Over the past 5 years or so, I have been specifically working on developing framework/tools for more dynamic spectrum management, primary auctions and secondary markets. I thought to myself, 85-99% spectrum “appears” to not be used. The demand for wireless services was exploding, i.e. huge demand. This was so obvious to me! If only I could build the system and develop the market, we could make a lot of money and do a lot of good for the marketplace. So we developed what I believe is still the only dynamic spectrum exchange system where buyers, sellers and leaseee/lessors could do analysis and conduct business in efficient and open manner using real time commerical FCC provided data. From a technical perspective, our teams succeeded. However, hoarding, speculation, bad use rules, bad auction design and general lack of quality spectrum inventory limited high level success of secondary markets. My guess is there has only been a 1-2% increase in overall utilization over the past few years. Not exactly great progress. Today, I am going to attempt to frame some of the issues and solutions which might help increase spectrum accountability and utilization, which I believe should be the goal.
I have a hard time defining/comprehending harmonization in a world where innovation is moving so rapidly. Harmonization is important when trying to create ubiquity in networks and devices in more narrowly defined frequency bands. I understand GSM (Standards) and it is and has been a great success. Harmonization typically describes time, space, frequency, standards, and use. A new concept, Open Harmonization simply takes away standards and use requirements. At an extreme, simply don’t cause interference and get on with your business model, suceed or fail. New innovations like WiMax (Standards) simply need spectrum to develop. The efficiency of IP and Open Access Internet Networks are taking shape around the world. They require a mix of licensed and license exempt spectrum in order to build simple coverage, capacity and economically viable networks for both public and private sector. Open harmonization may more easily achieved by advances in Radio/Network Technology and Packet Switching vs. extensive consultations/studies/workshops and strict regulatory mandates. From a communications perspective, the new world is All IP and efficiency in building different sizes of roads, some 2 way, and other 1 way. As an example WiMax technology is already scalable. However, certain EU member states spectrum bands have not been released? Nonetheless any slowing of the new allocation/assignment process in a world where spectrum “appears” to be vastly under-utilized may hold back country innovation. Further, this policy certainly entrenchs the STATUS QUO/INCUMBENTS, which may be the regulatory goal. The capability to enable new/advanced systems and enhancements are needed to support evolving potentially competing/complimentary ecosystems. I believe this is in the best interest of consumers and innovation. Regulators may not be able to keep pace with technology innovations, standards, how and where spectrum might be used therefore it might be prudent to simply let there be more flexibility in how the spectrum is allocated and used Leave this to new and existing operators to find and use ANY spectrum, as long as they actually use it and don’t interfere. There are evolving needs and solution out there that are poised to take advantage of this. An example of such company, Full Spectrum SDR has created a product which uses any frequency and any channel along with WiMax standard to allow new broadband pipes for utilities and public safety agencies. They will have flexibility in the radio spectrum resources (below 1GHz) which are available now neither the same everywhere nor the same quantity and get the cost/performance of emerging competitive standards like the WiMax open standard. Increased availability of spectrum is easily configured with little to no changes in the overall system. Another company in Silicon Valley, Adaptrum, have created a Cognitive Radio System which can easily adapt to any white space (low power rules) or licensed spectrum (higher power rules) based on availability and innovative sensing and easily move to others without changing anything or requiring a 2 year consultation/auction. Therefore, open harmonization may lead to more public and private sector services and ultimately more spectrum utilization. Regulators will play an ever increasing role. Regulators may be more focused on the task of getting spectrum into capable hands and verifying utilization/mission efficiencies. Also, analyzing why spectrum is not used and taking it back. Some systems are using technology dating back to WW II. Regulators will need increased resources/expertise to do this. This requires more dynamic management/administration where there is visibility and oversight, especially on commercial spectrum. Government spectrum use should also have checks and balances and create incentives for more efficient use. The US Congress is currently drafting legislation for Spectrum Inventory. This seems to have support from all sides as it will simply focus on spectrum reality. I anticipate FCC and NTIA becoming more transparent under the Obama administration thus spectrum becoming more visible and accessible. Here in the EU, Ms. Reding quotes “This is an important week for Europe’s telecoms companies and its 500 million consumers,” “Industry needs legal certainty to invest and easier access to radio spectrum for wireless services, in particular in these difficult economic times.” Spectrum accountability and easier access can only be achieved with the framework and tools I have been discussing for several years now. Competition benefits seem to be overlooked when it comes to this debate. Picking winners and supporting status quo mobile, fixed or broadband operators is something that should be carefully considered. If you don’t have high utilization of spectrum, 100% coverage with 100Mbps to everyone with very low cost per bit, let competition develop. If an investor wants to try to compete, let them try. When spectrum is vastly under-utilized, access to spectrum should not be a reason new entrants can’t evolve or existing entrants to enhance and offer new services. It seems to me that too much spectrum is locked up and somehow gone missing. Let’s get specific.
From a spectrum perspective, let’s start to put a name on the face. There are vast amounts of spectrum located in very viable bands where current and evolving viable technologies (economies of scale exist or are evolving) are available below 1GHz and below 5 GHz. This is 5000 MHz of spectrum. How much is actually used today where you live? Maybe the 80/20 rule is about right. 80% not used? Mr. Meek indicated today that 291 MHz of spectrum is supporting the entire UK mobile industry, approximately 7% allocated? How much are they actually using out of the 7%? There is not a spectrum shortage, it is artificial. I continue ask key regulators, politicians and business entrepreneurs if they can easily view/see/request specific allocations/assignment/utilizations? This data is either not available or too difficult to decipher. We need to get more granular and this info needs to be easily quantified and qualified across multiple jurisdictions, public and private. This is valuable spectrum that is sitting fallow. Who? Where? Why?
First and foremost, spectrum allocation and assignment should be completely transparent across a majority of spectrum channels/frequencies. These are valuable resources that are renewable every second. Yes, there might be some cases where spectrum within government is not and should not be transparent to public. It should be transparent to key national regulators and security cleared analyst and politicians as to prevent abuse and/or provide the necessary checks and balances. For the time being, the construction of quality networks require using spectrum with engineered technical constraints. This requires more efficient management. In the future, dynamic access and use may occur automatically. This migration does not occur overnight, but I believe it is coming.
By having real time analytics on spectrum allocation and assignment combined with technical or mandatory utilization reporting, you have the SPECTRUM FACTS. This will show where hoarding and speculation are occurring, specifically. We will most likely find that much of the hoarding/speculation may be overwhelmingly obvious and correctible. National spectrum managers/regulators will be operating in an open, transparent on-going real time process with debate and action at the highest levels of government, entrepreneurship, academia and of course the regulators who will provide the expert facts and opinions. Who has what where and how is or will it be used, specifically!
Because we don’t have automated analysis of who has what and where and how it is used, we can only speculate on each countries current situation, including my own. Given my assumption that much spectrum sits fallow, perhaps as high as 85%, protecting current incumbent’s spectrum rights across county and state borders has been an easy engineering excercise. However, the influence of incumbents on spectrum policy may be a more difficult challenge. Un-used and fallow spectrum should be immediately identified across multiple jurisdictions/countries.
In closing, the first initiative should involve creating and implementing the real time dynamic spectrum management/administration systems capable of illustrating allocation/assignment across all jurisdictions and eventually specific utilization with different levels of viewer ship (classified/non-classified). Many countries are moving in this direction already. Today these systems/processes exist and occur in dark closed rooms and even in some regulators minds alone. The next challenges will be far more difficult as regulators, policy makers, industry, academia will now have hard facts of spectrum reality and will be able to craft policy for increased allocation/utilization. More dynamic auction design where partitioning and disagregation along with different types of regional offers may finally take place among other ideas like real time dynamic auctions I have been developing. There is great potential of increased utilization for each country as well as the EU’s collective socio-economical gain. A more transparent and Open Spectrum Allocation/Assignment/Utilization Analysis is the first step. Thank you
Friday, June 19, 2009
Friday, May 30, 2008
US Secondary Spectrum Market
The U.S. economy relies on markets to allocate an enormous number of resources. This reliance on markets is based, in part, on one of the most important theorems in economics. Broadly speaking, this theorem – called the First Fundamental Theorem of Welfare Economics -- says by signaling to market participants where resources are needed and where they are not, market prices can under certain conditions lead to an efficient allocation of resources. One assumption of this theorem is that the market participant’s willingness to trade (sell or lease dormant spectrum) is efficient in that it reflects the underlying value of the resource. In particular, that sellers don’t have “too little” incentive to trade and buyers have sufficient incentive to buy or that efficient trade is not prevented by transactions costs or by strategic competitive issues. If either side of the market falls to satisfy this condition, the market will not perform as it should and money/resources will be wasted. In the vernacular of economics, if either condition exists, a market failure will exist. In the case of spectrum licenses, it may be too early to declare the success or failure of secondary markets; however, we should all be able to see the truth in utilization, bits, revenue/utility per MHz pop as the defining factors of success.
Cantor has spent considerable time and resources attempting to make the spectrum market more efficient. We have enjoyed some success in developing innovative spectrum management, auction and trading technologies. Unfortunately, along the way we have learned a great deal about the willingness of both buyers and sellers to trade. For example, we have learned all too well that many holders (i.e. FCC Licensees or the government itself) are typically not interested in leasing or selling outright, their unused/under-utilized spectrum. And in many cases this is independent of a buyer’s willingness to pay.
Why should this be the case? The reason is that many potential sellers are also currently operators that do not view a particular spectrum transaction in isolation, but rather as part of their overall strategy. Thus, in many cases the willingness of sellers to lease or sell unused spectrum outright is dampened substantially by the economic loss they believe they would incur by having, by virtue of such a sale or lease, another competitor expand its transmission capacity and/or some future vision of need that may or may not be realistic. The presence of such a cost biases the seller’s decision away from the value creating features of the optimum goal of putting spectrum to its best and highest use and, in so doing, wastes valuable spectrum resources and lessens the public good.
What can be done about this? The first thing that must be done is the industry and government must establish/enhance systems and rules that would promote greater transparency and competition in the wireless spectrum market. Access to licensed spectrum should not prevent companies from bringing services to American consumers and/or public service entities when overall spectrum utilization in the country is between 1-20%. The first step involves developing a definitive and transparent data set that identifies all public/private wireless spectrum assets over the next 6-12 months. (Cantor Fitzgerald Spectrum Exchange has developed such a tool and I believe this is feasible and can be done a relatively low cost). The second step involves developing an efficient dynamic allocation mechanism that would reallocate and/or release fallow spectrum from those rights holders that value it less to those entities that value those rights more. The mechanics for this will be complicated but could be much easier after the spectrum is quantified and qualified in real time in a format easy to use. Some companies won auctions for the right to use these resources while other allocations were made decades ago. Regardless of how spectrum use rights have been made in both private and public sector, there have been limited efforts to actually to quantify and qualify these use rights across multiple frequencies and jurisdictions. Further, proof of utilization would make spectrum management complete. In the mean time, needless to say, a great deal of spectrum continues to sit fallow. Each day spectrum is not utilized; there are losses in both private and public sector.
Because the status quo is not effectively allocating this resource (why does 90+ percent of the spectrum sit fallow and especially more (99%) in rural areas), we believe that the government through both regulatory and legislative means needs to establish/enhance a set of rules that would promote a more competitively structured wireless spectrum market. Spectrum owners constantly change the rules in their favor, perhaps after we have systems and tools that analyze these assets in real time, spectrum may have the opportunity to be freed up and put to its best and highest use. Some times, spectrum is gathered by speculative entities that then change the rules thus creating a windfall and not actually putting the spectrum on the air. Therefore, complete transparency across all frequencies and geography will actually show the reality of who owns what where with the potential of forced disclosure of usage matched by NTIA/3rd party spectrum use studies (simple spectrum analyzers). Then, public and private entity leadership would be more able to make decisions to buy, sell, lease etc and legislators and government might see abuses and make the necessary changes to policy. To that end, the FCC might re-institute its Spectrum Cap for un-used assets over time - a rule that would limit the amount of spectrum any one firm can own and not use in a single geographic area. Given that 80-99% of spectrum is not used today, based on analysis by NTIA, Shared Spectrum, Georgia Tech and others, along with the technical gains in spectral efficiency (10 MHz of spectrum today may be equivalent to 100 MHz a few years ago-Martin Cooper comments) indicate to us that more spectrum hoarding for incumbents may not be necessary because the challenges most incumbents may face today have more to do with tower siting, backhaul, indoor coverage, and other operational/service related issues than spectrum scarcity/over-utilization. Does the government really track this in real time across the US marketplace? Restrictions on the amount of spectrum any one entity can own may ensure that the prices that guide the reallocation and utilization of spectrum will be based on market participant willingness to pay and sell that are “just right” and not anti-competitive practices. Other ideas which will be better debated after you have quantification and qualification include use it or lose it, taxation, budget penalties etc. across the public and private sector.
Finally, with the advent of tools and systems that manage the real time allocation of spectrum rights, un-used and un-auctioned spectrum currently controlled by the FCC and NTIA could be made available to public and private entities who need the quality of service that licensed spectrum can deliver. The capability to dynamically assign these assets in real time in specific geographies is something Cantor has been developing over the past several years. (Real Time Dynamic Auctions) New technologies like Software Defined Radio and Cognitive Radio could make the business case more justifiable for short term spectrum leasing.
Absent such developments, I believe the spectrum market may continue to exhibit substantial signs of market failure, and the U.S. consumer and business sectors will fail to receive the full benefits associated with employing one of the world’s most important resources – wireless spectrum.
Cantor has spent considerable time and resources attempting to make the spectrum market more efficient. We have enjoyed some success in developing innovative spectrum management, auction and trading technologies. Unfortunately, along the way we have learned a great deal about the willingness of both buyers and sellers to trade. For example, we have learned all too well that many holders (i.e. FCC Licensees or the government itself) are typically not interested in leasing or selling outright, their unused/under-utilized spectrum. And in many cases this is independent of a buyer’s willingness to pay.
Why should this be the case? The reason is that many potential sellers are also currently operators that do not view a particular spectrum transaction in isolation, but rather as part of their overall strategy. Thus, in many cases the willingness of sellers to lease or sell unused spectrum outright is dampened substantially by the economic loss they believe they would incur by having, by virtue of such a sale or lease, another competitor expand its transmission capacity and/or some future vision of need that may or may not be realistic. The presence of such a cost biases the seller’s decision away from the value creating features of the optimum goal of putting spectrum to its best and highest use and, in so doing, wastes valuable spectrum resources and lessens the public good.
What can be done about this? The first thing that must be done is the industry and government must establish/enhance systems and rules that would promote greater transparency and competition in the wireless spectrum market. Access to licensed spectrum should not prevent companies from bringing services to American consumers and/or public service entities when overall spectrum utilization in the country is between 1-20%. The first step involves developing a definitive and transparent data set that identifies all public/private wireless spectrum assets over the next 6-12 months. (Cantor Fitzgerald Spectrum Exchange has developed such a tool and I believe this is feasible and can be done a relatively low cost). The second step involves developing an efficient dynamic allocation mechanism that would reallocate and/or release fallow spectrum from those rights holders that value it less to those entities that value those rights more. The mechanics for this will be complicated but could be much easier after the spectrum is quantified and qualified in real time in a format easy to use. Some companies won auctions for the right to use these resources while other allocations were made decades ago. Regardless of how spectrum use rights have been made in both private and public sector, there have been limited efforts to actually to quantify and qualify these use rights across multiple frequencies and jurisdictions. Further, proof of utilization would make spectrum management complete. In the mean time, needless to say, a great deal of spectrum continues to sit fallow. Each day spectrum is not utilized; there are losses in both private and public sector.
Because the status quo is not effectively allocating this resource (why does 90+ percent of the spectrum sit fallow and especially more (99%) in rural areas), we believe that the government through both regulatory and legislative means needs to establish/enhance a set of rules that would promote a more competitively structured wireless spectrum market. Spectrum owners constantly change the rules in their favor, perhaps after we have systems and tools that analyze these assets in real time, spectrum may have the opportunity to be freed up and put to its best and highest use. Some times, spectrum is gathered by speculative entities that then change the rules thus creating a windfall and not actually putting the spectrum on the air. Therefore, complete transparency across all frequencies and geography will actually show the reality of who owns what where with the potential of forced disclosure of usage matched by NTIA/3rd party spectrum use studies (simple spectrum analyzers). Then, public and private entity leadership would be more able to make decisions to buy, sell, lease etc and legislators and government might see abuses and make the necessary changes to policy. To that end, the FCC might re-institute its Spectrum Cap for un-used assets over time - a rule that would limit the amount of spectrum any one firm can own and not use in a single geographic area. Given that 80-99% of spectrum is not used today, based on analysis by NTIA, Shared Spectrum, Georgia Tech and others, along with the technical gains in spectral efficiency (10 MHz of spectrum today may be equivalent to 100 MHz a few years ago-Martin Cooper comments) indicate to us that more spectrum hoarding for incumbents may not be necessary because the challenges most incumbents may face today have more to do with tower siting, backhaul, indoor coverage, and other operational/service related issues than spectrum scarcity/over-utilization. Does the government really track this in real time across the US marketplace? Restrictions on the amount of spectrum any one entity can own may ensure that the prices that guide the reallocation and utilization of spectrum will be based on market participant willingness to pay and sell that are “just right” and not anti-competitive practices. Other ideas which will be better debated after you have quantification and qualification include use it or lose it, taxation, budget penalties etc. across the public and private sector.
Finally, with the advent of tools and systems that manage the real time allocation of spectrum rights, un-used and un-auctioned spectrum currently controlled by the FCC and NTIA could be made available to public and private entities who need the quality of service that licensed spectrum can deliver. The capability to dynamically assign these assets in real time in specific geographies is something Cantor has been developing over the past several years. (Real Time Dynamic Auctions) New technologies like Software Defined Radio and Cognitive Radio could make the business case more justifiable for short term spectrum leasing.
Absent such developments, I believe the spectrum market may continue to exhibit substantial signs of market failure, and the U.S. consumer and business sectors will fail to receive the full benefits associated with employing one of the world’s most important resources – wireless spectrum.
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