by Joseph Bravo, Heather Kopeck, Robert Tai, Josette Velasco, and Dale Wong

For full report click here.

The FCC’s Predicament
Currently, the Federal Communications Commission (FCC) faces the challenge of managing spectrum policy in a way that meets today’s consumer demands and incorporates emerging technologies. Spectrum access demands have not been met as a result of antiquated spectrum policies. Emerging technologies can increase the opportunities for spectrum access and utilization, but the FCC must undertake spectrum policy reform in order for their benefits to be realized. The critical question focuses on what kind of reform. This report addresses the following question:

What strategy should the FCC pursue to achieve spectrum policy that effectively incorporates emerging technologies to facilitate efficient spectrum use?
The delivery of the full benefits of these technologies is impeded by three major factors. The first impediment is the uncertainty regarding the technical capabilities of new spectrum sharing technologies, such as cognitive radio technologies. The second impediment is the political opposition by current licensees to changing spectrum policy and usage rights. Finally, there is the impediment created by current regulatory constraints. The FCC has already begun rethinking its management of spectrum policy, but has yet to establish a clear outline of the shape that policy reform will take. The FCC has already created the momentum for spectrum policy change. By examining three recent formal notices introduced by the FCC, this report provides an analysis of the nature and dimensions of the political debate over spectrum policy reform, the arguments regarding technological uncertainty, and regulatory limitations of the FCC.

Recommendations
This report examines the near-term and long-term barriers that these impediments will create for the FCC. Spectrum policy reform will likely take many years, and this report makes recommendations that provide a road map for the FCC’s reform efforts. In order to effectively incorporate emerging technologies in the most feasible manner possible given impediments to change, we recommend a phased implementation plan. This phased approach, consisting of two non-concurrent phases, will allow the FCC to strategically target the impediments to spectrum reform. Phase I targets technological uncertainty and political opposition to the utilization of spectrum sharing mechanisms. Phase II targets the regulatory constraints to spectrum change.

Phase I: Increase Unlicensed Spectrum AND Develop a Metric for Measuring Interference
Phase I has two aspects. The first aspect is maintaining the momentum for increased unlicensed spectrum and the second is developing an interference metric.

Increasing Unlicensed Spectrum
It is recommended that the FCC allocate more dedicated unlicensed spectrum. Increasing unlicensed spectrum is the most feasible initial step in spectrum policy reform because it allows for the use and experimentation of cognitive radio technologies in order to better prove and establish their capabilities. Increasing unlicensed spectrum serves two objectives: first, it allows for the incorporation of emerging technologies in the shortest term possible and second, it provides an experimental arena for these emerging technologies to establish proof for their capabilities. Increased spectrum will encourage growth of the market for spectrum sharing devices and create a political constituency that can challenge the power of incumbents. It will also reduce technological uncertainty through “real-life” experimentation.

Developing an Interference Metric
The FCC must develop an interference metric. A robust interference metric can be used to overcome all three impediments to spectrum reform. If the FCC is able to provide an interference metric, many of the arguments against spectrum sharing can be diverted. The FCC should continue evaluating the Interference Temperature Approach for Interference Management as it relates to various forms of spectrum sharing.

Phase II: Implementing Spectrum Sharing through Smart Technologies in Licensed Bands
There are certain conditions that must be met prior to moving on to Phase II. Phase II is contingent upon both establishing the proven capabilities of cognitive radio technologies, and the development of robust interference metric for different bands. Once these are met, the FCC can begin implementing some form of spectrum sharing, whether through opportunistic sharing or underlay sharing or both, in the licensed bands. The use of these interference mitigating mechanisms however, will depend on the characteristics of the licensed band. Both underlay and opportunistic sharing will use the interference temperature metric in its protocols for operating in the licensed bands. It is recommended that the FCC first allow for underlay sharing because it utilizes proven technology. Then, it should pursue the use of cognitive radio technologies through opportunistic sharing.

Phase II may not be ready for implementation for at least another ten years. The pace of achieving the goals of Phase I will determine the readiness of the FCC to implement Phase II. The conditional nature of Phase II makes it imperative that overwhelming support be given for the objectives laid out in Phase I. This gives the FCC a more tenable position on the issue of spectrum sharing using cognitive radio technologies.