Libertarian whackos...no regulation means the loudest guy in the shouting match wins, which will likely be a corporation.

Also as pointed out on slashdot. An open spectrum could easily lead to more commericlistaion than less since big companys could easily drown out all the little ones by now being able to broadcast on all frequencies.
Also it really wouldn't be a revolutionary force. The inetrnet, the telephone and even snailmail do a perfectly good job of communication with no need to clutter up the airwaves.

*coughs* Just to point out that interference is not a metaphor and anyone with even a passing knowledge of physiscs would understand that waves interfere with each other.

 
hey everyone I am new here just thought I would send a shout out!!

Edited by author 03-24-2006 11:47 AM
First the end of conventional modulation should come.
Really, more and more applications use spread spectrum, or CDMA(tm). This is _the_ modulation without interference. It's popularity comes out:
1. Existing interference avoidance.
2. Security.
3. Encryption available.
Broadcasting which doesn't requires subscription becomes obsolete, and so comes to digital technologies by need to encrypt content.
Field applications go digital by need to avoid interference ;-) and security.

So, conventional narrow-band modulation becomes narrower-used.
And IMHO in 5 or 10 years it will have no usage.

And then, when all transmission will be spread spectrum, spectrum will be open.

For Open Spectrum there must be no modulation but CDMA.
And Open Spectrum could be here only when all other modulations die.

(CDMA is trademark of Qualcomm)

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    It is simply amazing your lack of grasping of the fundamentals of radio systems. In a context of law, you would probably suggest that the Ten Commandments is all we need to govern the people. Try looking at the 900 Mhz free spectrum as a guideline to your proposal. Every manufacturer of wireless toys, cordless phones, garage door openers, and a host of other devices utilize this spectrum in such a manner that the FCC had to pass part 15 laws related to accepting harmful interference. ISM bands are next for this round of wireless interference battles. How long before 2.4 Ghz is a mess like 900Mhz? Another point that everyone must understand is radio(RF) is ANALOG!, there is no such creature as a digital RF waveform. You can digitally modulate a signal, digitally enhance a recieved signal(DSP), and even spread carriers with code, but in the end, a reciever must be able to detect the intelligence signal in this forest of interference. Just a couple of points to consider, my kudos to you for what I'd call a work of liberal science fiction. Flame on!

Another point not mentioned anywhere in the FAQ is radio astronomy. Senders in the sky are inherently dumb, and if we're going to do radio astronomy, we have to keep man-made sources out of those frequency bands.

Where are the UWB devices used currently? Is MIB avaiable for those devices?

Edited by author 10-21-2003 09:38 AM
Question, ignoring digital and sat radio, and the political econmoy issues and the stakes etc., is it physically and currently possible to design a smart radio receiver that eliminates noise and interference on the FM band, say, to this degree: I can receive 104.5, 104.6, 104.7 - cleanly.

In other words can the current radio spectrum be sub-divided?

Second, Open Spectrum seems to be based on the end to end model of the Internet, still predominantly a wired world. There is still a core architecture to the web.
Never mind the metaphors, where is this Open Spectrum, this fourth dimension, to be found?

In the heretofore unliscensed realm?

I read the FAQ...I still don't see where 'open spectrum' deals with the spectral equivalent of 'SPAM'. It would seem that if I wanted to build a nice high powered spark-gap transmitter as a fun project that would be OK wihtin the proposal. For that matter, presumably any corporation that wanted to set up a wide-band high-power transmitter could do so without any recourse from those who were shut down by it. Ultimately the open spectrum stuff seems to result in some form of anarchy...at best you'll have to personally sue anyone who is locally causing problems. The proposal seems to assume that everyone will work together and that there will be no selfish folks out there. Seems to go against my understanding of human nature...If I find that a cheap high-powered transmitter on the public bands can setup a nice link to my friends to play Quake over, what prevents me from slamming large portions of the spectrum (possibly with out-of-band noise as well)?

aok, that's pretty much how I feel.

Unfortunately, the Open Spectrum folks don't seem to want to give any substantive answer to the question about interference, which really pushes my "stop treating me like an ignorant consumer" button.

jleader, I don't doubt the legitimacy of the NAB's comments. They reflect every viewpont of every incumbent that feels threatened by the technology that is rapidly evolving - and rightly so. "Service preservation" is a really a code word for "self preservation".

My point is let's get real. You can't go around saying "interference is a metaphor" when it is a cold reality. When you have zillions of dumb receivers like your average TV set picking up noise, that's real. How do Open Spectrum advocates intend to deal with it?

I'm also pointing out how much clout the NAB has. The fact that they could produce bogus CDs at the low-power FM Congressional hearings and still get the ridiculous "Radio Broadcasting Preservation Act" passed demonstrates that.

We also have to remember that as hip as Michael Powell is to Open Spectrum, he may be around for only a short time. If Bush doesn't get re-elected, and that's certainly possible given the state of things, Powell goes poof. Hey, we may end up with a "Fritz Chip" chairman at the FCC.

I say grab all the unlicensed spectrum you can get and run with the ball. Technology will prevail. In the end the government will have no choice but to embrace an Open Spectrum policy, and I think it will happen sooner than we think.

I also think the Open Spectrum advocates have done an excellent job in planting ideas in the FCC's brain over the past year. My "criticism" is really devil's advocate.

aok, that sounds like a legitimate comment for the NAB to make. Not that their viewpoint should prevail, but it's legitimate to say "Hey, we've got this industry with lots of society's effort invested in it, lots of consumers use our services, you might want to think about that before throwing it all away to set up new services that may or may not pan out". I'm not sure "service preservation" should be a priority, but it's certainly a relevant consideration.

A few messages ago I half jokingly predicted that a new bill called the "Broadcasters' Public Service Preservation Act of 2003" would be introduced in Congress as a way to fend off those crazy Open Spectrum folks.

Here then from the FCC's website (docket #02-135) are the latest comments from the NAB:

"The Commission should make service preservation a priority in any future spectrum policy changes. Existing services such as broadcasting are the product of substantial investment, and provide jobs and social welfare benefits. Before the Commission permits the introduction of new uses alongside, but potentially compromising of, valuable existing services, it should ensure that its rules protect against degradation in or loss of service to consumers of the existing services caused by increased levels of interference."

Get ready for interference mania.

dpreed, /m41 sounds a lot better, clearer, and more sensible to me than the Open Spectrum FAQ. Only one problem at the end, where you can't seem to decide what you want:

"Unlicensed spectrum is only a first step. If all that happens is that bad legacy system designs move into the unlicensed spectrum, it will be worthless."

Um, if it's unlicensed, how are you going to prevent "bad legacy system designs" from moving into it? That's the missing piece I see in Open Spectrum: how do you prevent "bad legacy system designs" from causing problems for new, more polite and intelligent system designs? So far, the only answer I've heard is that there won't be any problems because, well, there just won't.

Look, folks. Open Spectrum is not a technology proposal. It's a policy proposal grounded in technology. There are several key tenets:

1. Communications by EM in free space are becoming more important. Devices move, and wires don't.

2. Today's EM communications architectures are wasteful, largely because they are based on pre-allocation of fixed channels and frozen technical architectures based on old technologies, reinforced by regulators that have been captured by incumbents.

3. Today's EM communications architectures are not rapidly scalable or adaptive to physical conditions as they occur in the natural environment.

4. Today's EM communications regulations are grounded in a theory that links "services" to "frequencies" in "areas". None of the elements of this theory match physical reality, nor do they match our understanding of information. E.g. by service is not a sensible way to allocate frequencies. Frequencies and areas show bad understandings of physics, because they don't accurately model the most useful coding of information into EM disturbances.

5. Presupposing that more communications involves more EM radiation which might be harmful to health misses a crucial point - the current radio systems expend energy many orders of magnitude more get bits delivered to the right place, on time. One can greatly increase the amount of effective communication capability using EM while drastically reducing the amount of EM energy incident on individual people and objects.

Open Spectrum's goal is to make room in policy for innovations that can demonstrate these things. Unlicensed spectrum is only a first step. If all that happens is that bad legacy system designs move into the unlicensed spectrum, it will be worthless.

Just to pick up on the easiest part of aok's message (m/38), the FAQ explicitly says (#28) that Open Spectrum would be phased in.

Photons, shmotons! Yes, waves can go right through one another without interference. Waves of a same frequency being received by one radio do cause interference. Period.
We should be talking about a better internet, with access uncontrolled by AOL Time-Warner, or whoever. Fiber to the home could offer unimaginable bandwidth. Here, photons can go both directions at once. Wavelength-division multiplexing
and other ingenious scemes now make terabytes per second data rates state-of-the-art on fiber links. I'm talking thousands of gigabytes per second on a single fiber. That's what we consumers could have. Filling the "ether" with more electromagnetic energy is not desirable. The wave/particles may go right through each other, but they do interact with matter. As a matter of fact, the CTIA is no longer able to hold back the tide of research that shows harmful effects to the brain from cell-phone radiation. By the way, do you know who Nikola Tesla and Edwin H. Armstrong were? Do you understand how radio works?

Edited by author 02-07-2003 06:19 PM
Open Spectrum certainly makes a lot of sense when you're talking about a world filled entirely with intelligent devices that are courteous, don't collide with one another, speak softly, and can hear the faintest whisper themselves. But the reality is we're living in a world filled with stupid, boorish devices: transmitters that shout, receivers that can't hear, etc. Even worse, these devices are supported by an infrastructure of corporations and lobbyists with very deep pockets.

How do Open Spectrum advocates intend to deal with this reality? I have yet to hear a good (i.e. specific) technical explanation as to how this massive dumb-to-smart phase-in of devices can be accomplished. According to the Open Spectrum FAQs, it cannot be phased in. It has to be done all at once. Good luck.

This doesn't provide much guidance for others who see the merits of Open Spectrum and want to do something to support it.

On the other hand, there are prominent Open Spectrum advocates like Dave Hughes and big tech companies like Intel and Microsoft who are pushing for a gradual phase-in. They're saying let's get any unlicensed spectrum we can get, do clever things with it, and then push for more.

Who are we supposed to believe? I'm inclined to believe the latter.

So here you have one faction of the Open Spectrum movement saying one thing, another faction saying something else, and NOBODY offering any technical specifics. Confusing to say the least.

Jock, part of what bothers me about the "Open Spectrum" movement, is your parrotting of QED and other physics without (apparently) understanding what it means. It makes it look like you're trying to snow people. Ted Nelson coined the term "cyber-crud" for this sort of argument in the computer field. It makes me distrust you even in the areas where I agree with you (of which there seem to be many)!

It's true that photons don't interact with other photons in free space. So what? No one is claiming that they do. You claim "photons can only interfere when they interact with electrons" like that's something really rare and irrelevant. But the ONLY time we have any contact with photons is when they interact with electrons! Photons interacting with electrons are _IT_. That's how we transmit radio signals, receive radio signals, even how we see.

If a few photons from a source we're interested in (the "signal") interact with some electrons (the "antenna") at the same time as large numbers of photons from a source we're not interested in (the "noise") also interact with the antenna electrons, practically speaking we may not be able to distinguish the "signal" from the "noise". This is what I (at least) mean by "interference". So stop pretending that we're talking about photons interfering with other photons in free space. When I talk about photons interfering, I mean at _my_ receiver, because I don't _care_ what happens anywhere else!

Based on your Open Spectrum writings, I'd be inclined to agree with uhClem, that you're spewing these technical half-truths to con society into giving you something you (or your backers) want, but can't get honestly. You're painting this utopia where all sources of RF are smart and polite, and saying that if we'd all just throw away all our TVs, radios, and other wireless electronic communication devices, everything will be wonderful. While I agree that smarter radios will do a better job, and regulations should be changed to allow that, I want to know why we should trash $billions of equipment so that _then_ we can get something better. If it's so much better, why can't it be demonstrated today?

And if what you're selling is so much better than the status quo, why can't you just show us? Instead of babbling about how photons in free space don't interfere, which while technically accurate, is irrelevant.

unClem: If, by "interference" you mean the problems that occur when photons collide with electrons in the send/receive hardware etc., then I agree that these photon/electron interactions cause poorly architected hardware with legacy technology systems some real problems. You are of course right that when two photons interact with an electron they can produce other photons with surprising behaviors.

We see these interactions every day. That is how signals interact inside antennas. (which are seas of electrons). That is how signals reflect and refract. You can get frequency doubling, you can get tropospheric tunneling, etc.

QED explains everything about radio, in theory, and it is remarkably precise. and predictive. It's one of the most well established parts of science.

However, it does appear from QED that the problem is not in the signal in EM space. So, if you meant by "interference" photon with photon interactions in EM space, I do not think that is actually possible. Are you suggesting that you want to re-write the work of Feynman, Schwinger and Tomonaga et al?

So the real question is why we write laws and regulations that ignore QED - that treat photons as if they exist in an Ether that can be divided up and "owned".

[Thanks to David Reed for his technical contributions to this note.]

I like the freedom talk. Unfortunately this really sounds like a sneaky sales pitch from a "wireless communications"
i.e. cellphone company. Exclusive use of radio bands is necessary because interference is a reality. True, FM demodulators will reject in-band signals that don't overpower them, but you can't have 2 stations on the same frequency in the same area without interference. This reminds me of the push for low-power FM--sounds like a new freedom, but now I get syndicated religimus fanatics where I could once get decent college stations. Digital computer geeks do not understand that this is an analog world, and their digital universes are limited by analog reality. You twist some techno-speak then con the majority of people into believing your vapor-ware. Another thing: not all bands are the same. They have different propagation characteristics, which is why you can get Chicago on the AM from 1000 miles away. The exclusive use of a frequency (the "clear channels" which only a few stations have) makes this possible. Shortwave stations which can be heard worldwide use frequencies and times arranged by international agreement. You could replace all radios and TVs with computerized frequency-hopping receivers
then make this change, but you simply can not "open
spectrum" without making billions of radios and TVs obsolete. Furthermore, "freedom" is NOT being available on the cell anywhere, anytime. More sacred antennae on sacred mountains is not an improvement on our world. Don't believe the hype.

Newly blogged at <www.greaterdemocracy.org >

The Regulators and the Candlestick Makers

Not too surprisingly, apparently only a very few of the recent comments to the FCC on spectrum policy reform have taken the Open Spectrum approach: David Weinberger's comments [based upon his work with the Greater Democracy group] and those of the EFF are two examples that look forward and not backwards.

There are two related questions here:

   1. Are the Congress, the NTIA and the FCC regulating to protect the status quo?

   2. Does the emperor have no clothes?

--- snip ...........>

Short replies:

1] For repeater I would have been more accurate if I had used the term "smart router" -- ie knows where it is and thus something of its environment. I regret the confusion.

2] As for FUD demos, yes they actually prove what is wrong with current bandwidth dependent solutions: They are very vulnerable to intentional harm. Dumb UWB is not what we are talking about. We respectfully suggest that distributed, cooperating, "smart" UWB, using GPS for environmental clues, and spectrum underlay for 'invisibility', offers a much safer, more robust and secure solution.

3] Cybiko is an interesting and informative step, but very incomplete, towards Open Spectrum. As is 802.11X. Itis important that they show new models. A key question is their ability, or inability, to offer scalable capacity that increases as the number of users increases.

4] The key is to realize, to borrow wildly from an old political saying: It is the architecture, Stupid! It is not what happens in the EM space. It is what happens in the encoders and decoders of the messages carried by the photons. To improve the quality of the signal/content translation process we need to look at the translators. It is here that regulation and innovation can be appropriately applied to great effect. Looking any p;lace else is like looking for the car keys under the street light when you know you dropped them back a ways in the dark and in the snow drift.

5] Is it appropriate to compare the nature of the signal carrier in the spectrum to concrete objects? No. But we do and so we get faulty analogies that suggest spectrum has "property like land" which is "scarce" and can be "privatized" and "priced" .

6} What does,actually, carry the signal through the spectrum? If it is photons, we know that they can not interfere with one another and thus all of the analogies in #5 can not be true. The implications for our current approach to wireless communications regulation is interesting.

I've asked others on the team, with greater technical chops, to make more detailed replies.

Very impressive FAQ, Jock. I agree that SDRs will be much more common, if not the rule, in the future. High bandwidth wireless will solve a whole lot of problems, as you say.

And I certainly agree that much of the current licensing system works against innovation. Indeed, as one of the commenter's pointed out, these are licenses for a fixed term (thus the Supremes applied traditional bankruptcy law to that asset of NextWave). A huge regulatory revolution of the last 20 years was to change the law to turn these licenses for a fixed term into a de facto property right, not because it says that, but because the licenses became renewable with effectively a post card.

Public auctions were a far better system than the prior freebies (public gets some value), but again no term was set with teeth (e.g. you get it for 15 years and then we re-auction).

I too value the clarion call when you are fighting for fundamental change, but I would caution you a little about overstatement of both the technology and business hurdles to get to your goal. I don't think most of the infrastructure for this is already deployed as the FAQ asserts, or that it will essentially be a very cheap or free good, as the same section implies. Similarly, I believe a lot of work needs to be done on SDRs and related technology before they are ready for commercial deployment.

Finally, having seen a NASA report and video of UWB transmissions killing a handful of critical avionic systems on a commercial jetliner last year (albeit parked on a runway), I'm not so sure that we can simply open the floodgates. And you wouldn't want to anyway. When I was on the Hill we fought with DOD, and with the NAB, but we never, ever, tried to go at them when they were allied!

The strategy of the Microsofts and Intels has been to push the unlicensed spectrum door wider and wider (i.e. adding more and more spectrum). This has limitations, but it means you don't have to attack all the castles at once.

Keep up the great work!

> Our view is that cooperating end points forward
> everyone's messages closer to their destination.
...
> End points just whisper at the lowest levels
> possible to reach the next repeater.

So this really IS like a Cybiko (http://www.cybiko.com/ ) using CDMA-style power control - possibly with CDMA-style coding?

The very existence of the Cybiko tends to suggest that you have mis-interpreted something - or not made clear what you are trying to do. Pick one, and fix it, then explain.

Jock, re point 2, Chris (in /m25) was making the point that while part 15 forbids "repeaters", it could be argued that what you're talking about is really a transceiver, not a repeater. That is, a repeater is a receiver directly connected to a transmitter, which just repeats the raw signal it receives. What you're proposing involves a receiver, a processor, and a transmitter, so while what it's transmitting depends on what it receives, it's not just stupidly re-transmitting the raw signal that it received.

I'm not a lawyer, let alone an expert in FCC regs, so I don't know if Chris's argument would hold up, but it sounds plausible to me.

A few notes:

1] Jeremey, fortunately, not everyone thinks we over stated the case. It has been quite favorably received by many. It has raised the hackles on the backs of few necks as well. However, I would rather under promise and over deliver. Our FAQ was intended more for a "lay" audience than a technical one. We plan more detailed essays for technical reader as we move forward.

2] Repeaters: Our view is that cooperating end points forward everyone's messages closer to their destination. This reduces radiation levels per user. Lower power output not only has a positive result on the health issues, but also allows batteries to last longer. End points just whisper at the lowest levels possible to reach the next repeater. This is key to achieving the paradoxical result that the capacity of the EM spectrum increases as users are added to the network.

3] We are not throwing up our hands. We are actively looking for "radio havens" where demonstrations can be run. There are already interesting developments at the MIT Media Lab and, I believe, the GNU radio team is doing very interesting work as well. We do have to be realistic about what can be done legally. Part 15 has many limitations that are constraining, so we are looking for a much broader opportunity.

4] Shortly we will be blogging a note on our view of what a desirable regulatory approach would be. Stay tuned.

Regards,

Jock

> The rules that regulate bankruptcy say that in bankruptcy
> the property of the bankrupted cannot be taken away by
> their creditors, in this case the FCC.

"property" or "assets"?

This may seem a niggling point to you, but it won't be to a bankruptcy court. Nextwave need not have purchased "property" - they may simply have purchased the authorization to use a certain chunk of spectrum for a certain time. When they account for the money they spent, they *must* also reflect the asset they acquired, or Securities and Exchange would be on their case. That assumes they could even pass an audit, which is unlikely - this is first year accounting stuff.

The asset - in tihs case, the authority to use the spectrum - cannot be reclaimed and resold by the creditor - the FCC. But this does not make the spectrum itself "property".

It could be similar to a long-term contract for freight hauling on a railroad. As a creditor, the railroad cannot reclaim the sold space on the railroad rolling stock and sell it elsewhere - but neither does that imply that the holder of the contract owns part of the railroad.

Even the first page of the decision makes clear that Nextwave did not hold the spectrum - it held a license.

I think the crowd here is getting nervous because you
want us to assume that the purchase of a license automatically means that someone has "bought the spectrum". As the licensing of software has made clear, that simply is not the case, and your insistence on this point is going to damage your credibility.

You don't need to go there. If you can show that your ideas for technology in receivers/tranceivers results in a vast increase in realized spectral efficiency, then current FCC rules and market pressures will - albeit slowly - result in the adoption of that technology and better use of the spectrum.

I was listening to NPR in my car this evening and they were talking about the Supreme Court's ruling today in FCC v. NextWave Personal Communications Inc. From what I understand (I don't have the opening briefs and have not read them, so I am going off of what NPR said), in the middle of the tech boom, when the FCC was auctioning off licenses in an effort to equal the playing field for smaller companies the FCC allowed people to pay for spectrum licenses in installments, much like most of us buy a house. NextWave bought a few spectrum licenses from the FCC in this manner but was unable to secure the funding required, became late in its payments, and then filed for bankruptcy. The FCC then took back the licenses to resell. It was this taking back the license that brought the court case and today the Court said that it is not legal for the FCC to re-auction off spectrum after a company files for bankruptcy.

The rules that regulate bankruptcy say that in bankruptcy the property of the bankrupted cannot be taken away by their creditors, in this case the FCC. What bothers me about that is that the Court essentially ruled that spectrum is property that the government is selling off, not that the government is holding spectrum in trust of the American people ensuring its fair, equitable, and efficient use.

It seems to me that the Court ruled very much against Open Spectrum without even knowing it. By saying that spectrum is private property that they government regulates (much like it does for land) the Court is ruling against the idea that spectrum is a resource that belongs to everybody.

-Grant M. Henninger
[ dram.teamslack.net ]

Jock, my name is Jeremy Leader. Nice to meet you!

If I haven't mentioned it before, I strongly agree with aligning FCC regulations (and other government policy) with modern technological capabilities, I just object to disinformation and overblown rhetoric in support of that goal. I don't trust groups like the NAB because they twist facts to support their position; doing the same thing from the other side of the question is a poor way to try to gain my support.

> Current FCC regulations do not permit
...
> repeaters in end user devices.
> Thus building demos which create "rough consensus
> and running code" is not legal in the US today.
> Thus we have to start with an attempt to make the
> demos legally possible - a political argument.

Doesn't a WiFi access point operating in infrastructure mode act "like a repeater"? I don't claim anything more than a bare minimum of undertstanding the of the relevant regs, but wouldn't what you are doing be permissible as pow-power work within Part 15?

Part of my thinking here is that you are not going to build a "repeater" in the classic, analog radio, sense of that word. Bouncing everything you receive back out will eventually cause something to cause problems - it never stops propagating around.

If I understand enough here, you need to make clear when you *stop* sending stuff you have just received. But the very act of making that decision places an intermediary between the 'input' and the 'output', making your device more like a transponder, and less like a receiver.

As a separate issue, you have a very strange attitude here. You claim that you can revolutionize the world, but first you need your revolution vetted by law???? We might have a little more confidence in your creativity if you could find a way to do some simple tests instead of throwing up your hands and saying "oh, we're not ALLOWED to do that". Heck, put the entire experiment inside a Faraday cage. I was also under the impression that Part 15 depended on a complaints process, rather than a certification process - so proceed carefully, make sure you don't interfere (for maybe more than a second or so) until you get the basics worked out. More to the point, if what you are doing is always going to cause interference in existing receivers, then that is a serious issue, which I hope you would even recognize, given that you propose co-existence with current systems. If it won't cause interference, then it seems you should be able to operate inside Part 15.

Cypherpunk,

I refer you to my earlier post re the requirement for co-existance via spectrum underlay. We are not proposing an either or dichotomy.

I also refer you the fact of the current political environment that makes testing illegal in the US. So we face first a poltical barrier which must be removed before we can address demonstration projects in the US. It would be a shame if these new ideas were developed overseas by competitors.

Regards,

JPG

jleader [?][Would you care to identify yourself?

A good point, but please consider this contradiction. In the early days of the internet there were no regulatory blocks to building demos that could create "rough consensus and running code". You could "just do it". Perfectly legally.

Current FCC regulations do not permit either 1] spectrum underlay or 2] repeaters in end user devices. Thus building demos which create "rough consensus and running code" is not legal in the US today. Thus we have to start with an attempt to make the demos legally possible - a political argument.

It is areal shame that the FCC 1981 Spread Spectrum NOI was blocked by parties with other agendas.

We are also looking at creating off shore "radio havens" in which to establish demos that would lead to "rough consensus and running code".

I would also refer you to the excellent work being done by the GNU radio people. Combine this with some of the new radio chips Intel is talking about and .....

Regards,
JPG

Jock, you (and/or Reed) compare your Open Spectrum movement to the beginnings of the Interent. But the Internet wasn't started by people saying in 1975 "We're going replace Ma Bell with packet switching. Throw away your out-dated dial phones, voice over IP is coming!"

Think about the principle of "rough consensus and running code". Save your "overthrowing the current metaphors and paradigms" until after you've demonstrated something working. That sort of rhetoric is suitable for the VCs when the next bubble starts, not the geeks who are going to make things work in the first place.

To get an idea of what Open Spectrum can expect from the broadcast industry check this out:

http://www.nab.org/newsroom/issues/lpfm/responsetofcc/

And for a real hoot listen to these audio files of "actual" interference:
http://www.nab.org/newsroom/issues/lpfm/re...cc/noiseandhiss.asp
http://www.nab.org/newsroom/issues/lpfm/re...technicalrecord.asp

The NAB blanketed Congress with these bogus CDs and the scary part is that Congress bought it and passed "The Radio Broadcasting Preservation Act of 2000", effectively killing low power radio.

The interference tests were based on the following 28 radios:
http://www.nab.org/newsroom/issues/lpfm/studycomparison.asp

Prediction - A new bill called "Broadcasters' Public Service Preservation Act of 2003" (or something like that) will be introduced soon. NAB chairman Eddie Fritts (Trent Lott's former college roommate and best buddy) will plead with Congress to save free over the air TV from those Open Spectrum commies with their Marxist style manifestos.

(Hint: tone down the "one world", "air is free", "End of Broadcast Nation" fanaticism).

Your FAQ is improved from the first version, but it still seems to have "pie in the sky" elements. Some specific questions:

"5... minimum set of rules..." This is the most crucial element in the whole FAQ. Everything else is just a sales pitch. What kind of rules are we talking about here? Obviously you can't just let everyone shout. Do we know what the rules need to be? Do we need ten years of research before we will know? Can we open up just a bit of spectrum to start learning the rules? Until you can firm up this question the FAQ ultimately fails to be convincing.

"12... BLAST ...". I looked at some of the BLAST literature. They use multi-element antennas (essentially like having multiple antennas and looking at how the received signals differ). That's great, you can get directionality, you can look at different path effects. But it would work best for stationary installations where the differentials between the antennas have a fixed meaning. Yet obviously for wireless one of the main application is mobile communication. Will BLAST work for mobile systems? It looks like it would be a lot more difficult because the differentials between the antennas would be constantly changing.

"15... unlicensed spectrum..." This answer is very confusing. Above you said that open spectrum needs some rules. Here you say that unlicensed spectrum has some rules. How are they different? You don't say. Further you go on to contradict yourself: "The lesson [of WiFi]: opening spectrums enables innovation." So WiFi is an example of "opening spectrum"? But WiFi is unlicensed spectrum, which you just finished saying is NOT open spectrum. So is it or isn't it an example? This all ties back into your failure to elucidate the necessary "rules" for Open Spectrum. Since you haven't identified the rules, you can't differentiate it from unlicensed spectrum.

"16... keeps us in a permission economy..." Sorry, but this is just rhetoric. In practice, you need to show that Open Spectrum will work by demonstrating it in some bands before you can make a case that everything should be opened! That's the real world. This kind of revolutionary talk may sound good at your meetings, but keep in mind that ultimately this is an engineering question. Wild throw-off-your-chains language does not help your case.

"17...accepts the current metaphors and paradigms..." Here we go. The bullshit detector just pegged. I'm sorry to be rude, but this rhetoric makes you look like a bunch of wild eyed fanatics, not someone to be taken seriously.

"29...still be able to watch The West Wing..." How can this be, if we are going to change all the rules? Will the broadcasters still have a monopoly on sending strong signals in those bands? How else can we still receive their transmissions on our old TVs? And if so, then what does this mean for your rhetorical promises to throw out all the old paradigms and bring in a whole new approach?

I hope you can accept these comments in a constructive manner. I would like to see experiments that prove that the new technologies can work in practice. But you need convincing arguments, which means avoiding the extremist and unrealistic rhetoric that you slip into far too often. You need to temper your Utopian vision of a revolutionary approach to spectrum by accepting that it has to be done gradually. Ultimately that is the path which will bring your closer to your goals.

With respect to detector issues:

We agree. The problem is one of receiver design and architecture which introduces problems. It is not an issue of EM interference. We need to focus on the "detectors" and using hte term interfernec badly confuses the issue.

And we of course include legacy receivers by using "spectrum underlay approaches" -- if the FCC will permit. Co-existence is a requirement and technically possible.

BTW: Reed has re-stated the basis fior this dialog in this way:

The real question is: if we look at the potential technologies that can be built to sustain wireless communications over the next 10-20 years, will we end up with more capacity and more flexibility and more innovation and more growth if: 1] we preserve the narrow-band, prescribed-in-advance frequency-based access control scheme that has been used since the first decade of the twentieth century, or: 2] can we do better with a more dynamic, networked, interoperability-based approach that is now possible with software-defined radios, digital very-wide-bandwidth signal processing techniques, ability to measure the EM propagation environment and build models of it in computer memory, etc.

The answer is obvious to me and to most who have looked closely at the problem.

The question is how quickly we can discard the legacy based technologies, replacing them with much better approaches, so that we can meet the rapidly growing demands for wireless digital communications.

It's the same question we asked in 1975 when we began the Internet project - should we continue to assume that telephony and the Bell-system circuit-switched, isochronous architecture is appropriate for all future communications needs, or should we build a system that assumes that computer-to-computer communications will dominate the demand, and that interoperability of all networks creates more value than balkanized, highly optimized networks per telecommunications service.

People thought the Internet was a joke, and that the mature Bell System was a technological wonder, never to be surpassed in its engineering quality and suitability to purpose. It was great. Then. When one had dial telephones.


Lastly, I recommend to for your consideration our new post on
Open Spectrum and the First Amendment. -- JPG

Jock, you (and David Reed) are right that the photons don't interfere at the pinhole; my point is that they "interfere" at the film. Are you familiar with the response curve for photographic film? It's only (roughly) linear over some limited range of exposure; above that region it saturates. As far as I know, all detectors exhibit some sort of non-linear saturation effect if exposed to too many photons.

So as you say, photons don't interfere, but as soon as you try to convert the information into another form besides photons, you run into detector sensitivity issues. If you want to coin some other term besides "interference" for this, I suppose you could, but why not use the term that has been used to describe this phenomenon since its discovery?

Not including "the radios in the game" kind of defeats the whole point of using photons to communicate information, doesn't it?

And dpreed, isn't "audio speech in open air" a rivalrous good if you get into a shouting match? All it takes is one spoilsport screaming at the top of his lungs to ruin your nice conversation. For that matter, trying to converse with someone while another conversation goes on between people in the middle is harder than conversing in the absence of those other people.

I agree with the basic points that "Spectrum regulation should recognize physics" and "Spectrum regulation should recognize rapid change and learning, especially technical innovation". It doesn't follow that "Spectrum regulation should be eliminated".

When Open Spectrum advocates use misleading arguments like "radio signals don't interfere with each other" and "bandwidth is infinite", I get the impression that either they don't understand the physics as well as they claim, or they're trying to pull something.

Oh, and the BLAST page is at http://www.bell-labs.com/project/blast/

If all you needed was the pinhole, all would be well.

But you have to collect the light.

Both silver halide crystals and the electrons in CCD cells are rival.

Similarly, the EM radio waves will happily pass through each other, but when it comes time to build the antenna and receiver, things are not so clean and simple.

You are quite correct about interference being something that occurs in regard to receivers. For that reason, a demonstration system for Open Spectrum is not just a good idea - it is the only thing that can validate the theory. Until you build it, it will be hard to convince people that it can exist.

A separate question is whether or not you can build it affordably. I can probably figure out how to cobble together an AM radio with a few cents worth of parts. How much will your receiver cost - and is the cost worth it, both in the value of the transmitted and received info and the harder-to-quantify benefit to the public good?

Things like CDMA are a step in your direction, right? One of the things done there is power control - this avoids having to try and discriminate between two signals that are several orders of magnitude different *at my receiver*. Similarly, I'm curious to see how a single implementation would deal with the disparate problems of downtown Manhattan and northern Alaska, especially regarding transmit powers.

A final thought: is something like the Cybiko and it's messaging mechanism a good starting point for people trying to get a handle on your ideas?

In reply to the question on pinholes, David Reed writes:

Light is EM radiation, a form of radio. The point [of the pinhole example] was that information encoded in EM radiation doesn't take up space, because EM radiation itself doesn't take up space (it's not "rivalrous" - it doesn't exclude).

Physics says this in a simple way: Bosons have no exclusion principle. Photons are bosons, whether they are RF photons or light photons. The only way that photons interfere with each other is when the same photon encounters itself traveling on another path. If it crosses any other photon, it doesn't interfere (this is the physical definition of the term interference, not the FCC or EE definition, which includes the radios in the game).

This is different from particles like fermions, which include massy particles like electrons. Electrons obey the Pauli exclusion principle - you can't have them pass through each other. Sending lots of electrons through a pinhole does cause problems.

The pinhole thing is NOT an analogy. It's the real deal.

Edited by author 01-23-2003 02:28 PM
2] If eletromagnetic information interfered, pin hole cameras would not work. They do.

OK, so why do you need the pinhole, then? Why not open up the whole front of the camera, to let more light onto the film? Could it be that light impinging on the film from all directions has some undesirable effect on the film's ability to record the information you want that's coming from one particular direction? The answer is that at some point, some "sensor" has to turn the electromagnetic information into an electrical signal, or a chemical change in a dye molecule, or something else that we can use. That sensor has a certain range over which it operates; too much extraneous "electromagnetic information" impinging on it makes it impossible to recognize the information you want. Maybe you don't call that "interference", but I don't know a better term for it.

Read the FAQ carefully on interference. Also please read the supporting documents, esp. those on David Reed's pages. See also the BLAST work on reflection that were once considered a form of "interference".

I don't know anything about BLAST; do you have a link to a good reference on it? I'm going to go back and re-read the FAQ and the Times article, to see if there's anything there I missed.

I also don't understand how the bandwidth available in a finite volume (say, the Earth out to 100 miles above sea level) over a finite frequency range (say, 0 Hz to gamma rays) can possibly be infinite. Unless you assume that your transmitters and receivers are infinitesimally small and infinitesimally far from each other.

(Edited to correct formatting.)

Edited by author 01-23-2003 09:28 AM
Grant - a couple of comments. It's important not to confuse the terms bandwidth and "bit rate" (as so many do in hip-digerati slang). Bit rate is the capacity to carry information. Bandwidth is the width of a frequency band in the spectrum. There is a limited amount of spectrum. My point is that the capacity of that spectrum, as the number of transceivers (antennas) scales, is unlimited. To be precise, any limitation results from limitations in the architecture of the system as a whole, not in the physical spectrum.

Second, there are other measures of economic utility that we might want to optimize. For example, the total amount of information that can be sourced in a certain amount of time at a particular point in space is still limited by bandwidth, so the "open one sliver" idea doesn't seem to be very useful in the long run. It puts a cap on any one user's use.

Third, your comment about structures and other kinds of interference. Structures and so forth actually increase the information carrying capacity of a medium. They do this two ways - one, by absorbing signals they increase the spatial reusability, and by diffusing signals they increase the value of adaptive space-time coding systems like BLAST. Even thermal noise has spatial structure, which doesn't increase information capacity per se, but by adapting to it dynamically, one can squeeze even more capacity out of a fixed amount of bandwidth.

The key idea here is that "bit transport over EM waves" is not necessarily a rivalrous good. No more than audio speech in the open air.

As I was writing my last comment a thought struck me, if wireless bandwidth is unlimited when we use smart radios and do all the other neat technological tricks the FAQ is talking about, why don't we try to get the FCC to release other thin slivers of the spectrum into the unlicensed domain, ones that are in different parts of the spectrum so they can be used for different purposes. If the FCC would release five or six slivers of spectrum just like the one that WiFi uses then the technology could develop and its use could be demonstrated. There is no need to try and open all of the spectrum, if the spectrum really is non-rival we would be able to do everything we wanted with very limited parts of the spectrum. This of course is not a defense for the way spectrum is licensed today, but it is an idea on how we might proceed to open up more of it so these new technologies can develop.

-Grant M. Henninger
[ dram.teamslack.net ]

I was thinking about interference and rivalness last night and I realized that there were two types of interference, that which is caused by surrounding structures and other objects, and that which is created by other electronic devices. (I realize that this isn't hard to figure out, but I'm a bit slow sometimes.) The first is the type of interference WiFi and other products that use unlicensed spectrum come across, yet the first type doesn't make the spectrum rival because it is not my use that is limiting your use, it is other outside factors. Because there is unlimited carrying capacity on other frequencies not being able to use a specific frequency does not lead the spectrum as a whole to be rival.

It is the second type of interference that would lead the spectrum to be rival, yet it seems as if this second type of interference doesn't exist. So the spectrum wouldn't be rival. When we are talking about interference we need to be sure we know what sort of interference we are discussing.

-Grant M. Henninger
[ dram.teamslack.net ]

Thak you all for reading our FAQ and posting comments. A few quick notes:

1] We are working towards a demonstration project. This will not happen over night. For example, we need end user devices which send, receive and route. Currently the FCC frowns on routers, which makes deployment of a test case in the United States very hard.

2] If eletromagnetic information interfered, pin hole cameras would not work. They do. Read the FAQ carefully on interference. Also please read the supporting documents, esp. those on David Reed's pages. See also the BLAST work on reflection that were once considered a form of "interference".

3] By using underlay technologies, not yet allowed by the FCC, you make it possible to phase in Open Spectrum without requiring a massive one time simultaneous upgrade.

4] Deliberate intereference is what makes fixed spectrum solutions less secure. I want my tax dollars to buy the government the most secure, robust and resilient communications money can buy. I suggest the current fixed spectrum policy does not pass this test.

5] What is the limit of the spectrum's CAPACITY to carry information? David Reed has been looking for years for an answer. We do not know of one. The BLAST experiments suggest it is vastly larger than current approaches would suggest. I suggest you ead up on BLAST. Bob Lucky suggests it is not impossible that it could approach the infinte -- see NY Times article, last paragraph.

6] I suggest you study Motorola's Canopy Technology. It is a significant step above and beyond Wi-Fi in that Canopy offers scalable capacity. Wi-Fi does not. Today Canopy is an off the shelf solution. It works today. It is not OS, but it is another step in that direction.

7] We did not go into either the First Amendment implications of current FCC policy or the changes, pro first amendment, Open Spectrum could make possible. We hope to post comments on the First Amandendment issues shortly.

8] Historians might want to look at the FCC 1981 Spread Spectrum NOI, A very interesting precursor to someof the ideas in the FAQ.

Thank you,

Jock Gill

The whole "Open Spectrum" thing strikes me as "Trust us, we should get rid of all the current rules, everything will be better, technology will fix all the problems. And none of it will cost anything, the market's invisible wand will wave away any problems."

The bit about "signals don't interfere" is (as I and others have mentioned before) crap. That's like saying "unlimited numbers of cars can pass each other on the highway, therefore I can fit an infinite number of cars into my garage."

I see they're now claiming that "Interference — which we've treated as as law of nature — is an artifact of the way radio were designed 100 years ago. If interference isn't an issue, then the reasons we started to license spectrum become irrelevant." Can they give one actually physically implemented example of a radio designed such that "interference isn't an issue"? Spread-spectrum and frequency-agile techniques make intereference less of an issue, but it doesn't go away entirely.

I'm in favor of having some "open" bands where transmitters below some maximum power can be deployed with no licensing or paperwork at all, as a sort of free market experiment/breeding ground, but to say "trash all our current RF equipment and start over with no rules, someone will figure out how to fix any problems" strikes me as either stupid, naive, or dishonost.

I sense a few contradictory points in that FAQ...

For example - interference may be an artifact of the way radios were designed 100 years ago. But this would imply that to avoid interference so as to allow "open spectrum" we need to change radio designs. So far, so good.

But this WILL mean that we will all have to buy new radios and TVs to benefit from the "open spectrum" concept. And, since I can't see any way we can all by them at exactly the same moment, there has to be a migration period - and during that time, "broadcasters" have to send stuff both the old way and the new way. That's going to be more costly than "one way", and that will create requests for compensation. The economic effects of the cutover are also "spend now, benefit later". That requires a fair bit of trust that this will work out.

Technologically, open spectrum might work. But socially and economically, it has all the problems of digital TV.

Other parts are just poorly defined - such as "with the minimum set of rules required to enable the success of a 'wireless commons.' " The problem is - I don't think anyone knows what those rules are, or even how to evaluate sets of rules to see if they are right. These are akin to rules of the road - everyone driving on the right, for example, and knowing about signs, lights, and how to make left turns.

Finally - interference can still occur, especially if it is DELIBERATE interference; that is, jamming. That's why that minimum set of rules is needed before we start out. Imagine the chaos - unproductive chaos - if we declared all areas "open roads", free for any driving in any direction at any speed, without a set of rules to manage the interactions.

Edited by author 01-21-2003 04:06 PM
cypherpunks-

I don't think I agree with you. If you look at question 10 of the FAQ part of the answer says:

Interference — which we've treated as as law of nature — is an artifact of the way radio were designed 100 years ago. If interference isn't an issue, then the reasons we started to license spectrum become irrelevant.

In fact, the core premise that has undergirded our spectrum policy has dissolved: There is no scarcity of spectrum. It does not need to be doled out. On the contrary, there is an abundance of spectrum.

From what I understand you can have any number of signals using the same frequency at the same time, the problem comes when your receiver tries to pick out the specific signal that you want it to. If we changed the way radio works into more like computers, where we have packets of information that have some sort of identifier, like who they are coming from, then I think it might be possible to have an infinite number of signals on every frequency. Of course then you would need to change the radios to make it so you could tell them you wanted the radio station KROQ and not the frequency 106.7.

Maybe each frequency does have a saturation point, I don't know the physics at all, so I don't know. But intuitively I don't see why that would be the case. To me this seems really simple, don't ham radio operators have a similar deal, I think it might even be called 'packet radio', where they use their computer with their radios instead of voice? I believe it even works similarly to the way I just described, although I think it might have a receiver identifier instead of or in addition to the sender identifier. (I just knew that ham radio I wanted to get when I was 10 would have come in handy some day).

-Grant M. Henninger
[ dram.teamslack.net ]

 Isn't spectrum allocated by nationality, as well as by use? In other words, the US has a certain amount of each spectrum "band," which broadcasters in other countries are supposed to avoid, just as American users are expected to stay away from foreign allocations. I seem to recall that each country does its best to use as much as possible of its allocation and even spill over a bit at the edges, so that at the periodic meetings called to review the arrangement, they can make a plausible case for their need for more spectrum.
 The point is, that if this is true, any one country could throw open only a certain amount of the spectrum.
 I hope that those who posted the FAQ will get around to answering the questions and points raised by these posts.

There is one other user of radio spectrum that needs clean frequency space, and cannot cope with people running all over the spectrum: radio astronomy.

Large chunks of spectrum are already unusable, and the (few and narrow) segments left to us are being impinged upon all the time. City lights stop us seeing the stars ourselves. Do we want to seal ouselves off even more from the universe around us?

Radio astronomy kicked off the communications revolution. It would be a sad irony if that same revolution closed the field down as a research and educational enterprise that can be undertaken from any building or garden.

Edited by author 01-21-2003 05:09 AM
This is in response to cypherpunks original post-

The use of the word commons - as in the wireless commons - is the wrong word to use. In economic terms a commons is a good that is not excludable yet it is rival. Nobody can stop anybody else from using it, yet one persons using it would diminish the amount another person could use. However, the Open Spectrum FAQ makes the case that spectrum is not rival. If this is the case (I don't know enough about the technology to know if it's true or not) then spectrum is not a commons, instead it is a public good. Therefore the Tragedy of the Commons will not apply to open spectrum like it would a field for cattle grazing.

As a side note I have made this same argument for intellectual property and so far it has stood up to scrutiny. But of course this all rests on the fact that spectrum is not rival, and on this I am taking David Weinberger at his word.

-Grant M. Henninger
[ dram.teamslack.net ]

Edited by author 01-20-2003 03:43 AM
There's no way in heaven or hell the FCC and NTIA are going to scrap their entire existing allocation plan and replace it with "open spectrum". Dream on.

But there is a logical place for open spectrum -- the Upper 700 MHz Band, otherwise known as UHF channels 60-69. The FCC originally intended to auction the Upper 700 Mhz Band to wireless carriers to encourage next generation services, but the carriers have since become skittish, and have lobbied to delay the auction indefinitely while they determine how to profitably put it to use. After delaying the auction several times, the FCC has finally acquiesced and taken the Upper 700 Mhz Band off the auction block for the immediate future.

Since Congress has decreed that the current UHF occupants can't be ousted until December 31, 2006, when all analog TV transmissions are scheduled to cease, there's plenty of time for open spectrum / cognitive radio enthusiasts to get a movement going -- and to figure out if the whole scheme will actually work.

In all the fuss over open spectrum and cognitive radio, it seems to have been overlooked that the idea is, as far as I know, completely theoretical at this point, an extrapolation based on existing technologies and a few academic papers. David Reed, cognitive radio's biggest advocate, cites a doctoral thesis by Tim Shepard and a paper by Piyush Gupta and P.R. Kumar to justify cognitive radio's future. Both documents are extensively mathematical in nature and address the theoretical possibilities and capabilities of imaginary networks. The Gupta/Kumar paper in particular imagines such a network being constructed of devices in the home, not of distant, rapidly moving, roving transceivers in a variable environment. In other words, open spectrum is still a dream. The engineering work hasn't even begun. As far as I know, there's not a single real world test or example of cognitive radio to point to. (If anyone has any information to the contrary, I'd love to hear it.)

Aside from that, open spectrum has Big Enemies. Wireless carriers, cable companies, and the National Association of Broadcasters, to name a few. If you thought the RIAA was bad, the NAB makes them look like Teddy Ruxpin. Politicians in the US rely so heavily on media exposure to ensure their re-election that they essentially let NAB lobbyists write FCC policy. You can see this happen over and over again, from the Great HDTV Swindle to the destruction of legal microbroadcasting in America. Getting Congress to ignore the threats of the NAB and legislate the Upper 700 Mhz Band as open spectrum will be a Herculean task.

If I were setting an agenda for getting the US to adopt open spectrum, the first thing I would do is forget about the US entirely. Concentrate on Canada. The Canadian government already allows microbroadcasting, and spectrum in Canada is much more sparsely populated than in the US. The CRTC is much more likely to be convinced of the benefits of open spectrum, and once it takes hold there, it would work as a wedge, forcing the US to adopt open spectrum to remain competitive.

It's worth a shot.