Test-Bed Proposal Imperils Spectrum Incumbents, FCC Told
Comments in an FCC proceeding on creation of a spectrum “test bed” illustrate why the Commission should proceed with extreme caution if such a bed is established, commenters said in replies, a number of which were playing defense. CTIA said the FCC must protect CMRS licensees. Shure accused some commenters of seeking a “spectrum give away.”
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Sources said the FCC and NTIA likely will have a tough time finding proper spectrum for opening separate 10 MHz test beds -- a key element recommended in a June 2004 presidential report on U.S. spectrum policy (CD July 12 p2). Nonetheless, commenters are urging caution.
CTIA said the test bed -- a means of examining spectrum sharing between industry and govt. -- is a good idea, provided wireless carriers are protected. “The test bed should not be used to impinge on the exclusive-use spectrum rights the Commission has awarded to CMRS licensees,” CTIA said: “Mobile wireless providers must be able to control their spectrum environments in order to achieve greater spectrum efficiency and the consumer welfare benefits.”
Equipment maker Shure said several commenters suggested the FCC make use of TV “white spaces,” or unused TV channels. “These commenters have not thoroughly analyzed the incumbent services in these bands,” Shure said: “The white spaces are densely populated with important incumbents whose operations could be severely affected by the introduction of potentially high-powered experimental devices.”
Some white spaces see use by low power TV and booster stations and translators, plus broadcast auxiliary devices, Shure said. Grandfathered medical telemetry units operate in channels 7-46, while private land mobile radio service and CMRS devices occupy channels 14-20 in some markets, Shure said. Radiocontrol devices operate above 70 MHz throughout the white spaces. “Significant precautions would need to be taken to ensure that these important incumbent services and devices would not be disrupted or adversely affected in any way before designating any part of the white spaces spectrum for the test-bed,” Shure said.
The Wireless Communications Assn. challenged a suggestion by M2Z that the 3650-3700 MHz band be established as the test bed. Wireless broadband providers plan to operate there, WCA said: “Contrary to what M2Z appears to suggest in its filing, the absence of broadband deployment at 3650-3700 MHz is attributable not to lack of interest but to flaws in the existing licensing system that effectively preclude the investment necessary to sustain broadband operations in the band.”
Shared Spectrum Co. said in a reply the test bed’s main focus should be dynamic spectrum sharing and cognitive radio technology. “Quite appropriately, most of the initial comments that addressed the issue of which technology would most likely produce substantial sharing improvements favored cognitive (or smart) radio technology for the test-bed,” the company said. Shared Spectrum said other technologies such as advanced modulation techniques, mesh networking and adaptive antennas can be tested but shouldn’t be required. The firm urged the FCC to allow for testing of proprietary technologies developed by a single company or group of companies.