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Cognitive Radio in the Television Bands
Julian Dunn | | | Unfortunately, although the FCC voted unanimously to approve the devices, broadcasters were able to put a thumb on the scale, skewing the ground rules for the TV Bands to favor incumbent interests. Existing uses in the TV bands were able to secure concessions from the FCC and white space advocates, without sufficient justification as to why such a move is in the public interest. While TVBDs are asked to bend over backwards just to be permitted on the air, broadcasters were not required to make any accommodation for the entrant to optimize traffic. TVBDs are essentially treated as a nuisance, even though they are capable of supporting more diverse applications and a greater number of users, using less bandwidth. | |
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- "More diverse applications ... using less bandwidth" than what?
| | | Placing the burden of coordinating uses entirely on the shoulders of TVBDs increases the barriers to entry, slowing – or potentially halting – the diversification of media and the closing of the digital divide. In most major markets white space service providers may find there is too little spectrum remaining to develop a viable product, let alone a service that could challenge cellular and wireline incumbents. Rural deployments have the advantage of more empty airspace, which will provide a deeper pool of bandwidth to share, but Wireless ISPs (WISPs) in these areas face additional obstacles that may keep them from viability. With these disadvantages it will be exceedingly difficult to put pressure on incumbents to innovate and lower their prices. As a result, the anticompetitive effects of spectrum oligopolies – oligopolies supported via broadcast licenses – will continue to suppress free speech and media diversity. | |
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< | At present there is too much uncertainty to say just how much these limitations will hinder the development of white space networks and cognitive radio. The two sides of the debate thus far have largely crafted to sway public opinion instead of address the key issues: Broadcasters harp on the ‘harmful interference’ that TVBDs will cause, while white space advocates have tried to create the impression TVBDs will bring of ‘universal free broadband.’ There are still a number of internal decisions and external trends that will determine how this technology can be deployed, and how disruptive it will be in the marketplace. | >
> | At present there is too much uncertainty to say just how much these limitations will hinder the development of white space networks and cognitive radio. The two sides of the debate thus far have largely crafted to sway public opinion instead of address the key issues: Broadcasters harp on the ‘harmful interference’ that TVBDs will cause, while white space advocates have tried to create the impression TVBDs will bring of ‘universal free broadband.’ There are still a number of internal decisions and external trends that will determine how this technology can be deployed, and how disruptive it will be in the marketplace.
| | | In any case, value will be created as this technology matures. But such gains must be evaluated against alternate courses of action that might produce more immediate and meaningful benefits. The Second Report and Order, which outlines device specifications and transmission protocols for TVBDs, reflects an antiquated view of the FCC’s role as a “traffic cop,” rooted in the Communications Act of 1934. While Red Lion still stands, the facts underlying its rationale no longer hold. While broadcast remains an important form of local and national media, is it no longer the most powerful or cost-effective way to receive information. Broadcasters were recently given 'beachfront property' spectrum in their DTV licenses, but they are simply not putting to the highest use. Given the numerical scarcity of broadcast channels in a given market, each license may confer market power on the licensee. The FCC’s continued preference for one-way broadcast, despite the fact that allocational scarcity no longer requires it, causes harm to consumer welfare by sustaining the high level of concentration and lack of diversity in media. Internet access provided over this spectrum would allow for more diverse and meaningful links to society. | |
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- This is the crux of the argument. I appreciate that to you and me it seems to need no explanation or expansion, but where the usual mechanism of argument is to show there's no reason why we can't have both, sharing broadcast spectrum with bidirectional commodity wireless networking appears to create a more direct conflict situation between broadcasting activities and real networking, which means that a clearer and more compelling explanation of the greater marginal value of the Internet needs to be given.
| | | As our spectrum policy slowly moves away from broadcast and towards an Internet-based platform, media will become more diverse and democratized due to the lower barriers to entry and ease of distribution. If the FCC moves away from the trustee and auction models towards unlicensed cognitive radio, the amount of wasted spectrum could be dramatically reduced, giving TVBDs the bandwidth to truly become mobile broadband devices. If cognitive radio can compete effectively with licensed wireless and wireline providers, it can exert pressure on the incumbents to provide better, cheaper and more diverse services. | |
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- But any wireless will do that: the issues is why we should use those particular frequencies in a condominium rather than look elsewhere for spectrum to use for WISPs.
| | | Despite the fanfare, the particular kind of cognitive radio approved by the FCC last year has a number of internal and external constraints that will hamstring its impact on competition, consumer welfare, media diversity and spectrum efficiency. Preserving a preference for legacy technologies despite a more efficient and flexible replacement is a fundamental error that will slow both the development of cognitive radios and the proliferation of broadband generally. Broadcasters should not be able to crowd out entrants using the legitimacy of the license. The FCC must revisit its spectrum policies and reevaluate its public interest commitments.
The Potential of Cognitive Radio in the TV Bands | | | White space advocates were also able to sell the FCC on the unknown innovations that an unlicensed network in the TV Bands could provide. Taking a cue from earlier unlicensed technologies, the white space spectrum was pitched by Larry Page and others as 'WiFi on steroids.' Opening the 'junk' bands to unlicensed innovation led to the creation of a multi-billion dollar market of products we use every day.
A TVBDs are actually said to have several advantages over WiFi? : Spectrum under 1GHz has much better propagation characteristics, allowing for longer range and high bitrates. | |
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- But with different interference characteristics and larger optimal antenna sizes. This would be a good place to discuss a little more fully the nature of the technological discussion between optimists and pessimists, or between those who favor using TV bands and those who prefer trading that spectrum for spectrum somewhere else.
| | | Combined with the flexibility and efficiency of cognitive radio, it is proposed that unlicensed use of the TV Bands would fundamentally challenge assumption of what spectrum was capable of. The WiFi? example stands in starkly against the assumption that a private actor will only have enough incentive to invest in spectrum if they are given the right to exclude. Given the numerical scarcity, licenses often convey market power which often allows them to act anticompetitively. Consumers would benefit greatly if licenses were only issued or renewed when absolutely necessary | |
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- This is a powerful argument summarized too quickly to achieve its full impact with a reader just learning the subject.
| | | On the other side of the table, the National Association of Broadcasters (NAB), wireless microphone manufacturer Shure, live event groups and the major sports leagues joined in opposition of TVBDs. F.U.D. was aggressively used to earn generous concessions to protect from legitimate concerns of coordinating uses, but even further to suppress even the suggestion that broadcast should have to accept some cost in order to maintain their licenses. These critics claimed that TVBDs would destroy our system of free broadcast and wireless microphones by creating profligate and unpredictable interference with existing uses. CEO of Maximum Service Television David Donovan liked TVBDs to “millions and millions of… interference causing devices, like "germs," [spreading] throughout America with the ability to attack the TV receivers in people' s homes, apartments, hotel rooms, hospital rooms, dormitories, etc. (Notice of Ex Parte Communication ET Docket Nos. 04-186, 02-380) Broadcasters’ sudden concern for the needs of the public was clearly pretextual for their own interest in keeping the costs of compliance as low as possible. But the meme of ‘harmful interference’ was pushed so aggressively that many more important and complicated issues were obscured, and TVBD backers were forced to make a number of concessions to quell opposition. | |
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< | The OET continued to test prototype devices from several manufacturers to get to further test TVBDs ability to sense and avoid broadcast and other licensed wireless signals. In the second round of field testing by the OET, it was demonstrated that long-range cognitive radios were capable of identifying television signals via spectrum sensing. Although the tests did not attempt to gauge transmission speeds, the Commission stated in its October 15, 2008 report that “at this juncture, we believe the burden of ‘proof of concept’ has been met.” (Evaluation of the Performance of Prototype TV-Band White Space Devices Phase II) But although ultimately the incumbents lost the interference battle, they successfully framed the debate in a way that put the entrant on the defensive, and assumed the continued legitimacy of their licenses and their protocol with . | >
> | The OET continued to test prototype devices from several manufacturers to get to further test TVBDs ability to sense and avoid broadcast and other licensed wireless signals. In the second round of field testing by the OET, it was demonstrated that long-range cognitive radios were capable of identifying television signals via spectrum sensing. Although the tests did not attempt to gauge transmission speeds, the Commission stated in its October 15, 2008 report that “at this juncture, we believe the burden of ‘proof of concept’ has been met.” (Evaluation of the Performance of Prototype TV-Band White Space Devices Phase II) But although ultimately the incumbents lost the interference battle, they successfully framed the debate in a way that put the entrant on the defensive, and assumed the continued legitimacy of their licenses and their protocol with . | | | November 4th 2008 | |
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< | On Election Day, the FCC voted 5-0 to allow both fixed and portable TVBDs on the TV Bands on a secondary basis within approximately 200MHz of spectrum scattered between 150 and 862 MHz. The this vote allowed the FCC’s experiment with cognitive radio to move forward, but their potential of this experiment was artificially capped due to fears of interference stoke by broadcasters, and the reluctance of taking on license holders. Mobile TVBDs are allowed to broadcast at a maximum 100mW, and the devices also employ automatic power controls that will ensure no more power is used than is necessary. There was no attempt to quantify the remaining utility of broadcast television to consumers, nor was there an attempt to balance this utility against the potential of TVBDs. While the legacy technology continues to receive a huge subsidy in their renewed licenses, TVBDs seem to be a merely tolerated use. TVBDs are forced to compete with one arm behind their backs, while no burden of any kind was to be imposed on incumbents to accommodate TVBDs. | >
> | On Election Day, the FCC voted 5-0 to allow both fixed and portable TVBDs on the TV Bands on a secondary basis within approximately 200MHz of spectrum scattered between 150 and 862 MHz. The this vote allowed the FCC’s experiment with cognitive radio to move forward, but their potential of this experiment was artificially capped due to fears of interference stoke by broadcasters, and the reluctance of taking on license holders. Mobile TVBDs are allowed to broadcast at a maximum 100mW, and the devices also employ automatic power controls that will ensure no more power is used than is necessary. There was no attempt to quantify the remaining utility of broadcast television to consumers, nor was there an attempt to balance this utility against the potential of TVBDs. While the legacy technology continues to receive a huge subsidy in their renewed licenses, TVBDs seem to be a merely tolerated use. TVBDs are forced to compete with one arm behind their backs, while no burden of any kind was to be imposed on incumbents to accommodate TVBDs. | | | [Determining empty channels] The mechanisms for determining which channels can be used where the TVBD is located are conservative and burdensome. To begin, mobile TVBDs are equipped with spectrum sensing technology that considers 'occupied' channels that report signal strength higher than a given level. The Second Report and Order set this threshold at -114dBm, 1000 times weaker than the minimum required to get a DTV signal. (cite) A threshold of -107dBm was recommended by the IEEE as more than reasonable, but license holders successfully stoked fear over interference. (cite) | | | Because TVBDs will be forced to work around multiple uses incompatible with the IP platform, many of the gains that cognitive radios could enable are squandered by incumbent uses that were grandfathered into this new scheme. This unequal sharing arrangement is a critical distinction from existing unlicensed bands such as WiFi? , but has been largely overlooked. Without the power to exclude wasteful, licensed users, the WiFi? on steroids analogy simply does not hold up. TVBDs will only be successful if more spectrum is returned to the commons for them to utilize. | |
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- You should have a conclusion here: the FCC gave with one hand and took back with the other.
| | | Unresolved issues that may limit the impact of TVBDs
The Commission referred to the Second Report and Order as a 'conservative first step' to test out this new technology; There are a number of unresolved issues that will have a significant impact the development on TVBDs. The FCC will next revisit the Second Report and Order next year, but as of now, the path to market is far from clear. | | | The 802.22 standard will continue to develop into a more powerful protocol, but without further details speculation on performance – and predictions of the competitive impact – is premature. Using channel bonding, MIMO or other techniques, the devices may eventually be capable of better performance in later generations. Needless to say, it is highly doubtful in the near future that a TVBD network will be able deliver mobile “broadband” service to a large number of people at once, especially given the new legislative definitions. | |
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- This graf sounds as though you didn't write it. You need to unpack more here for readers who don't follow this stuff habitually.
| | | Because of the negative correlation between the number of broadcast licenses in a given market and the number of vacant channels, there will be significant variations in performance between urban and rural markets. In urban markets, where most broadcast channels are spoken for and many additional applications such as Commercial Mobile Radio Service may be present, there may be insufficient spectrum for devices to function at all. In this respect, TVBDs will fail to become a free or low cost way to access the Internet for disadvantaged groups in urban markets.
White Space networks will have much greater bandwidth available in rural markets. Unfortunately, rural deployments face a number of additional barriers to deployment. Due to their distance from an Internet backbone, and between their scattered customers, WISPs have found it very difficult to make deployments that make economic sense. TVBDs will lower the cost of deployment, but given the small customer base, it is unclear that there will be enough incentive for large scale rural deployments. In Both rural and urban environments, it is unlikely that TVBD will be able offer a full-featured service, either as a first option or as a replacement for existing broadband service. | | | External Factors affecting the development of TVBDs | |
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< | As state above, the crowded TV Band is perhaps the biggest bottleneck to the development of TVBDs. Unfortunately, regulators missed a huge opportunity to move away from the licensed model and towards communal control of the network. Instead of reevaluating the continuing need for broadcast licences an era of media saturation, Congress simply renew existing licenses (at no cost) in the DTV transition. Although the switch to digital increased picture quality, preserved free broadcast and generated $19 Billion at auction, the primary beneficiaries were broadcasters, not consumers. It was also a huge transfer, perhaps as high as $70 Billion, from the public to private (Bob Dole dubbed "Telecom Giveaway,” Cong Rec. S135 (daily ed. Jan 10, 1995)) This reflects a bigger problem at the FCC of rubber stamping license renewals, to continue to do in the face of alternate media and multi-use platforms like the Internet is particularly troubling. (cite) | >
> | As stated above, the crowded TV Band is perhaps the biggest bottleneck to the development of TVBDs. Unfortunately, regulators missed a huge opportunity to move away from the licensed model and towards communal control of the network. Instead of reevaluating the continuing need for broadcast licences an era of media saturation, Congress simply renew existing licenses (at no cost) in the DTV transition. Although the switch to digital increased picture quality, preserved free broadcast and generated $19 Billion at auction, the primary beneficiaries were broadcasters, not consumers. It was also a huge transfer, perhaps as high as $70 Billion, from the public to private (Bob Dole dubbed "Telecom Giveaway,” Cong Rec. S135 (daily ed. Jan 10, 1995)) This reflects a bigger problem at the FCC of rubber stamping license renewals, to continue to do in the face of alternate media and multi-use platforms like the Internet is particularly troubling. (cite) | | | Despite this continuing bias, the end of broadcast is rapidly approaching. There are nearly 2,000 full power and 3,000 low power stations, and a significant number of them may not make the transition at all, moving to other media or ceasing operations all together. (cite). The amount of spectrum occupied by broadcasters is expected to decrease in the coming years, as ad revenues and viewership move to other media. It will be important to watch how long local broadcasters can hang on. | | | Though TVBDs share spectrum with broadcasters, perhaps the more relevant way to assess TVBDs potential for disruption is to compare their performance with close substitutes such as LTE, WiMax? , cable and Fiber-To-The-Premises. As long as broadcasters hold onto their licenses they indirectly benefit these competitors wireless providers by starving TVBDs of bandwidth. In the coming years, these technologies will continue to evolve, which should bring about greater performance, more complete coverage areas, and more diverse service offerings. Licensed wireless technologies will significantly increase total supply of wireless bandwidth, which should tend to lower the cost of bandwidth. But the performance of these technologies will greatly outstrip even generous estimates of TVBD bitrates. Making TVBDs unlikely to be seen an unlikely substitute for tomorrow’s bandwidth needs. Differentiation may allow the continuation of the anti-competitive behavior that exists today such as asymmetric upstream and downstream bandwidth and throttling of peer-to-peer. | |
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- Surely this would be the place to point out that the network operators who want to replace broadcasting with their own content-delivery models are interested in this technology only if they could own and control it.
| | | Given the many obstacles and unresolved issues facing this technology, it will be several years at best before TVBD networks have a significant impact. In the short term, TVBD service providers may only be able to peel off lower-bandwidth uses and users, but it will be too slow and unreliable for many key applications such as VoIP? or streaming video. This will blunt the impact of TVBDs on consumer welfare and media diversity. The incumbents may have to react to this competition to stave off substitution, but they'll only push themselves to innovate as much as they have to. Unless TVBDs can begin to offer dependable bandwidth in appreciable quantities, it will only service as a supplemental service, not a replacement.
Additional steps must be taken, both to develop cognitive radio and to ratchet up the pressure on broadcasters, either to force them to make the highest use of their licenses, or to force them to give their licenses up. The meme of harmful interference pushed by broadcasters is a false argument that assumes the superiority of Broadcast. All incompatible uses ‘interfere’ with one another; We must evaluate which uses create the most externalities relative to the value they offer, and embrace those that allow for the most robust performance, and diverse applications and users. | | | The government has a clear commitment to the promotion of information and culture through its spectrum policy. The FCC’s focus going forward should center on how to increase broadband access. Because the benefits of cognitive radio are so broad, each user can decide what their highest use is, instead of a corporate trustee. The FCC should refocus on subsidizing the growth technologies in pursuing truly universal broadband in this country. | |
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- This section is important, from my point of view, because it explains clearly what the Free World wants from the FCC, and I think it does so pretty powerfully. But it seems to be a disruption of the flow of this essay's argument, which is less theoretical and more practical. I'd hate to lose it, but I think it needs to be better integrated if it is to stay.
| | | Strategies to increase Unlicensed Spectrum under 1GHz
The decline of broadcast will grow the total amount of unlicensed spectrum, but a more aggressive approach should be taken to ensure investment in this technology is at an optimal level. The FCC and Congress must fight to recall the market power that they have given to media oligarchs via licensed spectrum. By redistributing the broadcast subsidy to the commons, consumer welfare, the public interest and the constitution will all benefit. | | | Once the 'proof of concept' was accepted by the FCC, they have an obligation to research how the technology can be utilized to further the FCC’s goal. The FCC should conduct more Notices of Inquiry to see how the 802.22 standard can be integrated into integrated into the other uses of the TV Bands such as wireless mics. The IEEE and device manufacturers will likely do much of the heavy lifting, but the FCC (and Congress) should focus on ensuring that our laws and regulations embrace this technology.
One of the most important thing the FCC can do in the short term is begin the process of converting the various users of the Television bands to a platform based on IP. If a single standard and protocol can be adopted for all users of the television bands, this valuable spectrum can be harnessed in ways never seen before. Users of different devices will benefit from others employing cognitive radio technology as they all become nodes of a single mesh. If these other uses were made to use the same technology as TVBDs, Kaldor-Hicks improvements in consumer welfare could be gained. This will not come without cost to those parties, so the FCC must decide how such expense will be allocated. But as cognitive radio and IP can become the standard use of these bands, the costs of implementation will continue to fall. Furthermore, the network would be more robust, reliable as the mesh becomes more and more dense. | |
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- This is the direction Reid Hunt would have gone, doubtless, if he could have also ended the interlacing of digital TV signals. But IPTV makes less sense when the video being streamed isn't compatible with other digital video. So you need to revisit an old controversy.
| | | And the efficiency gains are not limited to private licenses. The FCC can also play a greater role in encourage adoption by local, state, and federal governments. Municipal networks are a potential, as are public-private partnerships, with the city as an anchor tenant. Municipalities have a number of communications needs, from traffic monitoring to parking meters, to surveillance and public safety. To the extent governments can integrate this technology, more bandwidth will be left over for use by the commons. Eventually the government may indentify spectrum controlled by the government that could be “rented out” for unlicensed use using a process similar to the Google patent.
Conclusion | | | Unlicensed cognitive radios offer unique environment for investment in innovation, without the need to grant market power to a handful of trustees. This breakthrough allows spectrum to be more directly accessed by the public, the true owners of this resources TVBDs are just one form of cognitive radio and we should see further advancement as more money is poured into its development. Beyond that, it all depends on how powerful they are allowed to be. The Commission has not gone far enough to promote cognitive radio. The problems we face today in broadcast and telecommunicaitons will persist despite TVBDs, unless more aggressive action is taken.
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