Use It or Lose It : Google makes a play for part of the 3.3 GHz amateur band

I've presented several times at Pacificon on the topic of spectrum auctions and the threat to amateur radio's allocations.  In my talk Ham Radio Must Die (So It Can Live) at Pacificon 2010, I specifically talked about the threat to the 3300 - 3500 MHz band.  The threat increased exponentially when the FCC converted the 3500 MHz band to the Citizen's Broadband Radio Service for use in heterogenous networks and densified mobile data systems, and now Google is asking the FCC for permission to test a wireless last-yard technology for delivering Google Fiber service in the upper half of the 3300 MHz band.

In my Pacificon talk I pointed out that the 3300 MHz band is almost never used, and the possible auction valuation to commercial users is very high.  If we presume a $2 per MHz-POP auction price (which is about what the AWS-3 commercial carrier spectrum went for) and a US population of 320 million, the value of the 3300 MHz band is $128 billion.  The AWS-3 auction, record-setting though it was, only raised $47 billion.  For a government $19 trillion in debt, $128 billion isn't much but it's a start.  Google could afford to buy that spectrum, and with the unprecedented access it enjoys due to the revolving door between itself and the White House, it has the political clout to make this happen.

There are just over 800,000 licensed amateur operators in the USA.  $128 billion puts the value of our 3300 MHz band at $160,000 PER OPERATOR.  For something we never use.  I'd be willing to say (and I'm being very charitable in this estimation) that 0.1% of all US operators make use of the 3300 MHz band.  That's $160 MILLION PER ACTIVE OPERATOR.

I'm not saying what Google's doing is right.  If you think it's wrong, file comments with the FCC.  I'm saying what they're doing is not surprising, and that I predicted this would happen six years ago.

Thoughts on GoTenna

[Update Nov 30th 2016: The ARRL has asked Bay-Net to attempt a modification of the GoTenna for use in the amateur radio bands.  Also I should note that since I wrote this article, GoTenna has backed off on their performance claims to levels which are more in line with reality.  I'm looking forward to seeing the inside of these units and doing some real world testing.]

[Original Article posted July 20th 2014] GoTenna seems to be doing a good job of generating "buzz" for this proposed product - a cursory search of Google+ and Facebook turned up a HUGE number of posts.  Many people have forwarded this to me via email or social tagging.  The proles are calling it "Text messaging for CB radio".  facepalm

GoTenna's radio works in the MURS band - three channels at 151 MHz and two channels at 154 MHz.  Given what I know about their product, MURS rules will require them to operate on the two 154 MHz channels.  They say the product emits 2 watts, which with a 3 dB antenna would be 4 watts effective radiated power (ERP).  At that level they're going to have to undergo safety exposure testing, which is expensive - I guess this is why they're crowd-funding the project.

To be fair - GoTenna has an engineering advantage in that they're not dealing with large data streams - they send GPS coordinates, text messages (< 200 characters), and it's not real-time.  They claim 20 - 30 mile range in a "typical" urban environment - I'm struggling with the idea that something which emits 4 watts ERP can give you 20 - 30 mile urban range.

Coding gain from a forward error correction engine could help, but I can't imagine an effective coding gain of more than 10 dB.  (The device is battery-powered, and claims a 30 hours continuous on time - processors which could give them > 10 dB coding gain are going to wipe out a battery fairly fast.)  Let's be generous and say their coding gain 10 dB - this gives effectively 40 watts.  I suppose depending on your definition of "urban" this might be enough to cover 20 - 30 miles.  A more reasonable coding gain will be in the 6 dB range, which means effectively 16 watts - and I don't see 16 watts covering urban areas very well.

Here's a post on Make.com from Raphael Abrams, the GoTenna RF designer: http://goo.gl/L5rZ2e

GoTenna claims that the device can be used in-flight on commercial airliners.  This is a Bad Idea™, and I don't see the FAA signing off on this any time soon.

Lots of speculation on GoTenna right now in the radio community, but not many answers to the head-scratcher questions.

Spectrum inventory and reallocation snowball keeps growing...

Recently on the 9AM Talk Net mailing list Kristen K6WX noted an AP article "Cell phone mania forces scramble for more airwaves". This article came out on the same day Mashable reported that AT&T has stopped selling the iPhone in New York City; presumably because AT&T is finding that their network can't handle the data traffic. The AP article reports that the CTIA is asking the FCC for an additional 500 MHz of spectrum to handle current and anticipated capacity needs.

FCC chairman Genachowsky began talking about a looming spectrum crisis back in November, so it's not a surprise to me that a month later AT&T is shutting off iPhone sales in one of the most densely populated and highly-mobile cities in the USA; what better way to build populist outrage which will encourage Congress to support bills such as John Kerry's SB 649 "Radio Spectrum Inventory Act" and Henry Waxman's companion HR 3125? I wrote about SB 649, and how it potentially threatens amateur radio, back in March 2009.

Another recent development from the FCC is an effort which would terminate most or all over-the-air (OTA) broadcast television. Theoretically; if the FCC could migrate all OTA TV to cable, wired broadband, or some sort of multiplexed digital wireless system this would free up 300 MHz of spectrum. CTIA is asking the FCC for 500 MHz of spectrum, so the FCC would still need to locate 200 MHz of additional spectrum. It's unlikely that any amateur bands below 1 GHz would serve the cellular industry's needs, but consider our allocations above 1 GHz:

• 1240 - 1300 MHz = 60 MHz
• 2300 - 2310 MHz = 10 MHz
• 2390 - 2450 MHz = 60 MHz (In reality; 10 MHz see [a])
• 3300 - 3500 MHz = 200 MHz
• 5650 - 5925 MHz = 275 MHz (In reality; 0 MHz see [b])

[a] It's unlikely that the FCC would disturb the lucrative Wi-Fi business, so I presume that 2400 - 2483.5 MHz will be off-limits i.e. this leaves 10 MHz available for reallocation.

[b] This band overlaps with the UNII 5.7 GHz band's channels 128 - 165; so again the Wi-Fi (802.11a) industry will likely trump any CTIA interests.

Thus I'm going on record today with my prediction that 3300 - 3500 MHz is the band likely threatened by SB649/HR3125 or future variants. Of course it could be argued "So what?" and you'd be right; in all honesty how many hams are active in the 3300 - 3500 MHz band? A few guys in the 50 MHz And Up Club? 200 MHz of spectrum will bring in a LOT of money in a spectrum auction.

And the FCC will need that money, because apparently the FCC is planning to pay the NAB and TV broadcasters (who never paid for, and thus don't actually own, their spectrum) about $12 billion to shut down OTA television and migrate to the aforementioned cable, wired broadband, or multiplexed digital wireless system.

An additional $9 billion would be spent (think "DTV Converter Box Coupon" program -- on steroids) to migrate households to the new system. So in the end; the FCC wants to spend $21 billion dollars to ensure that the cellular industry has room to grow. Good thing Congress recently raised the debt ceiling to $12.4 trillion, eh?

I suppose that in the long run this makes sense; the tax revenues from adding more mobile phone subscribers is potentially huge; especially if the IRS succeeds in making it harder for taxpayers to count mobile phone expenses as a deduction. What frosts me is the idea that the NAB, who didn't pay for their spectrum to begin with, stands to reap a $12B windfall. Good work if you can get it.

S 649 : Radio Spectrum Inventory Act

I posted this because I think Senate Bill 649 : Radio Spectrum Inventory Act (intro'd by Sen. John Kerry-Heinz, D-MA) is the first shot in a battle I've been predicting for some time; the application of populist politics towards spectrum management and allocation. You need only spend an hour tuning around with a decent all-band receiver to discover that the vast majority of spectrum is nothing but static. The real targets of this "spectrum socialism" are the big guns; broadcasters, the military, and even divisions of the government itself (such as NTIA) which has been "warehousing" spectrum for years while hypocritically requiring auction-winning licensees for cellular/PCS spectrum to demonstrate high levels of loading; i.e. subscribers.

Radio amateurs, I believe, are especially at risk from unintended consequences if this bill becomes law. I've previously blogged that many amateur radio frequencies are largely unused. Some amateur bands; such as 1.25m (aka 222 MHz) and 23cm (aka 1.2 GHz) are used only in certain regions of the US. (1.25m is popular in the Los Angeles area because 2m is so laden with bootleggers and jammers it's effectively become CB radio.) One reason for this is that the radio manufacturers are not selling equipment for these bands; the last 1.2 GHz equipment was the Kenwood TS-2000X which was introduced 9 years ago. Alinco is reported to be releasing a 1.2 GHz handheld, but that's not enough to drive adoption of the band. If the RSIA is an attempt to document usage of spectrum as a precursor to re-allocation based on purpose and usage, then 23 cm is one of the most likely targets for re-allocation once the limited use of that band becomes public knowledge. Our only hope is that the proximity of 23cm to radio astronomy likely precludes the allocation of that band to commercial use; but it could still be lost.

Equipment availability is one issue but at a higher-level the problem amateurs face with RSIA is simply that there are fewer radio amateurs than there were in the past; younger people prefer communicating via the Internet and if they do express an interest in amateur radio they're all-to-often turned off by the arrogance of a few hygiene-optional curmodgeons who tend to hang around at club meetings and hamfests complaining loudly and constantly about how the demise of Morse code testing will lead to the death of amateur radio; ignoring the fact that it's their own urine-soaked elitism that's probably a key element in keeping younger people from the hobby. So when faced with a trend towards populist politics and thus policies, a Congressional Budget Office estimate that the federal deficit may exceed $1.5 Trillion dollars, and huge swaths of amateur spectrum laying increasingly fallow as the number of amateurs continues to decline; the likelihood that the government will pull spectrum from amateurs and attempt to auction it off as a revenue source is increasingly likely. It's critical that we change the face of amateur radio (even if it means slaying a few sacred cows) in order to attract licensees or the day will come that some lawmaker will decide that it's politically low risk to start pulling spectrum from amateurs in order to pay off the deficit.

Looking forward...

With 2008 officially behind us I've spent the last few weeks (as I'm sure many did) contemplating where we've been and where we're going. There seems to be a pervasive sense of relief, some trepidation about what 2009 might bring, but also a growing sense of hope that we're leaving behind a lot of baggage and moving into a period of revitalization and renewal. I believe that it's human nature to think that the troubles of today are unusual, unprecedented, and thus we long for days of old when "life was simpler". The reality is that in each generation there occurs a crisis of some sort that must be addressed. As the saying goes, "This too shall pass". Fortune, bad or good, is a fleeting thing. Our forefathers struggled, we struggle, and I guarantee our children will struggle. In between these struggles are periods of great happiness, and periods relative calm which often pass by almost unnoticed. From an amateur radio perspective I think 2008 will be remembered as a period of struggle, and hopefully in hindsight will be seen as a time when things began to change.

Amateur radio struggled during 2008. We ended the year with the lowest number of sunspots since the early 1900's. The sun's been so quiet for so long that any time the sunspot number isn't zero, or the solar flux index climbs over 70, everyone gets excited. The quiet surface of our sun was echoed in many ways throughout amateur radio. At the 2008 Dayton Hamvention (and smaller events such as Pacificon 2008) equipment manufacturers offered almost nothing new. In some cases popular equipment such as the Kenwood TH-D7A APRS handheld was suddenly discontinued. (It's speculated that certain parts in the TH-D7A were not ROHS-compliant and Kenwood couldn't get drop-in replacements.) It's worth noting that two of the biggest product offerings of 2008 were the Icom's IC-7200 HF transceiver, and Yaesu's VX-8R quad-band APRS handheld. The IC-7200 has "new" features such as (drum roll please) a USB port for audio I/O and control! How innovative! (I'm being sarcastic.) The VX-8R was shown at Dayton in early 2008 but wasn't actually shipped to customers until mid-December. It contains cutting-edge features such as APRS - which works if you buy their "GPS-Mic" which is insanely large and quite expensive. How is it that my Blackberry Curve can feature a high-contrast LCD display, QWERTY keyboard, battery, multi-band voice/data radio and a GPS in a housing that fits in my hand, but Yaesu needs that much room just to house a microphone and GPS? To add insult to injury; I had an on-the-air QSO with KI6CRL once he finally received his VX-8R after several months on a waiting list -- and it turns out it's got a thermal problem where his transmit audio level drops to nothing as the radio gets hot. This is the hot (no pun intended) new product people waited almost a year to buy?

Perhaps the Japanese manufacturers simply observe that amateur radio is struggling to grab the attention of younger people and believe that it's therefore not capable of producing a good return on investment. I would say that this is both a correct and incorrect observation. It's correct that in its current state amateur radio is largely unattractive to younger people. It's incorrect in that it doesn't take into account the concept of "making a market"; more on this later.

Why are young people not getting into amateur radio? It's not because it's technically challenging; you need only look at the surging popularity of the Maker Movement to know that technical innovation is alive and well among the younger generation. The fact of the matter is that it's our own Luddite mindset that's at fault: It's hard to recruit younger people into a hobby where the equipment manufacturers have only just this year discovered that USB is a viable interface option! I once watched a guy at Ham Radio Outlet whine for five minutes about how hard it was to get RAM modules for his 486 laptop; and amazingly he was finding a sympathetic audience. (By the way this happened in 2006, not 1996.) I was once chastized in an online discussion group for promoting the proliferation of APRS iGates; devices that route packet radio traffic onto the Internet -- my detractor stated that he felt "anything which blurred the lines between ham radio and the Internet" was a bad idea. Finding ways to revitalize older technology with the most pervasive technical revolution since the telephone is a bad idea? Give (unto) me a break.

Even when amateurs use computing they often miss the point. Many people who use APRS are still using the DOS version. One of the most popular APRS applications is UI-View32; the author of which (G4IDE) has been dead for several years -- and specifically asked that upon his death the source-code be destroyed rather than be placed into the public domain as an Open-Source project. How about despite the fact that it's marketed as a stand-alone APRS/packet solution Kenwood continues to build its TM-D710A without a USB or even a PS/2 keyboard jack. Simply put: Amateur Radio can't reach a younger audience until it integrates modern technologies and embraces development/collaboration concepts such as Open Source that younger people associate with "good technology".

You might be saying, "So what? Who cares if we fail to attract and retain younger people into amateur radio?" The answer is simply; we stand to lose everything. The current mood in Washington DC is already somewhat negative towards the FCC; there have even been calls for Obama to dismantle the FCC and implement a new innovation-centric technology governance model. Amateur radio is nothing without our spectrum allocations, and given how we're not really using the spectrum we have it's likely that under the new FCC leadership we'll lose some spectrum in the coming years; someone's going to have to pay back that $700 billion bailout and spectrum leases can be auctioned off to raise cash. As time progresses the incoming FCC leadership is going to be increasingly younger, and likely resistant to the idea of leaving large swaths of potentially cash-generating spectrum in the hands of older amateurs who insist on using out-dated computing technology that increasingly doesn't integrate with modern systems.

So how can we solve this problem? How can amateurs help "make a market" and create a potential for vendors to recoup long-term return on their engineering investment? First and foremost we have got to actively embrace modern computing technology, Maker-style hardware re-purposing concepts, and an Open Source licensing model for software and firmware. This means that:

• All amateur radios going forward should have USB ports, and if appropriate should support USB host-mode.
  
• I should be able to plug my HF transceiver or my handheld into my laptop and control it or configure it over USB.
  
• I should be able to plug a keyboard into my TNC-capable rig and type text without a computer.
  
• Rather than a proprietary interface, and a proprietary configuration app, all amateur radios should contain an on-board web browser (just like a $30 Linksys router does) running from an embedded controller and an Ethernet jack. I should be able to connect the radio to my LAN, and ideally I should be able to plug in a USB Wi-Fi dongle and attach to the radio wirelessly.
  
• The embedded controller should be some kind of standard (ARM-core, etc) and the operating system firmware should be Open Source and modifiable; picture OpenWRT or some variant.

We must start doing this now, or by the time we realize our mistake it will be too late. I firmly believe that a radical departure from our current mindset is the only way to move amateur radio forward.