Recently, the President’s Council of Advisors on Science and Technology (PCAST) – an advisory group of leading scientists and engineers – released a report entitled “Realizing the Full Potential of Government Held Spectrum to Spur Economic Growth.” The report proposes much greater sharing of spectrum currently allocated for U.S. government use so that the spectrum can also be used for commercial purposes.
We were excited to see that the report touts a spectrum sharing technical-regulatory paradigm that Qualcomm and some of our industry partners have developed called Authorized Shared Access (ASA). ASA enables wireless operators who desperately need more licensed spectrum for mobile broadband to use spectrum bands that cannot be cleared of incumbents on a coast to coast, 24/7 basis, but that are nevertheless under-utilized in time, geography, and/or frequency. ASA will allow operators to offer a predictable quality of service by granting them exclusive licensing rights to use the spectrum when and where the primary incumbent is not using it.
We were also pleased that the report calls for creation of incentives to motivate U.S. government agencies to make available spectrum that they are not fully using. These incentives do not exist today, and unless we create such incentives, the incumbents are unlikely to ever voluntarily make their spectrum available.
My colleague Joan Marsh of AT&T recently authored a blog post entitled “The Power of Licensed Spectrum,” making a number of good points about the report. Let me offer a few points of my own from the point of view of Qualcomm, a leading developer of wireless technology and provider of chips incorporating both licensed and unlicensed technologies.
Here at Qualcomm, we’ve developed a corporate goal of expanding wireless network capacity by 1,000 times from today’s levels. We decided upon that goal actually after learning that the actual growth in wireless data usage that wireless operators see today and expect in the future is substantially greater than even we had expected.
We won’t reach this goal overnight, to say the least. Reaching the goal will take massive investments in research and development by Qualcomm and our technology partners, and similarly large capital expenditures by wireless carriers, to commercialize and deploy a host of new wireless technologies, including small cells, wireless relays, heterogeneous networks, supplemental downlink, carrier aggregation, device-to-device communications, and other exciting new technologies that we’re inventing every day. There is a robust road map of these technologies—some are being deployed today, while others are still under development. We’re aiming to use each and every piece of spectrum, paired or unpaired, and high band or low, developing different technologies for each type of bands to ensure that every sliver of spectrum is put to use. Indeed, each year, Qualcomm spends over 20% of our revenues on research and development. We are moving forward with the technology work as rapidly as possible. The same goes for our industry partners—including both other vendors and the wireless carriers, who are all making large investments of their resources.
But, new technologies won’t be enough to reach the goal line. We will need much more spectrum to keep pace with demand. Let me discuss the three sources of this spectrum.
First, we need more licensed spectrum that can be completely cleared of incumbents in a reasonable time frame and auctioned. A good example of such spectrum is in the TV band. In June 2009, the U.S. completed its transition to digital television. A year before that, the FCC conducted a stunningly successful auction of the spectrum that was freed up as a result of the transition, raising over $19 billion for the U.S. Treasury and putting 70 MHz of new licensed spectrum for mobile broadband to commercial use. Earlier this year, with our strong support, Congress passed the Middle Class Tax Relief and Job Creation Act of 2012, which authorized the FCC to conduct a voluntary incentive auction of the remaining spectrum in the TV band. This voluntary incentive auction will hopefully clear and deliver another substantial swath of licensed spectrum for mobile broadband. The same legislation authorized auctions of other bands. Spectrum auctions put licensed spectrum into the hands of those companies that value the spectrum the most and will, therefore, put it to its most valuable use as quickly as possible.
Second, for spectrum bands that cannot be cleared of incumbents on a 24/7, coast-to-coast basis in a reasonable time frame, but are under-utilized in time, geography, and/or frequency, ASA will allow the spectrum to be used on a licensed basis when and where it is available—i.e., subject to the usage of the primary incumbents. We should not throw up our hands and conclude that nothing can be done just because there are some incumbents who need to continue to use a given spectrum band, even though there are times or places where the spectrum could be used for licensed wireless broadband service.
A good example of such a band is the 3.5 GHz band. We think it’s perfect for small cells since they do not need to cover a large radius and can operate at low power levels, even though there are Navy radars that use the band along the coasts. Using licensed small cells can shrink the large exclusion zones that had been assumed to be necessary. For this reason, we were excited to hear FCC Chairman Julius Genachowski announce the FCC plans to move forward with a proposal to make 3.5 GHz available as a dedicated band for small cells. But, in order to deliver the quality of service that Americans expect from their wireless devices, it’s important that licensed and unlicensed usage not be lumped together in the same band. And, to maximize the gains in capacity and coverage from the deployment of small cells, wireless carriers will need to reduce the power of neighboring macro cells. In other words, small cells will be deployed in conjunction with existing licensed wireless networks in order to maximize the capacity gains. Consequently, we do differ from the PCAST report on this point. The report calls for allowing unlicensed devices to operate at 3.5 GHz, but we favor licensing the band, which consists of 100 MHz, to ensure that it can be quickly used to expand wireless capacity, which is the band’s highest and best use.
Indeed, in an under-utilized frequency band, including one designated for commercial use, the incumbent spectrum rights holder could voluntarily convey ASA rights to another party. This would enable the spectrum to be used by the ASA rights holder when and where the incumbent does not need to use it, taking into account geographic partitioning or frequency disaggregation permitted under current FCC rules, hence providing rights based on a combination of geography, frequency, and/or time on a dynamic basis.
Recently, FCC Chairman Genachowski explained that in his view, we need to move forward with both the traditional clearing and reallocating spectrum where possible and, where that is not possible, new sharing ideas, such as ASA. As Chairman Genachowski said, “It’s not an either-or choice.” See “The FCC Mining for DoD Spectrum.” We wholeheartedly agree.
Third, we support allocation of additional spectrum to enable wider contiguous bandwidths for unlicensed, but this, too, should be done wisely. To achieve the fastest possible data rates within a relatively short range, such as home or an office building, Wi-Fi needs increasingly wide swaths of contiguous spectrum. Next-generation Wi-Fi, known as 802.11 ac, uses up to a 160 MHz wide channel. We’re supplying chips incorporating 802.11ac, and those chips use the existing 5 GHz unlicensed band, where such a wide swath of unlicensed spectrum is available. (In fact, the future generation of Wi-Fi, known as 802.11ad, is targeting bandwidths of more than 2 GHz at 60 GHz.) Unlicensed spectrum needs to be wide enough to accommodate this technology road map, and it would be ideal to widen an existing unlicensed band. This is why we were pleased to see that in the spectrum provisions in the Middle Class Tax Relief and Job Creation Act of 2012, Congress directed the FCC and NTIA to consider making another 195 MHz at 5 GHz available for unlicensed.
It is within this overall context of rapid technology development and deployment, as well as band-by-band analysis, that I suggest viewing the PCAST report. If you have questions and would like to know more, please tune-in to my upcoming webinar on September 18, 2012.