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ILSR Co-Signs FCC Comment Endorsing More Open Spectrum

The Institute for Local Self Reliance has joined with Public Knowledge, Common Cause, and the Open Technology Institute, in submitting reply comments to the FCC last week as the Public Interest Spectrum Coalition (PISC). The issue at hand is the FCC’s proposal of new rules for how to govern the 3.5 GHz band, a range of the electromagnetic spectrum useful for many different types of communication. 

The PISC comment focused on the importance of getting away from the long-standing FCC policy of simply auctioning off big slices of spectrum for telecom companies to use exclusively, which inhibits innovation and enables a monopolization of the communications marketplace. Verizon and AT&T, who hold licenses to large swathes of the spectrum already, are lobbying to FCC to keep the status quo in place. PISC (and ILSR) support a more open arrangement, allowing multiple users to share the same underutilized spectrum segment, while still avoiding interference. The full text of the comment is available here. 

The language and policy of spectrum management can seem arcane to people unaccustomed to it, but how we regulate and use the electromagnetic spectrum has wide ranging consequences for almost all the technology we use in our daily lives. For a general primer on the importance and possibilities of a more open spectrum licensing policy, see the wireless commons articles we published earlier this summer.

You can view the full text of the PISC comment through the link below.

Wireless Commons Part 2: The Possibilities of an Open, Unlicensed Spectrum

In the first part of this series, we discussed how spectrum could be better managed to allow far greater communications capacity, but only if the FCC abandoned its traditional approach of auctioning spectrum to carriers for monopolistic use. In this part, we’ll discuss how devices could take advantage of a new approach to spectrum management and how it might help to circumvent gatekeepers, whether corporate or government.

With increased unlicensed use of the spectrum, an astonishing range of possibilities emerges. Mobile devices could communicate with each other directly, without reference to a central node controlled by a telecom company or monitored by a government. Access points could be strung together wirelessly to create decentralized ad hoc networks, with each device forwarding data from every other, creating a seamless network throughout an entire neighborhood or city. Commotion Wireless is already attempting this on a small scale with just the existing spectrum.

Such networks already exist in a few places, but access to more unlicensed spectrum and permission to use stronger signals would allow them to grow, potentially creating a more decentralized and democratic way to share information and access the internet; an end-run around data caps, future “fast lane” policies, and other drawbacks of relying on one or two telecom oligopolists as a network owner and gatekeeper.

Another exciting possibility for unlicensed spectrum use can be found in emerging Ultra-Wide Band technologies. These allow devices to use a large swath of spectrum at very low power to send information in bits and pieces over short distances, somewhat similar to bitTorrents, and could allow for nearly instantaneous exchange of gigabits of data. All of this is dependent, however, on access to spectrum with the right characteristics, such as low frequency TV bands that can penetrate physical obstacles like walls or trees especially well.

These technologies have political ramifications as well. Rather than having to make monthly payments to a national provider as you do with your cell phone, we would have different models to choose from. Some would be just a matter of buying the right device, just as we already do with computers. Imagine setting up a neighborhood-wide network just as easily as setting up a home Wi-Fi network.

These possibilities are made both more enticing and more urgent by the huge growth in the demand for mobile data worldwide. The near ubiquitous status of increasingly high tech mobile devices, combined with the increased use of smart meters and other remotely controlled devices for homes and businesses, as well as the general growth in the size of audio, video, and other files all drive this trend.

Mobile connections grew from 1% to 13% of total Internet traffic from 2009 to 2012, and Qualcomm expects mobile data usage to grow by a factor of 1,000 from 2012 to 2020. With these demands, it is increasingly important to find new ways to use the spectrum that are not mutually exclusive. In this environment, the allocation of exclusive broadcasting licenses for the vast majority of the spectrum to incumbents who use those rights inefficiently makes little sense.

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The FCC has some choices to make about how it will meet these challenges. It could simply clear underused spectrum, chop it up, and auction it again for new one-time revenue. Clearing space on the spectrum through reallocation is expensive and time consuming, however, involving complex legal and technical maneuvering.

What if rather than having Wi-Fi, the U.S. Treasury had a few extra billion dollars by auctioning that space on the spectrum to a monopoly provider rather than creating a commons? These are the real trade-offs currently being weighed and you better believe that the big wireless companies and their allies in Congress are working hard to prevent any major changes to the system they rule.

There are smarter approaches. The FCC could create a framework for sharing licensed spectrum, retaining priority use for original license holders while also forcing them to allow intelligent devices that sense and make use of available frequencies to operate within their licensed space. Or they could clear more space to be used for unlicensed communications, currently restricted to a few tiny portions of the spectrum. More unlicensed space is the most likely approach to foster significant development of new wireless technologies, which are difficult or impossible to deploy while telecom companies control so much of the airwaves.

All of this is unlikely to happen in the current regulatory regime. Telecom companies have shelled out billions for exclusive licenses and made large investments in technologies that work within the current business model of spectrum ownership. They also covet the foreclosure value that their ownership provides, meaning the ability to shut out competitors by denying them spectrum. As a result, a few massive telecom corporations have little to gain by democratizing access to spectrum bandwidth.

National elected officials, most of whom are not known for their technological savvy, must weigh the temptation of quick money ($20 billion from one auction in 2008 alone) in new license auctions with the difficult to conceptualize but potentially massive economic and social benefits of a more open spectrum. Unless they feel pressure from ordinary citizens who stand to benefit from greater spectrum freedom, the status quo of expensive, centralized communications and suppression of innovation is unlikely to change.

Spectrum graphic courtesy of Wiki Commons.

Wireless Commons Part 1: Interference Is a Myth, but the FCC Hasn't Caught on Yet

This is the first in two-part series on spectrum basics and how we could better manage the spectrum to encourage innovation and prevent either large corporations or government from interfering with our right to communicate. Part 2 is available here.

We often think of all our wireless communications as traveling separate on paths: television, radio, Wi-Fi, cell phone calls, etc. In fact, these signals are all part of the same continuous electromagnetic spectrum. Different parts of the spectrum have different properties, to be sure - you can see visible light, but not radio waves. But these differences are more a question of degree than a fundamental difference in makeup. 

As radio, TV, and other technologies were developed and popularized throughout the 20th century, interference became a major concern. Any two signals using the same band of the spectrum in the same broadcast range would prevent both from being received, which you have likely experienced on your car radio when driving between stations on close frequencies – news and music vying with each other, both alternating with static. 

To mitigate the problem, the federal government did what any Econ 101 textbook says you should when you have a “tragedy of the commons” situation in which more people using a resource degrades it for everyone: they assigned property rights. This is why radio stations tend not to interfere with each other now.

The Federal Communications Commission granted exclusive licenses to the spectrum in slices known as bands to radio, TV, and eventually telecom companies, ensuring that they were the only ones with the legal right to broadcast on a given frequency range within a certain geographic area. Large bands were reserved for military use as well.

Originally, these licenses came free of charge, on the condition that broadcasters meet certain public interest requirements. Beginning in 1993, the government began to run an auction process, allowing companies to bid on spectrum licenses. That practice continues today whenever any space on the spectrum is freed up. (For a more complete explanation of the evolution of licensing see this excellent Benton foundation blog post.)

Although there have been several redistributions over the decades, the basic architecture remains. Communications companies own exclusive licenses for large swaths of the usable spectrum, with most other useful sections reserved for the federal government’s defense and communications purposes (e.g. aviation and maritime navigation). Only a few tiny bands are left open as free, unlicensed territory that anyone can use. 

NTIA Spectrum Map

This small unlicensed area is where many of the most innovative technologies of the last several decades have sprung up, including Wi-Fi, Bluetooth, Radio Frequency Identification (RFID), and even garage door openers and cordless phones. A recent report by the Consumer Electronics Association concluded that unlicensed spectrum generates $62 billion in economic activity, and that only takes into account a portion of direct retail sales of devices using the unlicensed spectrum. 

On its face, the current spectrum allocation regime appears an obvious solution; an efficient allocation of scarce resources that allows us to consume all kinds of media with minimal interference or confusion, and even raises auction revenues for the government to boot. 

Except that the spectrum is not actually a limited resource. Thanks to the constant evolution of broadcasting and receiving technologies, the idea of a finite spectrum has become obsolete, and with it the rationale for the FCC’s exclusive licensing framework. This topic was explored over a decade ago in a Salon article by David Weinberger, in which he interviews David P. Reed, a former MIT Computer Science Professor and early Internet theorist. 

Reed describes the fallacy of thinking of interference as something inherent in the signals themselves. Signals travelling on similar frequencies do not physically bump into each other in the air, scrambling the message sent. The signals simply pass through each other, meaning multiple signals can actually be overlaid on each other. (You don’t have to understand why this happens, just know that it does.) Bob Frankston belittles the current exclusive licensing regime as giving monopolies on colors. 

As Weinberger puts it:

The problem isn’t with the radio waves. It’s with the receivers: “Interference cannot be defined as a meaningful concept until a receiver tries to separate the signal. It’s the processing that gets confused, and the confusion is highly specific to the particular detector,” Reed says. Interference isn’t a fact of nature. It’s an artifact of particular technologies.

In the past, our relatively primitive hardware-based technologies, such as car radios, could only differentiate signals that were physically separated by vacant spectrum. But with advances in both transmitters and receivers that have increased sensitivity, as well as software that can quickly and seamlessly sense what frequencies are available and make use of them, we can effectively expand the usable range of the spectrum. This approach allows for squeezing more and more communication capacity into any given band as technology advances, without sacrificing the clarity of existing signals. In other words, (specifically those of Kevin Werbach and Aalok Mehta in a recent International Journal of Communications paper) “The effective capacity of the spectrum is a constantly moving target.”

In the next post, we’ll look at how we can take advantage of current and future breakthroughs in wireless technology, and how our outdated approach to spectrum management is limiting important innovation.

Save the White Spaces! From Public Knowledge

The FCC is now contemplating how much newly freed spectrum to retain for public use and how much to auction off to private companies for their exclusive use. Public Knowledge is leading the effort to ensure we retain enough shared spectrum to unleash more innovation and public benefits rather than simply padding the profits of a few massive firms that already control plenty of it.

In addition to the Gigabit Libraries Network's White Spaces Pilot Project, we have shared white space technology stories from North Carolina and New York

Public Knowledge recently created a video on the prevalence of spectrum in our lives, included below. Most of us take for granted the fact that shared (or unlicensed) spectrum permeates our culture. 

Instead of sitting by while the resource is auctioned off to the highest bidder, Public Knowledge has also created a petition to retain the spectrum needed for white space technology to spur more innovation. From the petition:

One of the most promising new technologies uses the empty spaces between television channels, the so-called "TV white spaces" (TVWS). The United States currently leads the world in this new technology. In the few short years since the FCC approved use of the TVWS, companies have built and shipped equipment to bring needed broadband to rural communities, creating jobs and expanding opportunities.

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We call on the FCC to set aside 4 reclaimed TV channels, or 24 MHz, for TV white spaces. This will still leave the FCC more than enough to auction to wireless companies for their commercial needs. By reserving 24 MHz of "unlicensed" spectrum across the country for TV white spaces, the FCC will encourage further innovation in wireless services and foster the growth of next generation WiFi contributing billions of dollars in new products and consumer savings.

Video: 
See video

Solar Powered Wireless on the Reservation - Community Broadband Bits Episode #76

When it comes to building a community owned wireless network, few have more experience than Matthew Rantanen, our guest for the Community Broadband Bits podcast this week. Rantanen has an impressive list of titles, two of which are Director of Technology for the Southern California Tribal Chairmen's Association (SCTCA) and Director of the Tribal Digital Village Initiative.

We discuss the need for better network access on reservations generally and how several reservations in southern California were able to build their own wireless networks using unlicensed spectrum and the power of the sun. This success has inspired others, including in Idaho, to take similar approaches to ensure modern connectivity.

We also discuss the importance of unlicensed spectrum to ensure that underserved communities can build the networks they need without having to ask for permission and the role that Native Public Media plays in expanding access to media across North America.

We want your feedback and suggestions for the show - please e-mail us or leave a comment below. Also, feel free to suggest other guests, topics, or questions you want us to address.

This show is 16 minutes long and can be played below on this page or via iTunes or via the tool of your choice using this feed.

Listen to previous episodes here. You can can download this Mp3 file directly from here.

Thanks to Haggard Beat for the music, licensed using Creative Commons.

Wireless Internet Access Fact Sheet

Wireless networks have been incredibly successful, from home Wi-Fi networks to the billions of mobile devices in use across the planet. So successful, in fact, that some have come to believe we no longer need wires.

We developed this fact sheet to clarify some misconceptions about what wireless Internet networks are capable of and the importance of fiber optic cables in building better wireless networks as our bandwidth needs continue to increase.

This fact sheet defines important terms, offers some key points clarifying common misconceptions, compares 4G and 3G wireless to wired cable, and more. We also include references to additional resources for those who want to dig deeper.

Download our Wireless Internet 101 Fact Sheet Here [pdf].

If you want updates about stories relating to community Internet networks, we send out one email each week with recent stories we covered here at MuniNetworks.org. Sign up here.

Dewayne Hendricks Explains the Forgotton National Information Infrastructure - Community Broadband Bits #34

Have you heard of the National Information Infrastructure, or the NII? Most of us either haven't, or have forgotten we once knew what it could be. Dewayne Hendricks joins us to remind us what it was and why we should care. It's "kind of a big thing." Since we conducted this interview, unlicensed spectrum issues became a hot topic; listen below to get a better sense of just how important this issue is.

In our discussion, Dewayne walks us through the original vision, one that now seems fanciful: a world of mobile devices that interconnect with each other on the wireless networks that surround us. While we do have wireless networks in most places, they are often controlled by a few companies, like Verizon and AT&T, that restrict how we can use them and how our devices can talk to each other.

But the NII was to be more decentralized, creating much more space for entreprenuers and innovators to create new business models. A few massive corporations were able to change that vision, creating a lucrative role for themselves as gatekeepers along the way.

Dewayne started this conversation by recommending a 1995 filing by Apple [pdf]. Whether you read it before or after our conversation, it is worth taking a look.

Dewayne has previously joined us to discuss wireless generally and then later to talk about the wired vs. wireless debate. A previous interview with Bruce Kushnick is also referenced over the course of this interview.

We want your feedback and suggestions for the show - please e-mail us or leave a comment below. Also, feel free to suggest other guests, topics, or questions you want us to address.

This show is 30 minutes long and can be played below on this page or subscribe via iTunes or via the tool of your choice using this feed. Search for us in iTunes and leave a positive comment!

Listen to previous episodes here. You can can download this Mp3 file directly from here.

Thanks to mojo monkeys for the music, licensed using Creative Commons.

Hey FCC: Time to Expand Unlicensed Spectrum!

Remember that Washington Post story about bigger, free Wi-Fi networks? It went hugely viral with all manner of outlets picking the story up, unintentionally distorting it, and amplifying it.

Some good has come of it. For one thing, I was reminded that Ars Technica does a really good job of tech reporting, better than anyone else in my estimation. Cecilia Kang offered a follow-up story to clarify the original that should help more people to understand what is at stake.

But more importantly, we saw a lot of media coverage about something really important, whether we allocate future spectrum for everyone to use (much like Wi-Fi) or will we reserve it just for AT&T, Verizon, or another big corporation?

Harold Feld has a strong opinion on the matter:

This past week, we’ve had quite the discussion around Cecilia Kang’s WashPo piece describing a plan by the FCC to create a national WiFi network by making the right decisions about how to allocate spectrum between licenses for auction and what to leave available for the unlicensed TV white spaces (“TVWS” aka “Super WiFi” aka “Wifi on steroids”). As Kang describes, the FCC’s opening of sufficient spectrum for TVWS could lead to “super WiFi networks (emphasis added) around the nation so powerful and broad in reach that consumers could use them to make calls or surf the Internet without paying a cellphone bill every month.”

Needless to say, the article faced much pushback, despite a subsequent Washpo clarification to indicate the FCC was not, actually, planing to build a network. Amidst the various critics, there were some general defenders of the concept. My colleagues at EFF noted that increasing the availability of open spectrum for WiFi-type uses , and my friends at Free Press argued that such a free public wifi network (or, more accurately, series of networks) is in fact possible if the FCC makes enough good quality spectrum, suitable for broadband and usable out doors, available on an unlicensed basis.

I will now go a step further than any of my colleagues. I will boldly state that, if the FCC produces a solid 20 MHz of contiguous empty space for TV White spaces in the Incentive Auction proceeding, or even two 10 MHz guard channels that could nationally produce two decent sized LTE-for unlicensed channels, then we will have exactly the kind of free publicly available wifi Kang describes in her article. Or, “Yes Cecilia, there really is free national public wifi. Don’t let the haters and know-it-alls tell you otherwise.” ...

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I wrote a much shorter, far less impressive piece for the Media Action Grassroots Network that embraces a similar argument:

You know how you can buy a simple little device for as little as $30 now to set up your own Wi-Fi network that creates an easy in-home network? Imagine if your neighborhood could do that too!

Wi-Fi works in your home because the federal government, which manages how the public airwaves are divided for various uses, decreed that a small slice of spectrum would be unlicensed - sitting there for anyone to use however they wanted. But that spectrum is not suited for a neighborhood-wide network. ...

And we have seen others take notice as well, including the Baltimore Sun Editorial Staff:

The companies who oppose the FCC's plan argue that the agency's mission to serve the public interest would best be achieved through the revenues from an auction of the airwaves. The last such auction, in 2008, generated nearly $20 billion for the government. That's a substantial amount of money, to be sure, but the relatively small portion of the spectrum that the commission now proposes to leave open to unlicensed use would be worth only a fraction of that — a pittance compared to the economic activity that could be generated through the creation of new products and services to take advantage of the unlicensed spectrum.

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Therein lies the danger. The big wireless lobbyists are pushing Congress and the FCC hard to ensure that they get the licenses. Republicans in particular are arguing that we need the billions (perhaps 3-5?) of dollars that an auction would fetch for the treasury. This would be a terrible tradeoff.

I doubt that anyone has a handle on the value of Wi-Fi, but it is orders of magnitude higher than a onetime infusion of a few billion dollars. How much would you pay any given day to use Wi-Fi? Multiply that by over 200 million people. And this new spectrum could allow bigger networks than Wi-Fi supports -- an even greater potential value!

Verizon and AT&T know this, of course. They will gladly spend billions to ensure that we are stuck paying far more for services from them than we can build for ourselves if only we are allowed to use our spectrum to do so.

Write your elected representatives to support increased unlicensed spectrum.

Don't Sell the Public Airwaves to the Highest Corporate Bidder

During the recent budget negotiations, one plan called for taking valuable wireless spectrum that is intended to be used as a commons and auctioning it off the massive corporations to monopolize. Rather than enabling a whole new generation of wireless technologies that would create countless jobs and ongoing opportunities for innovation (some have described it as Wi-Fi on steroids), it would have created a one-time cash infusion while further consolidating the incomparable market power of AT&T and Verizon. Preserving as much spectrum as possible as unlicensed commons allows communities, small businesses, and activists to build the wireless networks they need because they cannot afford to license spectrum for their sole use.

Wally Bowen wrote the following op-ed urging a more sensible approach. Fortunately, the spectrum auction was dropped from the plan - but it will undoubtedly come up again. This was originally published in the Charlotte Observer on July 31 and is reprinted here with permission.

U.S. House Republicans are pushing a proposal to sell off some of the nation's most valuable real estate as part of a debt-ceiling deal, apparently unaware of the harm it will do our economy.

This real estate is a portion of the public airwaves so valuable that it's been called the "Malibu beachfront" of the electromagnetic spectrum. This lower-frequency spectrum, previously reserved for broadcast radio and TV, is far superior to "Wi-Fi" frequencies used for Internet access - and for innovative devices ranging from microwave ovens and cordless phones to garage-door openers and baby monitors.

This prime spectrum can deliver broadband speeds that support high-definition video for telemedicine in rural and other underserved areas. This spectrum is especially plentiful in rural America, and could help connect millions of low-income citizens to affordable broadband services. It could also spark a new wave of high-tech innovation and job-creation far greater than the Wi-Fi boom of the last 25 years.

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The genius behind the first wave of Wi-Fi innovation was unlicensed spectrum. Though these higher frequencies were once considered "junk bands" by radio engineers, designating them for unlicensed access gave innovators the freedom to experiment. It also gave investors incentive to take risks in launching new products.

Unfortunately, the GOP-backed plan would gut the huge market potential of this high-octane spectrum by selling it to the highest bidders: incumbent carriers more interested in shutting-out competition than in igniting the next great high-tech boom. Once auctioned, the spectrum would be licensed, creating enormous barriers-to-entry and disincentives for innovators, entrepreneurs and investors.

Oddly, House members pushing this auction plan - inappropriately called the "Spectrum Innovation Act" - acknowledge unlicensed spectrum's market advantage. But their mechanism for providing unlicensed spectrum is bizarre.

The bill would allow companies - and presumably the public - to place bids for this spectrum either as licensed or unlicensed. This never-before-tried auction would then pit the highest bid for licensed spectrum against the sum of all bids for unlicensed use. If the latter exceeds the former, the U.S. Treasury would reap the proceeds and the nation's economy would reap the rewards of the next unlicensed Wi-Fi boom.

But common sense should red-flag this auction scheme as unworkable. Even if companies and concerned citizens attempted to coordinate bids for unlicensed use, laws against collusion would have to be set aside. And why would smaller firms risk their money if they can assume larger firms like Google and Microsoft will do the heavy-lifting? Clearly, this proposed auction scheme is cover for a cynical spectrum-grab that would rob us and future generations of this prime electromagnetic real estate.

Let's hope lawmakers come to their senses quickly and dismiss the lobbyists pushing this self-serving scheme.

The amazing array of wireless devices developed over the past 25 years proves that unlicensed spectrum attracts investment, spurs innovation and unleashes the power of competitive markets. Unlicense this next-gen spectrum and let the innovators and job-creators get to work.

Preserve Unlicensed Spectrum - White Spaces At Risk

If the future is wireless, we have to preserve unlicensed spaces. To explain: most wireless stuff uses licensed spectrum - where only a single entity has permission from the FCC to use a specific wavelength of spectrum. While this is great for those who can afford to license spectrum (companies like AT&T and Verizon), it is not particularly efficient because the rest of us cannot use those wavelengths even if AT&T and Verizon aren't (which is particularly a problem in rural areas).

Contrast that approach with Wi-Fi, which uses unlicensed spectrum. There are portions of spectrum where the FCC has said anyone can do anything. This is why we do not need permission to set up wireless networks in our house.

Last year, the FCC made a great decision to make "white spaces" wireless technology unlicensed -- which will allow more of us (again particularly in rural areas) to use white spaces without having to get permission. Because this decision creates a larger potential market, we would have more manufacturers interested in creating gear -- meaning more innovation and a lower cost to establish wireless networks (that are far more powerful than Wi-Fi allows).

But now Congress is considering reversing that decision and licensing that spectrum to generate a few billion dollars of one-time revenue for the government -- at a cost of far more than billions of dollars of lost opportunities, particularly in rural America where these unlicensed white spaces are the only real opportunity to rapidly deliver broadband in the short term.

In short, keeping these white spaces unlicensed will be far better for rural economies, innovation, and productivity than a one-time infusion of cash into the federal government.

These decisions are going to made shortly, so I encourage everyone to check out Public Knowledge's Action Alert calling on us to contact our members of Congress to oppose this approach.