A Critique of Open Spectrum from Within

1. A Critique of Open Spectrum from Within Robert Horvitz Director OPEN SPECTRUM FOUNDATION Amsterdam/Prague _______________ Wizards of OS 4.0 Berlin, Germany - 15 September 2006

2. Traditional approach to spectrum management • Divides spectrum into BANDS allocated to individual services • Technology specified in detail for each service • BANDS divided into CHANNELS • Fixed channels assigned to particular stations • LICENSES confer rights for specific “stations” to use specific channels • Geared to “peak” rather than “normal” use • Important rights cannot be changed or traded

3. Problems with traditional approach • Rigid: works best in static environment • no new services, no changes in technology, no changes in demand • Protects licensees against competition, change • Encourages investment, but acts as a “brake” on evolution of services and technologies • Technical controls  content controls • Harder to justify as radio use shifts from public to private spheres

4. Rigidity in times of rapid change • Blocks implementation of technical improvements, new services • Bad allocation decisions hard to correct • License conditions unresponsive to varying demand for and use of channels • CAUSES ARTIFICIAL SHORTAGE OF SPECTRUM

5. The Logic of Open Spectrum • Digitizing signals • unlocks new capabilities • + • Processors get cheaper/smaller/faster • = • Radios get smarter

6. “Getting smarter” means: • Better at rejecting interference and not causing it • Automatic power control • Automatic channel selection • No need for specialized user training/knowledge/skill • No need for regulators to assign channels • More efficient use of bandwidth • Better modulations and sharing techniques • Higher frequencies = more antenna directivity • Shorter transmit ranges = more channel re-use

7. The Logic of Open Spectrum • If pre-assignment of channels no longer needed... • If the devices themselves minimize interference... • If radio is increasingly used in the private sphere... • If “flexible/adaptive use” reduces “scarcity”... • If the traditional approach to regulation SLOWS technical progress and INCREASES scarcity... • WHY REGULATE?

8. Open Spectrum’s biggest problem • The core argument is self-defeating: • When interference is no longer a problem, one channel can accommodate an infinite number of users! • So no reason to change the way the rest of the spectrum is regulated • Belief that technology will inevitably make regulation unnecessary means no need to engage with regulators and work for reform

9. GNU Radio – Open Spectrum embodied Threat and Promise

10. Most spectrum still subject to traditional regulation • Many existing licenses have years to run • Buy-outs are expensive – who should pay? • Implementations to make Open Spectrum practical/affordable on a much larger scale are still years away • Open Spectrum advocates need to think in revolutionary terms - how to get from where we are now to where we want to be?

11. Think practically • What bands and services that are currently licensed can be de-licensed? • EC study of “collective use of spectrum” • We argued need for EC leadership and proposed de-licensing of the “Maritime Mobile” service • Ofcom study: is licensing needed above x GHz? • What de-licensed bands and services can have their power limits raised? • Ofcom consultation on WLANs in rural areas

12. Think ambitiously • What licensed bands can be opened to use by unlicensed devices? • Shifting from analog to digital TV will release a lot of spectrum • FCC “roadmap” for introducing unlicensed uses announced last Monday • Ofcom to release consultants’ recommendations next month • EC wants to “harmonise the Digital Dividend” across the region

13. Think creatively • How can the vetting of equipment be improved to reduce/eliminate the need for licensing? • Kalle Kontson and Michael O’Hehir propose granting spectrum access rights based on a “scorecard” assessing a device’s “good spectrum citizenship” • Standardised tests with points for bandwidth efficiency, resistance to interference, etc.; points subtracted for lack of interference mitigation, inefficient bandwidth use, etc.

14. “Continuum of spectrum access rights” - a major paradigm shift that already exists! • WiFi license exempt with “integral antenna,” licensed with “remote antenna” (Kyrgyzstan) • Indoor WiFi exempt, outdoor WiFi licensed (many countries) • Low-power WLANs exempt, hi-power WLANs registered (Japan) • “Class” licenses (many European countries) etc. • “Light licensing” (England, Bahrain) • Could the Konston/O’Hehir system coexist with the selling/trading of spectrum access rights?

15. The Silver Bullet • Change ITU Radio Regulation 18.1: • “No transmitting station may be established or operated by a private person or by any enterprise without a license...”

16. “Best Practice Guidelines for the Promotion of Low Cost Broadband and Internet Connectivity" • Unanimously endorsed by the ITU’s Global Symposium for Regulators (2004): • “We further encourage innovative approaches to managing the spectrum resource such as the ability to share spectrum or allocating on a license-exempt non-interference basis...”

17. Draft revision: ITU-R Recommendation SM.1538-1: “Technical and operating parameters and spectrum requirements for short range radiocommunication devices” • "...The ITU Radiocommunication Assembly... recommends... that these devices should not be restricted more than necessary in their use... There is a general agreement that when the efficient use of the frequency spectrum is not at risk and as long as harmful interference is unlikely, the installation and use of radio equipment may be exempt from a general licence or an individual licence...”

18. Know the rules • ...so you know which • are most worth changing

19. ROBERT HORVITZ • bob@openspectrum.info • http://openspectrum.info/