# Presentation: 546455

## The Role of the Regulator in Fostering Innovation

- Chris Haslett – Principal Propagation Adviser
- 7th March 2006

**Notes:**
Please note the job title:  I am a radio scientist within the technology department at Ofcom, the United Kingdom regulator.  

At Ofcom, we are at the policy-forming stage regarding our approach to fostering innovation.  Nevertheless, interesting investigations and associated research projects are taking place and these are, I feel, worthy of presentation to a technically-knowledgeable audience.

## Presentation overview:

**Ofcom’s spectrum management goals**
**Review of possible methods of fostering innovation**
**Spectrum usage rights and spectrum quality benchmarks**
**A propagation modelling tool for use in a liberalised environment**
**Accommodating innovative technologies**

**Notes:**
Here is a layout of the presentation.
Ofcom is charged with the responsibility of delivering the optimum use of the spectrum and sees innovation as a key feature in this.  
But fostering innovation is not that straightforward and possible methods are reviewed.
In general we do not want to put barriers in the way of would-be innovators whilst maintaining spectrum quality.  One way forward is the conferring of general rights to users of the spectrum that are not tied to any particular technology.
However, our modelling tools that help us regulate will need updating if we are to be able to cope with a liberalised environment.  A tool that is under development is described.
The way in which it will allow us to accommodate innovative technologies is a test for such a tool and a couple of cases are used as illustrations.

## Ofcom is required to:

**Deliver optimum use of the spectrum**

**Associated with this Ofcom has identified a major theme:**

**Fostering innovation**

**Notes:**
Ofcom is required to deliver optimum use of the radio spectrum within the United Kingdom.  

In association with this certain themes have been identified:
Facilitating trading and liberalization for example and, most significantly, opening new markets and fostering innovation.  
We do not wish would-be innovators to find themselves battling within and over-regulated environment.  
From the identification of Fostering innovation as a major theme is can be seen that Ofcom wishes to be supportive of innovators

## Possible methods of fostering innovation

**Free spectrum for innovators**
**Increase in licence-exempt spectrum/relaxation of rules for licence exempt transmitters**
**Ensure that the regulator does not obstruct innovation**

**Notes:**
Some general ideas have been discussed regarding ways of fostering innovation.

These will now be discussed in turn.

## Free spectrum for innovators?

**Not an idea that is warmly received**
**Spectrum should not be free of charge any more than accommodation or equipment**
**Spectrum must be valued from “day one”**
**Making spectrum free is unlikely to lead to securing its optimum use**

**Notes:**
It is fair to say that any innovators expecting to be granted fee-free spectrum are probably being optimistic.  

We are keen to see spectrum valued as a resource in the same way as staff, vehicles, accommodation, computers etc.  If governments wish to help innovators, they can do so with financial aid but spectrum should not be something that can be liberally handed out.

We need to secure the optimum use of the spectrum.  Giving it a way free will send the wrong message. 

## Increase licence-exempt spectrum/relax rules?

**An idea that is being explored (e.g. can transmit power be increased in rural areas?) but....**
**Existing users of the spectrum (including “innovators”) are very concerned about possible rises in interference levels as a result of liberalisation**
**Even innovative technologies require a certain quality of spectrum – this cannot be provisioned in licence-exempt spectrum**

**Notes:**
Licence-exempt spectrum has its place but it should not become a free-for-all.
A time-sequence seems to be that, initially, making the spectrum that will be used by a new technology licence-exempt proves popular.  
However, as use increases, interference events increase and people then look to the regulator to “do something”.  
The quality of spectrum (and, hence, quality of service) cannot be addressed in such spectrum.

## Ensure that the innovator does not obstruct innovation?

**Current assignments and licences are, perhaps, over-prescriptive**
**Technology to be used is dictated**
**Limits to number of licenses using a particular technology**
**Requirements for public wireless networks to provide a certain percentage coverage**

**Notes:**
A GSM licence can only be used for GSM.  

3G licence holders are required to cover a certain percentage of the population by a certain date.  
Other frequency bands are prohibited from being used for 3G

Microwave link licences dictate modulation scheme

The above represents something of a legacy situation that Ofcom must live with.  

But it does come over as anti-innovative.

Going forward, the talk is of becoming a “light touch” regulator.

## Ensure that the innovator does not obstruct innovation?

**Spectrum management is the process by which optimum use of the spectrum can be delivered.**
**Licensing and assignment is a vital element in the process of spectrum management.  **
**Can rights granted to licensees be modified to allow changes to the technology and/or use of spectrum whilst still facilitating the function of spectrum management?**

**Notes:**
It is good to remind ourselves that licensing is an element of the spectrum management process and that, in turn, exists to deliver the objective of optimal use of the spectrum.  

One goal being investigated is to confer rights on a licensee to use the spectrum in as non-prescriptive a manner as possible.  The word “technology-neutral” is commonly heard in this respect.  In particular, a licence should permit changes of use without it being necessary to apply for a new licence.  
This approach will require new radio modelling tools to ensure that quality benchmarks are maintained whilst changes of use are permitted. 

## Ensure that the innovator does not obstruct innovation?

**Ofcom’s vision for spectrum is expressed in the Spectrum Framework Review**
**Spectrum should be free of technology and usage constraints as far as possible. Policy constraints should only be used where they are justified.**
**It should be simple and transparent for licence holders to change the ownership and use of spectrum.**
**Rights of spectrum users should be clearly defined and users should feel comfortable that they will not be changed without good cause.**
**For the full document, visit www.ofcom.org.uk**
**Implications:**
**Need to check Change of Use (CoU) applications**
**Must be transparent, timely, evidence based, flexible, technology neutral...**

**Notes:**
Ofcom’s “Spectrum Framework Review” (available from our website) puts forward Ofcom’s vision.  
The desire to foster innovation is clear. 
Clearly, there are implications for spectrum management tools if this vision is to become a reality.

## Spectrum Usage Rights and Spectrum Quality Benchmarks

**Licensees rights and obligations should be summarised in a straightforward, technology-neutral manner.**
**The process of spectrum management can be viewed as placing as few restrictions as possible whilst ensuring that spectrum usage rights granted to one user do not infringe on the spectrum quality of another. **

**Notes:**
There is always going to be a kind of tension between rights to transmit (emission rights) and rights to receive in a relatively interference-free environment. 

It is likely that a true technology-neutral approach when considering sharing of spectrum comes to be seen as likely to lead to a sub-optimum use of the spectrum.  
Nevertheless, there is a determination that this should be explored so that the optimum location of boundaries between technologies can be identified.  
My personal feeling is that  the antenna being used will play a crucial role.  For example, a mobile terminal can tolerate a much higher interfering power flux density than a satellite earth station.  Sharing between these two services may prove impractical.   

## Spectrum usage rights

- Space
- Shelter
- Freedom
- Peace
- Light
- Air

- Often referred to as “property rights”.

- Space
- Shelter
- Freedom
- Peace
- Light
- Air

**Notes:**
As an aside, spectrum usage rights and quality benchmarks can be seen to be analagous to rights and obligations enjoyed by property owners.

Spectrum is perhaps somewhat more complicated than property as interference occurs over larger distances and tends to leak from one frequency band or geographical area to another.
Nevertheless, the same principle applies.

## Spectrum Usage Rights and Spectrum Quality Benchmarks

**Notes:**
It is possible that a hierarchy of usage evolves.  The Spectrum Management Regulator’s role may be divided or delegated to other bodies.  These bodies can grant spectrum usage rights to licensees.  These SURs can be straightforward (Tx power, antenna type, height etc.).  

It is the SMR’s responsibility to ensure that the SURs of one user do not infringe the SQBs of another.  This would be particularly important where the SQBs of another SMR was involved.

## A Possible Spectrum Quality Benchmark (SQB)

***Interference at the receiver should not exceed X dBW for more than Y % of the time [at more than Z % of locations]***
**Change of use (or a new assignment) should not violate this benchmark**
**What tools can be used to assess this?**

**Notes:**
An SQB should be as straightforward as possible whilst still fulfilling its spectrum management objectives.  The definition shown here seems to fit the bill.  However, it does throw up some interesting challenges regarding modelling the radio environment. 

With this in mind, Ofcom has been funding the development of a generic radio modelling tool.  

## Assuring Spectrum Quality Benchmarks

**A research project is being undertaken to provide a “Generic Radio Modelling Tool”.**

**Notes:**
A simple view of the tool being developed will take whatever emission rights are granted to users at face value and use these to determine whether spectrum quality benchmarks are being violated.  

## Accommodating time-varying phenomena

**SQB assures interference limits for a percentage of time.**
**Time-varying factors:**
**Propagation Loss**
**ERP **
**Frequency Hopping**
**Transmitter Location**
**Antenna Direction **
**Activity Factor**
**Monte Carlo simulation can accommodate the above variations**

**Notes:**
Historically, the time-varying nature of propagation conditions has been long known.  This has led to the concept of outage and unavailability times being planned for when designing a radio system.  
As systems have developed more time variation has been introduced.  Examples are listed here.  
In order to assess the interference being caused by a system with many time-varying parameters, the incorporation of some kind on Monte Carlo simulation is almost inevitable.  
One interesting area of study is predicting the number of snapshots required to provide a given level of confidence. 

## Assuring Spectrum Quality Benchmarks

**Notes:**
Here we have a screenshot from a prototype “generic radio modelling tool” that we have developed. 
We are assuming that a request for a change of use has been made and the impact on other users has to be assessed (from an SQB viewpoint).  The map shows the area under interest.  A search on the basis of geographic distance and frequency separation will be undertaken to identify those systems whose SQBs are at risk of being infringed.  In this case a system with 2 SQBs (at 50% and 0.1% thresholds) has been tested.  The assessment includes MC simulation and the result is a “pass”.  
Note that the possibility of increasing the fee payable by the licensee requesting the CoU has not been addressed.  E.g. although no existing SQBs have been violated, has the risk of future applicants being refused been increased by the CoU?  A simple case of a CoU would be a power increase request – that may not violate existing SQBs but a fee increase is clearly logical.
I would like to acknowledge the work done by Transfinite systems, the Radiocommunication Research Unit and University of Surrey in developing this modelling tool.

## Spectrum Quality Benchmarks for Area Licences

***Interference at the receiver should not exceed X dBW for more than Y % of the time [***_***at more than Z % of locations***_***]***

**Notes:**
When the CoU request is to be assessed against SQBs for a coverage area, the percentage of the coverage area for which the SQBs are adhered to is significant.  In this case, each pixel of the coverage area will be considered.  A pass/fail assessment is determined for each pixel and the percentage of pixels that pass is taken as the criterion for acceptability.

The number of snapshots required, and associated run time, could be significant.  In a first look at this, certain extreme cases required 1022 link budgets to be determined.  An investigation into reducing this is clearly necessary.

## Spectrum Emissions Rights

**Rights to transmit in a particular area provided that you do not cause interference outside that area. **
**Power Flux Density (PFD) on boundary is a possible significant parameter.**

**Notes:**
General transmission rights (perhaps granted to a spectrum management regulator) are likely to include a “power flux density  (PFD)on the boundary” criterion.  
One problem is that the pfd on the boundary does not give a very good indication of the pfd a significant distance from that boundary. 
The further away the transmitter is from the boundary, the slower the pfd will reduce as you move further away from the transmitter.
Even if the terrain is smooth, the usefulness of pfd on boundary as a spectrum management tool on boundary is clearly limited.

## Spectrum Emissions Rights: dual-boundary approach

**Spectrum Emissions Rights: dual-boundary approach**

**Area in which right to transmit is conferred and SQBs apply is not the same as that enclosed by PFD boundary.**

- Operational Area (SQBs apply)

- PFD boundary

**Notes:**
If the “pfd on boundary” approach proceeds further, we may need to consider two boundaries: one for the operational area and one for interference limits.
The operational area would have the SQBs considered whereas the boundary for interference limits would have the pfd on boundary limits applied. 
The level chosen for the pfd on boundary would be such that this level itself (without assuming any reduction with distance) would be small enough to represent an acceptably low level of interference to neighbouring users.  It is at this point that the experience of a user is clearly dependent on the receive antenna and noise factor.  

## Spectrum Emissions Rights: definition

**Boundary PFD limit could be made comparable to allowable interference (SQB) of neighbouring licensees.**
**Still possible issues with PFD being stronger beyond the boundary than at the boundary.**

- PFD boundary

**Notes:**
So, we conclude that the pfd on boundary should be commensurate with the allowable interference into a neighbour.
Consideration of possible terrain features makes it clear that it is by no means impossible for the pfd to rise beyond the boundary.
When wording the statement of the limit, it is easy to use the phrase “at or beyond the boundary”.  However, what implications does this have for the modelling tool?
Perhaps a buffer zone beyond the boundary could be assessed.  But how big should this buffer zone be and what are the implications does this have for run time?

## Possible definition of PFD limit

***The aggregate transmitted PFD at or beyond [definition of boundary] should not exceed X dBW/m^2/[Ref BW] kHz at any height up to H m for more than P % of the time;***

- PFD boundary

**Notes:**
The “at or beyond” statement combined with the time percentage definition clearly provide some challenges for the modelling tool that is to be employed.

## Out-of-band issues

***Interference at the receiver should not exceed X dBW for more than Y % of the time [at more than Z % of locations]***
**Can such a statement be applied to in-area, out-of-band scenarios?**

**Notes:**
I shall briefly move on to the consideration of out of band interference.  
The study could be widened to additionally consider polarisation and carrier types
Questions such as “what search criteria should be employed for oob studies” are worthy of consideration.
OOB issues for geographically coincident areas pose interesting questions.  In a nutshell: blocking.  Should a limit be imposed on the pfd even in the area of the assignment?
Interestingly the proposed wording could well be appropriate, it is just that the level in dBW will be much larger in band, in area that it will be out of band or out of area.  
This example also suggests that there will be a need for a “first in time” approach of some kind.  A transmitter will sterilise an area around it, preventing use in adjacent bands.  Clearly, if there is already a user of the adjacent band in this area, the assignment will not be granted.

## Accommodating innovative technologies

**Emissions rights and SQBs should be “technology neutral” and, yet, “technology aware”. **
**Exploring how such an approach to spectrum management would cope with innovative technologies is informative.**
**Smart antennas**
**Cognitive radio**

**Notes:**
Although we strive to be technology neutral throughout, when role-playing the manner in which the modelling too may work inevitably involved assumptions regarding the technology to be deployed.  We therefore tried to be technology neutral whilst remaining technology aware.  
As examples of how this can be done, we will consider how the spectrum usage rights and sqbs can be applied when change of use to smart antennas or cognitive radio is requested.

## Accommodating Smart Antennas

**Accommodating Smart Antennas**

**EIRP not a fixed value but can be defined by a probability density function.**
**Not dissimilar to an approach similar to that for scanning antennas**

**Notes:**
In discussions with operators wishing to consider deploying smart antennas, a concern is that we will consider the transmitted EIRP to be as if the gain of the antenna was a maximum in all directions simultaneously.  
This is not the intention.  Time variability is in general well established in the modelling process.  Possibilities for smart antennas include the eirp being declared as a cumulative distribution function (CDF), or it is regarded as some kind of scanning antenna similar to radar when it comes to assessing interference levels.   

## Accommodating Smart Antennas

**Ability to steer nulls permits operation with poorer SQB**
**Possible to incentivise operators to use Smart antennas**
**Identifiable route to improving spectrum efficiency**

**Notes:**
One strength of smart antennas is the capability to steer nulls in the direction of interferers.  This suggests that they can tolerate a poorer sqbs than “non-smart” antenna networks.  
Perhaps they should then be charged less for use of the spectrum.  Fees represent a significant method of incentivising the adoption of spectrum-efficient technologies.  
It may be that the regulator can maximise the use of the spectrum by forming “communities” of mutually tolerant users.  A problem can occur if smart and non-smart systems are mixed.  Some gain should result, but it may not be regarded as “optimum”.

## Accommodating Cognitive Radio

**A trickier problem**
**Cognitive radios do not transmit in already-occupied spectrum**
**But the radios themselves define “already-occupied”**
**Detectable by their receiver with their antenna**
**The incumbent may have more sensitive receivers with higher gain antennas**

**Notes:**
Now on to our final example: cognitive radios.

Cognitive radios pose something of a dilemma to the regulator.  On the one hand they give the clear advantage of using otherwise unoccupied spectrum and are a cost-free gain.  But the radios themselves define what is meant by unoccupied.  These radios will almost certainly have omnidirectional antennas.  Further, the lowest detectable signal will depend upon the receiver characteristics and the noise factor of multi-purpose radios (such as cognitive radios) may well be significantly worse than that of specialist receivers that share the band.  This means that they may determine that some spectrum is unoccupied when, in fact, nearby receivers are picking up important signals.

## Accommodating Cognitive Radio

**Accommodating Cognitive Radio**

**The “hidden mobile” problem**

**Notes:**
The “hidden mobile” problem is well known but remains somewhat intractable when it comes to sharing spectrum.

## Accommodating Cognitive Radio

***Interference at the receiver should not exceed X dBW for more than Y % of the time [at more than Z % of locations].***

**Notes:**
However, considering our generic spectrum quality benchmark definition, it is very possible to use this when considering cognitive radios.  
We need to know:
Number of radios in an area.
Activity factor
Transmit power
Detection characteristics
The layout of the victim’s transmitters
Then, from a detailed propagation prediction...
......we can predict the number of pixels that will be affected by a certain interference level.  It is likely that the levels of interference will be higher than those normally described as permissible.  But we have already mentioned the possibility of mutually tolerant communities being established.
The fact that we need to know the layout of the victim’s transmitters suggests that a “first in time” rule will be adopted.  This is pretty normal in the spectrum management world.
So, the generic tool should be able to simulate the effect of cognitive radios.
I note that there are several presentations scheduled on the topic of cognitive radio.  I await them with interest.

## Conclusions:

**Ofcom views fostering innovation as a key element in delivering the optimum use of the spectrum**
**A “light touch”, technology-neutral approach is seen as necessary in fostering such innovations**
**This approach could be based on the concept of spectrum usage rights and the assurance of spectrum quality benchmarks**
**Current propagation modelling tools need further development in order to be useful in a liberalised environment.  Such a tool is under development at Ofcom.  **
**This tool is likely to be useful in analysing the interference caused by modern technologies.**

**Notes:**
And so to summarise:
Ofcom wishes to foster innovation and has identified this as a key theme.
It is felt that Innovative use of the spectrum will lead to the use of the spectrum improving towards the optimum situation
Reducing the burden of regulation is seen as a key method of fostering innovation.  Licences should be more general and permit change of use where possible.
However, we need to ensure that interference does not rise as a result of this approach.  Generic emissions rights and quality benchmarks should be established.
We are developing a generic radio modelling tool that will allow us to assess the impact of a change of use in a transparent, timely, technology-neutral manner.
Thought is being given to ensure that this tool can accommodate new scenarios that arise from the use of innovative technologies such a smart antennas and cognitive radio.