharing avenues deserving of study. There are also many different ways to incentivize and finance clearing bands by relocating federal users. The implementation plan should put all of them in play and choose the one that makes the band most productive.

Consider tech life cycles and future needs

The federal government uses a lot of different wireless devices which are all in different phases of their life cycles. If, for example, a federal system will need to upgrade certain radios soon anyway, it would be better to accelerate that change rather than conduct a study that seeks to protect a soon-obsolete device. Accelerating the timeline of equipment upgrades will give the agency the benefit of better equipment and give NTIA more flexibility in determining what the spectrum needs of that agency really are.

Don’t take receivers for granted

While federal agencies’ radio receivers should be tuned and filtered to only listen to their assigned frequencies, in practice, many are not robust enough to do that. In the past, this fact has been used to block commercial access to frequencies that incumbents shouldn’t have been using in the first place. NTIA should be careful, therefore, to study the characteristics of receivers actually in the field, but it should also put the onus on agencies to account for their receivers’ performance.

Improving receiver performance not only makes federal agencies better neighbors to incoming commercial uses, but it also makes them more resilient and secure. The more critical the federal mission is, the more important it is for the agency's receivers to be hardened against interference from spurious or malicious transmissions.

Use established criteria as a baseline for studies

Everyone should be working from the same, realistic assumptions so that the outcome of the studies is comparable across alternatives. These assumptions should be based on input from stakeholders as to the capabilities of devices in need of protection, but they should not set parameters so unrealistic that they bake the policy outcome in before the study takes place. That means that simulated interference events should not stack worst case scenarios that produce outcomes that are far less likely than even the most sensitive risk tolerances demand. The goal here is to maximize the productivity of all spectrum, not cripple it with risk aversion that approaches infinity.

Look both ways for harmful interference

NTIA should not stop once it ensures federal users are protected in a reallocation. For example, an outcome in which commercial uses are allowed in a band, but the federal user just turns up the power such that any private applications are impractical, is a failure, not a success. The reallocation will do no good to American consumers if the federal system causes harmful interference to a commercial system.

By following these guiding principles, NTIA can ensure that its decisions are based on objective evidence that improves spectrum productivity across the board. The right studies will advance federal and commercial interests to the benefit of all Americans and set the stage for the NSS to reestablish U.S. leadership in spectrum policy.

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