Common Sense at the FCC

I was fortunate enough to hear an amazing speech by FCC Commissioner Jessica Rosenworcel at the Wi-Fi Forward meeting only a few months ago. It was unusual for a commissioner to so concisely explain, in common sense terms, how the wide variety of wireless communications users creates a need for different technologies and different allocations as the FCC manages the radio frequency spectrum. The Commissioner pointed out, among other things, that the various spectrum candidates for new allocation of unlicensed spectrum have varying needs and purposes, and many different applications. She also made it clear that there is a role, in spectrum allocation, for both licensed and unlicensed use of the radio frequency spectrum.

I strongly support these views as well as other points that she made. Opening up spectrum for unlicensed use will offer an opportunity for enhanced public value, but only if there is innovation that increases capacity of wireless spectrum and lowers the cost to the public of deployment and service costs.

The 802.11 standard has served us well, but it was not designed for large numbers of contending users. It is very inefficient in the way that it uses spectrum. It makes up for some of this inefficiency by limiting power output so that the spectrum is reused geographically, but the collision avoidance approach used in 802.11 is terribly inefficient. When even relatively small numbers of users try to operate in one band, an increasing number of collisions occur that require an increasing number of re-transmissions. This chews up unacceptable amounts of spectrum.

802.11 can be fixed, and in a backward-compatible way. There are techniques available TODAY that could use any new spectrum in a far more effective and that could be brought to market in a time frame compatible with the FCC’s regulatory efforts. These techniques include, but are not limited to:

1) More organized sharing and handling of collision avoidance,

2) smart antenna techniques – spatial processing and interference mitigation – that increase capacity and reduce cost, and

3) meshed networking techniques that, while somewhat reducing spectral efficiency, reduce backhaul costs.

Further, there is no one system solution that is optimum for every class of user. Given the right opportunity and stimulus for innovation, another powerful form of efficiency is achieved by virtue of matching categories of user requirements to technical attributes like range, building penetration, reliability, coverage, and speed, as well as social priority of different categories. It may be appropriate to allocate separate bands of spectrum for different applications and standards.

What would I do if I was the FCC?

I would make new spectrum allocations contingent upon industry proposals for system approaches that are responsive to the burgeoning need for more bandwidth at lower cost. An allocation that uses spectrum in the same old way is wrong. Spectrum efficient technology is continually advancing and the FCC, as the manager of the publically owned spectrum, should require periodic adoption of such advancements.

I would task industry advisory groups to work with the FCC to establish technical standards for spectral efficiency and perhaps even for user cost.

I would encourage trials, perhaps even competitive ones, that offer real-world proof of performance of system candidates.

I would reach out to impartial organizations like the National Academies, the IEEE, and the WWRF to create a periodically updated National Spectrum Technology Roadmap, to provide decision makers at the FCC and Congress with a multigenerational baseline for their decision making and stimulus of innovation.

I would undertake the enormous task of using the National Roadmap to solve the looming problem of effectuating the availability of very low cost bandwidth for essential services.

I look forward to seeing what dynamic and visionary leaders like Jessica Rosenworcel will do at the FCC to execute on some of my suggestions. After all, these suggestions are just common sense.