My five-year-old daughter has no concept of linear broadcasting – she is genuinely confused as to why she can’t watch whatever, whenever – as she can with almost all the media that she consumes, which comes either via YouTube or on-demand apps. She will be 18 in 2030, the date given in the Lamy Report for security of tenure for the remaining DTV band. Whilst PMSE users are still facing up to the loss of the 700 MHz band, we need to start thinking about what will happen to the DTV band (and by extension our access to spectrum) after 2030.
I had previously subscribed to what I will call the “King Canute” approach to PMSE spectrum – that the PMSE community must do everything it can to hold back the tide against the loss of our current spectrum – but watching how my daughter consumes media has changed how I see the situation. Clearly, anything I could say about the future of DTV is guesswork, but I offer the following observations:
- In 2030, I believe DTV will be a legacy service, so I suspect that we’re looking at more than another progressive loss of spectrum to the mobile phone companies. Furthermore, DTV continues to lag the curve in terms of image standards – which further suggests that its future will be purely as a legacy public service rather than as a commercial prospect.
- Certain territories with historically low uptake of DTT have already begun switching off services. However, I would be surprised if DTV was switched off altogether in the UK – it will be still favoured by senior citizens (who vote reliably more than the rest of us), and the optics of sweet old Mrs. Miggins missing Emmerdale because of the horrible people at Ofcom are not good. Furthermore, for a large change like this, I can see the attraction of a policy option that contains a degree of compromise.
- The amount of spectrum required by DTV could be reduced massively if regional offerings became online-only and broadcasting was moved over to a Single Frequency Network. This would also wipe out the whitespace used by PMSE.
But do the mobile networks really need this spectrum? There is plenty of evidence that estimates for mobile spectrum demand are unrealistically high. Furthermore, in high demand scenarios, lower band spectrum (the DTV spectrum) is of limited use – it goes too far! The only way to meet demand in those scenarios are is large number of short range (higher frequency) cells – which is exactly what is already done at festivals and sports events.
However, I believe that the pattern of bidding the US 600 MHz auction gives some insight in to what’s really going on. Irrespective of technical need, the income from spectrum auctions is attractive to administrations, and there are no major actors to challenge the prevailing wisdom on mobile spectrum demand. Correspondingly, the network operators will be under pressure from their shareholders to be seen to be keeping up with competitors in the acquisition of spectrum. So, as there is no brake on the system, while the prices paid for spectrum have dropped significantly, it will continue to be offered at auction, and it will continue to be bought.
There is also, I think, a measurement problem here: whilst the utility of spectrum continues to be predominantly understood in terms of easily-measurable first-order economic effects, the apparently optimal outcome will always be to flog it to the people with the deepest pockets. Whilst I’m sure regulators understand the paucity of this approach, I suspect they lack the political cover for a more nuanced approach.
Bearing the above in mind, I would suggest that it is highly likely that the amount of DTV spectrum available for PMSE shortly after 2030 could be low enough to represent a crisis for large events. King Canute will be well and truly underwater, and I believe that we need to look for new approaches to securing spectrum for PMSE.
I should add that this point that I do not mean to criticize lobbying efforts made on behalf of the PMSE industry up to this point. The needs of PMSE users are better appreciated and carry more weight in the UK than anywhere else in the world, and this down to the exceptional efforts of a body of extremely dedicated people (you know who you are…). I do think, though, that we need a new approach to face the post-2030 challenges, and I offer several suggestions as to how we might approach it:
- We should stop thinking in terms of “our spectrum” – whilst everyone’s taking the Canute approach, spectrum access is a zero-sum game. We need to remember that spectrum belongs to the citizens of the country and is regulated for everyone’s benefit – this public interest is important, and we need to recognise it as a starting point.
- We need to embrace new spectrum opportunities – I absolutely understand and respect people’s hesitancy about new, unproven PMSE bands; however, I do feel that there is a tendency to reject them on the assumption that this improves the case for defending our current allocation – again, we need to let go of Canute.
- PMSE needs to become a broader church – we should be moving towards an inclusive, technology neutral approach to short-term, short-range technically-assigned licensing. PMSE needs to lose the “special” and become are larger presence by brining other applications in to our space – on our terms. This will also remove regulatory barriers to innovation for PMSE manufacturers.
- We should be finding common cause with other spectrum users – a shared commitment to technical transparency and the public interest could open up any number of opportunities – particularly as it would help us to capitalise on what is arguably PMSE’s greatest extrinsic asset as a spectrum stakeholder – we’re attractive as a sharing partner. Use is hands-on, licenced, low power, and non-ubiquitous. You know where we are, and you can get hold of us. Also, a significant lobby largely aligned with the objectives of the regulator is essential for this next point:
- We need to change perceptions of what the mobile networks are, and therefore how they should be regulated – over the last two decades, how mobile networks are used has changed almost completely; the fact that you can use them to make telephone calls is almost incidental. Whilst it’s arguable that the majority of wireless data will still be carried by Wi-Fi (there’s a separate blog post to be written on how badly we need more spectrum for that!), I suspect that the mobile data networks will continue to become the backbone of more and more services, looking more like ubiquitous public utilities – and we need to make the case that they should be regulated as such.
The crux all this is that I suspect, post-2030, as well as taking advantage of new spectrum opportunities, for large events PMSE users will need to find a way to share spectrum with mobile networks under a Licenced Shared Access scheme. Current wisdom – from both PMSE users and mobile network operators – is that this is impossible. And the current direction of travel on LSA is for private contractual arrangements between incumbent and sharer – something that the PMSE industry won’t get a sniff of. But I think that this is Canute rearing his ugly head again – if we accept (as I think we have to) that mobile is going to dominate the UHF bands, we need to push for a regulatory environment where mobile networks are treated like a public utility, and access to sharing spectrum and/or infrastructure is open to as diverse a pool of secondary users as possible.
And it should be as wide a pool of users as possible – all the spectrum users put under pressure by the dominance of mobile. Sitting with our arms folded and only defending our own turf can only get us so far – like a certain Anglo-Saxon king. Special pleading by a single sector is easy to dismiss – a genuinely open and inclusive approach to spectrum access is not.