[arin-ppml] IPv6 Heretic thoughts

[Owen DeLong]

On Sep 5, 2008, at 10:05 AM, Milton L Mueller wrote:

>
>
>> -----Original Message-----
>> From: Owen DeLong [mailto:owen at delong.com]
>
>> The reality is that the FCC has chosen a non-auction mechanism for  
>> the
>> vast majority of spectrum and uses auctions to dispense what is left
>> after they have allocated spectrum to non-commercial uses that are
>> considered important by the FCC.
>
> To put it more accurately, when there are many contending commercial
> applications for _exclusive use_ of the same spectrum, i.e. scarcity  
> of
> the sort faced in IPv4, they tend to use auctions.
>
No... That is not more accurate.  That is more in line with your idea of
how things should work.

The FCC has reserved many chunks of spectrum as primary to
a number of non-commercial uses.  These chunks of spectrum
are not available to the auction process for exclusive use. The FCC
has auctioned off some of these chunks to "secondary" users.

For people unfamiliar with what this means, I'll digress briefly to
explain...

There is almost no RF spectrum allocated to exclusive use by a single
class of service or user(s).  The AM and FM broadcast bands, aircraft
communications and navigation, some of the military bands and a
limited number of others are allocated on a "exclusive use" basis.

Most RF spectrum is allocated to one primary and one or more
secondary uses.

A primary user of RF spectrum has the right to use that spectrum
as they are licensed so long as they are not causing harmful  
interference
to a fellow primary user. (For example if the primary use is Amatuer
radio, any licensed Ham may use the frequency, but, not in such a
way as to cause harmful interference to another Ham).

A secondary user of RF spectrum has the right to use that spectrum
so long as they do not cause interference to any primary user or
harmful interference to any secondary user.

Nonetheless, the fact remains that the vast majority of RF spectrum
is licensed, but, not exclusive use.  Additionally, only a tiny fraction
of that is auctioned, especially on a primary use basis.

> I personally have been a big advocate of unlicensed spectrum and  
> making
> more of that available, too. Some have tried to argue that all  
> spectrum
> should be exclusive/auctioned, others that it all should be  
> unlicensed.
> In fact, both models should exist, each has its strengths and
> weaknesses. And there is still some role for administrative  
> allocations.
>
You make this statement as if there is no licensed spectrum that is not
auctioned.  That simply isn't the case.  MOST licensed spectrum is not
auctioned, at least on a primary basis.

For more information, take a look at:

http://www.ntia.doc.gov/osmhome/allochrt.pdf

It does a pretty good job of displaying the US frequency spectrum and
how it is utilized.  Note that the vast majority of it is licensed and  
not
commercial.  To the best of my knowledge, auctions have only been
done for commercial use.

>
> The industry and most policy analysts have accepted this combination  
> as
> the best way to go, because each allocation model has its strengths  
> and
> weaknesses in different types of uses.
>
Of course industry likes it.  However, industry is not the only user  
of RF
spectrum, just as they are not the only user of IP.  Using the  
willingness
and ability to put dollars into getting a resource is a fine way of  
measuring
it's commercial value and optimizing the distribution on that basis.
However, when one non-commercial interests also need parts of the
same finite resource, such an approach tends to treat such users
as unimportant.

> One could compare IPv6 space to unlicensed, freely available and  
> IPv4 to
> exclusive/licensed/scarce.
>
One could compare scissors to pocket knives, and fingers to toes, but,
I'm not sure that such comparisons would be any more or less useful.

>> What if the Military had to add their spectrum
>> demands into their budget?
>
> It would very good, except that under most recent administrations  
> DoD is
> given a blank check. We should know how much military spectrum usage
> actually costs the country. Surely you are not suggesting that by not
> having a transparent cost for military resources it is somehow "free?"

I am suggesting that how you measure cost and how I measure cost
may differ.  You are convinced that your method is vastly superior to
mine.  I am not. I am not completely convinced either way.  However,
from my observations, the blind faith that using money to measure
importance will cause society to choose the correct priorities is
misguided at best.

The military has always had a nearly blank check in one form or
another with occasional and short-lived exceptions.

Under the current circumstances, the military's RF spectrum
use could be said to cost the country the opportunity of the
revenue that auctioning it might bring.  However, if the military
were to have to purchase its spectrum at auction, what it would
cost, instead, would be that opportunity (the government didn't
make the revenue, it merely moved it from the military pile
to the FCC pile) in addition to the costs of administering the
auction, dealing with the law suits about the auctioneer being
a bidder, the overhead and accounting costs on the FCC and
military sides of the transfer of funds, etc.

It would increase the costs without producing revenue to offset
those increased costs. This does not seem in the best interests
of the taxpayers in my view.

Owen