“To generalize, it is often true that studies will be promoted that tend to support the policy inclinations of the Chairman, under whose direction, after all, every draft decision is made.”
“[S]tatistics can lie. But cast as ‘studies’ by commentors, they take on the weight that a decision maker chooses to make of them.”
– Daniel Brenner
As a follow-on to its National Broadband Plan, the FCC last year released a Technical Paper intended to validate the Plan’s prediction of a 300 MHz mobile-broadband spectrum deficit by 2014. The Paper describes a spectrum requirements model that totals current spectrum assigned to mobile broadband and applies a multiplier based on expected demand, taking into account expected increased tower density and improvements in air-interface spectrum efficiency. The model’s result is a predicted deficit of 275 MHz in 2014, which rounds to 300 MHz. On the way toward that result, however, the analysis uses just a few of the available data forecasts, ignores offloading of macrocell data to Wi-Fi and femtocells, and assumes the continuation of flat-rate plans for consumers. Some of these oddities I noted in a post at the time. I had hoped the FCC would make the Paper a subject of public comment. That hasn’t happened. So, I’ve looked at the Paper in more detail. I find that when looking at the above factors in a more realistic manner, predicted spectrum requirements go down significantly.