Dana Barrett: “What is that thing you’re doing?”
Dr. Peter Venkman: “It’s technical . . . .”
Ghostbusters (1984)
So far I’ve successfully resisted the urge to comment on the 700 MHz D Block issues percolating at the FCC (although I did reference the FCC’s report in an earlier post). After coming back from my traditional 4th of July holiday, however, I’ve succumbed to the temptation to opine on the FCC’s “D Block Capacity Report.”
Others have already analyzed the Report in detail. (For Andrew Seybold’s comprehensive analysis, click here.) And I’ll try not to repeat their analyses in this post. Instead, I focus on the framing of the Report and, perhaps most importantly, what the Report doesn’t say.
The FCC frames its D Block capacity Report as a “technical” analysis intended to determine whether 10 MHz of spectrum is sufficient to meet public safety’s communications requirements in various scenarios. But, of course, this purported “technical” analysis is based as much on economic and policy assumptions as it is on engineering. It has to be: Because capacity is impacted by issues like cell density, which is in part a matter of economics, capacity isn’t solely a technical issue.
The FCC appears to concede that whether 10 MHz of spectrum is sufficient for day-to-day operations depends in part on how much money public safety has to deploy and maintain the network. (See Report at pages 5-7.) Indeed, the Report relies heavily on the potential economies of scope and scale that public safety would enjoy if the D Block is licensed to a commercial operator. (See Report at pages 16-17.) But the report erroneously assumes that the “benefits associated with sharing an LTE band class (Band Class 14) with the commercial D block licensee would evaporate” if the D Block were given to public safety. Isn’t it just as likely that public safety could use its access to an additional 10 MHz of spectrum (which, according to the Report, public safety doesn’t need) as an incentive to entice a commercial licensee into a mutually beneficial, voluntary partnership with public safety? Unfortunately, the Report doesn’t address this question or other alternative scenarios involving both economic and technical analysis.
Ironically, the FCC is clearly relying on significant relationships developing between public safety and commercial partners through roaming and priority access regimes. (See Report at pages 11-12.) However, the FCC apparently wishes to impose roaming and priority access requirements on commercial licensees as a matter of regulatory fiat, rather than allow them to develop through cooperative agreements between commercial licensees and public safety (using the D Block as leverage). It appears the FCC is more comfortable with imposing regulation on commercial licensees (who will be forced to allow public safety to access their spectrum and commercial resources) than giving more spectrum to public safety and relying on voluntary sharing arrangements. Regardless of its merits, this preference is one of policy and economics that has been given a dubious “technical” patina.