Too Little, Too Late

Public Knowledge is at it again. Writing white papers and having discussions on them. All well and good I guess, it keeps somebody employed in a bad economy. But in reality, this is like poking a whale with a bang stick. It does no good for the poker and makes the whale mad. Essentially the white paper in question, Breaking the Logjam:Some Modest Proposals for Enhancing Transparency, Efficiency and Innovation in Public Spectrum Management, suggests rearranging the deck chairs. (Besides the point that verbose titles were verboten when I went to high school.) But not all is lost, there was one glimmer out of the morass —

The Federal CTO, working with the NTIA and other federal agencies, should develop policies enabling and encouraging federal agencies to move from the current system of assigned spectrum allocations to a system leveraging new technologies to permit dynamic assignment to agencies on an “as needed” basis.
In essence, the federal government would transition from a system in which agencies hold the equivalent of a spectrum license to one where the federal government manages a vast pool of wireless capacity from which agencies may “draw” as needed.

The idea that the spectrum is a pool resource not carved up between the FBI, DEA, NSA, etc in small pockets. Much of which because of the utilization never gets used period. So that is a move in the right direction. But other suggestions —

• The NTIA and the Federal Communications Commission (FCC) should expand the cooperation required between the agencies by statute. In particular, the agencies should publish an annual joint spectrum plan based on the mandatory consultation between the Chairman of the FCC and the Administrator of the NTIA,2 and should clarify the “expedited” process mandated by statute for processing applications for mixed federal and non-federal use.
• The NTIA should take steps to improve opportunities for public involvement in its spectrum management decisions, and should launch its own e-government initiative, similar to the Reboot.FCC.Gov.
• The NTIA, the Secretary of Commerce, and the Director of the OMB should “zero base” federal spectrum use, requiring all federal agencies to reapply for spectrum allocations. Failure to reapply, and provide adequate detail on use, will result in elimination of existing spectrum allocation.
• The President should require all agencies to prepare a “spectrum budget” in the same manner they prepare a federal budget, assessing existing and future needs. The NTIA would serve as coordinator for these agencies and would provide technical support, assisted by the federal Chief Technology Officer (CTO) and the Office of Management and Budget (OMB).
• Based on these exercises, the CTO, with support from the NTIA, would assist agencies in upgrading wireless equipment and enhancing the use of spectrum resources for individual agencies, in order to enhance their overall missions.
• The NTIA and the OMB should conduct a comprehensive review of existing federal statutes to determine how private entities can make contributions to federal agencies to enhance federal spectrum efficiency and promote innovative use of wireless resources by the federal government. The review should also seek to establish ways to further enhance public transparency and account ability with regard to spectrum use.
• The NTIA and the FCC should work with state and local governments, and their trade associations, to find ways in which federal, state and local governments can enhance emergency communications and spectrum efficiency, and promote innovative uses of wireless technology at all levels of government.

The rest is merely paper shuffling, for paper shuffling sake for which someone will be issued a grant handsomely, pretty printed, shelved and forgotten in the matter of 18 months. Great work if you can get it. But it solves nothing and in the end just triggers a turf war among agencies in the whole matter.

What is lacking in this paper is the realization that technology renders most of the proposal moot. The glimmer out of the piece was the realization that spectrum is a pool to be utilized, not hoarded. But it does not go far enough. The technology exists today that CPE (Customer Premise Equipment) is capable of self allocation. With that capability in hand, all the other discussions are rendered useless. Poof.

Spectrum utilization by most entities are broken down into two components, infrastructure and ad hoc. Infrastructure being those facilities that have a long lived use of a band. Example being point to point wireless nodes interconnecting buildings. An example of the latter being tactical radios to be used by, say an FBI team for a mission. Regardless with spread spectrum equipment and a valid reservation system, on demand spectrum allocation is possible.Nay it is already being done by the DoD, so it is a reality.

So here is the ThridPipe Federal Proposal –

• Congress shall mandate that in 7 years that all federal wireless usage shall be self allocating spread spectrum CPE. Funding to be allocated to realize this end.
• The FCC is directed to a) Realign the ownership of spectrum to a single entity. b) Licensing is soft revoked, continued use but ownership transfers. c) That a drop dead date is issued for final revocation of license.
• The FCC is directed to issue an RFP for a) The development of infrastructure and ad hoc wireless CPE. b) The development of a spectrum reservation system for (a). c) Implementation of (a) across the federal footprint.

We are at the point, this is not a matter of technology, or a matter of discussion. It is a matter of the will to do it. Lets DO IT, not TALK it to death.