Transcript National Spectrum Managers Association Spectrum Management

National Spectrum Managers Association
Spectrum Management 2004
Diane Cornell
Vice President, Regulatory Policy
CTIA-The Wireless Association
May 19, 2004
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CTIA- The Wireless Association
• CTIA is the international organization of the wireless
communications industry for both wireless carriers and
manufacturers. Membership in the association covers all
Commercial Mobile Radio Service (“CMRS”) providers and
manufacturers, including cellular, broadband PCS, ESMR, as
well as providers and manufacturers of wireless data services
and products.
• CTIA is the voice of the wireless industry - representing its
members in a constant dialogue with policy makers in the
Executive Branch, the Federal Communications Commission,
and in Congress. CTIA’s industry committees provide
leadership in the area of taxation, roaming, safety, regulations,
fraud, and technology.
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Commercial Mobile Radio ServiceOver 164 Million Subscribers Today.
Wireless
Subscribers
160,000,000
150,000,000
140,000,000
130,000,000
120,000,000
110,000,000
100,000,000
90,000,000
80,000,000
70,000,000
60,000,000
50,000,000
40,000,000
30,000,000
20,000,000
10,000,000
0
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
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CMRS Delivers Digital Service
Over 140 million digital subs at year-end 2003
200,000,000
150,000,000
100,000,000
50,000,000
0
1993
1994
1995
1996
1997
Analog Subscribers
1998
1999
2000
Reported Digital Subscribers
2001
2002
2003
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Over 1 Trillion Minutes-of-Use by YE
2004
500,000,000
1,200,000,000
450,000,000
1,000,000,000
400,000,000
350,000,000
800,000,000
300,000,000
250,000,000
600,000,000
200,000,000
400,000,000
150,000,000
100,000,000
200,000,000
50,000,000
0
1996
1997
1998
1999
2000
Projected Wireless MOUs
2001
2002
2003
2004
0
2005
Year-ending Subscribers
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CMRS Track Record for Customer
Service and Innovation Hard to Match
1993
2003
•
5 providers per market for 83% of
2 providers per market
–
“A regulated duopoly”
consumers
•
Avg. monthly bill - $ 61.49
Avg. monthly bill – $ 38.73 (in 1993 $$s).
•
16 million consumers
159 million consumers
–
5% penetration
 54% penetration
•
Service on local/regional analog
networks
 92% digital nationwide networks
•
Data Rates of 9.6 kbps
Data Rates up to 500 kbps
•
Limited internet access
 Full Internet Access
•
Limited number of mobile data
capable devices
 Over 140 million mobile data capable
devices
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Spectrum Management:
Procedural and Structural Reform
• Some ideas for procedural and structural reforms to improve
efficiency of spectrum allocation process:
– Develop a “rolling” long-term spectrum planning process.
– Create an “independent review” mechanism similar to the Base
Realignment and Closure Commission (BRAC).
– Designate an entity to contribute an independent voice on difficult
sharing/ interference and technical decisions.
– Improve U.S. participation in the international spectrum process.
– Create a “relocation fund” from auction proceeds.
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Spectrum Management Reform
• NTIA should encourage more efficient use of spectrum by
those commercial and Government users that are currently not
subject to market forces or discipline.
• The FCC and NTIA should avoid creation of unlicensed
spectrum “underlays,” which could create serious interference
problems for licensed users.
• Any spectrum or network reliability planning relating to
Homeland Security or public readiness needs to be performed
at the Federal level to ensure an uniform, national response
during terrorist attacks or natural disasters.
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Issues with Upcoming Blocks of “New”
Spectrum
• Advanced Wireless Service
– Allocation of 90 MHz of spectrum in 1710-1755 MHz and 2110-2155 MHz
band for advanced wireless services.
– Need Spectrum Relocation Bill to be signed into law.
– The FCC and NTIA proceeding will need to be completed.
– Auction timing?
• MDS/ITFS rebanding
– Decision expected this summer.
– Will create opportunity for secondary market purchases.
• Nextwave spectrum
– What service rules apply?
– When will auction be held?
• Reallocated MSS spectrum
– Will it be allocated for CMRS?
– What blocks will be made available and what service rules will apply?
– “G” block controversy- 1910-1915 MHz /1990-1995 MHz.
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Flexibility: Two Perspectives
PROPERTY RIGHTS MODEL
• Licensees who buy their spectrum at auction should be given
property-like rights to do whatever they like within their
assigned spectrum, provided they do not interfere with other
licensees.
COMMONS MODEL
• License would be subject to efforts by the FCC to improve the
efficiency of utilization of the spectrum by allowing additional
“flexible” uses in assigned spectrum.
– Possibly results in additional services allowed to be provided in the
licensee’s spectrum.
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A Proposed Framework to Analyze
Requests for Flexibility in the Use of
Spectrum
• First, determine whether reallocation of the relevant spectrum
band is preferable to granting the requested flexibility.
• If reallocation is not appropriate, determine whether the
additional flexible rights can be auctioned, subject to
appropriate service rules.
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Secondary Markets
• Secondary market mechanisms will help ensure that limited
spectrum resources are used in the most economically efficient
manner.
• CTIA supports:
– The FCC’s proposal to forbear from requiring prior approval of
certain transfers and assignments.
– The FCC’s proposal to expand spectrum leasing.
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Receiver standards
– The FCC should rely primarily on market incentives and
voluntary industry programs, rather than a regulatory regime
that would subject all receivers to a set of mandatory
standards.
– The FCC should not impose unnecessary regulation where
competitive markets and industry cooperation have been
successful in improving the interference immunity of wireless
equipment.
– For some spectrum service users whose markets are not
driven by profit, such as public safety users and TV
broadcasters, receiver requirements or standards might be
appropriate.
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Interference Temperature
• The use of CMRS bands has been highly efficient. The
systems in CMRS bands are now designed to operate down to
(and in some cases below) the noise floor. Underlay
operations in CMRS band will cause harmful interference to
licensees.
• The introduction of ITemp-based systems in CMRS spectrum
would adversely affect existing consumer services by reducing
the coverage available from mobile networks, increasing
dropped call rates, decreasing the voice quality of service, and
limit data throughputs.
• The record in the ITemp proceeding was overwhelmingly
opposed to the concept, and most commenters emphasized
the many unanswered questions in the Notice.
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CMRS and Unlicensed
• CMRS carriers view unlicensed as a compliment to… but not a
substitute for licensed mobile offerings.
• Many are building unlicensed into their business models.
• Concern with unlicensed underlays (the interference
temperature model).
• But supportive of unlicensed in separately allocated spectrum
when demand is demonstrated.
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The Unlicensed Hype is Overdone…
• But unlicensed offerings today do not offer high-speed access
to the Internet, they only provide local area “hot spot” networks.
– They need some other means of connecting to internet access.
• Starbucks, for example, needs to buy T-1 access lines to offer
its hot spots, which affects the economics.
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Licensed Services Already Offer
Broadband Mobile Access
• EV-DO already deployed in two cities, many more in
2004/2005.
• Speeds comparable to DSL and Cable Modem.
• Rides on existing CMRS infrastructure.
• Other licensed technologies are on the way.
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Licensed Uses Should be a Higher Priority
for Most New Spectrum Allocations than
Unlicensed Uses
• Licenses provide certainty of spectrum environment needed to
stimulate investment and innovation.
• Allocations for unlicensed uses are appropriate, if demand is
demonstrated, and it can be shown that there is a greater need
for unlicensed than licensed uses in the target band.
• Unlicensed underlays, however, raise serious technical,
economic and practical concerns.
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Economic Concerns with Unlicensed
Underlays
•
Government-imposed underlay rights perpetuate the command-andcontrol that the FCC has recognized as flawed.
– These types of government-imposed rules are not technology
neutral, and distort innovation and investment incentives.
•
Regulation generally is not needed to create underlay rights and
promote efficient use of the spectrum.
– From the perspective of consumer welfare and economic efficiency,
allowing primary users to sublicense via secondary markets would
be better than unlicensed underlays.
•
CMRS spectrum is the wrong place to experiment with underlay rights.
– Unlicensed underlay devices could cause interference to incumbent
licensees and would prompt uncertainty that would stifle innovation
and hamper full use of spectrum.
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Spectrum Managers Must Consider
Opportunity Costs of Allocating Spectrum to
Unlicensed Instead of Licensed Operations
• Licensed CMRS offerings have a proven track record.
• Unlicensed offerings have an important role, but beware the
tragedy of the commons’ potential to curb innovation.
• International harmonization enables manufacturers to achieve
economies of scale, whether for licensed or unlicensed, and
should guide allocations.
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Questions?
Diane Cornell
Vice President, Regulatory Policy
[email protected]
202-736-3216
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