ORI’s Contribution to FCC Technological Advisory Council


Open Research Institute contributed to the US Federal Communications Commission Technological Advisory Council final report for the 2024-2025 term. A high-level summary of ORI’s final draft contribution to the report is presented here.

We describe how spectrum sharing models must evolve to meet growing demand, particularly focusing on terrestrial-satellite integration. The core thesis suggests we’re experiencing a crisis in current spectrum management that requires transitioning to a new “Era 4” model incorporating AI/ML automation and market-based mechanisms.


Historical Evolution of Spectrum Management

We identify three distinct eras of spectrum management.


Era 1 (1890-1912): Unregulated Model – A “loudest-served” system with no regulatory oversight, which collapsed following the Titanic disaster due to communication congestion.


Era 2 (1927-1981): Command-and-Control Model – Centralized FCC authority making static allocations based on “public interest.” This system struggled with emerging technologies like FM radio and cellular networks.


Era 3 (1993-present): Market-Based/Flexible Use Model – Introduced spectrum auctions and flexible licensing, but now showing signs of regulatory overload and crisis.


Evidence of Current Crisis


Several indicators suggest Era 3 regulatory models are failing.

219 MHz Band Limbo: Years of regulatory deadlock between amateur radio, commercial, and federal interests with zero amateur activity despite allocated rights


C-Band Aviation Disputes: $81 billion auction created interference concerns with radar altimeters, requiring presidential intervention


Inter-agency Conflicts: NTIA and FCC reaching opposite conclusions on identical technical evidence (Ligado case)


Reallocation Resistance: Broadcasting industry claiming all “low hanging fruit” has been picked from spectrum repacking


Technical Challenges in Terrestrial-Satellite Sharing


We highlight complex coordination requirements across multiple services in bands like 7.125-8.4 GHz, including Fixed Satellite Service, Mobile Satellite Service, and various terrestrial services. The SiriusXM situation exemplifies ongoing interference challenges between satellite and terrestrial broadband services.

AI/ML Enhanced Spectrum Management

The report positions AI/ML as essential for Era 4, comparing it to sophisticated air traffic control for the electromagnetic domain. Key capabilities include real-time spectrum sensing and occupancy analysis, dynamic allocation based on interference patterns, pattern recognition for optimization, and automated coordination at scale beyond human regulatory capacity


However, the report recommends against mandating specific AI/ML technologies, favoring technology-neutral approaches.


Proposed Era 4 Solutions


Band Managers and Spectrum Bucks: Government exits direct allocation, appointing non-governmental band managers who negotiate usage using a “Spectrum Bucks” currency system. This would enable both commercial and non-commercial users to coexist through market mechanisms.

Amateur Radio Model: Highlighted as a successful example of dynamic spectrum sharing through self-regulation, technical excellence requirements, and community governance. Amateur satellites demonstrate effective secondary service operations and have pioneered numerous technologies later adopted commercially.


Regulatory Sandboxes: Supplemental Coverage from Space (SCS) is the first terrestrial-to-satellite spectrum leasing framework, creating economic incentives for cooperation rather than just technical coordination. This hybrid model enables spectrum reuse in the same geographic areas.


Key Recommendations


Improve Spectrum Sensing: Establish independent measurement networks through citizen science projects, public-private partnerships, and dedicated monitoring systems to provide transparent occupancy data.


Create More Regulatory Sandboxes: Use controlled environments to test new sharing models before broad deployment, building on SCS and amateur radio examples.


Optimize Satellite Uplink Sharing: Prioritize sharing arrangements for uplink services while providing separate allocations for downlink services, recognizing the different interference characteristics.


Develop HetNet Principles: Create coordination algorithms that leverage satellite orbital mechanics and optimize handoffs between terrestrial and non-terrestrial networks.


The report concludes that the complexity and scale of modern spectrum management demands a paradigm shift toward automated, AI/ML-enhanced systems that can handle what human regulators cannot, while maintaining proven principles from successful sharing models like amateur radio.

[We’ll share full versions of all the charter items when the final report is approved by the TAC. This should be in early August 2025. -Michelle Thompson ]

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