Commercial Spectrum: Plans and Actions to Meet Future Needs, Including Continued Use of Auctions
Published: 2011-11-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The radio-frequency spectrum enables an array of wireless communications services that are critical to the U.S. economy and national security, such as wireless broadband. In 2010, a Federal Communications Commission (FCC) task force issued the National Broadband Plan that included recommendations to reform spectrum policy. Since 1994, FCC has used competitive bidding, or auctions, to assign licenses to commercial entities for their use of spectrum; however, its authority to use auctions expires on September 30, 2012.
Among other things, GAO examined (1) the extent to which FCC has made spectrum available for new commercial uses and the time taken to do so, (2) experts and stakeholders views on FCCs plans and recent actions to meet future spectrum needs, and (3) experts and stakeholders views on the continued use of auctions to assign spectrum. To address these objectives, GAO reviewed FCCs plans, notices, and orders; reviewed six instances in which FCC made spectrum available for new commercial uses; and surveyed 30 experts and 79 industry stakeholders about their views on FCCs efforts to make spectrum available for new uses, its plans and actions to meet future needs, and its continued use of auctions (the survey had a 68 percent response rate).
section_title: What GAO Found
paragraphs: Since 1994, FCC has made over 520 megahertz (a measure of quantity) of spectrum available for new uses, such as wireless broadband, through a process that can be lengthy. Because most of the usable spectrum in the United States has been allocated to existing uses, FCC must change its rules to move spectrum from an existing use to a new use, a process known as repurposing spectrum. Yet, this process can be lengthyfrom 7 to 15 years for the six repurposings that GAO reviewed. Four factors contribute to the time it takes FCC to repurpose spectrum: the regulatory nature of the process, which to some extent is guided by statute; opposition of incumbent users, who could be required to vacate spectrum; coordination challenges between FCC and the National Telecommunications and Information Administration (NTIA), which oversees federal agencies use of spectrum, on the repurposing of federal spectrum for commercial use; and concerns about interference from users of spectrum in adjacent bands of spectrum. FCC has identified voluntary approaches that it thinks could speed the process, but these approaches generally require congressional approval and face some stakeholder opposition.
Experts and stakeholders had mixed views on FCCs plans and recent actions to meet future spectrum needs. The National Broadband Plan included a set of recommendations to FCC, FCC and NTIA jointly, and Congress, aimed at meeting future spectrum needs. Some recommendations garnered broad support, including recommendations to auction certain bands of spectrum and enhance research and development. However, experts and stakeholders opinions diverged on other recommendations, such as reallocating a portion of spectrum from television to wireless broadband. Opinions also varied on FCCs progress in implementing the recommendations. In some instances, these conflicting opinions arose from participants divergent positions in the industry, with, for example, incumbent licensees such as broadcasters opposing recommendations that they believe could impose burdens or costs on their businesses.
Experts and stakeholders GAO contacted strongly supported extending FCCs auction authority, but varied in their opinions on potential changes to auctions. Since 1994, FCC has used auctions to assign mutually exclusive licenses to commercial entities providing certain wireless services. GAO previously reported that auctions were effective in assigning licenses to entities that valued them the most; were quicker, less costly, and more transparent than mechanisms FCC previously used to assign licenses; and were an effective mechanism for the public to realize a portion of the value of a national resource used for commercial purposes. Experts and stakeholders responding to GAOs survey strongly supported extending FCCs auction authority53 of 65 respondents supported extending FCCs authority. However, experts and stakeholders held varied opinions on potential changes to auctions. For example, respondents generally supported actions that would provide a clear road map detailing future auctions, which could reduce uncertainty. In contrast, a proposal to require winners of auctions to pay royalties based on their revenues rather than the full amount of their winning bids up front garnered the least support.
section_title: What GAO Recommends
paragraphs: Given the continued support of FCC's use of auctions, Congress should consider extending FCC's auction authority beyond the current expiration date of September 30, 2012. FCC provided technical comments that were incorporated as appropriate.

section_title: Letter
paragraphs: The radio-frequency spectrum is a natural resource used to provide an  array of wireless communications services that are critical to the U.S.  economy and national security, such as mobile voice and data services,  radio and television broadcasting, radar, and satellite-based services.  Demand for radio-frequency spectrum has exploded over the past several  decades as new technologies and services have been and continue to be  brought to the market in the private sector and new mission needs unfold  among government users of spectrum, including wireless  communications critical for public safety officials responding to natural  and man-made disasters. As a result, nearly all parties are becoming  increasingly concerned about the availability of spectrum for future needs,  because most of the usable spectrum in the United States has already  been allocated to existing services and users. These concerns are  compounded by evidence that some of the spectrum is currently  underutilized. Therefore, to promote more efficient use of this resource  and meet future needs, the Federal Communications Commission (FCC)  has increasingly adopted more market-oriented approaches to spectrum  management in recent years, including using a competitive bidding  process, or auctions, to assign spectrum licenses to commercial users.  From 1994, when FCC first implemented its auction authority, through  June 30, 2011, FCC held 79 auctions for over 68,000 licenses to select  between competing applications for the same license, and generated  nearly $52 billion for the U.S. Treasury. In addition, in March 2010, an  FCC task force issued the National Broadband Plan aimed at achieving  affordability and maximizing the use of broadband, or high-speed Internet  access, to advance a range of economic and civic goals. Because  broadband access and use is becoming increasingly mobile and wireless,  the plan included a set of recommendations aimed at ensuring efficient  allocation and use of radio-frequency spectrum for wireless broadband  services. In some instances, the plan recommends that FCC change its  rules to move certain bands of spectrum from an existing use, such as  television broadcasting, to new uses, such as wireless broadband, a  process known as repurposing spectrum.
In response to your request to review FCC’s management of commercial  spectrum, we examined (1) the extent to which FCC has made spectrum  available for new commercial uses since it implemented auction authority  in 1994 and the time taken to do so, (2) experts’ and stakeholders’ views  on FCC’s plans and recent actions to meet future spectrum needs, and  (3) experts’ and stakeholders’ views on the continued use of auctions to  assign spectrum. In addition, we examined the extent to which FCC  seeks to ensure the quality of its data on commercial spectrum licenses  (see app. II).
To address these issues, we reviewed FCC’s plans, notices, orders, and  other publications. We interviewed officials at FCC and analyzed FCC’s  quality control processes for its four spectrum license databases—the  Universal Licensing System, the Consolidated Database System, the  International Bureau Filing System, and the Experimental Licensing  System—and for FCC’s database of authorizations of equipment using  the radio frequency spectrum, the Equipment Authorization System. We  reviewed six instances since 1994 in which FCC made spectrum  available by repurposing it for new commercial uses; we limited our  analysis to repurposings that involved substantial amounts of spectrum  that were repurposed to a higher value use. We reviewed the National  Broadband Plan and reports and orders related to FCC’s implementation  of the plan. We also reviewed industry comments on the plan and FCC’s  steps to implement the plan. In addition, we surveyed 30 experts and 79  industry stakeholders about their views on FCC’s licensing data, the  amount of time it takes FCC to reallocate spectrum for new commercial  uses, the recommendations in the National Broadband Plan’s chapter on  spectrum, FCC’s steps to implement those recommendations, and the  continued use of auctions to assign spectrum. We selected the experts  and stakeholders based on their expertise in spectrum policy as  represented by presentations or publications, or on their organization’s  vested interest in spectrum policy. Twenty of the experts and 54 of the  stakeholders responded to our survey, representing a 68 percent  response rate. Because we selected a nonprobability sample of experts  and industry stakeholders, the information we obtained from the survey  may not be generalized to all experts and industry stakeholders who have  an interest in spectrum policy. We also conducted semistructured  interviews with representatives of academia, industry, and public interest  groups. (See app. I for additional information on our scope and  methodology.) We conducted this performance audit from August 2010 to  November 2011 in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient, appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The radio-frequency spectrum is the part of the natural spectrum of  electromagnetic radiation lying between the frequency of 3 kilohertz (kHz)  and 300 gigahertz (GHz). It is the medium that makes possible wireless  communications and supports a vast array of commercial and  governmental services. Commercial entities use spectrum to provide a  variety of wireless services, including mobile voice and data, paging,  broadcast television and radio, and satellite services. Federal, state, and  local agencies use spectrum to fulfill a variety of government missions,  such as national defense, air-traffic control, weather forecasting, and  public safety.
Spectrum is managed at the international and national levels. The  International Telecommunication Union (ITU), a specialized agency of the  United Nations, coordinates spectrum management decisions among  nations. Spectrum management decisions generally require international  coordination, since radio waves can cross national borders. Once  spectrum management decisions are made at the ITU, regulators within  each nation, to varying degrees, follow the ITU decisions. In the United  States, responsibility for spectrum management is divided between two  agencies: FCC and the Department of Commerce’s National  Telecommunications and Information Administration (NTIA). FCC  manages spectrum use for nonfederal users, including commercial,  private, and state and local government users under authority provided in  the Communications Act. NTIA manages spectrum for federal  government users and acts for the President with respect to spectrum  management issues. FCC and NTIA, with direction from Congress and  the President, jointly determine the amount of spectrum allocated to  federal and nonfederal users, including the amount allocated to shared  use.
Historically, concern about interference or crowding among users has  been a driving force in the management of spectrum. FCC and NTIA work  to minimize interference through two primary spectrum management  functions—the “allocation” and the “assignment” of radio spectrum.  Specifically:    Allocation involves segmenting the radio spectrum into bands of  frequencies that are designated for use by particular types of radio  services or classes of users. For example, the frequency bands from  88 to 108 MHz are allocated to FM radio broadcasting in the United  States. (Fig. 1 illustrates examples of services by frequency band.) In  addition to allocation, spectrum managers specify service rules, which  include the technical and operating characteristics of equipment.    Assignment, which occurs after spectrum has been allocated for  particular types of services or classes of users, involves providing  users, such as commercial entities or government agencies, with a  license or authorization to use a specific portion of spectrum. For  example, FCC assigned a license for the 88.5 MHz band in  Washington, D.C., to American University, for its radio station,  WAMU. FCC assigns licenses for frequency bands to commercial  enterprises, state and local governments, and other entities, while  NTIA makes frequency assignments to federal agencies.
In some frequency bands, FCC authorizes unlicensed use of spectrum— that is, users do not need to obtain a license to use the spectrum. Rather,  an unlimited number of unlicensed users can share frequencies on a  noninterference basis. Thus, the assignment process does not apply to  the use of unlicensed spectrum. However, manufacturers of unlicensed  equipment must receive authorization from FCC before operating or  marketing an unlicensed device. Traditional unlicensed equipment  consists of low-powered devices that operate in a limited geographic  range, such as cordless phones, baby monitors, garage door openers,  and wireless access to the Internet.
When FCC assigns a portion of spectrum to a single entity, the license is  considered exclusive. When two or more entities apply for the same  exclusive license, FCC classifies these as mutually exclusive  applications—that is, the grant of a license to one entity would preclude  the grant to one or more other entities. Since 1994, FCC has primarily  used auctions to assign spectrum for mutually exclusive applications.  Auctions are a market-based mechanism in which FCC assigns a license  to the entity that submits the highest bid for specific bands of spectrum.  FCC was provided with authority to use auctions to assign mutually  exclusive licenses for certain subscriber-based wireless services in the  Omnibus Budget Reconciliation Act of 1993. FCC implemented its  auction authority conducting its first auction in 1994. In subsequent  years, Congress has modified and extended FCC’s auction authority,  including exempting some licenses from competitive bidding, such as  licenses for public safety radio services and noncommercial educational  broadcast services. FCC’s auction authority is scheduled to expire on  September 30, 2012.
As of June 30, 2011, FCC had conducted 79 auctions to select between  competing applications for the same license, which have generated  nearly $52 billion for the U.S. Treasury. However, only about 3 percent of  licenses have been auctioned. The vast majority of the other 97 percent  of licenses were assigned through other means before FCC began using  auctions.
In March 2010, an FCC task force issued the National Broadband Plan.  Because broadband access and use is becoming increasingly wireless,  the plan includes a set of recommendations aimed at ensuring efficient  allocation and use of radio-frequency spectrum for wireless broadband  services. The plan recommended that FCC make 300 MHz of spectrum  newly available for mobile broadband use in the next 5 years and 500  MHz of spectrum for broadband within the next 10 years. In June 2010,  the President issued a memorandum with a similar goal for NTIA working  in collaboration with FCC.
section_title: Since 1994, FCC Has Made Over 520 Megahertz of Spectrum Available for New Uses through a Process That Can Be Lengthy
paragraphs: To accommodate new commercial uses of spectrum, such as wireless  broadband, FCC must often change its rules to move certain bands of  spectrum from an existing use to the new use, a process known as  repurposing spectrum. However, this process can be lengthy—from 7 to  15 years for the six repurposings that we examined. We identified the  following factors that contribute to the time it takes FCC to repurpose  spectrum: the regulatory nature of repurposing, opposition of incumbent  users, FCC and NTIA coordination on the repurposing of federal  spectrum, and concerns about interference. FCC identified voluntary  approaches that it thinks could speed the process by, for example,  avoiding some opposition; however, these approaches generally require  congressional approval and face some stakeholder opposition.
subsections: section_title: FCC Uses a Multiphase Process to Repurpose Spectrum
paragraphs: Since most of the usable spectrum in the United States has been  allocated to existing uses, FCC must often repurpose spectrum from an  existing use to make it available for new uses. When there are competing  interests for specific spectrum, FCC determines which use or uses of the  spectrum will best serve the public interest, considering factors such as  economic and social value, including importance for public safety. FCC  also seeks to ensure that the spectrum is technically suitable for the new  use. To repurpose spectrum for a new use, FCC uses a three-phase  process:  Identification. As a first step, FCC identifies a spectrum band, or  bands, that appear to be good candidates for repurposing. To identify  candidate bands, FCC conducts a formal study or releases a notice of  proposed rulemaking soliciting industry input, or another party, such  as NTIA or Congress, identifies a candidate band.    Reallocation. FCC subsequently reallocates the spectrum by  changing the designated use of the spectrum. FCC develops service  and other technical rules for the spectrum that define (1) the eligibility  criteria for users, (2) the services that users can provide, (3) the time  frames and other requirements for users to build the infrastructure  required to support the services, and (4) the interference limits.    Reassignment or secondary markets. If the new use entails a licensed  use of the spectrum, new users must be assigned, or provided  authorization, to use the spectrum. In some cases, FCC reassigns the  spectrum to new entities, often using auctions. In other cases, FCC  permits incumbent licensees to sell or lease their licenses to other  entities, through a process known as secondary market transactions.  If the new use entails an unlicensed use of the spectrum, FCC does  not need to complete a reassignment.
section_title: FCC Has Made Over 520 Megahertz of Spectrum Available for New Commercial Uses
paragraphs: Since 1994, FCC has completed six major repurposings of spectrum,  which have made over 520 MHz of spectrum available for new  commercial uses. In most instances, FCC repurposed the spectrum to  enable mobile broadband service. Five of the six repurposings collectively  generated over $47 billion in auction revenues, which provides one  measure of the new economic value arising from the repurposing. The  former uses of the repurposed spectrum included microwave services,  specialized mobile radio services (such as those used in radio dispatch  systems), and one-way systems that transmit video (see table 1).
The six major repurposings we reviewed took from 7 to 15 years to  complete, from the identification through the reassignment phase. For  example, the Enhanced Specialized Mobile Radio repurposing took 7  years while three repurposings—Personal Communications Service,  Advanced Wireless Services-1, and 700 MHz Wireless—took over 10  years to complete (see fig. 2). Similar to our findings, in the National  Broadband Plan, FCC noted that the process of revisiting or revising  spectrum allocations has historically taken 6 to 13 years.
In addition to the time required to complete the repurposing process  (identification through reassignment), time is needed to relocate existing  users and allow new users to construct new wireless networks before  new services can be made available using the repurposed spectrum.  Typically, existing users must relocate to a new spectrum band or bands,  and new users must construct the infrastructure required to support their  services. While the participants undertake most of these actions, FCC  and other government agencies’ actions and decisions can influence the  time frames. For example, FCC held the first auction for the Advanced  Wireless Services-1 repurposing in 2006, but NTIA expects that it will  take until 2013 for all federal agencies to relocate from the spectrum that  was repurposed for commercial use. In addition, FCC allowed licensees  15 years from the inception of their license term to begin providing  substantial service. Therefore, substantial service on a widespread  basis using the Advanced Wireless Services-1 spectrum appears unlikely  before 2013 and, in theory, could extend to 2021, fully 29 years after the  beginning of the identification phase, although FCC officials anticipate  that carriers will generally provide service sooner in order to meet their  business needs.
Large majorities of stakeholders and experts that replied to our survey  indicated that the repurposing process takes too long. In particular, 39 of  46 stakeholders and 16 of 20 experts reported that it takes longer than it  should from the time FCC or Congress designates a spectrum band for  reallocation until the band is available for the new use. Furthermore, 25 of  these stakeholders and 11 of these experts reported that it takes much  longer than it should.
section_title: Several Factors Contribute to the Lengthiness of the Repurposing Process
paragraphs: Based on our review of several completed and ongoing repurposings, the  relevant literature, interviews with agency officials and industry  participants, and our survey of stakeholders and experts, we identified  four factors that contribute to the time it takes FCC to repurpose  spectrum. These factors include the regulatory nature of repurposing,  opposition of incumbent users, FCC and NTIA coordination on the  repurposing of federal spectrum, and concerns about interference.    Regulatory nature of repurposing. FCC’s repurposing of spectrum is  often an iterative process involving deliberation based on extensive  industry participation. As shown in figure 3, the repurposing of  spectrum can involve stakeholder coordination efforts, issuance of  notices of proposed rulemaking and reports and orders, review of  stakeholder comments and reply comments, and multiple rounds of  assignment. For example, during the Personal Communications  Service repurposing, FCC adopted an order in September 1993, and  67 participants subsequently petitioned FCC for reconsideration  because of concerns about the spectrum to be reallocated and the  amount of spectrum to be individually licensed. In response, in June  1994, FCC amended the bands to be reallocated and assigned. In  1995, some stakeholders sued the Commission over the rules it  established in 1994 pertaining to ownership limitations in the wireless  communications industry. In November 1995, the Sixth Circuit Court  of Appeals decided against FCC’s rules and remanded the matter for  further proceeding. In June 1996, FCC issued an order addressing  these issues.
As also shown in figure 3, the assignment and, in some instances  multiple reassignments, of spectrum can lengthen the process of  repurposing spectrum. In some cases, prior to an auction and at the  direction of Congress or the courts, or the request of licensees and  potential bidders, FCC clarifies or revises the auction and relocation  rules. For example, in providing auction authority, which occurred  during the Personal Communications Service repurposing, Congress  directed FCC to expand opportunities for small businesses, minorities,  and women. FCC subsequently adopted competitive bidding rules  designed to encourage designated entities participation in Personal  Communications Service. However, 3 days before the auction, the  U.S. Supreme Court decided that “all racial classifications, imposed  by whatever federal, state, or local government actor, must be  analyzed by a reviewing court under strict scrutiny” and the  Commission subsequently postponed the auction. In other  instances, the bankruptcy or default of an auction winner lengthened  the repurposing of spectrum. On several occasions, after winners of  the original auction declared bankruptcy or defaulted on their  payments, FCC repeated auctions. For example, FCC’s auctions 10,  22, and 35 included reauctions of licenses won at prior auctions.    Opposition of incumbent users. The completed repurposings we  reviewed involved opposition from incumbent users that took time to  resolve. Incumbent users are likely to incur costs for relocating but  derive little, if any, benefit and are therefore often reluctant to make a  move. For example, during the Personal Communications Service  repurposing, incumbent microwave users, which included utilities,  public safety entities, and petroleum and natural gas companies,  raised concerns that an allocation would displace a large number of  them, disrupt their operations to the detriment of the public, and  require them to purchase new equipment. In the Advanced Wireless  Services-1 repurposing, incumbent government agencies had  difficulties identifying current users of the spectrum and were reluctant  to give up spectrum because they believed the spectrum was critical  to fulfilling their mission and that relocating would cause them to incur  staff time and expenses for which they had not budgeted. In the 700  MHz Wireless repurposing, television broadcasters raised concerns  about the transition from analog to digital television, including their  need to use more spectrum for advanced television services and the  financial costs of building digital television stations. A law firm with  experience in FCC’s repurposings characterized reallocations as  “contests between incumbent service providers and the new entrants  competing to unseat them.”    FCC and NTIA coordination on the repurposing of federal spectrum.
Government efforts to coordinate the repurposing of federal spectrum  to commercial use can take many years; several factors contribute to  the lengthy time frame, including the lack of data and resources and  the time necessary to relocate existing federal users. For example,  the Advanced Wireless Services-1 repurposing, which combined  federal and nonfederal spectrum, took over 14 years and the passage  of several laws to complete. In 1992, FCC first identified the upper  Advanced Wireless Services-1 band, 2110-2150 MHz, for reallocation  to services using new and innovative technologies. In 1995, NTIA  identified the lower Advanced Wireless Services-1 band, 1710-1755  MHz, for transfer from exclusive use by the federal government to  FCC for commercial use. In 1997 legislation was enacted that  required NTIA to accelerate the availability of the lower Advanced  Wireless Services-1 band, and in 1998 legislation was enacted that  sought to encourage the transfer of spectrum from federal  government to private use by providing for mandatory reimbursement  of government spectrum users required to relocate from their  spectrum, including the lower Advanced Wireless Services-1 band.
From 2000 through 2002, FCC and NTIA conducted further studies to  determine appropriate bands for Advanced Wireless Services-1.  Finally, in 2002, NTIA issued a study and FCC issued an order  allocating 90 MHz for Advanced Wireless Services.    Concerns about interference. Users in adjacent bands often oppose a  repurposing of spectrum because they are concerned that the new  service will interfere with their existing service. A good example of this  concern arises with the 700 MHz Wireless repurposing, which  included the relocation of broadcast television stations; public safety  organizations raised the concern that the proposed relocation would  result in increased interference between broadcasting and public  safety operations. Similarly, with the Advanced Wireless Services-1  repurposing, some stakeholders raised concerns about the potential  for interference between Multipoint Distribution Service licensees and  Advanced Wireless Services systems.
Resolving issues such as the opposition of incumbent users and  concerns about interference lengthens the time necessary to complete  the repurposing of spectrum, thereby delaying the introduction of possibly  more economically valuable services. As an independent regulatory  agency, FCC must follow many, but not all, federal laws related to  rulemaking. In particular, the Administrative Procedures Act outlines a  multistep process to initiate and develop rules and includes provisions for  parties to challenge them, which FCC must follow. Many steps require  agencies to provide public notice of proposed or final actions, as well as  provide a period of time for interested parties to comment on the notice.  Furthermore, the Communications Act outlines procedures for addressing  petitions for reconsideration by FCC and appeals to federal court for FCC  rules; the U.S. Courts of Appeals have jurisdiction to review all final FCC  rules. Given that the spectrum issues are often complicated and  controversial, FCC often issues multiple orders in the same proceeding to  deal with the many comments it receives and to address petitions for  reconsideration, as well as any direction from the courts. In the National  Broadband Plan, FCC identified voluntary approaches, such as incentive  auctions, that it thinks could speed the process. By incorporating  incentives into the process, FCC may avoid some opposition to  repurposings and thereby reduce the time necessary to repurpose  spectrum. However, these incentive approaches generally require  congressional approval and face stakeholder opposition themselves. As  we reported in 2003, “while spectrum reform is increasingly being  discussed, debated, and reviewed, it does not appear likely that timely  reforms can be agreed upon amid the diversity of views held by  stakeholders,” a situation that appears to hold to this day.
section_title: Responding Experts and Stakeholders Had Mixed Views on FCC’s Plans and Recent Actions to Meet Future Spectrum Needs
paragraphs: The National Broadband Plan includes recommendations in several areas  aimed at meeting future spectrum needs. Most of the recommendations  are directed at FCC alone, some are directed at FCC and NTIA jointly,  and some are directed at Congress. For our analysis, we group the  recommendations directed to FCC into five categories: make more  spectrum available for wireless broadband use by 2015, expand  incentives and mechanisms to reallocate spectrum, expand opportunities  for innovative spectrum access models, enhance the usefulness of  spectrum for wireless backhaul, and enhance FCC’s spectrum policy  making. Discussion of the first three categories follows; appendix III  provides additional details on those three categories and also discusses  the last two categories.
subsections: section_title: Responding Experts and Stakeholders Generally Agreed with Making More Spectrum Available for Wireless Broadband Use by 2015
subsections: section_title: Recommendations in Plan
paragraphs: To meet anticipated increases in demand for wireless broadband services,  the plan contained a recommendation that FCC make 300 MHz of  spectrum newly available for such services by 2015 and 500 MHz by 2020.  These targets were based on an FCC staff forecast of spectrum demand.  In the plan, the largest source of spectrum—120 MHz—arises from the  repurposing of a portion of the spectrum currently allocated for broadcast  television service. Most experts and stakeholders other than television  broadcasters responding to our survey supported this recommendation,  while most responding broadcasters opposed it (see table 2). Both a  wireless device manufacturer and an expert said that the recommendation  is consistent with expected increases in demand for spectrum. Two  broadcasters said that wireless service providers could meet additional  demand by using their existing spectrum more intensively.
To make 300 MHz of spectrum newly available by 2015, the plan included  five recommendations related to specific spectrum bands. In addition to  repurposing the 120 MHz of spectrum currently allocated to broadcast  television, the plan recommended accelerating terrestrial use of Mobile  Satellite Services spectrum by providing sufficient flexibility to licensees to  increase terrestrial broadband use of the spectrum, auctioning Advanced  Wireless Services and the Upper 700 MHz D-Block spectrum, and  revising outdated interference rules in the Wireless Communications  Services spectrum that largely preclude the use of the spectrum for  broadband. These recommendations, as well as experts’ and  stakeholders’ level of agreement with the recommendations, are shown in  table 2; in the table, we sometimes separately report broadcasters to  illustrate meaningful differences in their responses.
The majority of responding experts and stakeholders agreed with each of  the five recommendations related to specific bands. However, the  recommendation on reallocating 120 MHz of television spectrum has  generated a significant amount of controversy, and this was reflected in  our survey results; the 120 MHz of television spectrum in this  recommendation is in addition to the spectrum made available through  the transition of television from analog to digital service in 2009. Experts  and stakeholders other than broadcasters strongly supported the  recommendation, whereas all 11 broadcasters strongly opposed it. FCC,  as well as some experts and stakeholders who supported reallocating a  portion of the television band, said that the spectrum would have much  higher economic value if it were allocated for wireless broadband. FCC,  for instance, argues that reallocating television spectrum for mobile  broadband would increase its value by roughly a factor of 10. According  to FCC, this difference in value reflects, in part, “challenging long-term  trends” facing the television broadcasting industry; FCC noted, for  example, that the percentage of households viewing television solely  through over-the-air broadcasts declined from 24 percent in 1999 to 10  percent in 2010, and since 2005, broadcast television station revenues  have declined 26 percent. In contrast, broadcasters responding to our  survey cited the following arguments against reallocating a portion of the  television spectrum:    Doing so would likely have a significant, negative impact on the  public’s access to local television broadcasts, both via free over-the- air television and via cable and satellite, because broadcasters use  spectrum to provide local broadcasts to viewers both directly over-the- air and indirectly by broadcasting their signals to cable and satellite  television providers, which then retransmit the local broadcasts to  their subscribers.    Broadcasters are deploying mobile digital television with their  spectrum. This deployment will play a significant role in mobile  broadband content delivery and should be encouraged to flourish as it  is the most efficient way of distributing video, which Cisco Systems,  Inc. says will account for 66 percent of all mobile traffic in 2015.    A better way to move underutilized broadcast spectrum to mobile  carriers would be to allow broadcasters to sell or lease such spectrum  to mobile carriers in a private market transaction.    FCC should not implement this recommendation without completing a  full spectrum inventory that also analyzes current utilization. Action, if  at all, should be predicated on demonstrated need rather than on  assertions of a looming spectrum crisis and after full investigation of  whether less disruptive alternatives to reallocation of broadcast  spectrum could address demonstrated needs.
In the National Broadband Plan, FCC acknowledges that “over-the-air  television continues to serve important functions in our society,” by  providing, among other things, free access to news, entertainment, and  local programming; children’s educational programming; coverage of  community news and events; reasonable access for federal political  candidates; and closed captioning and emergency broadcast information.  Therefore, FCC says that the plan’s recommendations “seek to preserve   as a healthy, viable medium going forward,” and  the plan calls for FCC to “study and develop policies to ensure that its  longstanding goals of competition, diversity, and localism [in broadcast  television] are achieved.” However, these statements do not appear to  have assuaged the concerns of broadcasters.
To implement the plan’s recommendations to make more spectrum  available for broadband in specific bands, FCC, among other things:    performed technical analysis and worked with broadcast industry  engineers and experts in related fields on how reallocating a portion of  television spectrum to broadband could work;  issued a proposed rule to establish a regulatory framework to facilitate  wireless broadband uses of television bands, in anticipation of the  Commission’s intended future reallocation of this spectrum to  broadband;    granted a waiver to a Mobile Satellite Services provider,  LightSquared, allowing it to expand its terrestrial use of its satellite  spectrum for broadband, conditional on addressing concerns about  interference with Global Positioning System devices;    added co-primary fixed and mobile terrestrial wireless allocations to  the 2 GHz satellite band and gave Mobile Satellite Services licensees  the flexibility to lease their spectrum to terrestrial operators via  spectrum manager leasing arrangements, both of which FCC sees as  steps toward providing flexibility to allow greater use of the band for  mobile broadband;  revised its interference rules in Wireless Communications Services  spectrum to facilitate its use for broadband, along the lines  recommended by the plan; and  issued analyses supporting its recommendation to auction the Upper  700 MHz D block; while the plan recommends the auction of this  band, several proposals in the 112th Congress, such as the  SPECTRUM Act, S.911, and the Public Safety Spectrum and  Wireless Innovation Act, H.R. 2482, call for the reallocation of this  band for deployment of a nationwide broadband public safety network  and therefore FCC is waiting to see if any related active legislation is  passed before proceeding with implementation of this  recommendation.
Experts and stakeholders responding to our survey that supported the  plan’s overall recommendation to make 300 MHz of spectrum available  for wireless broadband by 2015 were fairly evenly split between those  satisfied and those dissatisfied with FCC’s overall progress in  implementing the recommendation (see table 3). In contrast, regarding  FCC’s progress on the recommendations aimed at specific bands,  experts and stakeholders tended to be more satisfied than dissatisfied.  For example, experts and stakeholders were generally satisfied with  FCC’s progress on implementing the recommendation to accelerate  terrestrial deployment in Mobile Satellite Services spectrum but were  generally dissatisfied with FCC’s progress on the Upper 700 MHz D  Block; although, as we note above, FCC is waiting on the outcome of  pending legislation pertaining to this spectrum band before taking further  action.
Respondents expressed a variety of views on FCC’s progress. For  example, one expert reported that FCC should have auctioned the Upper  700 MHz D block already but was satisfied with FCC’s efforts to  accelerate terrestrial deployment in Mobile Satellite Services spectrum.  Another expert said that FCC’s approach to spectrum policy has resulted  in the U.S. mobile and fixed wireless broadband industries losing ground  to their foreign counterparts. An infrastructure provider responded that  FCC is working well with NTIA to free up spectrum for auctions.
Additional details on FCC’s actions to implement these recommendations,  as well as experts’ and stakeholders’ views on the recommendations and  on FCC’s implementation, are contained in appendix III.
section_title: Responding Experts and Stakeholders Had Mixed Views on Expanding Incentives and Mechanisms to Reallocate Spectrum
subsections: section_title: Recommendations in Plan
paragraphs: The National Broadband Plan included four recommendations aimed at  expanding incentives and mechanisms to reallocate spectrum. We  considered the following three of those recommendations in our review:  to motivate existing spectrum licensees to voluntarily give up their  licenses so that FCC could more quickly reallocate the spectrum to  higher valued services, the plan recommended that Congress should  consider giving FCC the authority to conduct incentive auctions in  which licensees that choose to relinquish their licenses would receive  a portion of the proceeds realized by the auction of their licenses;  to promote the efficient use of spectrum by compelling spectrum  licensees to recognize the value to society of their licenses, the plan  recommended that Congress consider granting authority to FCC to  impose fees on licensees; and    because of concerns that its rules allowing spectrum licensees to  lease their licenses—designed to promote access to underutilized  spectrum—are not as effective as they could be, the plan  recommended that FCC should identify and address barriers to  secondary markets.
The recommendations enjoyed varying levels of agreement from the  experts and stakeholders responding to our survey (see table 4). In the  table, we sometimes separately report different subgroups of  stakeholders to illustrate meaningful differences in their responses.
Far more experts and stakeholders other than broadcasters agreed than  disagreed with granting FCC authority to conduct incentive auctions,  while more broadcasters disagreed than agreed. FCC proposed incentive  auctions as a mechanism to free up 120 MHz of spectrum currently  allocated to television service, which as we noted above, broadcasters  oppose. The experts and stakeholders expressed a variety of views about  incentive auctions. For example, one expert commented that Congress  should simply allow FCC to pay some of the auction revenues to  broadcasters instead of the U.S. Treasury and avoid legislating any  details of the auction. An infrastructure provider said that incentive  auctions would take years off of FCC’s usual repurposing approach,  which as we noted earlier has taken from 7 to 15 years. A broadcaster  commented that instead of using incentive auctions to reallocate  television spectrum, FCC should allow licensees to sell or lease their  licenses to wireless service providers. Another broadcaster commented  that incentive auctions would be acceptable so long as (1) participation by  broadcasters is truly voluntary and (2) FCC reimburses broadcasters who  choose not to participate for the costs they incur to relocate to new  frequencies.
Many more experts agreed than disagreed with granting FCC authority to  impose fees on licensees, while slightly more wireless device  manufacturers and stakeholders in our “other” category agreed than  disagreed. All broadcasters disagreed with granting FCC authority to  impose fees, and about twice as many wireless service providers  disagreed as agreed; as licensees, broadcasters and wireless service  providers could be subject to the fees. The experts and stakeholders  expressed a variety of views about fees. An expert commented that the  value of spectrum is usually far greater than the amount recovered in  auctions, and that fees can better capture this value by being adjusted  upward if the value of the spectrum appreciates. Similarly, a public  interest group commented that annual fees would increase spectrum  utilization, give license holders who do not use their spectrum an  incentive to return it, and raise far more money for the U.S. Treasury than  auctions do. Alternatively, an expert responded that fees would not create  incentives for efficient use of spectrum, and suggested that instead FCC  allow competitive forces wider scope by permitting licensees to deploy  any service, technology, or business model that may be profitable. A  range of stakeholders commented that fees should be reduced or waived  for current licensees that purchased their licenses at auction or that  already pay annual regulatory fees.
Almost all responding experts and most stakeholders agreed with the  recommendation that FCC identify and address barriers to secondary  markets. An expert responded that addressing barriers to secondary  markets would eliminate the need for incentive auctions. Similarly, a  broadcaster commented that allowing all current licensees to participate  in secondary markets would enable market forces to determine the best  use for spectrum without requiring wholesale reallocation of designated  bands. A wireless service provider noted that FCC’s secondary market  rules have been greatly successful in creating access to spectrum  resources by nonlicensees, with leasing arrangements becoming  increasingly commonplace.
In response to the recommendation on secondary markets, FCC officials  told us that the Commission reviewed its secondary markets policies and  concluded that it should do more to promote these markets. It also  requested public comments on technologies that could enable dynamic  sharing of spectrum, including how such technologies could facilitate  secondary markets. FCC officials told us that the Commission intended  to issue a related order, tentatively by the end of 2011. Among those  responding to our survey and that support the recommendation, more  experts and wireless device manufacturers were satisfied than  dissatisfied with FCC’s progress, while more wireless service providers  were dissatisfied than satisfied (see table 5).
Two broadcasters commented that FCC’s analysis of barriers to  secondary markets must include broadcast spectrum to be credible and  effective. An expert questioned the relevance of dynamic spectrum  access to secondary markets, and two stakeholders commented that  dynamic spectrum access is not yet technically mature enough to support  secondary markets.
section_title: Responding Experts and Stakeholders Had Mixed Views on Expanding Opportunities for Innovative Spectrum Access Models
subsections: section_title: Recommendations in Plan
paragraphs: The National Broadband Plan includes four recommendations aimed at  expanding opportunities for innovative spectrum access models. Such  models provide alternatives to the traditional means of accessing  spectrum—exclusive-use licensing. Examples include allowing unlicensed  devices to use certain portions of the spectrum without any guarantee of  interference protection and dynamic spectrum access. The four related  recommendations are as follows:    FCC, within the next 10 years, should free up a contiguous nationwide  band for use exclusively or predominantly by unlicensed devices.    FCC should move expeditiously to complete new rules permitting  unlicensed use of the unused spectrum between television channels,  referred to as television “white spaces.”    FCC should spur further development and deployment of  opportunistic uses (i.e., dynamic spectrum access) across more radio  spectrum.    FCC should initiate proceedings to enhance research and  development (R&D) that will advance the science of spectrum access.
Stakeholders and experts responding to our survey expressed varying  levels of support for these recommendations (see table 6). In the table,  we sometimes separately report different subgroups of stakeholders to  illustrate meaningful differences in their responses.
More experts, wireless device manufacturers, and stakeholders in our  “other” category agreed than disagreed that FCC should free up a  nationwide band for the exclusive or predominant use of unlicensed  devices, while more broadcasters and wireless service providers  disagreed than agreed. Experts and stakeholders expressed a variety of  views about unlicensed uses. For example, an expert commented that  future demand for rich wireless media cannot be satisfied by licensed  spectrum alone but will require more unlicensed spectrum to provide  many more wireless fidelity (Wi-Fi) access points so that wireless traffic  can be off-loaded to the wired network. A wireless service provider said  that the potential benefit of unlicensed uses is so great that FCC should  be aiming to set aside a band for such uses within 2 to 3 years rather  than 10 years. In contrast, a Mobile Satellite Services company  responded that there is already enough spectrum available for unlicensed  uses. Similarly, an expert commented that because there are now  affordable devices that can operate effectively over a range of  frequencies, FCC should assist the market in using an online database as  it is doing for television white spaces so that unlicensed devices can  sense available spectrum and use it dynamically, rather than clearing a  new band for unlicensed use.
More responding experts and stakeholders other than broadcasters  agreed than disagreed that FCC should move expeditiously to complete  new rules permitting unlicensed use of television white spaces, while  more broadcasters disagreed than agreed. Experts and stakeholders  expressed a variety of views on the recommendation. A wireless device  manufacturer that supported white spaces noted that white spaces are  primarily available in rural areas where spectrum congestion is less  common than in densely populated environments like urban areas. But,  three broadcasters responded that FCC must ensure that its rules protect  incumbent users from interference. Two experts expressed concern that  unlicensed use of television white spaces could adversely impact or be in  tension with an incentive auction of television spectrum.
Experts and stakeholders generally supported the recommendation on  opportunistic uses, and they made a variety of comments on the  recommendation. For example, a wireless service provider supported the  continued development of dynamic spectrum access but expressed  strong opposition to FCC’s development of any related rules that would  diminish the rights of licensees of exclusive spectrum purchased at  auction to control access to their spectrum. A broadcaster also  commented that FCC should protect the integrity of existing services; the  broadcaster disagreed with the recommendation on opportunistic uses  and stated that FCC should free incumbent licensees from technical  restrictions that hinder innovation. Similarly, an expert commented that  instead of implementing this recommendation, FCC should develop rules  that create incentives for competitive processes to create efficient  solutions to spectrum shortages. Another expert expressed doubt that  mass market technology and the demands of the commercial  marketplace will allow for opportunistic uses within the next decade.
Experts and stakeholders generally supported the recommendation on  R&D. For example, a wireless service provider commented that, in  implementing this recommendation, FCC should leverage work that is  currently being done in private industry and in academia. Two other  wireless service providers reported that rather than trying to foster R&D  directly, FCC should instead focus on ensuring a highly competitive  marketplace for wireless services because competition spurs innovation  by market participants. A Mobile Satellite Services company responded  that spectrum shortages are already providing incentive for licensees to  spend their funds on R&D for ways to use spectrum more intensively. An  expert also noted that there is no need for FCC to enhance already  substantial ongoing R&D efforts by the private sector.
To implement the recommendations aimed at expanding opportunities for  innovative spectrum access models, FCC has taken or plans to take the  following steps:    Unlicensed spectrum. FCC intends to consider making additional  spectrum available for unlicensed use in conjunction with NTIA’s plan  to make available 500 MHz of spectrum for wireless broadband, which  addresses both licensed and unlicensed uses.    White spaces. FCC eliminated the requirement that white spaces  devices include technology to sense what spectrum is available, and  substituted requirements for geo-location technology and the ability to  access databases of available spectrum. FCC also conditionally  designated and began working with nine companies to develop and  administer the databases.    Opportunistic uses of spectrum. FCC requested public comment on  how dynamic spectrum access radios and techniques can promote  more intensive and efficient use of the radio spectrum.    R&D. FCC issued a proposed rule that would expand the agency’s  existing Experimental Radio Service rules to promote cutting-edge  research and foster development of new wireless technologies,  devices, and applications. Specifically, FCC proposed a new type of  license, called a “program license,” which would give qualified entities  broad authority to conduct research without having to seek new  approval for each individual experiment.
Among those that agreed with a recommendation aimed at expanding  opportunities for innovative spectrum access models, generally more  experts and more stakeholders were satisfied than were dissatisfied with  FCC’s progress on implementing the recommendation (see table 7).
More experts were satisfied than dissatisfied with FCC’s progress on the  unlicensed spectrum recommendation, while stakeholders were evenly  split. An infrastructure provider said that television white spaces has been  the focus of FCC’s efforts related to unlicensed use; the provider was  concerned that the white spaces will not support devices that work in  other countries because other countries use different spectrum bands  than the United States for television. A public interest group commented  that FCC has not made meaningful progress in this area, and that given  the success of unlicensed spectrum in dramatically increasing the public’s  access to the public airwaves, unlicensed spectrum—rather than  spectrum auctions to corporations—should be FCC’s priority.
While more experts and stakeholders were satisfied than dissatisfied with  FCC’s progress on the white spaces recommendation, experts and  stakeholders expressed a variety of concerns about FCC’s  implementation. For example, an expert said FCC’s approach is too  complicated. A device manufacturer was troubled by FCC’s decision to  remove the requirement that white spaces devices have sensing  technology that could scan the spectrum for available frequencies, which  the manufacturer said had been deemed essential for sharing spectrum.  A public interest group responded that FCC was moving too slowly.
More experts and stakeholders were satisfied than dissatisfied with FCC’s  progress on the opportunistic uses recommendation, but they expressed  some concerns about FCC’s implementation. For example, an  infrastructure provider commented that FCC has been too slow to resolve  interference issues in the 5 GHz band, which FCC has allowed for use by  devices capable of dynamically accessing spectrum. A wireless device  manufacturer was dissatisfied that FCC, rather proposing rules to  facilitate the use of smart radios, had instead taken the more preliminary  step of requesting public comments on how opportunistic uses can  promote more intensive and efficient use of the radio spectrum. The  manufacturer was also dissatisfied that the plan and the notice of inquiry  showed a preference for geo-location database approaches to dynamic  access over sensing approaches.
More experts and stakeholders were satisfied than dissatisfied with FCC’s  progress on the R&D recommendation, and they expressed a variety of  views about FCC’s implementation. For example, a wireless device  manufacturer described FCC’s proposed rule as a good step forward.  Other stakeholders expressed concerns about the proposed rule. For  example, a private user noted that FCC’s proposal to expand the  Commission’s Experimental Radio Service rules should be strengthened  to ensure that licensees are aware of experimental operations that may  cause harmful interference to them, and that FCC should more strictly  enforce against such interference.
For examples of survey participants’ comments on FCC’s implementation  of the recommendation on opportunistic uses of spectrum, see appendix  III.
section_title: Responding Experts and Stakeholders Strongly Supported Extending FCC’s Auction Authority but Varied in Their Opinions on Potential Changes to Auctions
paragraphs: In the Omnibus Budget Reconciliation Act of 1993, Congress provided  FCC authority to use auctions to assign certain spectrum licenses. From  1994 through June 30 2011, FCC conducted 79 auctions that have raised  nearly $52 billion for the U.S. Treasury. In 2005, we reported that FCC’s  use of auctions to assign spectrum appeared to have had little to no  negative impact on end-user prices, infrastructure deployment, and  competition, but that evidence on how auctions impacted the entry and  participation of small businesses was less clear. We also reported that  FCC’s implementation of auctions had mitigated problems associated  with comparative hearings and lotteries, which FCC previously used to  assign licenses. In particular, auctions were quicker, less costly, and  more transparent; were more effective in assigning licenses to entities  that valued them the most; and were an effective mechanism for the  public to realize a portion of the value of a national resource used for  commercial purposes. We recommended that Congress consider  extending FCC’s auction authority beyond the then current expiration date  of September 30, 2007. Subsequent to our report, FCC’s auction  authority was extended twice, first until September 30, 2011, and then  until September 30, 2012. Further, subsequent to our report through  June 30, 2011, FCC successfully completed 20 auctions, which raised  over $37 billion for the U.S. Treasury.
Experts and stakeholders responding to our survey, by large margins,  supported extending FCC’s authority to assign mutually exclusive  licenses by auction beyond the September 30, 2012, expiration date. In  particular, 53 of 65 experts and stakeholders supported extending FCC’s  auction authority (see table 8). Experts and stakeholders made a variety  of comments related to extending FCC’s auction authority. For example, a  wireless service provider commented that auctions are by far the most  efficient way to assign spectrum.
Experts and stakeholders responding to our survey expressed varying  levels of support for five potential changes to FCC’s auction policies that  we asked about (see table 9). In particular, we asked experts and  stakeholders about whether FCC should provide a clear schedule for future  auctions, allow all-or-nothing bids on multiple licenses (known as  “combinatorial auctions”), reduce the geographic areas covered by  licenses, modify bidding credits that provide financial benefits to certain  auction participants, and implement royalties as the means though which  auction winners compensate the government instead of up-front payments.
Among the potential changes we asked survey participants about,  reducing uncertainty about future spectrum auctions received the most  support. Currently, FCC provides information on scheduled auctions and  identifies auctions not yet scheduled. Most experts and stakeholders  agreed that FCC should reduce uncertainty by providing a clear road map  for future auctions, including their timing and size, so that potential  bidders can develop effective strategies. However, experts and  stakeholders that did not agree with the recommendation cited several  concerns. For example, a broadcaster was concerned that by providing a  road map, FCC would limit its flexibility to respond to changing  technological solutions and spectrum demand, and an expert was  concerned that if spectrum beyond that included in the road map were to  become available, the road map could be used by incumbents to protest  the release of the additional spectrum, harming consumers.
Most responding experts agreed, and more stakeholders agreed than  disagreed, that FCC should allow all-or-nothing package bids on multiple  licenses in an auction (referred to as “combinatorial auctions”) as  opposed to requiring bids on individual licenses. According to FCC, this  approach allows bidders to better express the value of any benefits from  combining complementary licenses and to avoid the risk of winning only  part of a desired set of licenses. However, a broadcaster and a wireless  service provider commented that package bidding would unfairly favor  large companies that can afford such approaches.
An equal number of responding experts agreed and disagreed, and more  stakeholders agreed than disagreed, that FCC should reduce the size of  geographic areas covered by licenses to promote the participation of  small companies. In 2010, we reported that, according to some small  wireless carriers and stakeholders, the size of spectrum blocks has had  the effect of pricing small and regional carriers out of auctions, making it  difficult for these carriers to enter into new markets or expand their  services. However, an expert and a Mobile Satellite Services company  expressed concern that if FCC were to implement this recommendation,  small companies that get spectrum would sooner or later cash out and  sell to larger carriers, which the service provider said would add to  licensees’ costs without actually fostering competition. However, a  wireless device manufacturer said that FCC could avoid this problem by  requiring any entity that acquires spectrum and sells it without a network  to pay a tax to the U.S. Treasury. Another expert responded that  implementation would result in the fragmentation of spectrum and  complex secondary market transactions aimed at recombining the  spectrum into larger geographic bundles.
More experts disagreed than agreed, while more stakeholders agreed  than disagreed, that FCC should modify bidding credits designed to  promote the participation of small companies. Bidding credits are a  percentage discount applied to the high bid amount for a license if the  bidder meets specific designated entity criteria—designed to make  spectrum available to new entrants—established in the auction rules.  Several experts and stakeholders expressed concerns about FCC’s  experience with bidding credits. For example, an expert commented that,  rather than promoting efficiency, bidding credits provide windfalls to the  owners of small companies who can use the credits to buy spectrum and  then turn around and sell it for a profit at market rates to larger firms. In  2010, we reported that some stakeholders said that, in the past, large  national carriers have used entities eligible for the credits as proxies,  allowing eligible entities to win certain licenses and then acquiring the  desired licenses from them later; a wireless service provider responding  to our survey expressed a similar concern. A device manufacturer cited  a case in which the Department of Justice, on behalf of FCC, settled with  a Wall Street money manager for $130 million to resolve allegations of  such abuse. A wireless service provider commented that the credits do  not work as intended, and an expert and a device manufacturer felt that  FCC should stop using them altogether.
Requiring winners of auctions to pay royalties based on the amount of  revenues the winners earn by using the spectrum rather than requiring  them to pay the full amounts of the winning bids up front garnered the  least support. Both experts and stakeholders were nearly evenly divided  on this potential change and expressed several concerns about royalties.  For example, a public interest group commented that royalties based on a  share of revenues would have the undesirable effect of imposing risk on  the government. Similarly, a wireless service provider commented that  royalties would have to be paired with penalties for nonuse of spectrum in  order to be effective, or else licensees—particularly large incumbents— would have an incentive to buy and not use spectrum to avoid the royalty  or to limit competition by smaller competitors and new entrants. Another  wireless service provider commented that royalties would create  disincentives for licensees to build out quickly, and that it would be  difficult for FCC to determine appropriate royalty amounts because of the  difficulty of parsing out a licensee’s revenue from various spectrum  bands, some of which would be covered by a royalty fee and some of  which would not.
section_title: Conclusions
paragraphs: As commercial enterprises increasingly utilize spectrum to provide  consumer services, FCC’s ongoing implementation of the spectrum- related recommendations of the 2010 National Broadband Plan is of great  importance. Most of the plan’s recommendations enjoyed fairly broad  support from experts and stakeholders responding to our survey,  although some recommendations were strongly opposed by some  experts or certain types of stakeholders. For example, the plan’s  recommendation for incentive auctions, which could speed the lengthy  repurposing process, received mixed responses from expert and  stakeholder respondents. In some instances, these conflicting opinions  arise from participants’ divergent positions in the communications  industry; for example, incumbent licensees, such as broadcasters, are  likely to oppose recommendations that they believe could impose  burdens or costs on their businesses. In addition, experts’ and  stakeholders’ satisfaction with FCC’s implementation of the  recommendations to date tended to be more tempered than their support  for the recommendations themselves. Perhaps most challenging, experts  and stakeholders expressed a range of views—sometimes conflicting— on how Congress and FCC should proceed. In this respect, little has  changed since 2003, when we reported that “it does not appear likely that  timely reforms can be agreed upon amid the diversity of views held by  stakeholders.” One potential step that did achieve broad agreement  among experts and stakeholders responding to our survey was extending  FCC’s auction authority beyond the current expiration date of September  30, 2012. We previously found that spectrum auctions are very effective  for assigning licenses for commercial entities. We also previously found  that as implemented by FCC, spectrum auctions resolve problems  associated with previous assignment mechanisms, while giving rise to  little or no problems. Since we issued our last report on auctions in  December 2005 through June 30, 2011, FCC has successfully completed  an additional 20 auctions, which raised over $33 billion for the U.S.  Treasury.
section_title: Matter for Congressional Consideration
paragraphs: Given the continued success of FCC’s use of auctions, and the  overwhelming support among experts and stakeholders for extending  FCC’s auction authority, Congress should consider extending FCC’s  auction authority beyond the current expiration date of September 30,  2012.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC for its review and comment.  FCC provided technical comments that we incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Chairman of the Federal Communications  Commission, and other interested parties. In addition, the report will be  available at no charge on GAO’s website at http://www.gao.gov.
If you or members of your staff have any questions about this report,  please contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. Major contributors to this report  are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: This report addresses the Federal Communications Commission’s (FCC)  management of commercial spectrum, including (1) the extent to which  FCC has made spectrum available for new commercial uses since it  implemented auction authority in 1994, and the time taken to do so; (2)  experts’ and stakeholders’ views on FCC’s plans and recent actions to  meet future spectrum needs; and (3) experts’ and stakeholders’ views on  the continued use of auctions to assign spectrum. In addition, we  examined the extent to which FCC seeks to ensure the quality of its data  on commercial spectrum licenses (see app. II).
To address all research questions, we conducted a web-based survey of  experts and industry stakeholders. We selected a nonprobability sample  of 30 experts and 79 industry stakeholders; we selected the experts and  stakeholders based on their expertise in spectrum policy, as represented  by presentations or publications, or on their organization’s vested interest  in spectrum policy. Within the industry stakeholder group, we surveyed 20  representatives of the broadcast industry, 15 representatives of the  wireless device manufacturing industry, 26 representatives of the wireless  service provider industry, and 18 other industry stakeholders, including  satellite, spectrum management, infrastructure, private user, and public  interest groups.
We developed and administered the web-based survey through a secure  server. We provided participants with unique passwords and usernames  and subsequently notified participants on May 25, 2011, when the  questionnaire was available. We sent follow-up e-mail messages to those  who had not responded, and subsequently contacted all remaining  nonrespondents by telephone. The questionnaire was available online  until June 28, 2011. We received completed responses from 20 experts  and 54 industry stakeholders, representing a 68 percent response rate.  Because we selected a nonprobability sample of experts and industry  stakeholders, the information we obtained from the survey may not be  generalized to all experts and industry stakeholders who have an interest  in spectrum policy.
The practical difficulties of conducting any survey may introduce errors,  commonly referred to as nonsampling errors. For example, difficulties in  interpreting a particular question, sources of information available to  respondents, or entering data into a database or analyzing them can  introduce unwanted variability into the survey results. We took steps in  developing the questionnaire, collecting the data, and analyzing them to  minimize such nonsampling error. For example, social science survey  specialists designed the questionnaire in collaboration with GAO staff  who had subject matter expertise. Then, we pretested the draft  questionnaire with four experts and industry stakeholders; we also  reviewed the survey with FCC staff. We conducted these pretests and  reviews to ensure that (1) the questions were clear and unambiguous, (2)  terminology was used correctly, (3) the questionnaire did not place an  undue burden on respondents, (4) the information could be feasibly  obtained, and (5) the survey was comprehensive and unbiased. On the  basis of the feedback from the pretests and reviews we conducted, we  made changes to the content and format of the survey questions. When  we analyzed the data, an independent analyst checked all computer  programs. Since this was a web-based survey, respondents entered their  answers directly into the electronic questionnaire, eliminating the need to  key data into a database, minimizing error.
In addition to the survey, to address all research questions we conducted  semistructured interviews with a variety of industry stakeholders, experts,  and officials with government agencies; for industry stakeholders, we  interviewed both associations and individual companies. We interviewed  the following types of organizations and individuals: government agencies  (FCC and the Congressional Research Service), wireless service  providers, wireless device manufacturers, a wireless telecommunications  infrastructure company, broadcasters, Mobile Satellite Services  companies, a spectrum data manager, academics, public interest  organizations, and consultants.
To examine the extent to which FCC seeks to ensure the quality of its  data on commercial spectrum licenses, we reviewed the following FCC  spectrum-related databases: Universal Licensing System, Consolidated  Database System, International Bureau Filing System, Experimental  Licensing System, and Equipment Authorization System. To review these  databases, we interviewed FCC officials responsible for maintaining the  systems about FCC’s processes for ensuring the quality of the data, and  we compared FCC’s processes with GAO guidance on internal controls  and information technology. We also interviewed industry stakeholders  who use these databases, as well as the Spectrum Dashboard and  License View systems that pull data from these systems, and included  questions in our survey of experts and stakeholders pertaining to the  usefulness, accuracy and completeness, and user-friendliness of FCC’s  systems. We also reviewed prior FCC audits of records in the Universal  Licensing System.
To examine the extent to which FCC has made spectrum available for  new commercial uses, we reviewed six instances where FCC repurposed  spectrum from an existing use to a new use. The six repurposings we  reviewed involved substantial amounts of spectrum that were repurposed  to a higher value use. In particular, these repurposings met the following  criteria: (1) the amount of spectrum repurposed was 5 megahertz (MHz)  or more; (2) the repurposing yielded $100 million or more in auction or  industry revenue; and (3) reassignment occurred in 1994, when FCC first  implemented its auction authority, or later. For these repurposings, we  reviewed FCC’s notices, orders, and auctions; comments filed in the  proceedings by industry participants; and relevant court decisions. We  also included a question in our survey of experts and stakeholders  pertaining to the amount of time it takes from when FCC or Congress  designates a spectrum band for reallocation until the band is available for  a new use.
To examine FCC’s plans and recent actions to meet future spectrum  needs, we reviewed the National Broadband Plan and notices of inquiry,  reports and orders, and other publications related to FCC’s development  or implementation of the plan’s chapter on spectrum. We reviewed  comments filed in various FCC proceedings from industry stakeholders  on FCC’s development of the plan and FCC’s steps to implement the  plan. We reviewed publications and presentations from academic and  industry consultants and other experts. We included questions in our  survey of experts and stakeholders pertaining to the recommendations in  the plan’s chapter on spectrum and FCC’s steps to implement those  recommendations. We asked survey participants for their opinion on each  recommendation and where appropriate, FCC’s steps to implement the  recommendation; we excluded three recommendations that were  addressed in our questions about FCC’s data quality, fell under the  purview of the National Telecommunications and Information  Administration (NTIA), or pertained to a narrow population.
To examine FCC’s continued use of auctions to assign spectrum, we  reviewed prior GAO reports that addressed FCC’s use of auctions to  assign spectrum licenses. We reviewed publications and presentations  from academic and other experts. Finally, we included questions in our  survey of experts and stakeholders pertaining to spectrum auctions. In  particular, we asked survey participants for their opinion on whether  Congress should extend FCC’s auction authority and on five potential  changes to FCC’s implementation of auctions.
We conducted this performance audit from August 2010 to November  2011 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Federal Communications Commission’s Spectrum-Related Data Systems
paragraphs: In this appendix, we provide information on FCC’s spectrum-related data  systems. Specifically, we discuss (1) FCC’s data systems for spectrum- related records, (2) experts’ and stakeholders’ views about attributes of  FCC’s data systems, (3) FCC’s quality-control process for its data, and  (4) FCC’s efforts to improve its spectrum-related data.
subsections: section_title: FCC Has Several Data Systems for Spectrum- Related Records
paragraphs: We examined seven of FCC’s spectrum-related data systems, of which  six are related to spectrum licenses, and one is concerned with radio  equipment authorizations (see table 10). Four of the six spectrum  license-related systems allow (1) entities to apply for a license, (2)  existing licensees to apply for a license renewal or to update their license  information, and (3) the public to search for information on licenses; these  systems are the Universal Licensing System for wireless  telecommunications licenses, the Consolidated Database System for  broadcasting licenses, the International Bureau Filing System for satellite  licenses, and the Experimental Licensing System for experimental use  licenses. According to FCC officials, the Universal Licensing System is by  far the largest system with the most licenses, and is therefore the system  that the public is most likely to interact with. FCC recently implemented  the other two systems related to spectrum licenses—Spectrum  Dashboard and License View—to provide the public with more user- friendly tools, such as enhanced mapping capabilities, for searching for  information on spectrum licenses. These two systems pull data on  licenses from FCC’s spectrum licensing systems; they do not allow  entities to file applications for licenses or update information on their  licenses. The Equipment Authorization System allows entities to file  applications for authorizations of radio equipment, such as cell phones,  and the public to search for information on these authorizations. FCC  uses these various systems for multiple purposes, including processing  applications for spectrum licenses or radio equipment authorizations and  helping to determine where spectrum is available.
Most users of FCC’s spectrum-related data systems responding to our  survey reported that the systems generally provide the type of information  they are looking for to either a great or moderate extent (see table 11). In  particular, for each of the seven systems, large majorities of survey  respondents expressed a favorable opinion on the availability of  information. However, respondents’ opinions varied somewhat across the  systems. For example, a large majority of respondents reported a positive  evaluation of the Universal Licensing System; 54 of 58 respondents said  that the Universal Licensing System provides the type of information they  were looking for to a great or moderate extent. Spectrum Dashboard, a  system that pulls data from FCC’s spectrum licensing systems, had a  somewhat lower level of support; 33 of 48 respondents reported that  Spectrum Dashboard provides the type of information they were looking  for to a great or moderate extent.
According to some users of FCC’s spectrum-related data systems that  responded to our survey, inaccurate and missing data hindered their use  of the systems to a great to moderate extent (see tables 12 and 13).  Respondents reported such problems most often with the Universal  Licensing System. In particular, 19 of 54 respondents and 23 of 55  respondents reported that inaccurate information and missing information,  respectively, in the Universal Licensing System hindered their use to a  great or moderate extent. Dissatisfaction with inaccurate data rose to a  similar level only for the Consolidated Database System; 10 of 29  respondents reported that inaccurate data in the Consolidated Database  System hindered their use to a great or moderate extent. In addition to  the Universal Licensing System, respondents reported the most  difficulties arising from missing information with the Consolidated  Database System and the International Bureau Filing System. In  particular, almost one-third of respondents reported that missing data in  the Consolidated Database System and the International Bureau Filing  System hindered their use to a great or moderate extent.
For some users, FCC’s primary spectrum-related data systems can prove  challenging to use. In the National Broadband Plan, FCC noted that the  complexity of its data on licensing of spectrum and the lack of  transparency and usability of data created impediments to public policy  and restricted the development of new technologies, such as dynamic  spectrum access, that could utilize spectrum data. Several stakeholders  told us that systems, such as the Universal Licensing System, are  relatively user-friendly for “expert” users with technical knowledge and  experience, but that the systems could pose challenges for other users.  Consistent with this view, half or more of respondents reported that the  International Bureau Filing System and the Experimental Licensing  System were not too or not at all user-friendly, and about one-third of  respondents reported similar views of the Universal Licensing System  and the Consolidated Database System (see table 14).
To respond to these concerns; to help ensure greater transparency in  spectrum allocation, assignment, and use; and to help promote  secondary market transactions; FCC developed the Spectrum Dashboard  and License View systems. As discussed earlier, these systems pull and  compile data from the primary spectrum-related data systems, such as  the Universal Licensing System and the Consolidated Database System,  and are designed to present the information in a meaningful, easy-to-use  format to the public. In designing these systems, FCC sought a means  whereby its data could be leveraged by citizens for greater purposes, and  both Commission staff and external parties are better positioned to  identify data inaccuracies or inconsistencies. As shown in table 14, over  four-fifths of respondents reported that Spectrum Dashboard was very or  somewhat user-friendly, thereby meeting FCC’s intent of the system while  more than half of respondents reported that License View was very or  somewhat user-friendly.
section_title: FCC Has Processes Aimed at Ensuring the Quality of Its Data; However, Past Audits Identified Some Problems
paragraphs: FCC has commissionwide programs, policies, and procedures for the  collection and management of information, which help ensure FCC’s  compliance with governmentwide laws and regulations pertaining to  information collection and management. For example, FCC’s records  management program is intended partly to control the quantity and quality  of records produced by the Commission. In 2010, we reviewed and  reported on 30 information collection systems used by FCC, including  those associated with the Experimental Licensing System and the  Equipment Authorization System data systems. We found that FCC  followed relevant policies and procedures, including those pertaining to  quality control. For this report, we examined the processes in place to  ensure the quality of data in FCC’s five spectrum license and  authorization systems. We identified several quality-control features  incorporated in the five systems, which we discuss below and illustrate in  table 15.    Edit checks. FCC’s spectrum-related licensing and authorization  systems each incorporate edit checks, which check for missing or  anomalous data elements; these edit checks occur either online  during the filing process or in batch mode. All five systems incorporate  online edit checks, which check the accuracy of data entered by filers  in real time and flag potential errors for users. FCC officials said that  these online checks are helpful to filers and help ensure data  accuracy. In addition, the Universal Licensing System, the  Consolidated Database System, and the International Bureau Filing  System incorporate edit checks in the nightly batch processing of data  submitted by users. Among other things, the edit checks address  acceptable ranges of values, filings from parties with delinquent debts,  and accuracy of geographic coordinates.    FCC staff review. Before granting a spectrum license or equipment  authorization, FCC checks all information provided by the applicant or  licensee using automated or staff reviews. For example, FCC staff  scrutinizes all spectrum license renewal applications that require  exhibits demonstrating compliance with license requirements. FCC  staff seeks correction or clarification of any inaccuracies detected in  the information. According to FCC officials, these ongoing staff  reviews of applications supplement the automated edit checks. In  addition to its own reviews, FCC accepts reports of data  discrepancies from members of the public.    Filer notification. According to FCC officials, the Commission in part  depends on the applicants for licenses to submit accurate data. FCC  believes this is appropriate because entities filing applications are in  the best position to know the relevant facts and are often experts and,  therefore, the data these entities submit should be of high quality.  Furthermore, FCC officials noted that when entities submit  applications or renewals, they must certify and affirm the accuracy of  the data. When FCC staff discovers errors, the Commission alerts the  original filer and solicits correction.    Tracking systems. FCC maintains a help desk, with access via  telephone and e-mail. Applicants, licensees, and the general public  may use these resources to obtain help with FCC’s data systems. In  addition, the Universal Licensing System, the Consolidated Database  System, and the Equipment Authorization System incorporate  systems that track e-mail and phone queries and thus help FCC to  identify problems with the data systems.
While these quality-control features can help promote the quality of FCC’s  spectrum-related data, past Commission audits have uncovered some  problems with the timeliness of FCC’s data. FCC periodically reviews its  systems and data and, from 2001 through 2005, FCC audited licensees in  three spectrum bands. FCC conducted these audits because of concerns  that some licensees for certain types of services included in the Universal  Licensing System were not keeping FCC informed of their operating  status. These audits were aimed at determining, for each license, whether  the licensed service was operational, and canceling the licenses in cases  where service had been discontinued. The audits resulted in the  cancellation of the following licenses:    220 MHz licenses: 94 licenses cancelled out of 956 licenses audited  (10 percent cancelled)    Paging licenses: 2,076 licenses cancelled out of 7,770 licenses  audited (27 percent cancelled)    Private land mobile radio licenses: 37,448 licenses cancelled out of  420,112 licenses audited (9 percent cancelled)
As these audit results illustrate, FCC’s spectrum-related systems may not  incorporate the timeliest information. FCC acknowledged that the extent  to which its data match real world conditions depends upon the particular  rules governing filers and the burden of filing upon industry. For example,  since a broadcaster must renew its license once every 8 years, the data  on file, as of the most recent renewal, may not remain accurate over time.  Although FCC also requires that filers update information about significant  events as needed, FCC has no practical way to ensure that filers comply  with that requirement. FCC officials said that the Commission could take  measures, such as requiring more frequent updates and certification of  data in its databases, but such measures must be balanced with the  burden placed upon industry. According to FCC officials, the Commission  has focused on checking the accuracy of the data submitted to FCC at  the time of submission, not on maintaining accuracy over time. But FCC  now recognizes that there is a need to ensure that the data in its systems  reflect conditions in the real world on an ongoing basis to determine  where spectrum is available. Regarding the possibility of future audits,  FCC officials said that the Commission does not currently have concerns  that would warrant additional audits of license holders but, that if such  concerns were to arise, it would consider conducting additional audits.
section_title: FCC Has Several Efforts Under way with the Potential to Improve Its Spectrum-Related Data
subsections: section_title: Data Innovation Initiative
paragraphs: Recognizing the need to improve the Commission’s information practices,  in July 2009, the FCC Chairman initiated a review of FCC’s systems and  processes for information collection, processing, analysis, and  dissemination, and this effort continued with the June 2010 launch of the  Data Innovation Initiative. According to FCC staff, the Commission has  been working to improve its data collection, analysis, and dissemination  practices in order to reduce the reporting burden on outside parties and  ensure that the agency has timely, complete, and accurate data on which  to base its activities and decisions. As part of this effort, FCC has sought  to streamline the processes by which parties supply information, thereby  minimizing work and potential errors. Furthermore, FCC is developing  data quality analytics to measure its data quality. This effort will assess  the accuracy of FCC’s data from an input perspective (the quality of  information submitted by filers) and from a system perspective (the  maintenance of accurate information in FCC’s databases, including the  extent to which the data reflect conditions in the real world).
Alongside the Data Innovation Initiative, FCC created a Chief Data Officer  for the Commission and Chief Data Officers inside each Bureau and  Office. The Commission’s Chief Data Officer is responsible for improving  how the Commission collects, uses, and disseminates data, among other  things, and oversees the Data Innovation Initiative. The Wireless  Telecommunication Bureau’s Chief Data Officer reports directly to the  Bureau Chief and, according to FCC officials, has been closely engaged  in spectrum-related data analysis, including the identification of spectrum  needs.
In 2009, FCC began an effort to consolidate its numerous, bureau-based,  and separately managed licensing systems into a single system known as  the Consolidated Licensing System (CLS). According to FCC staff, as  currently envisioned, CLS would provide the public with a single portal for  access to all FCC licensing systems and would have user-friendly  features. In addition, CLS would incorporate enhanced edit check  capability, including for example, validation of geographic coordinates for  antennas to ensure that the coordinates coincide with the locations of the  antennas. FCC staff said that CLS would include information from its  legacy databases, such as the Universal Licensing System, and that cost  considerations may affect how much legacy information the new system  includes; however, FCC believes that the information for the current  filings and the previous filings should be sufficient to meet FCC’s needs  for spectrum management. Because of the complexity and size of this  effort, FCC expects to deploy CLS in phases over a period of years.
section_title: Appendix III: Expert and Stakeholder Respondents’ Views on FCC’s Plans and Recent Actions to Meet Future Spectrum Needs
paragraphs: This appendix presents the views of experts and industry stakeholders on  the spectrum-related recommendations in the National Broadband Plan  and FCC’s steps to implement those recommendations. We surveyed 30  experts and 79 industry stakeholders, and 20 of the experts and 54 of the  stakeholders responded to our survey, representing a 68 percent  response rate (see app. I for additional information on our survey  methodology). For each recommendation from the National Broadband  Plan covered by our survey, we provide the following:  the text of the recommendation;    a summary of the rationale for the recommendation presented in the    data on experts’ and stakeholders’ level of agreement with the    excerpts from experts’ and stakeholders’ comments on the    a description of FCC’s progress on implementing the recommendation    data on experts’ and stakeholders’ level of satisfaction with FCC’s  progress on implementing the recommendation through May 2011 (for  those recommendations directed at FCC); and    excerpts from experts’ and stakeholders’ comments on FCC’s  progress on implementing the recommendation.
subsections: section_title: National Broadband Plan Recommendations Aimed at Making More Spectrum Available for Wireless Broadband Use by 2015
subsections: section_title: Make 300 MHz of Spectrum Available by 2015 and 500 MHz by 2020
subsections: section_title: Recommendation
paragraphs: FCC should make 500 MHz newly available for broadband use within the  next 10 years, of which 300 MHz between 225 MHz and 3.7 GHz should  be made newly available for mobile use within 5 years.
FCC believes that additional spectrum should be made available to help  meet anticipated increases in demand for wireless broadband services.  The targets were based on an FCC staff forecast of spectrum demand.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)
Comment excerpts  I believe that this approach will align with market demands.
Expert (somewhat  agree)
I strongly agree with the direction of change (more licensed  spectrum), and the amounts are not trivial - but ‘still more’ is  the correct answer.
Expert (somewhat  disagree)
If the need for data is increasing by 25x (only the next five  years, I would expect it to continue to increase if the report of  the increase is accurate) then how is a 2x improvement in  spectrum going to fix the problem. Cellular works because of  spectral reuse, not because of spectrum.
Expert (strongly  disagree) (1) This is an unrealistic objective for many reasons including  the fact that there are no mechanisms in place that have even  a remote chance of success. (2) This is a dangerous objective  since its promise will result in a false sense of complacency  that will keep the FCC and NTIA from stimulating the REAL  solution to the broadband spectrum problem - stimulation of  technologies that can multiply spectrum capacity rather than  just add increments and (3) even if the objective succeeds, the  problem will not be solved.
Expert (strongly  disagree)
This…plays into the pocket books of the big incumbents.  Broadband is not in the desert southwest or Appalachia  because it is not now and never will be financially workable.  …Instead, the FCC should require incumbent reporting of  fallow spectrum so the FCC can identify chunks of   to be licensed to small enterprises whose primary business is  not telecommunications (such as trucking companies,  agriculture, tourism) so that they can use programmable  wireless devices to bring broadband to niche markets in a way  that promotes entrepreneurism in those markets, such as the  desert southwest and Appalachia.
Broadcaster (strongly  disagree)
Need for more spectrum is a result of wireless provider’s OWN  CHOICE on not reducing cell size; cheaper to buy more  spectrum.
Broadcaster (strongly  disagree)
Type of commenter  (level of agreement)
Broadcaster (strongly  disagree)
Comment excerpts  This plan does not adequately take into account that (1) over  2/3 of the spectrum currently held for mobile broadband has  not yet been deployed, (2) femto/pico cell and wifi offloading  can have a substantial role, (3) that 66% of mobile broadband  traffic will be video, and MDTV broadcasting should be used to  deliver that high-volume data. The approach of simply shifting  spectrum in this manner only serves to consolidate more  spectrum in the hands of fewer gatekeepers, rather than  creating more bandwidth for users by understanding the usage  patterns and applying the proper technology/spectrum  combination. Spectrum is not a panacea and this approach will  ultimately create a recurring scenario of “spectrum crisis” every  few years with the inevitable calls for more spectrum.
Wireless device  manufacturer (strongly  agree)
It is well-documented that mobile broadband use is increasing  dramatically and will outstrip the supply of available bandwidth  in the near future.
Wireless service  provider (strongly  agree)
Additional spectrum that is made available for auction must  come with an assurance of device interoperability across each  band of spectrum auctioned. Without this assurance via  license requirement or other mechanism, future spectrum will  be subject to the same sort of balkanization into proprietary  bandclasses by carriers large enough to influence or control  the specifications of devices or network equipment, as has  been the case in the 700 MHz spectrum.
Wireless service  provider (somewhat  disagree)
Wireless service  provider (strongly  disagree)
This spectrum will be hoarded by the large carriers and further  squeeze the small rural carriers out of the market. This will  further eliminate competition in the wireless industry.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: Our survey asked respondents how satisfied they were overall with FCC’s  progress on this recommendation, which had five subrecommendations.  However, rather than providing an overall description of FCC’s progress,  our survey referred respondents to the descriptions of FCC’s progress  contained within the survey’s questions on the subrecommendations.  Those descriptions are shown in this appendix under the other  recommendations in this section of the appendix.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of  satisfaction)
Expert (somewhat  satisfied) should have auctioned  D block already, but  is  working hard on MSS.
Expert (neither  satisfied nor  dissatisfied)
The Congress is in the leadership role on the auctions [that are  needed to implement several of the components of this  recommendation].
Expert (somewhat  dissatisfied)
Expert (strongly  dissatisfied) … FCC is falling well behind other international markets in its  efforts to avail spectrum resources for the US to attain a  leadership position in mobile and fixed broadband.
Infrastructure provider  (somewhat satisfied) … FCC is working well with NTIA to free up other spectrum for  traditional auction.
Wireless device  manufacturer  (somewhat satisfied)
The Commission established an aggressive timetable for  implementation, not anticipating the political environment and  Congressional limbo on incentive auction authority.
Wireless service  provider (somewhat  satisfied) if steps are not taken soon  to accelerate the reallocation of suitable federal spectrum for  commercial provider use, to repurpose significant amounts of TV  broadcast and MSS spectrum for terrestrial broadband use  under incentive auctions, and to auction the 700 MHz D Block or  otherwise provide for public/private commercial mobile uses of  excess capacity on  spectrum.
Type of commenter  (level of  satisfaction)
Wireless service  provider (somewhat  satisfied)
The FCC has issued an item seeking comment on NTIA- identified bands—a good initial step.
section_title: Reallocate Portion of Television Spectrum (120 MHz)
subsections: section_title: Recommendation
paragraphs: FCC should initiate a rulemaking proceeding to reallocate 120 MHz from  the broadcast television bands.
FCC believes that spectrum currently allocated for over-the-air television  broadcasting would have much higher economic value if it were allocated  for wireless broadband.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)  Perhaps the single most important step the government can  take to improve US wireless broadband is to let the FCC  auction off broadcast TV spectrum. It is beyond argument that  broadcasters do not need everything they have and that the  national interest—jobs, public discourse, economic growth,  improved health care service—is with expanding wireless  broadband.
Expert (strongly agree)  TV has been the blatant abuser of spectrum so this is righting  a wrong.
Expert (strongly agree) should also have considered reallocation with leasing  rights.
Expert (somewhat  agree)
Reallocating the TV band spectrum toward more market-based  approach is important.
Expert (strongly  disagree)
The FCC could solve this problem immediately by: (1) de- zoning broadcast spectrum and allowing other uses and  expanding secondary markets; (2) reorganizing remaining  broadcast licensees in each market into more compact bands  and reclaiming broadcast spectrum that is not licensed.
Broadcaster (strongly  disagree)
More US citizens use and rely on the broadcast spectrum than  any other spectrum category being considered. Broadcasters  are also deploying MDTV with this spectrum. This deployment  will play a significant role in mobile broadband content delivery  and should be encouraged to flourish as it is the most efficient  way of distributing video, which Cisco says will account for  66% of all mobile traffic in 2015.
Broadcaster (strongly  disagree)
The solution to moving underutilized broadcast spectrum to  mobile carriers is to lift the FCC rules that prevent  broadcasters from selling or leasing such spectrum to mobile  carriers in a private market transaction. Applying the FCC’s  secondary markets policy to broadcast spectrum would enable  the parties to clear the spectrum where needed, on a voluntary  basis, without government involvement. If a checkerboard of  spectrum is freed up (that is, non-adjacent channels), the FCC  could streamline its channel-change and channel-swap  procedures for the new mobile licensees just like the FCC did  about 10 years ago to clear the 700 MHz band of  broadcasters. By the way, it is not entirely clear that mobile  operators really need two adjacent 6 MHz channels. Qualcom  has a new chip that uses just one 6 MHz channel for two-way  mobile data, and Sprint has argued that adjacent channels are  not necessary for 4G systems.
Broadcaster (strongly  disagree)
The proposal to reallocate 120 MHz of spectrum from the TV  band is likely to have a significant impact on the public’s  access to free over the air television. Any reallocation must be  based on fair data and after a full evaluation of spectrum use  and public need.
Type of commenter  (level of agreement)
Broadcaster (strongly  disagree)
Broadcaster (strongly  disagree)
This recommendation should not be implemented absent  compelling data, and absent a full and complete spectrum  inventory that also analyzes current utilization. Action, if at all,  should be predicated on demonstrated need rather than on bare  assertions of a “looming spectrum crisis,” and after full  investigation of whether less disruptive alternatives to reallocation  of broadcast spectrum could address demonstrated needs. This  proposal, if implemented, will impose real and substantial costs on  broadcasters and will have a significant negative impact on the  public’s access to free over-the-air television.
Wireless device  manufacturer (strongly  disagree)
The incumbents say they need this right away when they don’t  use 50-90% of what they already control at all, let alone efficiently.  The FCC approved white space and then decided to do incentive  auction. This is crazy policy. Make the carriers show how much  they use and how efficiently before you do anything.
Wireless service  provider (strongly  disagree)
Allocating 120 MHz to mobile broadband completely  eviscerates the needs of fixed wireless broadband. At least 42  MHz of unlicensed TV band spectrum must be preserved to  allow fixed wireless broadband providers to provide broadband  for citizens who have NO AVAILABLE TERRESTRIAL  BROADBAND options today.
Public interest group  (strongly disagree)
This process will directly undermine dynamic spectrum access  technologies (e.g., television white space devices), killing one of  the most innovative new spectrum utilization ideas we’ve seen in  a generation. Instead, the FCC will continue using much the  same remarkably inefficient system of spectrum licensure that  has lead to current artificial scarcities and inefficiencies. Bribing  license holders to vacate from bands is a horrible idea.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In June 2010 FCC issued a technical paper providing more detail than  the National Broadband Plan on how reallocating a portion of the  television bands might work. It presented an analysis of bandwidth  requirements of various video streams, data to support the assertion  that two television stations could voluntarily share a single six-MHz  channel and continue to broadcast their primary video streams in high  definition, and an initial look at the television allotment optimization  model being developed by the FCC.
In June 2010, FCC held a “Broadcast Engineering Forum” with  broadcast industry engineers and technical experts in related fields  regarding future rulemakings on reallocating spectrum from the  broadcast television bands, including rule-makings regarding service  areas, distance separations, and channel-sharing.
In November 2010, FCC issued a Notice of Proposed Rulemaking  (NPRM) to establish a regulatory framework to facilitate wireless  broadband uses of the UHF and VHF television bands, while  maintaining current license assignments in the band.
In March and April 2011, FCC held a series of web-based seminars  with state broadcasting associations to describe how FCC thinks an  incentive auction might work and give broadcasters a chance to ask  questions.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter (level of  satisfaction)
Expert (very satisfied)
Comment excerpts  Good example of how to do it right.
Expert (strongly dissatisfied)  My dissatisfaction is with Congress, not the FCC. This  should move faster and the broadcasters should stop  trying to derail this process.
Expert (strongly dissatisfied)
Congress is the big problem here.
Wireless device manufacturer  (very satisfied)
We believe that the FCC is doing everything in its power  to move along the 120 MHz reallocation, but believe that  FCC progress will only continue if Congress lets the  FCC do its job.
Wireless device manufacturer  (very satisfied) … it is very important that the Congress empowers the  FCC with the ability to implement voluntary incentive  auctions, as this is the mechanism that will provide the  opportunity to ensure this valuable spectrum is put to its  most highly valued uses.
Wireless device manufacturer  (somewhat dissatisfied)
Unfortunately the need for incentive auction authority  lays at the hands of congress.
Wireless service provider  (somewhat satisfied)
The prospect of the FCC holding auctions to license as  much as 120 MHz of repurposed TV Broadcast  spectrum in the 2012-2013 timeframe as originally  proposed in the FCC’s NBP is increasingly problematic.  Legislation authorizing incentive auction authority has  been proposed but passage is uncertain. In addition,  numerous requirements have been proposed to be  included in such legislation which, if adopted, would  substantially reduce the amount of repurposed spectrum  available for auction.
section_title: Accelerate Terrestrial Deployment in Mobile Satellite Services Spectrum (90 MHz)
subsections: section_title: Recommendation
paragraphs: FCC should accelerate terrestrial deployment in 90 MHz of Mobile  Satellite Services spectrum.
To address what FCC now believes are overly-burdensome requirements  that it set for Mobile Satellite Services operators before they could deploy  terrestrial networks to enhance coverage in areas where their satellite  signal is weakened or unavailable, the plan recommends accelerating  terrestrial deployment by providing sufficient flexibility to licensees to  increase terrestrial broadband use of Mobile Satellite Services spectrum,  while preserving market-wide capability to provide unique mission-critical  Mobile Satellite Services.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)  FCC is doing everything it can to move MSS spectrum into  terrestrial wireless market. [The provisional waiver that FCC  granted to] LightSquared is unexpectedly complicated due to  GPS interference, but FCC definitely seems to be on the right  track with the 40 MHz of S Band spectrum.
Expert (strongly agree)  Having spectrum set aside for satellite use is potentially a very  inefficient use of spectrum and unlocking the value of that  spectrum could be very beneficial.
Expert (somewhat  disagree)
The business case and public interest is not clear;   should identify and develop more alternatives.
Broadcaster (somewhat  disagree)
Making terrestrial allocations in this band has increased  interference to uses adjacent to that band (e.g., ENG facilities  in 2Ghz band); interference criteria should be strengthened  and strictly adhered to.
Wireless device  manufacturer (strongly  agree) se … incentive auctions in  this band to allow deployment of terrestrial mobile broadband  systems.
Wireless service  provider (strongly  agree) o long as no  harmful interference occurs to wireless carriers and public  safety from LightSquared operations.
Wireless service  provider (strongly  agree)
Good spectrum, cleared and ready to use. But FCC can do  little as this spectrum is trapped in bankruptcy proceedings. It  will be very difficult for FCC to change the rules for ultimate  new licensees after they pay value in bankruptcy.
Type of commenter  (level of agreement)
Wireless service  provider (somewhat  disagree)
Comment excerpts  Interference concerns regarding locating a terrestrial band next  to a space-based band were well-founded. Testing has already  proved substantial interference will occur with GPS systems.  Other MSS spectrum may not share these same problems (i.e.  not near GPS L1), but the FCC needs to move cautiously.
Public interest group  (strongly agree)
There are certainly complexities with this approach, but it is  worthwhile - this is valuable, useful spectrum.
Mobile Satellite  Services company  (neither agree nor  disagree) would be  very different depending on whether the recommendation was  interpreted to mean accelerate removal of MSS players to  allow for terrestrial deployment, or simply accelerate ongoing  progress to manage both satellite and terrestrial deployment in  the bands.
Private user group  (somewhat disagree)
Terrestrial deployment in MSS bands raises significant  technical issues that require careful study and should not be  rushed.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In July 2010, FCC issued an NPRM to add co-primary Fixed and  Mobile allocations to the 2 gigahertz (GHz) band, consistent with the  International Table of Allocations. This allocation modification is a  precondition for more flexible licensing of terrestrial services within the  band. FCC also proposed to apply its secondary market policies and  rules applicable to terrestrial services to all transactions involving the  use of Mobile Satellite Services bands for terrestrial services in order  to create greater predictability and regulatory parity with bands  licensed for terrestrial mobile broadband service.
In July 2010, FCC requested comment in a notice of inquiry on further  steps it could take to increase the value, utilization, innovation, and  investment in Mobile Satellite Services spectrum generally.
In January 2011, FCC granted a waiver to LightSquared allowing it to  expand its terrestrial use of its satellite spectrum, conditional on,  among other things, addressing concerns regarding interference with  Global Positioning System devices to FCC’s satisfaction.
In April 2011, FCC issued a Report and Order adopting the proposals  in its July 2010 NPRM.
In May 2011, FCC solicited input on approaches to maximize  terrestrial mobile broadband use of 2 GHz range spectrum that is  allocated for fixed and mobile use.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (somewhat  dissatisfied)
I have some concerns regarding interference with existing  spectrum used for other systems such as GPS.
Infrastructure provider  (very satisfied)
The LightSquared GPS interference issues aside, this is an  important block of spectrum that would be better utilized for  terrestrial networks, provided the interference issue with GPS  can be managed.
section_title: Auction Advanced Wireless Services Spectrum (60 MHz)
subsections: section_title: Recommendation
paragraphs: FCC should make up to 60 megahertz available by auctioning Advanced  Wireless Services (AWS) bands, including, if possible, 20 megahertz from  federal allocations.
The plan noted that FCC has already allocated spectrum for AWS, and  called for FCC to expeditiously resolve the future of this spectrum.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)  Congress should learn from the unexpectedly slow AWS  transition from government to commercial use and just  compensate government agencies for transition costs to  accelerate the repurposing.
Expert (strongly  disagree)
These changes will cost $B in DoD and DHS which is not  resourced to address the changes.
Wireless device  manufacturer (strongly  agree)
To the greatest extent possible, the allocations also should be  globally harmonized to promote economies of scale, which will  drive benefits to network operators and ultimately consumers  in the form of lower priced equipment and devices.
Wireless device  manufacturer  (somewhat agree)
H block will create interference concerns to existing PCS band.  J block downlink should be aggregated with AWS-3 and paired  with Federal spectrum bands 1755-1780 MHz to expand the  existing AWS-1 band.
Type of commenter  (level of agreement)
Wireless service  provider (strongly  agree)
Comment excerpts  Had FCC moved quickly on this—or on D Block auction—T- Mobile would not have agreed to be acquired by AT&T  because it would have better spectrum opportunities. So …  there is a direct line between  FCC failure to act quickly …  and likely creation of a wireless/wireless duopoly that cannot  easily be undone.
Wireless service  provider (strongly  agree)
NTIA should reallocate 25 MHz of spectrum (1755-1780 MHz)  to pair with AWS-3 and Upper AWS-2 J Block.
Wireless service  provider (strongly  agree)
We support the pairing of 25 MHz of Federal spectrum  including 1755-1780 MHz with 2155-2180 MHz (combining the  AWS-3 band with upper J Block spectrum). We also support  the reallocation of additional Federal spectrum, 1695-1710  MHz, to be paired with unspecified Federal or possibly non- Federal spectrum.
Wireless service  provider (somewhat  disagree)
Until rules are in place that facilitate efficient and complete use  of currently licensed spectrum (e.g., device interoperability  requirements across all blocks of paired spectrum in each  band), there is not an urgent need for more to be auctioned.  Moreover, without the assurance of such things as device  interoperability, small operators and new entrants are unlikely  to participate in future auctions—reducing the number of  bidders and, therefore, reducing auction revenues.
Wireless service  provider (strongly  disagree)
Interoperability needs to be resolved first on current spectrum.  The device ecosystem is of paramount importance to carrier  buildouts and lack of interoperability has many carriers on  hold. We need to effectively use current spectrum first. This  also needs to be part of any and all future auctions or it will  limit interest to only the Tier 1 carriers.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In July 2010, FCC requested comment in a Notice of Inquiry on  whether the opportunity to integrate the AWS-2 J Block and 2 GHz of  Mobile Satellite Spectrum would help attract new investment and  utilization.    FCC consulted with NTIA on the 10-year “Plan and Timetable to Make  Available 500 Megahertz of Spectrum for Wireless Broadband” and  the “Assessment of the Near-Term Viability of Accommodating  Wireless Broadband Systems in the 1675-1710 MHz, 1755-1780  MHz, 3500-3650 MHz, and 4200-4220 MHz, 4380-4400 MHz Bands”  (also referred to as the “Fast Track Evaluation”), both of which NTIA  issued in November 2010.    FCC officials told us that the Commission intends to take further steps  to implement this recommendation, in consultation with NTIA as  appropriate, after NTIA completes its assessment of the suitability of  the 1755-1850 MHz band for repurposing.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (very satisfied)
1755 to 1850 MHz is critically important to the commercial  wireless sector. Steps should be taken as soon as possible to  begin moving in that direction.
Expert (somewhat  satisfied)
AWS-3 pairing in the hands of executive branch. Makes sense  to hold off on AWS-2.
Infrastructure provider  (somewhat satisfied)
Kudos to the FCC for pressing ahead. NTIA has known for a  while how important this spectrum is, and clearly wanted to  avoid having to move federal users, some of whom would be  moved for the second time. Without legislative improvements  in federal relocation process, moving users is difficult.
Mobile Satellite  Services company  (neither satisfied nor  dissatisfied)
Significant interference issues and  into adjacent  bands must be considered to effectively integrate the AWS-2 J  block with the 2GHz MSS band.
Public interest group  (strongly dissatisfied)
Nothing meaningful has been implemented.
Wireless device  manufacturer (neither  satisfied nor  dissatisfied)
The holdup is NTIA to allow pairing of  1755-1780 [MHz  band] with FCC’s AWS-3 band.
Wireless device  manufacturer  (somewhat dissatisfied)
NTIA manages spectrum the same way they did 20 years ago.  … hey protect the status quo.
Type of commenter  (level of satisfaction)  Comment excerpts  Wireless service  provider (somewhat  satisfied)
Good progress at discussion level but execution and timing will  be critical.
Wireless service  provider (somewhat  dissatisfied)
Need quicker review and reallocation of the 1755-1850 MHz  band.
Wireless service  provider (strongly  dissatisfied)
Progress has not been rapid enough to meet the near-term  needs of regional and local commercial providers for additional  mobile broadband spectrum.
section_title: Make Wireless Communications Services Spectrum Available (20 MHz)
subsections: section_title: Recommendation
paragraphs: FCC should make 20 megahertz available for mobile broadband use in  the 2.3 GHz Wireless Communications Service band, while protecting  neighboring federal, nonfederal Aeronautical Mobile Telemetry and  satellite radio operations.
Since FCC first auctioned Wireless Communications Service spectrum in  1997, a number of new and robust wireless telecommunications  technologies have been successfully introduced. Such technologies,  coupled with the exploding demand for broadband services, suggest that  the Wireless Communications Service spectrum may provide fertile  ground for the provision of high-value mobile broadband services to the  public. In order to realize this potential FCC needs to revise outdated  rules intended to protect against interference from use of the spectrum.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (somewhat  agree)
Comment excerpts   should have been 25-30 Megahertz …  rather than just 20 megahertz.
Expert (somewhat  disagree)
The 2.3GHz band offers a lot of potential for mass market  services. … the mass market will provide more than enough  economic incentive to reallocate incumbent systems.
Wireless device  manufacturer (strongly  disagree)
Aligning this band with global allocation for mobile   was the right thing to do. However, the imposed duty-cycles on  the technologies to operate in this band negatively impact the  business case because the rules do not allow the right ratio of  downlink to uplink when using . Also  there are issues with the stringent  and  power limits.
Wireless device  manufacturer  (somewhat disagree)
This spectrum should be made available for mobile broadband,  and while neighbors should be protected the FCC should not  go further than absolutely necessary or else risk diminishing  the value of this 20 megahertz.
Wireless service  provider (strongly  agree)
At least 25 Megahertz should be made available for mobile  broadband under technology-neutral rules, and neighboring  services should be protected to appropriate (but not excessive)  levels.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In May 2010, FCC adopted rules that will make available 25 MHz of  spectrum for mobile broadband service in much of the United States,  while protecting adjacent satellite radio and aeronautical mobile telemetry  operations.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (neither satisfied  nor dissatisfied)
Processes to accomplish this take a long time and nothing has  been done to change that. … the amount of spectrum is  infinitesimal in the context of the demand.
Expert (somewhat  dissatisfied)
Too slow.
Expert (strongly  dissatisfied)
Spectrum is not available for broadband use because FCC has  not completed rules or addressed licensing issues.
Mobile Satellite  Services company  (somewhat dissatisfied)
Absence of consensus by WCS and [satellite digital audio  radio] licensees negates the effectiveness of FCC decision on  technical rules.
Public interest group  (strongly dissatisfied)
The FCC has still not implemented anything meaningful.
Wireless device  manufacturer (neither  satisfied nor  dissatisfied)
Too early to determine whether rules will result in effective  deployment of mobile broadband in this spectrum.
Wireless service  provider (somewhat  dissatisfied)
Petitions for reconsideration filed in this proceeding raise  questions about whether the band can actually be used to  provide mobile broadband service.
Type of commenter  (level of satisfaction)  Comment excerpts  Wireless service  provider (somewhat  dissatisfied)
The FCC could have been more aggressive by placing more of  the burden on SDARS.
Wireless service  provider (somewhat  dissatisfied)
While FCC’s May 2010 decision was a useful first step,  petitions for reconsideration filed by WCS interests illustrate  material flaws in technical rules and performance requirements  that jeopardize the prospects for the band actually being used  for the offering of broadband services to the public.
section_title: Auction the Upper 700 MHz D Block (10 MHz)
subsections: section_title: Recommendation
paragraphs: FCC should auction the 10 MHz Upper 700 MHz D Block for commercial  use that is technically compatible with public safety broadband services.
To realize the high potential value that FCC believes the 10 MHz Upper  700 MHz D Block has for commercial broadband while supporting the  simultaneous development of public safety broadband capability through  equipment development, roaming, and priority access.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  disagree)
Comment excerpts  The past has proven that auctioning the spectrum for  public/private use is not workable. If the FCC intends to pursue  this type of mixed use it needs to adopt rules to incentivize not  discourage bidding and such mixed use.
Expert (strongly agree)  Long overdue is the approach to make a commercial system  that can serve emergency needs but that is viable in normal  times. The FCC should set a low auction minimum for this  service since it is more risky for the commercial operator but  the public safety requirement is crucial.
Expert (somewhat  disagree)
Congress has not adequately addressed public safety for the  past 10 years. FCC is trying to solve on its own, and it does  not have either the authority or the resources adequately to do  so.
Expert (strongly agree)  The original premise of the D-Block for the 2008 auction was  sound. The lack of definition in the interaction with public  safety entities created uncertainty and thus made the auction  not viable. Define the rules and interactions explicitly and this  can work.
Expert (somewhat  agree)
This 10 Megahertz and the public safety aspect are well  informed and have the potential to support the public interest.  Watch out for the “Motorola-ization” of this band where  hardware providers manipulate the 3,000 local government  entities into spending way too much on hardware. This stuff  should be available at BestBuy, not from Motorola, Johnson, or  whoever. That will happen if the usage is liberalized and low  power (femtocell class) devices are allowed (e.g., per police  car and fire truck) as well as by homeowners. First responders  should have a code that allows them to use the bandwidth,  basically unnoticed by home owners, of the Internet access  points when there is a police, fire, or rescue operation within  radio distance of the home. This could be done securely.
Infrastructure provider  (neither agree nor  disagree)
The FCC doesn’t control this—Congress does and Congress  needs to decide what to do: whether to combine with public  safety spectrum.
Public interest group  (strongly disagree)
A single-use national public safety network will simply not  work. It is impossible to build a network to the level of  robustness required for anything less than a half-trillion dollars.  Thus, this entire endeavor is destined for failure and should be  ceased before we spend additional public funding for  something that will simply not work. We should concentrate  instead on building mixed-use communications infrastructure  with a public safety priority during declared emergencies.
Wireless device  manufacturer (strongly  disagree)
Give this to public safety at local county level and let them put  it to use in their own way and their cost and structure.
Type of commenter  (level of agreement)
Wireless service  provider (somewhat  agree)
Comment excerpts  While we believe that the presence of additional commercial  competitors in the 700MHz spectrum would help to break the  stranglehold AT&T and Verizon currently have over device and  equipment development in that spectrum, an auction of the D- block without an assurance of interoperability would do little to  benefit the public interest. Device interoperability is necessary  to bring the benefits of scale to the 700 MHz market: reducing  the costs of consumer and public safety devices, as well as  enabling roaming across networks by both consumers and  public safety.
Wireless service  provider (strongly  agree)
The right thing to do, but a lost cause. Reallocation to public  safety is more likely at this point. Our concerns assuming  reallocation then go to interoperability and fair commercial  opportunity to be part of partnerships and solutions — rather  than see the D Block go by default to partnerships with the  Twin Bells.
Wireless service  provider (strongly  disagree)
Public safety needs 20 MHz to deploy an efficient LTE  network.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In May 2010, FCC issued the results of its analysis indicating that a  stand-alone public safety network would be substantially more  expensive than a network constructed under an incentive-based  partnership approach, under which public safety network operators  would partner with commercial operators or systems integrators to  construct and operate the network using the 10 MHz of dedicated  spectrum currently allocated to public safety.
In June 2010, FCC issued a paper concluding that the 10 MHz of  dedicated spectrum currently allocated to public safety will provide the  capacity and performance necessary for day-to-day communications  and serious emergency situations; that dedicating the 10 MHz Upper  700 MHz D Block for public safety, or even 30 MHz, may not be  sufficient to support public safety broadband communications in a  major emergency; and that instead public safety should be given  priority access and roaming capability across the commercial  broadband wireless spectrum. FCC said that such access will make at  least 50 or 60 MHz of additional spectrum immediately available.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (somewhat  dissatisfied)
The FCC is concluding that the peak use of public safety  operations may be many orders of magnitude greater than  normal use. This conclusion indicates that allocations should  be commensurate with normal use and policy should address  access for peak use.
Expert (strongly  dissatisfied)
This approach is excellent but practical implementation will  take much planning, negotiation, and governmental vision. little  of this has yet to be done.
Broadcaster (neither  satisfied nor  dissatisfied)
A stand-alone public safety network will be much more  expensive initially and over the life of the system. It will also be  prone to technical deficiencies as technology evolves. A  priority access approach makes much more sense.
Wireless device  manufacturer  (somewhat satisfied)
The debate in Congress on whether the spectrum should be  auction or reallocated has create uncertainty in the FCC to  take action on this band.
Wireless service  provider (strongly  dissatisfied)
FCC was correct; but 5.8.2 is dead. FCC missed opportunity to  start rulemaking proceedings a year ago for D Block auction.  FCC has been marginalized and is no longer a player on this  issue. So 5.8.2 is no longer relevant.
Wireless service  provider (strongly  dissatisfied)
The FCC has completely failed to follow its own National  Broadband Plan and federal statute to commercially auction  this vital block of spectrum.
section_title: National Broadband Plan Recommendations Aimed at Expanding Incentives and Mechanisms to Reallocate Spectrum
subsections: section_title: Grant FCC Authority to Conduct Incentive Auctions
subsections: section_title: Recommendation
paragraphs: Congress should consider expressly expanding FCC’s authority to enable  it to conduct incentive auctions in which incumbent licensees may  relinquish rights in spectrum assignments to other parties or to FCC.
To motivate existing spectrum licensees to voluntarily give up their  licenses so that FCC could more quickly reallocate the spectrum to higher  valued services.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)
Comment excerpts  Incentive auctions will give the FCC the ability to repurpose  spectrum from inefficient service-specific allocations to more  flexibile allocations in an efficient manner.
Expert (strongly agree)  Congress should simply grant the FCC the ability to pay some  of the revenues to broadcasters instead of the Treasury and  avoid legislating any details of the auction.
Expert (strongly  disagree)
Receipts from government auctions should go to the  government. The FCC is not an consignment auction house  auctioning the assets of third parties like Christies or  Southebys.
Broadcaster (neither  agree nor disagree)
VOLUNTARY auctions may be acceptable so long as resulting  repacking costs of remaining users are guaranteed.
Broadcaster (neither  agree nor disagree)
If Congress authorizes incentive auctions, it should make clear  that the Commission must not take any actions in its  implementation that could harm existing licensees (e.g.,  involuntary repacking into VHF band, loss of coverage areas  and/or increased interference).
Broadcaster (strongly  disagree)
The FCC should allow licensees to sell or lease to mobile  operators directly and immediately.
Infrastructure provider  (strongly agree)
A voluntary incentive auction is a market-based mechanism  that will allow spectrum to be transitioned from one use to a  new use, and should take years off the current process.
Public interest group  (strongly disagree) … Incentive auctions will dramatically increase spectrum  hoarding and make further band clearing far more difficult.
Wireless device  manufacturer (strongly  disagree) (FCC) should force and recover spectrum from those who  have not used what they have before going after spectrum  used by broadcasters and recent (television) white spaces  rulings. (This would) actually (take) away from new innovative  spectrum use.
Wireless service  provider (strongly  agree)
The primary reason spectrum identification and reallocation  takes so long is political pressure from incumbents. Incentive  auctions would reduce this pressure and allow the government  to move more quickly.
Wireless service  provider (somewhat  agree)
OK to have as another tool in the spectrum management  toolbox, but very uncertain how effective it will be in bringing  commerically valuable amounts of spectrum to market to  support wireless broadband.
section_title: Grant FCC Authority to Impose Fees on Licensees
subsections: section_title: Recommendation
paragraphs: Congress should consider granting authority to the FCC to impose  spectrum fees on license holders.
Fees may help to free spectrum for new uses with potentially higher value  than current uses, since licensees who use spectrum inefficiently may  reduce their holdings once they bear the opportunity cost of spectrum.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)  The value of spectrum is far greater, in most cases, than is  recovered in auctions. Spectrum fees can be based on the  appreciating value of spectrum.
Expert (strongly agree)  Spectrum fees are a critical market-based mechanism used in  the UK to ensure that government spectrum is used efficient  or repurposed for commercial use. US should do the same.
Type of commenter  (level of agreement)
Expert (strongly agree)  Without the ability to impact the bottom line, the FCC is less  effective than otherwise. However if the incumbents write the  legislation as is the current practice, it will come out that the  FCC will have the power to fine the little guys and the big guys  will have many loopholes and time wasters. If, however, the  FCC were to work with the NTIA, DOD, and DHS regarding  criteria for imposing fees so that the FCC could shape the  behavior of the huge incumbents in a meaningful way without  accidentally or unfairly penalizing the smaller entrepreneurs,  then the public interest would be served.
Expert (strongly agree)
It is ridiculous to give some spectrum away and charge for  others. It is equally ridiculous to have a one time payment that  provides rights into perpetuity.
Expert (somewhat  agree)
Only if the FCC cannot grant flexible rights whereby the licensees  realizes the opportunity cost of the spectrum it uses … or the  licensee is in a shared band, then fees are one tool to provide  more accurate price signals about the cost of using the spectrum.
Expert (strongly  disagree)
Spectrum fees on private parties do not create incentives for  efficiency. At best (worst?) a fee that makes a particular  license unprofitable will result in the license going back to the  government — that does not create value, but reduces output.  The way to create value is to allow competitive forces wider  scope, permitting the licensee to deploy any service,  technology, or business model that may be profitable.
Broadcaster (strongly  disagree)
Payment is already made in the context of required public  interest responsibilities of broadcasters.
Broadcaster (strongly  disagree)
Broadcasters already pay for their spectrum in the form of  public interest obligations that exceed those for any other  privately-held spectrum. Congress should recognize the public  value of these obligations and the cost to broadcasters of  complying with them.
Broadcaster (strongly  disagree)
Broadcasters already pay enormous “regulatory fees” and  absorb regulatory costs not imposed on others.
Broadcaster (strongly  disagree)
The FCC already collects annual regulatory fees. Moreover,  there is no elaboration of how such fees would be assessed or  for what purpose such collected fees would be used. Further  any use of spectrum fees to encourage licensees to give up  their spectrum for other purposes disserves the public interest.
Broadcaster (somewhat  disagree)
We disagree in terms of applying fees to spectrum holders that  are actively using their spectrum for the intended purpose.  These fees should *only* be applied to license holders that are  squatting or allowing their spectrum to sit unused.
Public interest group  (strongly agree)
Yearly spectrum fees will increase spectrum utilization and  incent license holders who do not use their bands to return  them. Furthermore, over time, yearly license fees raise far  more money for the public treasury than one-off auctions and  are thus a superior and more fiscally responsible choice.
Type of commenter  (level of agreement)
Mobile Satellite  Services company  (strongly agree)
Comment excerpts  Spectrum fees are preferable to auctions or any other  regulatory method for ensuring that spectrum is used  reasonably efficiently. There never would have been auctions  if the broadcast industry was not unalterably opposed to  spectrum fees in the 1980s.
Satellite radio service  provider (somewhat  agree)
Spectrum fees should be tied to how a licensee acquired its  spectrum. Licensees that paid fair market price through an  auction should pay less in usage fees than those licensees in  bands that initially acquired licenses through means other than  auctions.
Infrastructure provider  (neither agree nor  disagree)
No clear economic evidence that fees leads to more efficiency.  So if the goals is improved spectrum policy, this would fail to  support the goal.
Wireless device  manufacturer  (somewhat agree)
However, such fees should not be imposed on licensees that  obtained their spectrum license through competitive bidding  mechanisms.
Wireless service  provider (strongly  agree)
This assumes these fees are for either non-auctioned  spectrum and/or spectrum that is not licensed for flexible use.
Wireless service  provider (somewhat  disagree)
If already paid for spectrum in an auction, then no. Ultimately  increases prices to consumers.
section_title: Address Barriers to Secondary Markets
subsections: section_title: Recommendation
paragraphs: FCC should evaluate the effectiveness of its secondary markets policies  and rules to promote access to unused and underutilized spectrum.
FCC believes that the performance of secondary markets under the  Commission’s current policies has been mixed and is concerned that  unused or underutilized spectrum is possibly not be being made available  to smaller providers, especially in rural areas where spectrum goes  unused.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (strongly  agree)
Comment excerpts  The FCC should update and revise its secondary markets  policy to include all spectrum to allow all current licensees to  participate in a secondary market so long as their primary  spectrum uses remain intact. This will allow market forces to  determine the best use for spectrum without requiring  wholesale reallocation of designated bands for other purposes.
Expert (strongly agree)  A reasonable suggestion that obviates the need for incentive  auctions.
Expert (strongly agree)  FCC has been doing a good job, but should consider a legislation  to form a private public interest company or FFRDC to create the  secondary spectrum databases and to assist and support  spectrum use. The German Fraunhofer model requires 1/3  industry funding, and that is a good model for responsiveness to  industry (vs. the US FFRDC model which has little such  incentives)
Expert (strongly  disagree)
Type of commenter  (level of agreement)
Comment excerpts  (roaming agreements), and they frequently buy/sell licenses. But  once they construct a network to use particular airwaves, they find  it inefficient to split off spectrum rights and lease them to other  networks. This reflects efficiency; the premise of the “do more for  secondary markets” policy is that such markets are failing. But  they are not; they work in a matter that is often misunderstood.
Infrastructure provider  (somewhat agree)
The FCC’s policies here are good, and are being used, but  further evaluation is helpful.
Public interest group  (neither agree nor  disagree) needs to avoid creating transaction costs that  undermine the utility of secondary markets.
Mobile Satellite  Services company  (strongly agree)
All secondary market tools - spectrum leasing, partitioning,  disaggregating, etc, should be available to all licensed wireless  services, including satellite.
Wireless device  manufacturer (strongly  agree)
Wireless device  manufacturer (strongly  agree)
FCC should … expand the applicability of secondary markets  policies to all spectrum-based services and bands. While it has  proposed this for certain mobile satellite bands, FCC (and  NTIA) should also apply the same leasing policies and  procedures (including the notion of “private commons”) to the  broadcasting, other satellite and Federal bands. It should also  lift restrictions on shared channels in the private land mobile  radio … bands below 512 MHz in connection with the 10- channel limitation and leasing restrictions.
Wireless service  provider (somewhat  agree)
It is not secondary markets policies that are the problem. They  work well with carriers that want to make spectrum available.  Problem is warehousing by carriers attempting to keep  spectrum from competitors. Not a secondary markets problem,  but an FCC enforcement problem.
Wireless service  provider (somewhat  agree)
While in general there are mechanisms that facilitate  secondary market transactions, the FCC should create greater  incentives for license holders that are not using their spectrum  to sell/lease it to entities that will.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: FCC officials told us that the Commission conducted an internal review of  its secondary markets policies that concluded that it should do more to  promote secondary markets. Toward that end, in November 2010, FCC  issued a Notice of Inquiry on dynamic spectrum access technologies that  have the potential to enable sharing of spectrum in common locations,  including how such technologies could facilitate secondary markets. In  January 2011 FCC officials told us that the Commission was assessing  the input it received in response to that inquiry, and that it intended to  issue a related order, tentatively by the end of calendar year 2011.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (somewhat  satisfied)
Expert (neither satisfied  nor dissatisfied)
Expert (somewhat  dissatisfied)
Broadcaster (strongly  dissatisfied)
This efforts needs a definition of what DSA must meet as  potential for interference. Without a definition of “harmful”, it  will be hard to deploy any DSA.  No evidence that dynamic spectrum access technologies would  promote secondary markets. On the other hand, removing any  barriers that arbitrarily block dynamic access technologies would  be good even if it had no effect on secondary markets.  FCC’s slowness in Docket 04-186 shows its ambivalence in  this area. This is a very technical area and FCC as presently  structured doesn’t deal well with such issues.   analysis must include broadcast spectrum to be  credible and effective.
Infrastructure provider  (neither satisfied nor  dissatisfied)
Dynamic spectrum access is  very early days and will  probably not be important for years.
Wireless service provider  (neither satisfied nor  dissatisfied)
FCC policies on dynamic sharing may do more harm than  good. More testing regarding the potential for interference and  the economic case is necessary before making any decisions.
Wireless service  provider (somewhat  dissatisfied)
Type of commenter  (level of satisfaction)  Comment excerpts  provider (somewhat  dissatisfied)
Type of commenter  (level of satisfaction)  Comment excerpts  establish “squatter’s rights” (with a later right to a  partitioned/disaggregated license where they are serving  customers) on unused spectrum in limited identified areas,  and only if the licensee has not agreed to contribute the  spectrum for leasing,might incentivize greater leasing.  Streamline current spectrum leasing rules — The FCC  could eliminate unnecessary spectrum manager lease  filings (arguably no filings should be necessary for short- term spectrum manager leases, and only a notification filing  for long-term spectrum manager leases when they begin  and end); eliminate lease renewal filings; act on all long- term de facto transfer leases within 21 or 15 days, etc.
Wireless service  provider (strongly  dissatisfied)
It should not take one year to assess the input obtained from  the Dynamic Spectrum Access NPRM.
section_title: National Broadband Plan Recommendations Aimed at Expanding Opportunities for Innovative Spectrum Access Models
subsections: section_title: Provide Spectrum for Unlicensed Use
subsections: section_title: Recommendation
paragraphs: FCC, within the next 10 years, should free up a new, contiguous  nationwide band for unlicensed use.
To enable innovators to try new ideas to increase spectrum access and  efficiency through unlicensed means and to enable new unlicensed  providers to serve rural and unserved communities.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (strongly agree)  No amount of licensed spectrum will ever satisfy the future  demand for rich wireless media, so the FCC needs to ensure  that wireless carriers and others have access to enough  licensed spectrum for many more wi-fi access points to  move wireless traffic onto the wired network at the earliest  opportunity in the transmission session.
Expert (strongly agree)  essential to promoting competition and innovation in wireless  Expert (neither agree  nor disagree) … the success of unlicensed systems depends on global  coordination and therefore allocations in the US alone will not  achieve the necessary dividends.
Expert (somewhat  disagree)
There is an opportunity cost to making unlicensed spectrum  available and it may not be the most efficient use of spectrum  — there should be a price tag put on this so that people realize  the oppotunity cast and potential inefficiency of allocating more  spectrum for unlicensed use.
Expert (strongly  disagree)
Contiguity no longer is needed because of the emergence of  affordable devices where, say a 2 GHz device can operate  effectively and affordably between 1.3 and 2.3 GHz (and  similarly in other bands). Unlicensed chunks in different parts  of the spectrum can be effectively hybridized via  heterogeneous spectrum management, promoting market  entry of new small to medium product suppliers. FCC should  assist the market in using  on-line database like for   so that unlicensed devices can learn  about available spectrum and use it dynamically versus  clearing a new band for unlicensed use. A 60 MHz band  around 1 GHz in bandwidth for indoor use would be a  significant contribution to the development of unlicensed  markets.
Type of commenter  (level of agreement)
Broadcaster (somewhat  disagree)
Comment excerpts  Strict interference protection standards will be crucial in any  such initiative.
Infrastructure provider  (strongly agree)
Where spectrum is sorely needed is to support Wi Fi  technologies at 5 GHz. An increased footprint of “shared”  spectrum is required to meet future needs and support next  generation Wi Fi technologies.
Mobile Satellite  Services company  (somewhat disagree)
There is already plenty of spectrum available for unlicensed  use. This is a low priority.
Wireless device  manufacturer  (somewhat agree)
There is substantial amount of unlicensed spectrum that has  been recently allotted which remains vacant. After this  spectrum has systems, more spectrum may need to be made  available.
Wireless service  provider (strongly  agree) … an appropriate amount of unlicensed spectrum should be  made available that is dedicated exclusively to unlicensed  outdoor fixed wireless broadband delivery and NOT shared  with consumer-type (i.e., Wi-Fi) devices.
Wireless service  provider (somewhat  disagree)
Spectrum is not an unlimited resource. Priority should be given  to reallocation of available spectrum subject to auction under  exclusive licensing.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: FCC intends to consider making additional spectrum available for  unlicensed use in conjunction with NTIA’s “Plan and Timetable to Make  Available 500 Megahertz of Spectrum for Wireless Broadband,” which  addresses both licensed and unlicensed uses.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (somewhat  dissatisfied)
Too slow.
Infrastructure provider  (somewhat dissatisfied)
The FCC’s focus has been white spaces, which provides 6  MHz channels and will never be a global footprint (other  countries have different channelization for TV). The FCC has  not proposed, for example, opening up more spectrum at 5  GHz for shared use.
Public interest group  (strongly dissatisfied)
There has been no meaningful progress on this  recommendation. Currently, unlicensed is an afterthought in  both planning the by FCC and the Obama administration ….  Given the success of unlicensed in dramatically increasing the  public’s access to the public airwaves, it should be the priority;  spectrum auctions to corporations rich enough to buy exclusive  use to the public airwaves should be secondary.
Wireless service  provider (somewhat  dissatisfied)
We believe that creating a new nationwide unlicensed band  will result in very substantial economic benefits for the nation  as a whole. For this reason, we support rapid action FCC to  create this band. 10 years is too long to wait. We would like to  see this band created within the next 2 to 3 years.
section_title: Issue Rules on Television White Spaces
subsections: section_title: Recommendation
paragraphs: FCC should move expeditiously to conclude the television white spaces  proceeding.
To accelerate the introduction of new innovative products and services  that would use the television white spaces.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Expert (somewhat  agree)
Comment excerpts  The database aspect is inviting abuses, many unintentional.  When people measure spectrum use, patterns appear, some  of which compromise law enforcement, privacy, etc. Thus, the   should not be public but should be administered by  a public trust corporation with security clearances that will  redact information that compromises the public interest such  as law enforcement, personal privacy, etc.
Expert (strongly  disagree)
TV white spaces proceeding moves in the wrong direction;  more efficient to reorganize spectrum in each market and  auction off unlicensed spectrum rather than white spaces.
Expert (strongly  disagree)
The conclusion of the white spaces could impact other  spectrum decisions, including the incentive auctions and  repacking and it can be very hard to undo unlicensed uses.
Broadcaster (neither  agree nor disagree)
The FCC must have adequate rules for the database  administrators to ensure accuracy and avoid unnecessary  interference.
Broadcaster (somewhat  disagree)
The FCC should move only as expeditiously as it can based on  sound engineering and spectrum principles. The FCC must  ensure its rules for white space use fully protect incumbent  users and do not cause interference to viewers.
Wireless service  provider (somewhat  disagree)
The FCC needs to ensure that actions it takes do not create  potential future issues with additional TV spectrum identified  for reallocation to mobile broadband use.
Wireless service  provider (strongly  disagree) … Too much interference risk. …  should allow this good  propagation spectrum to be used for broadband backhaul.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In September 2010, FCC issued an opinion and order that: (1)  eliminates the requirement that television bands devices that  incorporate geo-location and database access must also include  sensing technology to detect the signals of television stations and low- power auxiliary service stations (wireless microphones); (2) requires  wireless microphone users who seek to register in the television  bands databases to certify that they will use all available channels  from 7 through 51 prior to requesting registration; and (3) reserves  two vacant UHF channels for wireless microphones and other low  power auxiliary service devices in all areas of the country while  maintaining a reasonable separation distance between television  white space devices and wireless microphone usage.
In January 2011, FCC conditionally designated nine companies to  develop and administer the databases that new unlicensed wireless  devices would use to identify available channels.    FCC conducted three workshops with the database administrators,  one each in March, April, and May 2011. The workshops covered  development, security, and testing of the databases. FCC plans to  hold additional workshops towards final approval of the database  administrators.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Public interest group  (somewhat satisfied)
The process has taken longer than it could have, I believe.
Public interest group  (strongly dissatisfied)
The FCC’s current plan is to kill off the utility of TV white space  technologies … y auctioning off these bands to the highest  bidder .
Wireless device  manufacturer (very  satisfied)
This is perhaps the only segment in wireless we are actually  leading the world. More resource should be applied to this  endeavor to make improvements. Next Gen Wi Fi....
Wireless device  manufacturer  (somewhat satisfied)
The removal of the sensing requirement is somewhat troubling  because it was deemed essential in the sharing of spectrum.  As the FCC continues to support sharing in other bands, it is  troubling, that the FCC may define sharing based on  technology that is unsuitable or unavailable commercially.
section_title: Spur Opportunistic Uses of Spectrum
subsections: section_title: Recommendation
paragraphs: FCC should spur further development and deployment of opportunistic  uses across more radio spectrum.
To significantly increase the efficiency of spectrum utilization by enabling  radios to access and share available spectrum dynamically.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (strongly  disagree)
Comment excerpts  The FCC must protect the integrity of existing services while  encouraging innovation. The FCC should free incumbent  licensees from technical restrictions that hinder such  innovation.
Expert (strongly agree)  But opportunistic uses should be prioritzed based upon  intelligent technical analysis, i.e., a spectrum technology road  map.
Expert (strongly  disagree)
This is precisely the sort of thing that regulators should not do.  They should focus on something distinct: creating rules that  yield optimal incentives for competitive processes to create  efficient solutions.
Expert (strongly  disagree)
Expert (somewhat  disagree) , FCC should adopt  policies that facilitate agreements among private parties.
Type of commenter  (level of agreement)
Mobile Satellite  Services company  (somewhat disagree)
Comment excerpts  If the FCC does this, there will be more interference  complaints. The FCC has to commit to devote resources to  investigating and resolving interference complaints quickly.
Wireless device  manufacturer  (somewhat agree)
Cognitive radio is promising; however generally speaking the  technology needs further development before appropriate for  many bands; in any event, should be commercially driven not  as a regulatory mandate.
Wireless device  manufacturer (strongly  agree)
It is great that the … NBP recognized that “pportunistic  sharing arrangements offer great potential to meet increasing  market demand for wireless services by promoting more  efficient use of radio spectrum.”  is  absolutely correct in stating that “‘opportunistic’” or ‘cognitive’  technologies can significantly increase the efficiency of  spectrum utilization by enabling radios to access and share  available spectrum dynamically.” However, this  recommendation over-emphasized the unproven and  inefficient database approach to advanced sharing and  disregarded spectrum sensing (detect-and-avoid) and hybrid  sensing/geolocation approaches. The FCC’s preference for  geolocation approaches is apparently based on its lack of  information regarding spectrum sensing, its decision in the TV  White Spaces proceeding to eliminate the sensing requirement  and recent enforcement issues (unrelated to sensing  capabilities) in the 5 GHz U-UNII band in which sensing is  required to share with radar operations. Hopefully, the record  developed in the FCC’s DSA NOI proceeding (ET Docket No.  10-237) and NTIA’s spectrum sharing test bed should provide  additional information on sensing.
Wireless service  provider (somewhat  agree)
We support … dynamic spectrum access … shared and  secondary market access to spectrum capacity but would  strongly oppose FCC adoption of rules or policies which  diminish the rights of the licensees of exclusive spectrum  purchased at auction to control and/or to exclude access to  their spectrum.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In November 2010, FCC issued a Notice of Inquiry seeking comment on  how dynamic spectrum access radios and techniques can promote more  intensive and efficient use of the radio spectrum.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Private user group  (somewhat satisfied)
This direction holds some promise as long as the inherent  limitations of dynamic spectrum access techniques are taken  into account and are not relied upon inappropriately.
Wireless device  manufacturer (strongly  dissatisfied)
DSA has a place in providing communications solutions  however there is a concern that the FCC is unaware of the  state of technology and how it operates to provide solutions.  So mandating solutions may delay the usage of the bands  considered for DSA.
Wireless service  provider (strongly  dissatisfied)
Additional study is needed as dynamic spectrum access radios  technologies have not been proven yet.
section_title: Enhance Research and Development on Spectrum Access
subsections: section_title: Recommendation
paragraphs: FCC should initiate proceedings to enhance research and development  that will advance the science of spectrum access.
A robust research and development pipeline is essential to ensuring that  spectrum access technologies continue to evolve and improve.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  agree)
Comment excerpts  While it is good to stimulate research and development, the  FCC should not assume that government should direct the  effort.
Expert (strongly  disagree)
There is no need for government efforts to “enhance” R&D in  this area. Substantial efforts already in place.
Expert (somewhat  agree)
Not clear what role there is that isn’t already met by private  sector; eliminating barriers would be good.
Mobile Satellite  Services company  (strongly disagree)
Spectrum shortages have provided enough incentive for  licensees to spend their funds on research and development of  ways to use spectrum more intensively. The government does  not have to be involved in this. It will only stifle development.
Wireless service  provider (somewhat  disagree)
If guidelines were in place that assured a competitive  marketplace among wireless carriers of various sizes and new  entrants, then competitive carriers and new entrants would  accomplish this innovation in the marketplace. Such grant- funded innovation becomes necessary when there is a lack of  competition within the market.
Wireless service  provider (strongly  agree)
The FCC should leverage work that is currently being done  both in private industry … or by academic institutions ….
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In November 2010, FCC issued an NPRM that seeks to expand the  Commission’s existing Experimental Radio Service rules to promote  cutting-edge research and foster development of new wireless  technologies, devices, and applications. Specifically, FCC proposed a  new type of license, called a “program license,” which would give qualified  entities broad authority to conduct research without the need to seek new  approval for each individual experiment.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Expert (strongly  dissatisfied)
This NPRM is mostly PR. In reality big firms … already have  the equivalent of a “program license.”
Private user group  (somewhat dissatisfied)
The existing Experimental Radio Service rules do not bar  progress but should be strengthened to ensure that licensees  are aware of experimental operations that may cause harmful  interference to them.
Wireless device  manufacturer (neither  satisfied nor  dissatisfied)
A lot of questions remain, including the scope of eligible  entities — the private sector should not be excluded.
Wireless service  provider (somewhat  dissatisfied)
The FCC proposed to exclude non-public entities under  blanket licenses. For the type of experimental license available  to commercial entities, it was stated the licenses are not  intended for commercial campuses. No explanation for either  of these arbitrary exclusions were provided in the NPRM.  Further, the FCC proposes to shift the burden of discovering  potential interference to the existing licensee, which will  discourage experimental use.
section_title: National Broadband Plan Recommendations Aimed at Enhancing FCC’s Spectrum Policymaking
subsections: section_title: Measure Spectrum Utilization
subsections: section_title: Recommendation
paragraphs: FCC and NTIA should create methods for ongoing measurement of  spectrum utilization.
To provide policymakers and the public with important information on  how, where, and when spectrum is being used.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (strongly  agree)
Comment excerpts  This should be an objective measurement, not subjective  based upon content in the use.
Broadcaster (somewhat  agree)
The FCC and NTIA should complete a comprehensive  inventory of how spectrum is currently allocated, who is using  it, and how it is being used before proceeding with any steps  related to spectrum reallocation.
Broadcaster (strongly  disagree)
Measurement is not an effective means of finding unused  spectrum.
Broadcaster (strongly  agree)
Without identified and peer reviewed methods there is no  certainty that any measurement of spectrum utilization  measurement will be accurate or will provide the information  the agency needs to evaluate how spectrum is currently being  used.
Expert (strongly agree)  Use does not necessarily equate to active transmissions.
Expert (strongly agree)  Spectrum utilization has been on on-going and contentious  issue. Without specific information the arguments become very  subjective. Understanding how this resource is being used  would provide significant insights PRIOR to making new policy  decisions. It appears that many policy decisions are not based  upon the technical facts but more on subjective analysis.
Expert (strongly agree)  The data is measured by licensees to manage their own  bands, so FCC could require reporting vs “measuring” per se  or to complement and validate measurements.
Expert (neither agree  nor disagree)
It’s a good idea in principle, but it’s not clear how to  meaningfully define “spectrum utilization.”
Expert (strongly agree)  Target towards bands with likely usage issues; not cellular,  broadcast.
Infrastructure provider  (strongly disagree)
If by “spectrum utilization” the meaning is to measure how RF  emissions are being used to transport information, the  recommendation would yield an outcome that is meaningless  from a policy perspective. “Use” of the spectrum depends on  the service, and if commercial, whether the licensee has  placed the spectrum into service. There might be a few bands  where this type of analysis is helpful, but this should not be the  way forward for spectrum policy. Rather, the way forward is to  understand the technologies under development, their  spectrum requirements and capabilities, likely use  cases/demand, and expectations for innovation (how will the  technology change over time). This is knowable from  standards bodies and the vendor community.
Private user group  (somewhat agree)
Meaningful spectrum utilization measurement is very difficult.  Examples: How does one measure the spectrum utilization of  passive radioastronomy? There may not be many  transmissions on a distress and calling frequency, but this  does not mean it can be made available for other uses in  between. Typical spectrum monitoring will not detect utilization  by services that habitually use low signal levels such as the  amateur radio service.
Type of commenter  (level of agreement)
Public interest group  (strongly agree)
Comment excerpts  NTIA and FCC spectrum utilization records should include  allocation information, assignment information, and actual use  measurements from the field and at a level of granularity  allowing informed decisions at the local (census block) level.
Satellite radio service  provider (somewhat  agree)
Spectrum utilization is rarely a binary question of whether  spectrum is or is not being “used” by having transmissions in  the spectrum. For example, in order for spectrum to be  “utilized,” it should be used in a meaningful way to serve the  public or the intended government/business use; this is far  different from just testing whether signal is being transmitted to  preserve the license, as can be the case with wireless  spectrum. In the public safety context, spectrum can be used if  it is unused but available for use during the next public  emergency. In the context of broadcast spectrum, the question  of whether spectrum is being used might even consider  whether the station is being operated in a manner that serves  the public interest.
Mobile Satellite  Services company  (strongly disagree) … This is impossible without drastically increasing the number  of government employees and the number of regulated  company employees who would have to monitor and report.  This cannot be done in any reasonably efficient manner. There  would never be agreement on what to measure and how.
Wireless device  manufacturer  (somewhat disagree)
Usage is only one consideration; the main consideration is the  ROI.
Wireless service  provider (somewhat  agree)
The key is to measure in spectrum bands where there are no  market incentives to efficiently use spectrum, e.g., government  and restricted use bands.
Wireless service  provider (somewhat  agree)
Very complex subject; spectrum use varies by time of day,  weather, events, etc. Such results can be misused so  measuring methods needs to be carefully developed and  results properly calibrated and interpreted.
Wireless service  provider (somewhat  disagree)
It depends what is meant by “utilization” data. If it means only  transmissions using spectrum, it would be relatively useless.  Such data would only be relevant if it included data regarding  the economic value of the spectrum use at issue, the amount  of time that has passed since the relevant rules were put in  place, the applicable of secondary markets rules, and potential  alternative uses.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In the National Broadband Plan, FCC presented its estimate that it would  cost approximately $10 million to $15 million to deploy measurement  equipment nationally. FCC also stated in the plan that one way these  measurements could be accomplished is by frequency scanners installed  on a fleet of vehicles. FCC officials told us that the Commission will not  implement this recommendation unless it receives adequate funding.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Broadcaster (somewhat  dissatisfied) … FCC should be directed to evaluate the costs of contracting  this function to a knowledgable engineering firm experienced in  spectrum matters, such as a frequency coordinator or  consulting engineering firm, and the FCC should be required to  measure spectrum utilization on an ongoing basis.
Expert (somewhat  dissatisfied)
The objective could be achieved by having spectrum users  measure their usage using methods and criteria specified by  the FCC with spot checks by the FCC. This would reduce cost  of measuement and provide order of magnitudes more data.
Expert (strongly  dissatisfied)
Require reporting. This is just like CALEA. FCC should not  waste money on the generation of data that incumbents  already have or must have in order to provide services in  existing spectrum. FCC should order that they report it and  should fine licensees who do not report or who do not report  accurately.
Public interest group  (strongly dissatisfied)
The FCC has a mandate to collect the information it needs to  make informed policy. It also has the ability to either reprioritize  existing funding or raise additional funding through license fees  in order to implement  recommendation.
Type of commenter  (level of satisfaction)  Comment excerpts  Wireless device  manufacturer  (somewhat dissatisfied)
The scope and scale of such a project need not be this broad  (nationally), but FCC (and NTIA) should conduct an initial  series of spectrum occupancy studies at a diverse set of 10 to  20 fixed locations across the country, augmented by mobile  data collections, in urban and rural areas over several days or  weeks. Some or all of this effort could be contracted out to  independent third parties or academic institutions in  coordination with the National Science Foundation who is  already funding some similar data collection efforts. See NTIA  CSMAC Report, Spectrum Inventory Working Group (May  2010) at pp. 6, 13 (spectrum measurements initially will best  serve as an auditing function for certain assignments/licenses  in the inventory). The sensors used in the UK study referenced  by the FCC would likely cost tens of thousands of dollars (and  spectrum analyzers are even more costly). However, spectrum  sensor equipment and software could cost below $1,000 per  unit in the near future.
section_title: Maintain a Strategic Spectrum Plan
subsections: section_title: Recommendation
paragraphs: FCC should maintain an ongoing strategic spectrum plan including a  triennial assessment of spectrum allocations.
To ensure, now and in the future, that spectrum is allocated to support the  growth of broadband services and to accommodate new technologies that  deliver it.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  agree)
Comment excerpts  We support the concept of developing a strategic spectrum  plan. However, the FCC and NTIA should complete a  comprehensive inventory of how spectrum is currently  allocated, who is using it, and how it is being used before  proceeding with any steps related to spectrum reallocation.  Moreover, given the complex and dynamic nature of spectrum  use and demand, spectrum allocations should not be  reassessed every three years pursuant to an arbitrary  timetable; instead, the FCC should consider spectrum  reallocations on a case-by-case basis and only when  presented with an extremely compelling justification and  detailed cost/benefit analysis.
Broadcaster (somewhat  agree)
Trienniel re-assessment may be too disruptive, but some  regular approach is a good idea.
Expert (strongly  disagree)
The main thrust for spectrum policy ought not be to “plan the  market,” which is what “a strategic spectrum plan” explicitly,  through “triennial assessments,” seeks to do. Instead it should  provide as much spectrum to the market as possible. This  means that it should create generic, exclusive use rights —  similar to CMRS licenses — that allow licensees to flexibly use  spectrum. That releases bandwidth to existing applications  seeking to expand, or to new wireless services attempting to  compete. The government should not be attempting to wage  how much one application needs vs. others, but allowing  demands to be registered via price bids in a spectrum market.
Expert (somewhat  agree) … FCC should focus on getting spectrum to its highest value  uses by facilitating the working of the market through flexibile  and tradable rights, not by measuring “use” of spectrum.
Expert (somewhat  agree)
The FCC should play a much smaller role in allocations. A  triennial assessment would make sense if it is part of an  overall strategy along these lines.
Private user group  (somewhat agree)
In general, triennial assessment is too ambitious and creates  too much uncertainty. Spectrum utilization planning requires a  longer timeline.
Wireless device  manufacturer (strongly  agree)
Strongly agree that FCC should maintain an ongoing spectrum  plan, however, biennal/triennial/quadrennial reviews are  cumbersome for both industry and the FCC and often result in  little or no action.
Wireless service  provider (somewhat  agree)
Triennial is probably too often. First, the task is Herculean.  Second, the gestation period for new spectrum uses is often  much longer than 3 years. The rules for wi-fi spectrum were  put into place in the mid 1980’s but it took until the late 1990’s  before the wi-fi standard was complete. Nearly everyone would  agree that Wi-Fi is very useful, but if a triennial review of those  spectrum rules had been conducted and the use changed, we  wouldn’t have Wi-Fi. Cellular telephone took a similar amount  of time to develop and deploy. A detailed assessment every  ten years would be better.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In March 2010, FCC issued its current strategic spectrum plan and  assessment of spectrum allocations in the form of the National  Broadband Plan’s chapter on spectrum. FCC officials told us that the  Commission plans to complete an update of its strategic spectrum plan in  consultation with NTIA in 18 months.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Broadcaster (strongly  dissatisfied)
The approach of drafting a staff plan with limited input from  stakeholders has created confusion and a lack of  transparency.
section_title: Identify Additional Spectrum for Wireless Broadband Use
subsections: section_title: Recommendation
paragraphs: FCC and NTIA should develop a joint road map to identify additional  candidate federal and nonfederal spectrum that can be made accessible  for both mobile and fixed wireless broadband use, on an exclusive,  shared, licensed and/or unlicensed basis.
The specific bands identified in the National Broadband Plan will only  partially meet future needs for wireless broadband use.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  agree)
Comment excerpts  The US needs a comprehensive plan that involves all  stakeholders, including carriers, broadcasters, commercial  providers, consumer electronics, academia, etc. The road map  needs to be more comprehensive than just spectrum and  should include usage patterns, trends and technologies to  meet those demands.
Broadcaster (somewhat  disagree)
The FCC must first complete a comprehensive spectrum  usage review to determine what spectrum is already in use for  mobile/wireless broadband, what is coming online in the next  several years and what the actual realistic needs will be based  on predicted usage and predicted technological advances.
Private user group  (strongly agree)
Close cooperation between the two entities is essential.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs:   FCC consulted with NTIA on a plan to make available 500 MHz of  spectrum for wireless broadband over the next 10 years, which NTIA  issued in November 2010. The plan identified over 2,200 MHz of  candidate spectrum; the exclusively commercial portion consisted of  280 MHz identified in the National Broadband Plan and 500 MHz from  3.7 GHz to 4.2 GHz. At the same time, NTIA presented the results of  its first evaluation of some of the candidate spectrum, which  recommended that 115 MHz from various federal bands be made  available in some parts of the nation for wireless broadband within 5  years.
In March 2011, FCC issued a public notice inviting comment on these  bands, one additional federal band, and the 500 MHz plan.    FCC officials told us that the Commission is trying to identify  additional candidate nonfederal spectrum through its ongoing review  of spectrum allocations, using the following criteria: (1) bands should  be suitable for ubiquitous, wide-area systems or networks, namely,  from 225 MHz to 3.7 GHz; (2) bands should be sizeable, contiguous  blocks of spectrum in order to accommodate the high bandwidths of  current and emerging wireless technologies; and (3) bands should be  of sufficient size and be in a part of the spectrum that encourages  competition by allowing multiple providers and new entrants. For  example, bands at higher frequencies require more cell sites, and  hence greater investment, making it harder for small companies or  new entrants to compete. Bands at lower frequencies require larger  antennas in devices, which make them less desirable to consumers.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Broadcaster (no  response)
In reviewing spectrum allocations, the FCC must continue to  recognize and appreciate the inherent technical differences  between higher band and lower band frequencies. In this  regard, broadcasters should not be forced to relocate from a  UHF channel to a VHF channel under any scenario.
Expert (neither satisfied  nor dissatisfied)
Fundamentally lower frequencies are more desireable for  coverage, higher frequencies for capacity. For this reason,  low/high frequencies should be paired and if possible availed  simultaneously (such as occured in Germany for  800MHz/2.5GHz bands).
Type of commenter  (level of satisfaction)  Comment excerpts  Public interest group  (neither satisfied nor  dissatisfied)
The agenda is right and many of the right steps are being  taken. However, the lack of better data on actual utilization of  spectrum will continue to complicate efforts to identify the most  suitable bands for repurposing.
Wireless device  manufacturer (strongly  dissatisfied)
The FCC has identified many of the important characteristics  needed to provide a wide-area mobile terrestrial system that  supports data bandwidth intensive services. Unfortunately  NTIA may not have the same goals as industry and the NBP.  The spectrum it has identified in unpaired, fragmented or  above 3 GHz (this can be used but will not serve at the macro  layer of a wireless network), and has many operational  exceptions because the spectrum being presented is usually  considered only for shared use.
Wireless service  provider (somewhat  satisfied)
Both the FCC and NTIA should focus on spectrum that has the  best physical characteristics for mobile broadband rather than  on just “getting spectrum out there.” For example, the 100 MHz  identified by NTIA between 3550-3650 MHz is suboptimal for  mobile broadband and includes exclusion zones that cover at  least half the US population, which makes this spectrum  generally unsuitable for commercial use.
section_title: Promote Innovative Approaches to Global Spectrum Allocation
subsections: section_title: Recommendation
paragraphs: FCC should promote within the International Telecommunication Union  (ITU) innovative and flexible approaches to global spectrum allocation  that take into consideration convergence of various radio communication  services and enable global development of broadband services.
Consumers want to use many applications offered on wireline and fixed  radio communication systems on mobile terminals. The next generation of  mobile terminals encompasses multiple radio communication services  functions (e.g., fixed, mobile, broadcasting, and even radio determination)  that provide for voice, data and video as well as positioning (i.e.,  convergence). The ITU’s current radio regulations, however, may not be  sufficiently flexible to accommodate these technological changes.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  agree)
Comment excerpts  But the FCC and US Government should, in reaching  international positions, carefully consider and take into account  broadcasting spectrum and needs of US domestic television  distribution. Positions seem to promote broadband at expense  of existing television distribution uses.
Expert (neither agree  nor disagree)
The ITU has never been a vehicle for progress. Often a better  way to initiate reforms is for the FCC to act on its own, as it did  with international settlement rates. On the other hand, it  doesn’t hurt to push for it within the ITU even if nothing comes  of it that way.
Expert (strongly agree)  So long as it does not create excessive multiband support  requirements.
Private user group  (somewhat disagree) “Flexible” has a down side. There are significant benefits to be  had from global standards and common allocations.
Wireless device  manufacturer (neither  agree nor disagree)
Radios are becoming so agile that we don’t need  harmonization like before.
Wireless device  manufacturer  (somewhat disagree)
Convergence of services is necessary but the FCC could have  done more with WRC 2012 Agenda item 1.2. The flexibility  aspect can be deceptive in that it can also introduce regulatory  uncertainty. For example if the duplex direction is not  specified, deployed solutions could have different rules where  transmission could be adjacent in frequency to receivers. This  lowers overall network performance and creates confusion and  dissatisfaction with the offered services.
Wireless service  provider (strongly  agree)
Spectrum harmonization internationally is critical to economies  of scale.
section_title: National Broadband Plan Recommendations Aimed at Enhancing the Usefulness of Spectrum for Wireless Backhaul
subsections: section_title: Revise Rules to Allow for Increased Spectrum Sharing
subsections: section_title: Recommendation
paragraphs: FCC should revise Parts 74, 78, and 101 of its rules to allow for increased  spectrum sharing among compatible point-to-point microwave services.
Many wireless providers increasingly rely on microwave to connect their  wireless infrastructure to the telephone network (referred to as “wireless  backhaul”), especially in rural areas. Therefore, FCC should take steps to  ensure that sufficient microwave spectrum is available to meet current  and future demand for wireless backhaul, especially in the prime bands  below 12 GHz.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  disagree)
Comment excerpts  Strong interference standards must be established and  adhered to in order to safeguard the respective services and  maximize interference protection.
Expert (strongly  disagree)
Secondary markets, not FCC rules, can handle sharing more  efficiently.
Expert (strongly agree)  Wireless backhaul enables progression of cyberspace/  broadband into rural and unserved areas and thus is  commendable; the technology has been available for a  decade. Sustainment after government loans is the key issue.
Wireless device  manufacturer (strongly  agree)
90 percent of backhaul in europe and uk is microwave. we  need flexibility and we need competition in special access as it  is a monopoly today and limited in speed to T1 ‘s mostly.
Wireless device  manufacturer (strongly  agree)
Also need dedicated licenses, but increasing access to bands  is good.
Wireless service  provider (strongly  agree)
We support the FCC proposal to make an additional 750 MHz  available for Fixed Service by allowing sharing with bands  reserved for Broadcast Auxiliary Service and Cable TV relay  service. We would note that formalized frequency coordination  procedures will be necessary for operations within this band to  ensure non-interference.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: FCC’s progress and experts’ and stakeholders’ satisfaction with FCC’s  progress are described under the following recommendation, which FCC  is implementing jointly with this recommendation.
section_title: Revise Rules to Allow for Greater Flexibility and Cost-Effectiveness
subsections: section_title: Recommendation
paragraphs: FCC should revise its rules to allow for greater flexibility and cost- effectiveness in deploying wireless backhaul.
FCC’s Part 101 microwave rules are intended to enable a high level of  service reliability, but they may also limit deployment flexibility in  coverage- or capacity-limited situations. Therefore, the FCC should  commence a proceeding to update these rules to reduce the cost of  backhaul in capacity-limited urban areas and range-limited rural areas.
section_title: Expert and Stakeholder Comments on the Recommendation
paragraphs: Type of commenter  (level of agreement)
Broadcaster (somewhat  disagree)
Comment excerpts  Any action in pursuit of this recommendation should thoroughly  study and address interference issues and require adequate  protection standards.
Expert (somewhat  agree)
However, I advise the FCC to consider public interest versus  private interest. It is not the FCC’s job to enhance profits of big  incumbents under the guise of cost-effectiveness. I like profits  … but the argument needs to be for competition to improve  quality while keeping costs low vs one size fits all solution that  only one or two big incumbents can supply.
Expert (strongly agree)
I agree in the respect that wireless backhaul is critical for future  services.
Mobile Satellite  Services company  (somewhat disagree)
Part 101 prior coordination rules must be retained to protect  incumbent licensees. The Commission should not allow  operation of distributed radiating elements (DREs) as  proposed by Wireless Strategies Inc without part 101  frequency coordination.
Wireless device  manufacturer (strongly  agree)
The government should consider what Australia is doing with  NBN.
section_title: FCC’s Progress on Implementing the Recommendation through May 2011
paragraphs: In August 2010, FCC issued an NPRM and a Notice of Inquiry proposing  to remove regulatory barriers to the use of microwave spectrum for  wireless backhaul, in order to increase flexibility, capacity, and cost- effectiveness of microwave bands.
section_title: Expert and Stakeholder Comments on FCC’s Progress
paragraphs: Type of commenter  (level of satisfaction)  Comment excerpts  Wireless service  provider (somewhat  satisfied)
The speed of the rulemaking proceeding is a concern. Item is  not that controversial and we are still awaiting an order after  almost a year.
Wireless service  provider (somewhat  satisfied)
While in general flexibility is desirable in spectrum  management, the FCC should ensure that its rules do not  create new interference or efficiency concerns, e.g., the harms  of using auxiliary stations outweigh their benefits.
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Michael Clements, Assistant  Director; Eli Albagli; Richard Brown; Stephen Brown; Sharon Dyer;   David Goldstein; Josh Ormond; Kelly Rubin; Andrew Stavisky; Hai Tran;  and Mindi Weisenbloom made key contributions to this report.