The open spectrum group is proposing a model where both open wireless networks and property-based spectrum systems can operate in parallel, as there is currently no evidence showing which is better. They argue open networks encourage innovation, are more secure due to decentralization, have lower long-term costs for users, and that spectrum is not truly scarce. However, they recognize property rights may also have benefits. If their demands to experiment with both models are rejected, the group may stop advocating for open networks, increase public pressure through media, or lobby manufacturers to advocate on their behalf in Congress.

1. Q1. Can you justify the rationale for the demands being made by the open spectrum group?
Response :
 Open spectrum group is not convinced that property based system is best approach in long term while they
also accept that there is no empirical evidence to conclude this.
 Therefore they are proposing a model wherein both Open Wireless Network (or Spectrum Commons) and
property right based system should run in parallel until there is sufficient data points to conclude which
model is better and why.
 They also think that Open wireless network model is more fertile ground for innovation as has been normally
seen in any open system as compared to closed system like property right.
 Given that end user system is decentralized and there is no one single point of failure, it is more secure and
difficult to bring down the entire system. Parallel drawn with internet system which is also decentralized and
could withstand the testing times like 9/11 when all other communication channels went down.
 Since Open Wireless approach is based on one time equipment cost whereas Property right based system is
rental model, there is strong likelihood that overcall cost of ownership for a fairly long period will be less in
case of Open Wireless approach. Also this end user devices are huge in number which can be exploited by
manufacturers to bring to bring down cost further by using economy of scale.
 They also argue that spectrum does not have some of the property of a scare resource which is subjected for
property rights. There are technology and ways by which additional users themselves become contributors to
the supply rather than only consuming it.
 While there are no conclusive evidences but there are theoretical inferences that overall cost of
communication which includes equipment cost, displacement cost and overhead (administrative and
transaction), is less for Open Wireless system. Continue for Q2 =>

2. Q2. What do you expect the outcome to be if all their demands are rejected?
Response : Proponent of Open Wireless Network are making following very specific demands:
 Encourage innovation in end user devices: This will allow equipment manufacturers to make a credible
investment in devices that rely on commons-based strategies:
• “Part 16/Meta-Part 68” equipment certification, with streamlined FCC certification processes, or
• Privatization to a public trust that serves as a non-governmental standards clearance organization
 Leverage U-NII for Open Network : Aligning U-NII Band regulations for the 5 GHz range for the needs of open
wireless networking by
• Clearing those bands from incumbent services,
• Shifting that band to one of the models suggested for the 2 GHz range
 Leverage unutilized/available bandwidth : Permitting underlay and interweaving in all bands by
implementing a general privilege to transmit wireless communications as long as the transmission does not
interfere with incumbent licensed devices;
• Underlay relates to ultrawideband (“UWB”) communications perceived as “below the noise floor” by the
incumbent licensed devices, given their desired signal-to-interference ratios.
• Interweaving relates to the capability of “software defined” or “agile” radios to sense and transmit in
frequencies only for so long as no one is using them, and to shift frequencies as soon as their licensed
user wishes to use them. Continued…

3.  Leverage 50 GHz band : Opening higher frequency bands (>50 GHz) currently dedicated to amateur
experimentation to permit unregulated commercial experimentation and use alongside the amateur users.
This will allow a market test of the plausible hypothesis that complete lack of regulation would enable
manufacturers to develop networks, and would lead them to adopt cooperative strategies
 Flexibility to experiment with other proposed models : Increase the flexibility of current spectrum licensees
to experiment with market-based allocation of their spectrum which includes adoption of the modified
property right proposed by Faulhaber and Farber
 Option to revisit policy decision : Subject both property rights sold and commons declared to a preset public
redesignation option, exercisable no fewer than, say, ten years after the auction or public dedication, to allow
Congress to redesignate the spectrum from open to proprietary, or vice versa, depending on the experience
garnered.
These are very specific demands to ensure that government agrees to experiment with both models – Open
Wireless Network system and Property based system instead of going with big-bang auction approach with later.
I presume that these are hard demands to bring government to negotiating table and get buy-in for more time.
While they will more happy if all there demands are met but I presume that they would also be willing to accept
middle path where some of the demands are met. If all of their demands are rejected, probable fallout could be:
 Accept the reality as-is as stop building case for Open Wireless Network
 Create more pressure by building public perception using media channels
 Use some of end user device manufacturers to lobby hard with congress