by Patricia Fusco Managing Editor ISP-Planet [March 28, 2001]

Sometime between the time that first-crop hay made its way to the loft and second crop was left to grow a few inches more, my family would pack up the Ford Fairlane and head off to see some vista of Americana—up close and personal.

The hours of seemingly endless ennui would be broken by an occasional tussle to determine who had violated who's space after me and my brother had drawn imaginary lines of demarcation in the soft, viscid vinyl of the backseat. Once the skirmish had ended, we were quick to redraw our imaginary boundaries in the hopes of taunting each other into conflict once again.

Those backseat battles over well-defined spaces resemble the attempt of the Federal Communications Commission to reallocate U.S. airwaves—the lines are being redrawn right now and skirmishes are certain to break out—on the road to third generation wireless spectrum allocation.

Mission control
FCC Commissioner Michel Powell last week called for a national policy on managing U.S. airwaves. For Powell, the issue is all about control—or more accurately, the lack of control that the FCC has over allocating all of the nation's available airwaves.

The FCC, along with the National Telecommunications and Information Agency, is expected to release a working report at the end of this week on the potential use of all U.S. airwaves. At issue is 3G wireless spectrum, the devices that will operate in the allocated frequencies, and services that will carry voice and data through the air.

Last fall, then-President Clinton ordered government agencies to work together with the private sector to hasten the adoption of 3G technologies amid concerns that U.S. high-tech companies were falling far behind overseas rivals.

The first FCC/NTIA report about possible reallocation of government airwaves for 3G services is due on March 30, but federal regulators have until Sept. 30, 2002 to implement the spectrum allocation plan.

In order to fulfill its presidential 3G mandate, the FCC issued a Notice of Proposed Rule Making (NPRM) in January, inviting anyone and everyone to respond with possible uses for frequencies below 3 GHz to support the introduction of new high-speed wireless services, including 3G broadband systems. The NPRM specifically proposed to:

• Allocate the 1710-1755 MHz band for mobile and fixed services, which was designated for reallocation from the Federal Government use to non-Federal Government services
• Seek comment on providing mobile and fixed service allocations for the 1755-1850 MHz band, if spectrum in the band is made available for non-Federal Government use
• Designate advanced mobile and fixed service use of the 2110- 2150 MHz and 2160-2165 MHz bands that currently carry emerging fixed wireless and mobile technologies

Schools of thought
There are two divergent throughts about what to do with U.S. spectrum and how the FCC should allocate available frequencies. First, there is the government's assumption that the various bands of spectrum used for defense operations and managing the commercial aviation system are off limits to commercial carriers.

Second, there's the collective opinion of mobile phone and wireless Internet service providers, which covet the spectrum in which government agencies operate. Wireless firms are lobbying for spectrum used by the Defense Department to be reallocated for commercial use including potentially so-called third generation 3G applications like mobile high-speed Internet access.

After these two major points of departure over what spectrum is available for use, industry arguments break up into self-serving squabbles over wireless technologies, FCC spectrum auction delays, and spectrum leasing do's and don'ts.

Array of advice
Longtime telecom policy expert Ambassador Bradley P. Holmes recently joined ArrayComm, Inc., to advocate its take on how to use America's spectrum resources. The radio technology firm recently made its case before the FCC concerning current wireless technologies and spectrum auction shortcomings.

ArrayComm contends that it is wrong for the FCC to only auction spectrum for use with Frequency Division Duplex (FDD) protocols. FDD is explicitly suited for voice communications—one channel up and one channel down, which is quite not how data traffic behaves. The Commission needs to allow technologies utilising Time Division Duplex (TDD) protocols—where one band of spectrum both sends and receives data, which the company believes is much better suited for data transmission because it efficiently matches how data is sent and received.

Additionally, ArrayComm contends that TDD is far more cost effective and spectrally efficient for IP-based traffic. Because TDD technology does not require paired spectrum, it is easier for regulators to find spectrum for TDD-based wireless services.

Holmes argues that if the FCC sincerely desires to bring the widest possible range of technologies to market, regulators must change the allocation rules to include both TDD and FDD systems—as European and Asian regulatory agencies have already done.

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