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GROUPS FRET OVER SPECTRUM RECOMMENDATION PORTRAYALS AT ITU

CTIA, the Telecom Industry Assn. and the Satellite Industry Assn. raised concerns to NTIA Tues. on how some of the FCC’s spectrum reform ideas were being presented to international regulators. The groups said they backed the efforts of the Spectrum Policy Task Force, which delivered a report to the FCC last fall. But they said they were “alarmed” that recent U.S. submissions to the ITU could be misinterpreted as formal FCC policy rather than a staff report.

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At issue is a U.S. govt. submission to an ITU study group last month that’s examining potential changes in international spectrum regulations. A resolution adopted by the World Radio Conference (WRC) this summer had covered options for improvements in the ITU Radio Regulations. The resolution directed that studies be carried out in that area on existing and future technologies, to be reported to the next WRC in 2007. A recent U.S. contribution to Study Group 1, which was tasked to examine this question, outlined spectrum management reform efforts in Japan, Europe and the U.S.

CTIA, TIA and SIA said they were concerned the Spectrum Policy Task Force recommendations were written in such a way as to risk misinterpretation by other govts. that they reflected “decisions by the FCC.” The groups told NTIA that the U.S. submission citing the work of the task force “fails to make it clear that these are staff recommendations that are far from settled policy.” The groups stressed that in comments at the FCC, they had lauded efforts of the task force staff in crafting the report. But some recommendations have generated concern from the private sector. In particular, the report raised the possibility of an interference temperature. That would entail putting a ceiling on the noise environment for receivers. If that threshold weren’t reached in a particular band, a user that operated below that limit would gain the benefit of additional operating flexibility.

SIA has raised concerns about some of the task force’s proposals, including receiver performance standards and the interference temperature. Wireless carriers said the idea of an interference temperature proposal wasn’t yet backed up by “real-world” information, such as noise floor data.

The 3 groups said some of the ideas raised in the report were “nascent” and were the focus of current or future FCC proceedings. “The Commission itself has not acted on most of the concepts and the issues raised in the report also will be considered in the Executive Branch’s Spectrum Policy Initiative,” they told NTIA. “Many of the concepts need to be fleshed out domestically in notice and comment proceedings before it can be determined which of the many ideas may prove worthwhile.”

CTIA, SIA and TIA said their concern was that the ideas were presented in such a way that they could become part of the ITU Radiocommunications Bureau’s report to the WRC. “This could, in turn, lead to some of the unproven and undefined concepts discussed above being incorporated in the ITU’s Radio Regulations,” the letter said. “As the Spectrum Policy Task Force report clearly notes, there is no one-size- fits-all approach, and many of these concepts are inappropriate for existing service bands, which are, in many cases, currently used very efficiently,” the letter said. In general, the groups said the task force report promotes concepts that in some cases, such as the interference temperature, are “unproven.” In other cases, technologies such as completely agile software defined radios and ultra- wideband radios “while having useful properties in theory, will be limited in scope by commercial economics.”

The U.S. submission itself said the task force presented recommendations to the FCC in Nov. on how to modernize U.S. spectrum management for civilian applications, providing a “starting point for a long-term review of spectrum policy approaches that could be implemented for nongovernment use.” It described the task force’s recommendations, including shifting from a command-and-control spectrum model to exclusive use and commons approaches. It said the study group would hold about 3 meetings over the next 3 years to develop information and possible recommendations for consideration at the next WRC.

SIA Pres. Richard DalBello said the concerns the letter addressed had to do with prematurity of some of the ideas being thrown into an international arena before they hade had time to develop fully domestically. Among the ideas cited as possible causes for concern was the interference temperature. “We don’t dispute that these ideas are worth examining,” DalBello told us. “We are saying… please curb your enthusiasm until we have had time to test and validate these concepts.”