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CHAPTER VI - International Harmonization of Spectrum Allocations

The International Telecommunication Union allocates specific spectrum bands for high-level uses (fixed satellite service, mobile service, etc.). This process happens every few years (currently on a 4-year schedule) at the World Radio Conference (WRC), which lasts for four weeks and involves 192 countries. The WRC may also identify bands for certain uses, such as International Mobile Telecommunications (IMT).

There is an important difference between allocations and identifications. Under the ITU treaty, the only activity described is allocation and there are a limited number of allocation categories, such as Fixed Service, Mobile Service, or Fixed Satellite Service. There is also the practice of “identification,” within an allocation, identifying spectrum for a particular set of uses, such IMT. While identification is commonly used, it has no status under the treaty. Identification may appear as footnotes in the table of allocations and some countries use identifications as guideposts for their national spectrum policies. It is necessary to have an allocation (e.g., Mobile Services) before obtaining an identification (e.g., IMT).

Both allocations and identifications are important to U.S. spectrum policy, and to promoting global harmonization, thereby allowing services and equipment to be used in the same or similar bands globally. For example, there are spectrum borders as well as geographic borders, and when you take your phone from one place to another, it helps a lot if the spectrum allocation is harmonized. For users who have medical applications on their devices, the availability of harmonized spectrum and the ability to use a device globally may be life-saving. The priority is always to get the allocations in place, said a participant; allocations are more important than identifications.

World Radio Conference 2019
The WRC-19 ran from October to November 2019, with decisions on numerous international spectrum issues of importance to the United States. The United States left the conference with more globally harmonized 5G spectrum, said Jennifer Manner. Officials at WRC identified significant spectrum for IMT and for High Altitude Platform Services (HAPS). In addition, satellite operations were provided with flexibility for Earth Stations in Motion (ESIMs) to be used on ships or planes. The WRC also allocated more spectrum for satellites and for RLANs (Radio Local Area Networks). On the regulatory side, the WRC adopted milestones for Non-Geostationary Satellites (NGSOs) to prevent speculative filings. The conference also adopted future agendas for WRCs in 2023 and 2027, including which bands should be studied for IMT going forward. These bands are below 10 GHz and include the C Band.

There is a certain amount of flexibility in the implementation of the results of WRCs. Sometimes there is a global agreement, and everyone agrees that a particular band is going to be used for a particular service. Alternatively, there may be Region 1, Region 2, or Region 3 agreements that a particular band is going to be used for a specific service. In the absence of a regional agreement, there may be a footnote that says this is how it is going to be in the United States, or the United States and Bolivia, for example. The United States makes use of footnotes when it is not in lockstep with the rest of the world or the region. Without a footnote (if the United States operated differently from the rest of the world) there would be no protection at all, and the service would be operating on a non-interference basis, which would be highly unusual.

This flexibility has historically been important because there is a tension between harmonization and the United States moving with policies in advance of the rest of the world, noted Michael Calabrese. On balance, however, identifications have had more benefits than drawbacks for the United States. They are also helpful in allowing the United States to drive a global framework, such as a global market for equipment, said Steve Sharkey. Identifications have been reasonably successful in building a focus on which bands are used for certain services and helping to drive policymaking in the United States and other countries.

Global Harmonization and the Value of the ITU Process
Building on the discussion of CBRS, the group considered whether dynamic sharing would eliminate the need for global harmonization, especially over time. Dynamic sharing requires that devices have recourse to more than a single frequency assignment or frequency plan, stated Preston Marshall of Google. For example, CBRS radios must support the full 150 MHz. In addition, dynamic sharing works better with Time Division Duplexing (TDD) than with Frequency Division Duplexing (FDD). Charla Rath said that over time (i.e., 20 years), these issues could be resolved, and then dynamic sharing would reduce the value of global harmonization. There would still be a need for some kind of global framework for the bands to be supported in the devices and have the infrastructure to take advantage of dynamic sharing, though perhaps 3GPP could provide part of this framework. In addition, for some government services, such as radio astronomy, it may be essential to have particular frequencies allocated worldwide, and there is no substitute for the ITU to address this need.

Global harmonization has always been important to some services, such as satellite systems. And it is increasingly important to terrestrial mobile services. Even though the people who work with the ITU complain about the WRC process and the difficulty of working with the organization, it performs an important function for spectrum-based services, and the ITU/WRC process is the best of the available alternatives.

Nonetheless, there are certain disadvantages to the WRC process. The main issue is that it consumes significant federal government and private sector resources. U.S. delegates are supposed to commit to be at the WRC for a month. And there are seven study groups, which meet for ten days, three times a year. An additional challenge for the United States is that, by statute, the WRC ambassador cannot be appointed until six months before the WRC.

At past WRCs, the United States was seen as a primary leader in policy development. Now, the United States has lost its primacy and is instead seen as one of a group of leaders, together with China, Russia, India, the United Arab Emirates, France, and a couple of others. But without a country acting as the primary leader, regional groups have become more important and Manner reported that the regional groups negotiated the final outcome on big issues at WRC-19. Harking back to the China discussion, Manner stated that Huawei is doing a brilliant job at the ITU and had approximately 77 people at the conference, not all of them identifiable as Huawei. She also said that the Huawei representatives and China in general expanded their leadership roles at the most recent WRC.

Some participants suggested that government periodically re-evaluate participation in the World Radio Conference. Numerous people have questioned whether getting 192 countries together for four weeks is the right use of the ITU, or whether there is a better way to review and revise the Radio Regulations. As an alternative, Commissioner Michael O’Rielly has suggested using the G-7 to establish international spectrum allocations. Other vehicles might include the private sector standards setting bodies, such as 3GPP and the European Telecommunications Standards Institute (ETSI), the European standards body. However, standards setting bodies are led by equipment vendors, such as Nokia, Ericsson, and Huawei, and lack government input. Further, federal uses will not be standardized through private standards bodies, stated one participant. When governments are trying to protect important government services, the ITU is better than a private standards organization because governments have a voice in the ITU but are observers at 3GPP. In addition, the importance of a government use such as radio astronomy, particularly if it is competing with a commercial use such as high-density fixed satellite service, is more likely to be recognized in a forum like the WRC. Private standards-setting bodies such as 3GPP also lack transparency, making it difficult for academics and civil society organizations to understand what is going on, according to Dale Hatfield of the University of Colorado at Boulder.

There is a trade-off between the value of coordination and the cost of coordination. This trade-off is different according to the services (satellite versus mobile) and the users (commercial versus government). For instance, coordination can yield economies of scale, which are valuable. Satellite values economies of scale, and obtains additional value from the coordination process, because many satellite systems operate globally and cover multiple countries. Additionally, the ITU process is used by the United States to signal where it is going, and the United States tends to be in the forefront of new spectrum uses. Historically, the United States has frequently been several steps ahead of the rest of the world, pioneering a new use for a given band, as with PCS spectrum in the 1990s, 700 MHz in the 2000s, or 600 MHz in the 2010s. Occasionally, the WRC process helps push the United States forward, as with Advanced Wireless Service (AWS-1).

The costs of the ITU process include the need for serious resource commitments (including both funds and sending people to the conference for a month and preparatory meetings), as well as the economic cost of spectrum not being available, or not being available as soon as it might otherwise have been. In addition, there is the need for vigilance to measure rigor in the process. In the end, for satellite services, the value of global harmonization and other benefits of the ITU process far exceed the costs. For government users, similarly, the WRC process is likely to be significantly better than available alternatives in which the government does not participate in the same way.

The group agreed that the value of the ITU process currently appears to outweigh its cost because it creates the opportunity for coordination (and attendant benefits) and there is flexibility in implementation. The alternatives to the ITU process appear to be less desirable, particularly those that involve private sector groups such as 3GPP. To paraphrase Winston Churchill, “The ITU Radiocommunication Sector (ITU-R) is the worst form of coordination, except all those other forms.”

 
 
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