Searching for a better way
While the LightSquared-GPS debate is the hot interference topic of the day, it seems clear that such debates will continue to arise and that the impact of the decisions spawned by them — measured in economic dollars or preservation of life and property — will continue to be great.
For this reason, many industry observers believe it is important that federal officials examine the procedures used to create service rules soon to ensure that the regulatory environment appropriately protects incumbent users without placing burdens that might unnecessarily discourage or delay investments in new technologies.
One prime example is cognitive radio. If implemented properly, the dynamic-spectrum-access characteristics and other features of cognitive radio can provide unprecedented levels of spectrum utilization, create new market opportunities and help address the much-chronicled “spectrum crunch” in the United States. However, if not done correctly, cognitive radio could introduce significant interference risks in multiple spectrum bands.
Of course, the policymakers establishing such rules typically do not have technical backgrounds, and even some engineers can have difficulty grasping all the implications associated with cutting-edge technologies. Given this, it is important for policymakers to have access to information from qualified, independent testing organizations prior to making key technological decisions, Seybold said.
“As far as I’m concerned, nothing should be voted on that involves technology that hasn’t been passed by at least an engineering study by the FCC engineers,” he said. “The testing [in the LightSquared case] was done after the waiver was approved, not before.
“If I were chairman of the FCC, that would be a rule — nothing would come before the commissioners that hadn’t been vetted from a technology point of view.”
But laboratory tests may not be enough in all cases, particularly with groundbreaking technologies or those that will operate in spectral environments that are particularly sensitive, Seybold said. In those cases, conducting tests on small-scale, real-world pilot deployments of the technology makes sense, just as the FCC did with “white spaces” technology testing in locations such as Wilmington, N.C.
“That’s the right way to do something,” Seybold said. “You run lab tests. You run real-world studies. You look at the results, and you make a recommendation based on a technology assessment first.
“You don’t do it the other way around. You don’t make a political decision, and then say, ‘By the way, go test it.'”
In fact, Seybold advocates the FCC establishing a 20 to 30 MHz of testbed spectrum to enable such real-world pilot testing of new technologies. The testbed airwaves would not need to be in prime lower bands that would be attractive for auctions, because the focus of the tests would be on functionality, not distance/coverage issues, he said.
“They could take 20 or 30 MHz of spectrum and set it aside for technology pilots,” Seybold said. “They could say, ‘In L.A., you’re allowed to use this spectrum to test cognitive radios; in Chicago, you can use this spectrum to test something else; and over here, you can test something else. When you have definitive results, call our engineers to come out and verify it.'”
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