My Insanely Long Field Guide To The LTE-U Dust Up. Part I: Spectrum Game of Thrones.

I keep reading about the LTE-U/LAA dust up and deciding that, as I predicted back in January, this has become the epic Spectrum Game of Thrones. Which means it’s time for an epically long series of Insanely Long Blog Posts.

 

For those just tuning in, I can sum up this issue as follows: should we worry that wireless carriers are looking to deploy a protocol developed for the 4G licensed world (LTE, or Long-Term Evolution) over unlicensed spectrum (called “LTE-U” for LTE over unlicensed or “Licensed Assisted Access,” for reasons I explain later) will “kill” Wi-Fi — for various values of the word “kill.” You can read some stuff on this from my Public Knowledge colleagues here and here.

 

Let me give you the headline version:

 

  • Can you build a version of LTE-U that plays nicely with Wi-Fi? Yes!
  • Can you build a version of LTE-U that looks like it should play nicely but when you deploy it over hundreds of millions of devices it would stomp all over Wi-Fi and crush it flat totally by accident? Absolutely!
  • Can you make and deploy a version of LTE-U where it plays nicely unless the mobile carrier decides it doesn’t like competition from Wi-Fi first providers of rival mobile video and voice services? You bet your sweet patootie!

 

A lot of the argument you see in the press and from the LTE-U supporters has to do with whether the LTE-U Forum (more on them later) have the best interests of wireless users at heart, have gone to great lengths to make sure LTE-U will play nice with Wi-Fi, have released their specs on the LTE-U Forum website, etc. etc. But none of this addresses the points above. What happens if you put this out there and stuff goes bad, either by accident or intentionally.

 

To understand the thinking here, imagine Qualcomm and the rest of the LTE-U Forum are Iran building a nuclear reactor for peaceful purposes. Google and the Cable industry (and us public interest types, for all that anyone notices) are Israel and the Sunni Arab states like Saudi Arabia and Egypt. Iran/LTE-U forum maintains they are building their nuclear programs for peaceful purposes. GOOG/Cable asks how they can be certain, given that the same technology might (a) screw things up accidentally; and, (b) give the carriers the capability to screw things up intentionally, if they ever start to feel the competitive heat. Qualcomm, LTE-U Forum, et al. are shocked, hurt and offended that anyone could even suspect such a thing, despite everything Qualcomm has done in the last 3 years to turn LTE-U into a “Wi-Fi killer”, and despite some of the biggest global carriers telling 3GPP to shut out non-carriers from first generation of LTE over unlicensed. According to Qualcomm, the only reason anyone would question the peaceful intentions of LTE-U Forum is for anticompetitive reasons.

 

But here’s the complicated thing. As I’ll explain below, it’s not like LTE on unlicensed is intrinsically bad. There are lots of really good pro-competitive reasons for carriers to start using LTE on unlicensed. Heck, it may ultimately turn out that a stand alone version of LTE on unlicensed is as useful (or even more useful) than Wi-Fi is today. Who knows? That’s the beauty of the unlicensed band — innovation without permission and all that good stuff.

 

This puts the Federal Communications Commission (FCC) in a rather awkward position. On the one hand, the FCC recognizes the real problem of LTE-U, accidentally or intentionally, messing up Wi-Fi. Additionally, while Wi-Fi is in the unlicensed band and must therefore accept whatever interference comes its way, is only ONE of many, many protocols, etc., you don’t let companies with the obvious incentive to screw up Wi-Fi develop and deploy a potential Wi-Fi killer with no safeguards. But since the success of the unlicensed space comes from its flexibility and easy deployment, how do you not ultimately approve some version of LTE-U/LAA? Are we going to lock in Wi-Fi as the protocol for unlicensed the way LTE is the protocol for mobile wireless? That could be just as awful for the future of innovation as letting LTE-U/LAA trash the place.

 

To make sure all you Tales of the Sausage Factory Readers know what’s going on, I bring you yet another in my occasional “Insanely Long Field Guide” series. Below, I cover everything from a brief refresher on what the heck is “unlicensed spectrum” v. “licensed spectrum,” the history of what’s going on here, and why I focus on Qualcomm rather than the wireless carriers as the chief bad guys here. However, as this is too long even for me, I will need to break this up into two insanely long pieces. In Part 2, I’ll explain about the FCC, why it got involved, why this is so complicated from the FCC’s perspective, and what the FCC can do about it.

 

But first, our insanely long background briefer below . . . .

Although most people only woke up to this recently, LTE-U goes back several years. Readers may recall I previewed this in my 2015 Spectrum Wars Preview Post back in January as part of the problems in the 5 GHz band (which I compared to Game of Thrones). I’m pleased to announce that, due to widespread popular interest in the fate of LTE over unlicensed (LTE-U), and particularly the flavor Qualcomm was pushing until recent bad press, License Assisted Access (LAA), the FCC has given LTE-U/LAA its own spin-off series!  And, just like Game of Thrones, you’re only hope of understanding what the heck is going on here is to slog through several thousand pages of background. But, as fans of Game of Thrones constantly re-assure everyone bored out of their minds by this stuff, it’s totally worth it.

 

First, Some Basic Alphabet Soup: LTE, Wi-Fi, 3GPP and IEEE

 

For those new to this, let us start at the beginning, what are technical standards and standard bodies and why do they matter here?

 

If everyone in an industry agrees to do things in a particular way, it can bring down costs enormously. Economies of scale kick in, as do other efficiencies. So professional organizations, trade associations, and others, get together and set standards. This can be a very focused narrow group, or a very broad group with lots of members.

 

One of these organizations is the Institute of Electrical and Electronic Engineers (IEEE). IEEE goes back to the 1880s, and members include individual engineers as well as various companies. It has a broad ranging mandate for setting standards. Most notably, in 1999, IEEE finalized the 802.11 set of standards for wireless wide area and local area networks using unlicensed spectrum. Today, we generally call technology using this set of protocols as “wifi” (as opposed to Wi-Fi, which we will get to in a minute).

 

Wi-Fi became enormously popular, leading us to the next standard setting body, the Wi-Fi Alliance. Wi-Fi Alliance consists mostly of equipment manufacturers and vendors who wanted to make sure something sold as “Wi-Fi enabled” actually meant something. So they have a bunch of standards and registered service marks. If you buy a device with the Wi-Fi Alliance symbol stamped on it, it means the device not only uses 802.11 protocols, it also meets the standard set by the Wi-Fi Alliance.

 

On the licensed spectrum side of the street, the big standard setting organization is 3GPP. 3GPP is a standards body for the international mobile phone industry, and consists primarily of international telcos, telco equipment manufacturers, and other telco standards organizations. Because the mobile equipment market is (a) made up of giant companies (due to economies of scale making an enormous difference); and, (b) genuinely international in scope, the standards set by 3GPP have enormous influence on the world market. Bluntly, if you don’t have a 3GPP standard for what you want to do as a licensed wireless technology, it’s very hard to get a manufacturer interested in making equipment or a major carrier to adopt. Nothing nefarious about that, it’s just a natural consequence of economies of scale and network effects. But it means that 3GPP standards are extremely important and often have the effective force of law (the Larry Lessig “Code is Law” sense).

 

Case in point, LTE aka “Long-Term Evolution.” For 3G wireless, the world evolved two major standards: CDMA and GSM, with different carriers in different countries adopting one standard or the other. While many standards were developed for 4G (WiMax, HSPA+) the one that won was LTE. Why? Because that was the standard developed by 3GPP, so it got adopted by nearly every global carrier. Economies of scale kicked in, and the few early-adopter carriers that had adopted different standards (such a Sprint, which went WiMax initially) ended up changing over to LTE, because the economies of scale and need for interoperability with other carriers made LTE so much more attractive.

 

The upshot of all this is that we have three global standards bodies that develop protocols for two very different environments and operate in very different ways. IEEE has a very diverse membership, consisting of individuals as well as lots of different types of tech companies, and has one standards group that handles Wi-Fi. Wi-Fi forum is a collection of equipment manufacturers that certifies that Wi-Fi actually means something and stays compatible for all manufacturers of equipment. Then there is 3GPP, which is dominated by licensed carriers and manufacturers of equipment for use in licensed spectrum.

 

Remind Me The Difference Between Licensed And Unlicensed Again?

 

Spectrum comes in a bunch of flavors depending on who can use it and what sort of protection it gets. You can read a very old in-depth explained on this by me here and here. For now, what you need to know is that some services depend on having exclusive permission from the government to use specific electromagnetic frequencies in specific geographic areas. We call these little grants of government monopoly “licenses” for “spectrum.” For example, a local TV station operating on Channel 5 has an exclusive right to use the 6 MHz of spectrum from 76-82 MHz in the geographic area of its license. No one else can operate on those frequencies in the same geographic area. This protects the broadcasters from “interference,” meaning unwanted transmissions of energy in that frequency range that confuse the receiver causing you to see static instead of a clear picture on your TV.

(Yes, this is an oversimplification. I’m trying to do a blog post here not write an engineering treatise.)

 

Unlicensed spectrum, sometimes called “license exempt” or “open” or “shared” spectrum, means anyone with equipment that operates by certain rules can use the spectrum for whatever they want. But if you operate in unlicensed spectrum, you need to take whatever interference comes your way, and you can’t interfere with any licensed operator. This does not give other people the right to deliberately jam your unlicensed systems, as the FCC keeps pointing out. Section 333 of the Communications Act (47 USC 333) prevents anyone from “willfully or maliciously” blocking a signal “authorized” by the FCC. But it does mean that if my unlicensed device starts interfering with your unlicensed device, or vice versa, then neither of us has a legal right to make the other one yield. We either work it out or deal with the interference in some other way.

 

For many years, academics and activists debated whether exclusive licensed spectrum (which gets auctioned for billions of dollars) or unlicensed spectrum (open to everyone, so free), was the superior form of providing spectrum access. This got to be known as the “property school” (for those who wanted exclusive licenses treated as a form of property) and the “commons school” (for those who viewed spectrum access as a common pool resource subject to management as a commons). Eventually, the rest of the world got bored with this debate and just deployed boatloads of equipment and invested squingillions of dollars in both the licensed flavors and unlicensed flavors of spectrum access.

 

In particular, although unlicensed spectrum supports an endless number of possible protocols, Wi-Fi became the most popular and most well known flavor of unlicensed. Meanwhile, LTE became the dominant technology for wireless services as we deployed 4G technologies. And while the licensed community started totally hostile to the unlicensed stuff back in the day, prohibiting manufacturers from even putting Wi-Fi chips in cell phones, the licensed guys eventually warmed up to Wi-Fi. Why? Because demand for mobile data became so insatiable that no amount of licensed spectrum could keep up. So today, wireless carriers incorporate unlicensed spectrum (particularly Wi-Fi) into their network architecture and depend on it for Wi-Fi offload.

 

So, harmony achieved, right? Wireless doves cavort in the air as licensed and unlicensed spectrum intertwine in universal harmony? Not quite.

 

A Grinch Named Qualcomm.

 

While All other chipmakers loved Wi-Fi a lot.

The one named Qualcomm absolutely did not.

Whenever the FCC tried to expand

Unlicensed access to some other new band,

Then Qualcomm would be there to fight and complain.

If you asked “why?” Qualcomm always explained

That pure licensed spectrum was what we all needed.

So this nasty unlicensed stuff must be defeated!

Whether TV white spaces, or in the 3.5 band,

Qualcomm insisted unlicensed be banned!

 

But Qualcomm makes Wi-Fi chips, so why all the fuss?

Why does Qualcomm hate expanding Wi-Fi so much?

It’s not that their hearts are 3 sizes too small.

The answer, I fear, lies with our PATENT law.

 

Qualcomm developed what became the standard essential patents (SEP) of first 3G, then 4G, mobile technology. That means that every manufacturer of a mobile phone pays Qualcomm a huge licensing fee for every mobile phone that rolls off the assembly line. Not only does Qualcomm make a ton of money from these patents, it uses these patents to exclude rival chip manufacturers out of the extremely lucrative 3G and 4G mobile markets. This combination means (a) Qualcomm keeps getting sued for antitrust violations for abusing its patents; (b) Qualcomm has become a major patent troll and opponent of patent reform; and (c) Qualcomm really, really hates more spectrum going to unlicensed, meaning Wi-Fi, where it does NOT control the essential patents – as evidenced by its almost total opposition to expanding unlicensed spectrum.

 

Curiously, the one place where Qualcomm actually supports opening more spectrum for unlicensed use is the 5 GHz band. Which brings us to the birth of LTE over unlicensed, aka LTE-U, brought to you by – you guessed it – Qualcomm! And where do carriers intend to deploy LTE-U? Why, the newly opened totally greenfield 5 GHz U-NII-1 band. Astounding! The only place Qualcomm supports expanding unlicensed spectrum is the only place where it has a technology primed for deployment and which is totally dependent on access to Qualcomm’s LTE patents. What a coincidence!

 

Now I am happy for Qualcomm to support more open spectrum in 5 GHz. But when Qualcomm says “we love unlicensed! Look how we are pushing to expand unlicensed use in 5 GHz,” take this with a mammoth grain of salt.

 

Are We Finally Up To The LTE-U Stuff? Thank God!

 

Yes, but we still have some background to go. So just hang in there.

 

Fine. When Did All This Start?

 

The first discussion I can find of anything that looks like LTE using unlicensed spectrum goes back to March 2012, but the implication from this presentation and my own memory suggest that talk of LTE over unlicensed goes back earlier. Interestingly, Broadcom has a patent on something that looks an awful lot like the “Licensed Assisted Access” flavor of LTE-U that it filed back in 2011, that was granted in 2012.

 

But while folks were talking about possible interest in LTE on unlicensed spectrum, the real story was Wi-Fi. Starting in ’08, when AT&T started drowning in iPhone data, Wi-Fi offload became the lifeline for the wireless industry. Increasingly, it looked like the future of mobile phone service was “hetnets” using “small cells” to combine licensed spectrum use with Wi-Fi offload. As a result, interest in LTE on unlicensed flagged.

 

Then, at the end of 2013, Qualcomm launched a major initiative to promote LTE over unlicensed. As one trade publication put it, Qualcomm appeared determined to “crush” Wi-Fi and push carriers to use LTE over unlicensed instead. Mind you, there is nothing intrinsically wrong with a company launching a competing technology and trying to market that technology. Competition is good, it spurs innovation, etc. But for purposes of our story here, it’s important to note that Qualcomm from the very beginning developed its proprietary version of LTE-U as a competitor to Wi-Fi based carrier offload alternatives.

 

Far more troubling, throughout 2014-early 2015, Qualcomm began to insert itself aggressively into the 3GPP working group on LTE-U. Most tellingly, Qualcomm moved LTE-U away from being a stand alone product and explicitly linked it to use of licensed frequency as the “control channel” for LTE-U. Next, Qualcomm developed its own pre-standard release of LTE over unlicensed (and pushed 3GPP to move its standards development accordingly) so that it could only work for mobile carriers. (I’ll explain how below.)

 

Throughout 2014-early 2015, the non-carriers that participate at 3GPP, like Cablelabs, and Cisco kept getting more and more and more worried about the direction Qualcomm kept leading the 3GPP working group. Additionally, under Qualcomm’s influence, coordination between IEEE and Wi-Fi Forum with the 3GPP working group deteriorated rapidly from reasonable coordination to outright hostility by 3GPP. Essentially, 3GPP stopped communicating with IEEE and Wi-Fi Forum, refused to respond to requests for consultation, and generally put off any further substantive communications.

 

By the time 2014 came to a close, Wi-Fi Forum and IEEE were both hopping mad and deeply concerned about where 3GPP would end up. To everyone depending on commercial Wi-Fi, and hoping to deploy carrier-grade Wi-Fi based equipment in the newly enhanced for unlicensed 5 GHz UNII-1 band, it seemed pretty clear that Qualcomm and the Qualcomm LTE-U/LAA club (mostly Verizon, T-Mo and Ericsson) wanted to deploy a technology that could cut them out of any newly opened spectrum.

 

How Did Qualcomm Restrict LTE-U To Licensed Mobile Carriers?

 

The first version of Qualcomm LTE-U (and the one it still wants to deploy) requires that the “control channel” for the LTE-U operation (the channel that beams instructions about things like how much power to use and how to operate within the scope of the standard). (Qualcomm/LTEU Forum did not release a stand alone version of LTE-U until June 2015, after the FCC started nosing around and making it very clear they did not like the fact that only mobile carriers with licensed spectrum could use LTE-U.) This is why Qualcomm (and now 3GPP) started calling LTE-U “Licensed Assisted Access” (LAA or LTEU/LAA). You can see a very good, albeit somewhat technical (and therefore boring), explanation by Ruckus Wireless (with a timeline of development) here and here.

 

In other words, in the version that Qualcomm originally planned to release back in February of 2015, only carriers could use it. To further emphasize this point, in the largest carriers in the world, including AT&T and Deutsche Telekom (T-Mo’s German parent company), told 3GPP explicitly to limit the first LTE-U standard to carriers only – explicitly shutting out any potential competition from “Wi-Fi First” providers of rival services. The 3GPP standard, and Qualcomm’s pre-release version that it wanted to release in 2015, both would explicitly require that anyone trying to use LTE over unlicensed use the LTEU/LAA flavor, which means having licensed spectrum authorized for mobile carrier use, which effectively limits the entities that can use this flavor of LTE-U to mobile carriers – since no one else has the needed licensed spectrum for a control channel.

 

What would stop cable operators or other Wi-Fi first providers from deploying their own version of LTE-U? First, Qualcomm has the essential patents for LTE. Without access to those patents (and Qualcomm has a history of refusing to provide such patents to rivals), a rival can’t really make its own version of LTE for unlicensed. Second, it’s not so easy to develop a standard. Qualcomm, because of its unique position as monopoly LTE chipset provider to the world, has a huge advantage in its built-in customer base. It can massively deploy and set a de facto standard quickly, and then have that approach ratified by the 3GPP working group (which, you may recall from several paragraphs ago, Qualcomm effectively controls). Get a couple of tens of millions of chips using LTE/LAA in the newly opened portion of the 5 GHz band and you effectively poison it against anything else. Wi-Fi chip manufacturers won’t bother to manufacturer a competing Wi-Fi chip because LTE/LAA won’t play nicely with Wi-Fi in 5 GHz U-NII-1. By the time the Wi-Fi guys get something to market it would be too late. So they don’t even try, because why invest in a technology you don’t expect to be able to deploy?

 

Why Does Qualcomm Have It In For Wi-Fi? Don’t They Make Wi-Fi Chips?

 

As noted above, Qualcomm controls the patents for LTE, but that alone does not explain Qualcomm’s push to keep Wi-Fi out of newly opened spectrum for unlicensed like U-NII-1.

 

Additionally, in 2013, IEEE began to change it’s policy on licensing essential patents incorporated into standards. To understand the importance of this, you need to recall from above that having an industry standard makes a technology much easier to mass manufacture and market. Standards may be “open” in the sense that an organization (like IEEE) makes them available to anyone who wants to use them. But these standards may still contain patents, and you need to get permission from the patent holder (which is not necessarily the standards body) to use the patent or patents in the standard.

 

Patents included in standards and critical to the operation of the standard are called – wait for it – “standard essential patents” (SEP). Most standards bodies have some kind of policy that requires anyone with patents in a standard to disclose the patents. Many standards bodies also have a requirement that if you incorporate a patent in a standard, you must license the patent to anyone using the standard on Fair, Reasonable and Non-Discriminatory terms (“FRAND”). But while most organizations have FRAND policies, there is a lot of variation in how much or how little control the FRAND policy gives the patent holder.

 

Throughout 2013 and 2014, the IEEE undertook a serious review of its FRAND policy and tightened it up considerably. Qualcomm fought improvements to the IEEE change in the FRAND policy tooth and nail. Ultimately, Qualcomm quit IEEE and refused to have anything to do with them under their new FRAND policy.

 

As it happens, the IEEE FRAND update occurred at exactly the same time Qualcomm began moving LTE-U out of IEEE and solely over to 3GPP. As you might expect, 3GPP has a FRAND policy much nicer to Qualcomm’s business model of exploiting its patent portfolio. While the case is highly circumstantial, it appears that Qualcomm really, really does not want any of its patents to get anywhere close to the IEEE new FRAND policy. It also clearly wouldn’t mind displacing Wi-Fi with something Qualcomm can patent and control – like LTE.

 

Mind you, Qualcomm is not stupid. Qualcomm is well aware that if it went after all of Wi-Fi everywhere and crushed Wi-Fi with LTE-U not only would it have regulators around the world crawling all over it, but the carriers themselves would revolt. As noted above, carriers actually use Wi-Fi. Fortunately for Qualcomm and the carriers, the most popular Wi-Fi bands in the U.S., the 2.4 GHz band and the 5 GHz U-NII-3 band, are waaaaaay too crowded to support reliable competing streaming services via Wi-Fi. It is only the newly opened spectrum, 5 GHz U-NII-1 (and possibly 3.5 GHz) which creates an opportunity for Wi-Fi First providers to offer services of competing quality. Hence the drive to get into these newly opened unlicensed bands first.

 

So no, even if Qualcomm and the wireless companies deployed the Qualcomm version of LTE-U/LAA according to plan, it wouldn’t “kill” Wi-Fi in that Wi-Fi would continue to work the way it does now in the existing, overcrowded bands. It would, however, potentially kill next generation Wi-Fi and improvements like mass-deployment of 802.11ac. Without these improvements to Wi-Fi, it is unlikely that Wi-Fi first providers, like the cable companies or Google potentially, could provide competing services of a high enough quality.

 

Is There A Reason You Spent 4000 words on History?

 

I’ve belabored this time line because it is important to understand why the Wi-Fi using world was so suspicious of LTEU/LAA that Qualcomm pushed. You need to understand this history to understand why the FCC took the action that it did in 2015. If we didn’t have so much circumstantial evidence pointing to bad intent by Qualcomm and the carrier world about possible impacts on Wi-Fi in the 5 GHz U-NII-1 band and the still-to-be-opened 3.5 GHz band, the FCC would have continued in its usual “wait and see mode.” But because Qualcomm and a number of other carriers did pretty much everything possible to build a circumstantial case that they wanted to build a Wi-Fi killing LTE-U, accessible only to carriers by tying it to licensed spectrum under the term LAA, the FCC decided to weigh in some and slow things down.

 

So That’s Qualcomm’s Angle. I Suppose The Carriers Just Want To Stop Cable From Competing?

 

No, actually, carriers have lots of good reasons to deploy LTE-U/LAA without getting into anything anti-competitive.

 

Say What?

 

It has to do with the high price of spectrum and the fact that mobile carriers find themselves increasingly spectrum constrained. That’s why they are suddenly so into unlicensed spectrum.

 

Wait, So LTE-U Is Not A Wholly Evil Plot To Destroy Wi-Fi?

 

I wish it were that simple. But remember, we’re talking spectrum Game of Thrones here. Wheels within wheels and more characters and subplots than you can shake a phased-array antenna at. Happily, no torture so far (other than the need to read all the filings in FCC dockets).

 

Anyway, the big reason T-Mobile, Verizon and other mobile carriers want LTE-U is because, and this will sound utterly shocking, they need more spectrum and they can’t afford it. The last spectrum auction cost about $40 billion (less the $3.3 billion DISH forfeited). T-Mobile spent about $1.75 billion and came away with almost nothing. Verizon spent about $10 billion, and then promptly sold off a bunch of its wireline systems to Frontier to pay for it.

 

T-Mobile is rapidly approaching the point where its subscriber growth will once again start to exceed its capacity. Even if it wins a boatload of licenses in the upcoming TV broadcast incentive auction, T-Mo will need affordable available spectrum access in the short term. Hence T-Mo’s extreme urgency to get LTE-U of some flavor, any flavor, up and running. T-Mo wants to start deploying this stuff yesterday, and would have if it hadn’t all blown up because of the above 4000 word skanky history and Qualcomm behaving like a total Patent Troll.

 

For Verizon it’s a bit more complicated, but comes out to the same thing in the end. Verizon wants to start this out as an enterprise product to make sure it works, but it ultimately hopes to make this part of its expanded 5G network. In addition to facing lots of demand, Verizon has launched a mobile video product called Go90. If successful, Go90 will suck up an awful lot of capacity. So Verizon needs lots of cheap capacity that it can deploy as G090 ramps up. While Verizon did get a boatload of AWS-3 spectrum in the last auction, it always takes years to clear out the federal users so the wireless guys can deploy.

 

But If These Guys Need More Unlicensed Spectrum Access, Why Not Just Use Wi-Fi?

 

LTE-U offers carriers a number of advantages. For example, as this article points out, using LTE-U would allow carriers to access unlicensed spectrum an keep charging you on your plan. By contrast, when you use Wi-Fi, you go out of network and the carriers stop charging you. The article suggests that switching to LTE-U over unlicensed will make unlicensed investment revenue positive for carriers, not revenue negative.

 

Now from a consumer perspective, being charged for stuff you access for free right now via Wi-Fi is not a big advantage. But as long as you still have a Wi-Fi option, and as long as the LTE actually adds value, then why not?

 

Additionally for the carriers, much as they loath Qualcomm’s patent royalty fees on LTE, they live in an LTE universe and these are the equipment manufacturers they know and do business with regularly. By contrast, while they have experience with Wi-Fi, it’s not yet at the same level of integration. So when Qualcomm came along in 2013 and promised them LTE-U instead of Wi-Fi as the way to access unlicensed spectrum, it seemed like a good deal and not in the least nefarious.

 

So LTE-U Won’t Kill Wi-Fi in 5 GHz?

 

I didn’t say that either. See the part above the fold. The problem is that, as Verizon’s own testing shows, LTE-U deployed in the way Qualcomm originally suggested would be totally incompatible with Wi-Fi. And Verizon, to its credit, has published this information and – with the LTE-U Forum – been working on what would protect Wi-Fi. Mostly. As long as it isn’t too inconvenient or expensive.

 

But again, for all that Qualcomm and the LTE-U cheerleaders keep insisting that LTE-U is totally safe, that is a slight exaggeration to say the least. The best thing you can say about the work published by LTE-U forum is that “if our limited lab tests are right, and everything works as we expect it to, and nothing goes wrong, then LTE-U will get along just fine with Wi-Fi. In theory. But we have no way to pull LTE-U back or curtail deployment if it turns out we are wrong or if someone messes with the pre-standard version we deploy.”

 

Which brings us to the counter testing done by Google and by Cable Labs that show that LTE-U will totally mess up Wi-Fi. Or could mess up Wi-Fi. The LTE-U Forum like to point out that this wasn’t done with “actual LTE-U equipment.” Of course, no testing, including LTE-U Forum’s testing, got done with actual real LTE-U approved equipment because no actual LTE-U equipment for the U.S. market exists, and the stuff developed for the EU has an explicit, mandatory spectrum etiquette to make it play nice with Wi-Fi — something the LTE-U Forum and LTE-U supporters explicitly oppose incorporating into the version they want to release.

 

So we default back to square one. No one has done tests on real world equipment in the real world, because real world equipment of the kind Qualcomm, Verizon, T-Mo and Ericcson want to deploy hasn’t been approved for deployment. Even if we got basic lab tests right under ideal conditions, we have no idea as to what will happen when you ramp it up into real world deployment over 100s of millions of devices (see more on this point below).

 

Why Do The Press Keep Reporting It as Cable v. Wireless Carriers When It Sounds Like Qualcomm Are The Total Patent Troll Skunks at the LTE-U Party?

 

To answer the second question first, it is the wireless carriers who are actually going to deploy this stuff, and it took 5000 words to get to the point where folks can see the problem is really with Qualcomm rather than Verizon. If you look at the situation without this background, this looks like cable versus mobile wireless. The whole chip manufacturer stuff is another layer deep. I keep telling you –

 

Yeah, Yeah. Spectrum Game of Thrones, Wheels Within Wheels, Winter Is Coming, Whatever. If Everybody But Qualcomm Is So Sensible Why Are We Having This Fight? Why Can’t Folks Just Work It Out?

 

As I said at the beginning, while you can deploy LTE-U in a way that plays nicely with Wi-Fi, it is a heck of a lot easier to deploy LTE-U in a way that totally messes up Wi-Fi. Heck, that is the default way LTE-U works, because LTE is designed for an environment where it doesn’t share with anybody. The 3GPP is supposed to be settling on a standard in March 2016, and most folks (including the FCC) have asked Qualcomm and friends why they can’t wait for the 3GPP standard to get approved, which is how this stuff usually works. Qualcomm and friends responded with a lobbying blitz around the non-responsive “Why Wait.”  Again, if you want to convince everyone with concerns that you are planning something underhanded, anticompetitive, and potentially reckless with Wi-Fi, responding to a reasonable question with a lobbying blitz filled with anti-regulatory buzzwords and accusing everyone who raises doubts of harboring their own anti-competitive intentions is absolutely the best way to convince everyone in DC you are totally up to something and not to be trusted.

 

But even without Qualcomm and friends acting as if they totally have something to hide and launching a lobbying blitz practically designed to confirm for anyone paying attention that Qualcomm either knows their LTE-U product interferes or they don’t care, we have other issues. As noted above, the default for LTE, since it operates in the exclusive licensed space, is to not play well with anything else because nothing else should be using the frequencies. If you rush to deploy LTE-U quickly, as T-Mo, Verizon and Qualcomm all certainly want to do, then you are much more likely to deploy a version that does not play well with Wi-Fi just by sheer accident.

 

This is especially true if you are Qualcomm and no longer talking to the Wi-Fi guys because you don’t like their patent licensing policy and want to extend your LTE patent monopoly into the unlicensed space. When you compound this further by blowing off everyone in the Wi-Fi world, spending a year telling anyone who raises objections to just trust you despite their obvious economic incentive to the contrary, it looks a little fishy. When you respond to reasonable questions about your intentions with a bunch of double-talk, question the motives of those asking, and launch a glitzy lobbying campaign, it looks a lot fishy.

 

OK, It Looks Fishy and It Is Likely To Get Screwed Up If Deployed In A Rush. What Else?

 

Even if Verizon, T-Mo and everyone think they have the LTE-U formula right, it can still turn out to screw up Wi-Fi when it scales up to millions of units. We are seeing a version of this happening now with T-Mobile and Sirius XM. As explained in this Wall St. Journal piece, T-Mobile now has more customers and is using its spectrum more intensely. This is a Good Thing. Despite the fact that T-Mo is acting totally in the rules, the more intense use is now causing the electromagnetic waves we call “spectrum” to behave in unanticipated ways. This causes unforeseen interference to Sirius XM Radio subscribers under certain conditions. Both T-Mo and Sirius agree on the physics, but disagree on who ought to remediate the problem. Sirius says T-Mo needs to control its out of band emissions. T-Mo says it is operating fully within the rules, including the limits on out-of-band-emissions, and Sirius needs to upgrade its radios with better filters.

 

Suppose we have a similar problem happen here. Lets pretend that every single experiment Verizon and LTE-U forum have done is totally on the up-and-up. They deploy LTE-U thinking its safe. Turns out when you scale it up it destroys the ability to provide competing Wi-Fi service in the 5 GHz band. Ooopsie! Note it does not get in the way of LTE-U, because LTE-U does not have listen before talk. LTE-U has a control channel, which allows carriers to coordinate with each other to get out of each other’s way, and avoid self-interference.  But it doesn’t give a rat’s ass about Wi-Fi. By contrast, because Wi-Fi uses a “listen before talk” protocol, LTE-U poorly deployed can muck it up and Wi-Fi will never recover.

 

This is even more fatal to Wi-Fi because Wi-Fi and LTE-U are both unlicensed services, so the wireless carriers using LTE-U have no obligation to fix the problem. As long as carriers aren’t deliberately jamming, those using Wi-Fi would just be totally screwed. Heck, the FCC has trouble resolving this kind of unexpected interference when you have two licensed services, like T-Mo and Sirius XM. Trying to get the FCC to address LTE-U crushing Wi-Fi after the fact would be incredibly difficult – especially if the problem ramped up gradually.

 

(Because we are already at about 6000 words, I will not regale you all with the story of Nextel, public safety, and the 800 MHz rebanding debacle. Just look it up and trust me that you don’t want the FCC to try to resolve massive interference problems after they emerge.)

 

Finally, even if we assume wireless carriers like Verizon have no anti-competitive motives now, nothing prevents them from juggling things on LTE-U to use it to interfere with competing services in the future. That’s another feature of unlicensed that makes it impossible for parties to trust each other here. Once equipment is approved for deployment, then you can adjust it as long as you don’t go out of frequency or above the legal power limits. If cable streaming Wi-Fi in 5 GHz is beating the crap out of Go90 in the future, nothing prevents Verizon from adjusting the LTE-U duty cycle to introduce jitter into competing cable services.

 

Like the Ring of Power from the Lord of the Rings, the temptation to use the power of LTE-U for anticompetitive interference will grow the more carriers find themselves faced with competition from Wi-Fi first services. Eventually, even if they start out with good intentions, the temptation will corrupt them. Verizon will end up going all Boromir and Comcast and Google are going to have to wander into the FCC version of Mordor to cast LTE-U into the fires of Mount Doom. Or something. I think that metaphor got away from me there.

 

Got it. So because LTE-U Is Too Dangerous, the FCC Needs To Ban It.

 

No.

 

What Do You Mean No??!! Why NOT??!!!

 

Banning LTE-U would be a terrible precedent. It would make compatibility with Wi-Fi the de facto standard for technologies in the unlicensed space. That would be deadly to the level of innovation we have seen in the unlicensed space. LTE-U might prove a better technology, just like Wi-Fi proved better for a lot of applications than the rival Bluetooth. Or we might find that LTE-U is a wonderful compliment to Wi-Fi. Or something might come along in the future that will get stopped because it can’t prove it’s 100% compatible with Wi-Fi.

 

Mind you, contrary to what some folks seem to think, there is a world of difference between “letting something hundreds of millions of people and billions of dollars of economic activity depend on get screwed up or deliberately messed up” and “banning LTE-U because we can’t prove it will always play 100% nicely with Wi-Fi. Qualcomm and the rest of the “LTE-U right now” crowd keep trying to set this up as the only two alternatives – let Qualcomm and friends deploy LTE-U right now with no restrictions, or accept the strangling hand of government enforced standards blah blah FCC evil overregulation socialist spectrum command and control etc.

 

Happily, there is a much better alternative. And it is not unduly burdensome and relatively straightforward to implement. We do not have to allow Qualcomm, which has done pretty much everything but hang an “I am an evil patent troll out to destroy Wi-Fi” sign on its Washington Office, have a free hand and deploy a pre-standard LTE-U with no hope of stopping it if it causes nasty interference with Wi-Fi. Nor do we need to make total compatibility with Wi-Fi the de facto standard for deploying new wireless technologies in the unlicensed space.

 

SO WHAT IS IT ALREADY??!!! WHAT SHOULD THE FCC DO???

 

Well, as I keep saying, this is spectrum Game of Thrones. What happens in Game of Thrones just when you have slogged through 900+ pages and everything seems so hopelessly tied up in knots there is no way to resolve it?

 

You Start Another Book?

 

Exactly.

 

So This is Only the End of Part I?

 

That’s right. Come back next time for what the FCC has done so far, the limits of the current FCC strategy, and what the FCC should do to resolve this.

 

This Better Not Go To 5 Books!

 

Stay tuned . . . .

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