Reports are circulating that some within the Republican Party are organizing to dismantle the Federal Communications Commission, citing there is no longer a need for a government organization to regulate spectrum and communications services. I hope those who agree with them will take the time to find out more about the overall workings of the FCC, the issues involved in managing the limited resource that is the radio spectrum and the need for some form of regulation.
First, it is important to understand that radio spectrum is a finite resource. It always has been finite in size. Because of advances in technology, more of the spectrum has become usable during the past 50 years or so, but it is still limited.
The radio spectrum is a subset of the electromagnetic spectrum and has boundaries, as defined by the laws of physics. It is not possible to expand the spectrum beyond its current boundaries. It is only possible to make better use of the spectrum. Inside this band that stretches from 30 Hz to 300 GHz, we must provide for all of our wireless communications needs. Further, due to the characteristics of the radio spectrum, much of what is available is not suitable for normal types of wireless communications services. There are a number of reasons for this. The most important are the characteristics of a radio wave at a given frequency. The lower the frequency, the longer the wave. The longer the wave, the further that wave will travel over the earth and the more likely it is to bounce off clouds and other layers of atmosphere to travel still longer distances. AM broadcast signals in the 500-1300 kHz band travel considerably farther than the signals of an FM broadcast station that operates in the 88-108 MHz band.
For these reasons, the type of wireless service and the distance that needs to be covered generally determines the frequency range of the service. Another factor is as technology has improved, additional portions of the spectrum have become available for use. For example, in the early days of two-way radio communications for public service and business radio, the available spectrum was a 20 megahertz section in the 30-50 MHz range. Over time, as technologies were developed, additional spectrum was allocated for use in the 150-170 MHz range, then in the 450-470 MHz range and, finally, in the 800-900 MHz range.
New technologies
As each technology improvement made possible the use of more of the higher end of the radio spectrum, the FCC allocated its use and determined which type of service was entitled to how much band. The FCC had to balance the need for public access broadcasting (television and radio) with the need for public-safety and business two-way radio use, amateur radio needs and public radio access (mobile phones, etc.).
The task was complicated further because when a given region of spectrum was technically accessible, federal government agencies had first crack at the allocation. The organization that represents federal agencies, the National Telecommunications and Information Agency, is permitted to lop off portions of radio spectrum for government use before passing what is left over to the FCC to allocate for use by other groups.
Because spectrum allocations were made over time, users do not have single chunks of contiguous spectrum. Rather, they have been allocated a number of smaller chunks located at various points in the radio spectrum. Television channels are a good example of this. The first TV channels to be allocated (2 through 6) were in the 54-88 MHz band (Very High Frequency, or VHF).
However, before the television industry experienced a demand for more channels, the FM broadcast radio band was established just above TV channels, and the commercial aircraft industry needed and was allocated channels above the FM broadcast band. Amateur radio operators have been experimenting with radio communications for many years and, in many cases, developed new technologies. They needed higher spectrum and were allocated bands above the aircraft systems (144-148 MHz). And public-safety and business users asked for, and were allocated, more channels in the 150-174 MHz range. By the time the TV industry proved that it needed additional channels, the spectrum allocated to channels 7 through 13 wound up in the 174-216 MHz range.
Today’s lay of the land
Today with the wireless spectrum fully allocated up to the 300 GHz range, frequency allocations resemble a patchwork quilt with pieces for government usage, public access, public-safety, business and public wireless services.
The last allocation of spectrum for personal communications services required that other users of the spectrum be relocated. Until the PCS auctions, this band of spectrum was used for point-to-point microwave transmissions. With the new technologies available today, this same spectrum now can be used for handheld voice and data devices. Thus the FCC reviewed the spectrum allocations and with some not-so-gentle nudges from various lobbying organizations, it decided to reallocate the 2 GHz band for PCS and to move the existing users to higher bands.
Spectrum from 800 MHz to 2 GHz now is allocated heavily in favor of public access for the end user of wireless voice and data services. A total of 180 megahertz of spectrum is allocated for cellular and PCS. These allocations are enough spectrum for a minimum of four service providers in each of the major areas now covered by cellular communications. In addition to this allocation, there are others in the same band for one- and two-way messaging systems, dispatch radio systems such as that run by Nextel Communications Inc., and some spectrum is reserved for public-safety and other two-way radio users.
Abundance and shortage
While the general public now has an abundance of spectrum for its use, the two-way radio community, including public-safety agencies, still is strapped for channels. The FCC and several organizations such as the Association of Public-Safety Communications Officials International Inc. are working on proposals to provide better access to the spectrum for their users.
Currently, there is a critical shortage of available radio spectrum for them. Further, because of how allocations were made over the years, many agencies within the same geographic area are not able to use their communications systems to talk among themselves. They have to rely on the use of a second radio in each vehicle or on a dispatcher to relay information between agencies. This, of course, limits their ability to provide emergency services in a timely fashion-a situation that can, and has, resulted in needless delays.
While we, the end users, are busy considering how to use the spectrum that Washington has been so willing to make available to us (if we pay for it), there are hundreds of public-safety agencies that are not able to obtain even a single new channel in the band in which they now operate. Many of our public-safety dispatch systems are overloaded, and many would like to add data capabilities to their systems. But obtaining even a single new radio channel for such use is either not possible, or requires years of waiting for one to become available.
The reason
I have taken the time and effort to present this information because we all need to be aware that even though the wireless spectrum seems to many to be an unlimited resource, it is severely limited. Unless this resource is used wisely, it will not be available for the applications that are the most important.
Today, we do not have to choose between being able to sit at the beach and hold a full-motion video conference and being able to dispatch a paramedic unit to save a life on that same beach. However, if we continue to treat radio spectrum as an infinite resource, we may in fact have to begin making such decisions.
Maybe the FCC as it is now structured and as its directives are now worded, is not in the best position to allocate and administer the ether, but some form of regulation and co
ntrol is necessary to ensure that all users have access to some spectrum. For years we have been working under the premise that all of the potential users of this resource will get some of it-but not as much as they may want or feel they need. Suddenly, we are able to obtain almost as much spectrum as we want as long as we are willing to write the federal government a big check.
I believe it is important for all of us to realize that we are dealing with a finite resource and that there must be a way to determine the best uses for it. One way to get more spectrum (or, more appropriately, to make more available) is to look back at previous allocations and see what could be accomplished by reallocating some of the spectrum for other uses. Just as the FCC reallocated existing microwave spectrum to PCS and has ordered the relocation of existing users, spectrum currently being held for other uses could be released to form a pool of available channels.
Reallocation
An example of such a reallocation of resources is the recent ruling by the federal government to force the NTIA to release some of the spectrum that has been allocated to federal government agencies so it can be used by the private sector.
However, there is another area of spectrum that has, thus far, remained out of bounds. This spectrum is where the upper UHF TV channels are allocated. Channels 7 through 13 were allocated in a different portion of the spectrum than channels 2 through 6, as were the UHF TV channels 14 through 69. A few years ago, the FCC did reallocate UHF channels 70 to 83 and made them available to special service TV (such as educational TV broadcasting), and permitted them to be shared by land mobile radio users (two-way radio systems).
The television industry
However, there remain many channels that were allocated for but are not being used for TV systems. If the FCC reallocated UHF TV channels 40 through 69, it would free up an additional 174 megahertz of spectrum for other uses. This spectrum is in the range of 626-806 MHz and is ideal for two-way radio and wireless communications. This 174 megahertz of spectrum could be made available simply by moving the few TV stations using it to other locations within the channel 14 to 39 range.
The cost of such moves could be borne by the new users. (There is already a precedent for this. The new PCS providers have to pay to move existing microwave users.) The cost of moving TV stations would run into millions of dollars as compared to the cost of moving microwave users which will run into multimillions of dollars.
How much spectrum is this?
With today’s technologies, each of the 29 TV channels could be used for up to 240 two-way radio channels or cellular phone channels. Since radio waves at these frequencies do not travel long distances, it is possible to re-use these channels across the nation without experiencing interference problems. For example, allocating 10 of these channels for public-safety use would provide a nationwide pool of 2,400 channels-all of which could be divided into national, regional and local-use channels so every emergency vehicle in the entire nation would be able to communicate with every other emergency vehicle.
The balance of these channels could be used for a variety of purposes such as more bandwidth for private access, more two-way radio systems or whatever. In any case, since the trend in this country is toward more and better cable TV systems and small satellite TV systems, it appears as though these channels will probably be vacated and should become available for reallocation.
A strong lobby led by the National Association of Broadcasters is preventing such reallocations today. The NAB has been able to hang onto these channels even though they have remained largely unused for years. It is time to tell the NAB to either buy them at auction, as the PCS vendors did, or to relinquish them for other uses.
Final comments
As we rush toward a world where each of us has an individual phone number that works at home, on the road and at the office, and as we hear promises that in time these services will be expanded to include data services and full-motion video, it is important that we understand that we are making use of a limited resource. And even with the new technologies on the horizon that will allow us do more with the spectrum, it is still finite. As such, it needs to be protected and doled out (no pun intended) in a judicious manner and not just because it can raise money for the government.
I hope that as we move forward we will recognize that there are other uses for radio spectrum than simply being able to call home from the beach. There already is demand for spectrum well beyond what is available today and we must have someone looking at the overall requirements and planning to see that everyone’s needs are met. We also must have some form of governmental body responsible for allocating spectrum. To not have someone overseeing how we use it would be short-sighted and could result in chaos further down the road.
Sensible administration of the spectrum can be achieved. I believe, for the most part, it is being accomplished by the organization that has been charged with the task. We do not need to abolish the FCC. Rather, we need to give the FCC autonomy as an agency so that members of Congress cannot bring undue pressure to bear, as has been the case in the past and as is the case today.
Andrew M. Seybold is Associate Director of a computer and communications industry consulting and newsletter company.
