Three Invalid Assumptions that Make the FCC’s Spectrum Requirements Model Skew High « Steven J. Crowley, P.E.

“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.

via Three Invalid Assumptions that Make the FCC’s Spectrum Requirements Model Skew High « Steven J. Crowley, P.E..

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