Spectrum-Sharing Reports Leave Many Questions Unanswered, CSMAC Members Say

"The working groups provide useful answers to how sharing might or might not work with specific federal users,” Furchtgott-Roth said (http://1.usa.gov/14Y2yES). “In some, but not all, instances, relocation of federal users is only partially examined and addressed. Many observers, however, are asking entirely different questions. For those entirely different questions, the CSMAC working group reports may not provide useful answers.” Among the unanswered questions is whether some federal users can be moved out of the s 1755-1850 MHz band entirely, he said. “The Working Group papers do not focus on relocation as the primary solution,” he said. “That is a shame.”

Among other unanswered questions, Furchtgott-Roth cites: “Which specific federal services can be relocated and which cannot?” “How much of the 1755-1850 band can be cleared through relocation, and how much cannot?” and “How long would it take and how much would it cost to relocate some or all federal users in the 1755-1850 band?"

"CSMAC has not directly addressed any of these issues,” Furchtgott-Roth said.

Also raising fundamental questions about three of the working group reports are seven other members of CSMAC, including T-Mobile Senior Vice President Tom Sugrue, who represents the carrier on the CSMAC. Also signing the letter were Carl Povelites of AT&T; Thomas Dombrowsky of Wiley Rein; Mark Gibson of Comsearch; Kevin Kahn, representing Intel; Charles Rush of CMR Consulting; and Dennis Roberson, professor at the Illinois Institute of Technology.

"First, by voting to approve the report and recommendations to be transmitted to NTIA, we are in no way endorsing the assumptions and methodologies that went into the analysis,” the seven wrote (http://1.usa.gov/1bPFVBm). “Initially, the analysis performed in each of these working groups was both conservative and limited. We believe that additional effort should be initiated that would greatly mitigate the protection zones for Federal operations including, but not limited to, considering other effects such as clutter, more reasonable interference protection limits and considering a more representative LTE system model. We believe that many of the current analysis results do not represent the real-world interference environment between Federal and commercial users.” The reports are also flawed because members had only limited access to technical data on federal systems in the band, the letter said. “We believe that the process recently initiated to allow the release of more Federal system technical characteristics to parties signing non-disclosure agreements will better inform the commercial parties to understand what can be done to better model an analysis of real-world effects."

CSMAC member Janice Obuchowski, president of Freedom Technologies and former NTIA administrator, noted that NTIA asked CSMAC to look at sharing after it determined that relocating federal users from 1755-1850 MHz band could take up to 10 years and cost as much as $18 billion. “The recommendations of the working groups represent limited findings, based on time and information constraints, about sharing in this band,” Obuchowski said (http://1.usa.gov/13PnoA1). “They do not serve as a broader litmus test for sharing over relocation. The working group effort was initiated precisely because the initial NTIA findings about total clearing for 1755-1850 MHz were deemed to be not compatible with a feasible auction for this spectrum. ... Sharing was not a first choice for finding a path forward for making this spectrum available for broadband but it was, at least in part, an unavoidable starting point for the CSMAC working group’s effort.”

Obuchowski noted that questions have been raised by others about whether the working groups had adequate access to government data. “The working groups were open forums, including to foreign nationals, which also affected releasability from the perspective of national security disclosure requirements,” she said. “These issues will remain pertinent and must be managed going forward in any other band that will be considered for Federal and non-Federal spectrum sharing. In this area, too, progress has been made given the non-disclosure agreements that are now in place with private sector stakeholders and [the Defense Department].”

CSMAC member Michael Calabrese, with the New America Foundation’s Wireless Future Project, said in an interview he believes CSMAC has helped push things forward on sharing. “Industry and the Defense Department, in particular, have moved quite a bit on their willingness to share bands of spectrum, certainly at least on a transition basis,” he told us. “I think industry went into the process believing they could demonstrate the ability of the military to clear off these bands completely in a reasonable amount of time,” he said. “The military went into the working group process convinced that they could demonstrate that it was impractical to be moving out at all. Within the course of the year, I think everyone has been pleasantly surprised that there’s a middle ground emerging that will allow substantial industry access to the band even while it’s shared on at least a transitional basis through exclusion zones and other mechanisms.”, (hbuskirk@warren-news.com)