Last week, TIA submitted our views to the National Telecommunications Information Administration (NTIA) on the development of a national spectrum strategy. At a time when establishing U.S. technological leadership on emerging wireless technologies – such as 5G – is especially important, we support the government’s push to establish a balanced, forward-looking, flexible, and sustainable approach to spectrum management.
TIA supports a new national strategy that encompasses federal, state & local, commercial, and private users of spectrum. It should also account for the manufacturers of communications technologies and platforms that support those users. The strategy should be built on several key principles:
- Predictability in spectrum allocations and regulations,
- Flexibility for commercial allocations, following the recent trend of avoiding service-specific mandates,
- Efficiency of spectrum use where technologically and economically feasible,
- Priority for those with superior spectrum rights in cases where band sharing occurs, and
- Global harmonization to promote economies of scale.
And where spectrum sharing is concerned – an increasing likelihood as bands become more crowded – the strategy must recognize that one-size-fits-all approaches will not work since each band will be somewhat different.
The government recognized the importance of predictability in its request for comments, and there are several things it can do to support that goal. First, TIA has long supported longer license terms, and are pleased the FCC recently extended the terms of licensees in the 3.5 GHz CBRS band from 3 years to 10 years. However, the government should avoid spectrum fees since they could produce market distortions, particularly if manipulated in ways that are not technology-neutral. It should instead focus on providing greater clarity and transparency regarding government needs and future transition plans.
Second, it can also focus on improving its own spectrum management procedures through better tracking, stronger central coordination, allowing agencies to use spectrum-transition funding flexibly, and having agencies think more creatively about their own spectrum needs. And while NTIA asked about the potential for automation to help with spectrum management – and it surely can – a national strategy should also recognize that opportunities for more simple sharing (geographic, calendar- or time-based, etc.) may still exist.
Beyond general principles, a national spectrum strategy should also recognize the need for federal investment in key areas to maintain U.S. leadership. For example, supporting standardization efforts – while always necessary as a complement to regulation – is particularly important amid a global race to 5G.
The government should also increase funding for the development of new technologies, including through direct investments such as wireless testbeds but also by re-investing a portion of all future spectrum auction proceeds into research and development. Spectrum R&D has been the “seed corn” that leads to new technologies, which in turn leads to more efficient spectrum use (and profits for the Treasury), and there are many areas of fundamental wireless research needing greater attention.
Finally, we agree with NTIA on the importance of predicting spectrum needs over the next 15 years and assessing whether current allocations are sufficient to meet expected needs. While it’s clear there is not enough spectrum to meet short-term needs, predicting the path of technology over the longer term is tough. After all, the iPhone is only 12 years old, and the Internet of Things has only just become a practical reality with everything from industrial sensors to light bulbs – and even clothing – connecting to the network.
Despite the challenge, it’s worth the effort. We support the creation of a tangible set of goals to motivate progress from government and industry alike. However, a national spectrum strategy should account for different types of spectrum (low-, mid-, and high-band) and different licensing models (licensed, unlicensed, third-way, etc.).
In the end, the development of a comprehensive national spectrum strategy represents an important opportunity for all stakeholders, including governments at all levels, service providers, the ICT industry, and consumers. The President has called for this strategy to be developed and released by this summer, and TIA looks forward to engaging with the government as the work toward that goal continues.