The following transcript has been edited for length and readability. Listen to the entire discussion here on The Broadband Bunch. The Broadband Bunch is sponsored by ETI Software.
In this episode, we catch up with Noah Campbell, CEO of RS Access. Noah is part of the group that was formed to advocate for rule changes to bring the 12 GHz spectrum out of the stone age, to be useful for modern connectivity. He shares his knowledge and expertise in spectrum policy. In the episode, we discuss:
Craig Corbin:
Welcome to the Broadband Bunch. A podcast about broadband and how it impacts all of us. Join us to learn about the state of the industry and the latest innovations and trends. Connect with the thought leaders, pioneers, and policymakers helping to shape your future through broadband. Join us on Facebook at the Broadband Bunch and see the latest episodes, news, and photos. The Broadband bunch is always sponsored by ETI Software. Hello everyone, and welcome to another edition of the Broadband Bunch. I’m Craig Corbin. Thanks so much for joining us. It is certainly no surprise that demand for bandwidth here in the United States is immense, and it shows no signs of slowing down anytime soon.
Craig Corbin:
One segment of the allocated radio spectrum is the 500 MHz contiguous spectrum located between 12.2 GHz and 12.7 GHz licenses for 12 GHz multichannel video distribution and data service, or MVDDS were auctioned by the FCC back in ’04 and ’05. But the technology was immediately obsolete, and for the next decade, very little changed. In 2016, a group was formed to advocate for rule changes to bring the 12 GHz spectrum out of the stone age, and then be useful for modern connectivity. 5G for 12 GHz Coalition. Our guest today is one of the leaders of this effort. It was a pleasure to introduce the co-founder and CEO of RS Access, V. Noah Campbell. V, welcome to the Broadband Bunch.
Noah Campbell:
Thank you so much for Craig, I really appreciate it. Happy to be one of the bunch who’s discussing broadband.
Craig Corbin:
There’s never a shortage of timely and interesting and extremely important topics in the broadband world. And we thank you so much for your time. Very interested before we launch into the efforts of the coalition for those that might not be aware of the background of RS Access, Radio Spectrum Access, give us the 30,000-foot overview if you would please sir?
Noah Campbell:
I founded RS Access about three years ago with my partners at MSD Capital. It’s a family office for Michael Dell, and we were very excited when we came across this opportunity, these licenses as you mentioned just out there, I call the band, time left behind. And we created a company to invest in 80 licenses in this band, covering about 15% of the US population. We spend some time building out networks. So we currently operate across 60 markets in 28 states. And then the effort has really been at the commission and then Washington to try to get the rules changed for the band.
Craig Corbin:
That is a very time-consuming effort I know. And then let’s talk about how the coalition came into being. I think right at two dozen members, I think initially give us the background on that group?
Noah Campbell:
So the there’s a coalition as you mentioned in 2016, filed a petition for rulemaking to get these rules changed. So about five years ago and you’re right, it is very time-consuming and the rule-making process of the commission can take a long time. And not only that, a lot of things are happening with changing the industry that affects the timing for that as well. So about five or four and a half years after the original 2016 petition, a new coalition was formed, this we’re talking about today. And there are lots of different types of entities that are in it.
Noah Campbell:
There are licensees in the band, of course, which were one. Dish Network is the other big licensee in the band. And then there’s a handful of smaller licensees and then public interest groups and fiber providers and fixed wireless providers. The commonality amongst all these entities is that they’re seeking to be able to use this frequency as 500MHz, which is a huge amount of spectrum for highly in-demand mobile broadband services, and to bring this spectrum into the 21st century. So it’s a broad coalition and we’re very happy to be part of it.
Craig Corbin:
That’s an interesting aspect of this project from my perspective. The fact is that it is an incredibly diverse coalition. So obviously there is a very widespread belief that there is a need for the FCC to address this. And there is currently underway effort to make that become reality. I know that much effort has been put into that. Talk if you would, about where the process is currently? And then we’ll get into a little more of the specifics of what the hope is for the long-term success.
Noah Campbell:
The FCC earlier this year did choose to look at this issue because of our advocacy and the advocacy of the other people in the coalition did choose to address this. And so in January, they voted to open what’s called a Notice of Proposed Rulemaking, which is effectively a complex policy decision-making process to study what changes should occur in this band. We’re in the middle of that process right now. So the initial comments have already been submitted, then the next deadline is July 7th for reply comments. My company submitted a very complex and very thorough technological overview of coexistence with one of the other participants of the band. Potential operators of the band, I’m sure we’ll talk about that as well. We’re right in the thick of things and it’s across the FCC, it’s on the hill, it’s an industry. And we’re raising awareness of this. I think thus far we’ve been successful in doing so, which is great.
Craig Corbin:
You talk about the efforts that went into providing data for the submissions. And I guess at face value, okay, people would assume that it wouldn’t be a very complex effort to do so in support of what’s being requested. But I’m not sure that’s the reality. If you could go into a little bit of the elbow grease, the effort that went into providing that information.
Noah Campbell:
I should say that the reason that this is becoming more difficult and there’s more effort that has to go into these types of spectrum rule changes is that the spectrum is finite. They’re not making any more of it. It can’t be created or destroyed. It’s a naturally occurring magnetic radiofrequency wave. And the more devices and the more uses we have for radio spectrum, the less of it there is. Because they’re just a lot of devices and a lot of people that want to use it for increasing applications, lots and lots of applications. And you have to remember this, the wireless data market is basically brand new. I mean, I’ve been doing it for 17 years now. And when I came into the market, it was very difficult to explain what I did because the iPhone didn’t exist yet.
Noah Campbell:
The iPhone was really the threshold moment for when people started to understand that there’s a real scarcity of spectrum. So it has gotten more complex because the spectrum is finite, and because it’s a very, very important asset. So in our case, we had to deal with a whole regulatory sphere. We had to deal with the commercial sphere in terms of saying, “Look, this is what the spectrum is good for. It’ll be very, very good for wireless broadband for 5G services.” And people are using a lot of 5G services. And our brand is very unique because it has a sharing built into it. And that’s a little bit complex as well, but there’s direct broadcast satellite service, which is an incumbent in the band.
Noah Campbell:
There is an emerging NGSO Low Earth Orbit Service that has conditional access to the band. And so it’s about raising awareness for what the frequency can do because it is such a unique asset. It’s about talking to lawmakers and the folks at the commission, all of them are very sharp on this. And that just takes time and it takes engineers. We have the best RF engineers in the world working on this. And it’s lawyers, its engineers, its policymakers, and they all come together to figure out the best policy for what to do with these limited resources.
Craig Corbin:
When you just mentioned those other groups that reside within the spectrum, obviously when there’s an effort to have changes made to rules, there can be pushback from the other perspective, the other points of view, and that’s obviously a big part of this conversation. If you could address that component and what the current status is there?
Noah Campbell:
This goes back 100 years. These types of conflicts go back to the days of Edwin Armstrong and David Sarnoff and Marconi and colored television, black and white, AMFM. This is a constant conflict that’s happening in the policy and the technology space because there are commercial interests at play here. And so you see, you don’t see this in lots of different bands. The band that we’re working with here is relatively speaking versus a lot of these are more difficult and thorny rebanding or rule changes for existing licenses. Because one thing that’s very good is we don’t have any government users here, right? So we don’t have the Department of Defense or NTIA or involvement of very sensitive, for example, radar systems, right? That you see in other bands, which are very, very important. What you have here is a commercial service, which is important.
Noah Campbell:
But direct broadcast satellite or DBS services, at one point, were really competitive and they’re adding subscribers. And people were very enthusiastic about linear television. People are less enthusiastic now about satellite television, and all you need to do to understand that is just look at the subscriber numbers. I’m not taking anything away from a company as DirecTV is well-run and a great company and Dish is obviously a great company. And they provide a great service for those subscribers. But I think medium-term long-term, the direction that technology is going and the direction where consumers are going, is bi-directional broadband-based, IP based services, streaming services, et cetera. So in this situation, we’re in, we really seeing a legacy service that is really… And look, don’t take my word for it, right? Like AT&T is on the record saying, “We’ve launched our last satellite.” They’re in the middle of divesting their direct TV service to basically a joint venture with a private equity fund.
Craig Corbin:
Sure.
Noah Campbell:
And so the legacy service here is one that’s really not long for this world we think. The we’ve gotten a sending service with NGSO Low-Earth Orbit, which hasn’t even come out of Beta yet. So we’ve got this window from a policy perspective where we can really pause and say, “What’s the best way to use this very unique, big block of mid-band 5G spectrum that is relatively clean. What’s the best thing we can do? And my company thinks the best thing we can do is use this spectrum for mobile 5G services.
Craig Corbin:
And knowing the oncoming tsunami of 5G demand. This is a tremendous conversation to be had because putting it in the perspective of the consumer, you’re talking about being able to more than double the available mid-band spectrum that’s available for this type of use. And that makes a tremendous impact on the end-user. Talk about the projections that I’m sure that has been made with regard to how this will impact in part helping to close the digital divide?
Noah Campbell:
So just very briefly, and I know a lot of your listeners know this. But the scale that we’re working on here is one of capacity versus coverage, right? So low-band spectrum, 700 MHz, 600 MHz. That’s really good for coverage, right? You get a long-distance signal from this tower millimeter-wave frequency, say 24 GHz and above. That’s really good for capacity, but you don’t get a lot of range. And so what’s emerged over the last several years, is this sweet spot, or what people are calling the Goldilocks mid-band spectrum. And we saw this with the recent C-band auction that the projections were maybe that it would go for $25-$30 billion. It went for $90 billion. And that was 280 MHz of spectrum at around 3.7 GHz. Actually doesn’t really behave the same way as that spectrum, but when you put it into context, it’s very similar.
Noah Campbell:
And that spectrum in the C-band auction was 280 MHz of spectrum. Now, when I was a kid and I first started doing this, it would be a big deal to get 10 MHz blocks out. When you think about what you can do with a 500 MHz block of mid-band spectrum, you could do five, 100 MHz channels. And that’s extremely important, right? The channel sizes here are very, very important because it really dictates what the consumer can use, see in terms of speed and throughput and to a lesser some latency. So just the sheer capacity and the dynamics of this frequency and what it can provide for the over, and this is a mind-boggling, over 400 million US mobile subscribers. It’s a huge market and it will be extremely impactful.
Craig Corbin:
V, when we talk about the impact on that, that massive amount of spectrum and what it can do, there are so many different ways to utilize that. And we talked about the diversity in the coalition. What is the belief within the group, within the coalition that the FCC will respond favorably to the efforts for this petition?
Noah Campbell:
So it’s interesting. Within any coalition like this, you’ve got different interests for the different participants that broadly are aligned. And I think the broad alignment here with our coalition is that these… And look, this is, I mean, you don’t have to be a genius to figure this out. And Craig you said at the top of the show, the rules for this frequency were created in 2002. And in 2002, it was, I mean, the future that we have in 2021 is like the Jetsons. Is it possible to understand the proliferation and the social impact that mobile services, mobile broadband services would have and how rapidly the technology would advance? So you don’t need to be a member of the coalition to look at this and say, “Hey,” when you’ve made rules for the frequency that I haven’t really talked about it.
Noah Campbell:
I mean, this 500 MHz that we’ve got here, it’s, it’s limited by rule to a one-way pipe, one way. So right now you can do two and a half megahertz or five megahertz, two ways, or 10 MHz two ways. To have one 500 MHz pipe is like having city water main, like a huge city water main the size of a garden hose.
Craig Corbin:
Good illustration.
Noah Campbell:
Yeah. It’s outrageous. So I think the members of the coalition just look at this and on the face, you just say, “This just doesn’t make any sense.” But I think also more specifically, you’ve got providers, you’ve got people in the entities in the coalition who say, “Wow, this could be really good for fixed wireless,” or, “Wow, there could be an unlicensed or unlicensed underlay service, or a lightly licensed or a user share it dynamic here which could be for very rural areas.” Very important.
Noah Campbell:
And you could do that. It’s really up to the commission, and it’s up to the participants in the rulemaking. Because of the sheer depth of what you have here is, there are so many possibilities. And I’ve had fixed wireless folks. People have spoken with the fixed wireless market, looking at the spectrum, and say, “This is the best spectrum there is for fixed wireless.” And fixed wireless in rural areas is extremely important. You can get a lot of range here, you can get a lot of capacity here. With a path back to the tower, I mean, you could be looking at a service that competes with MSOs in rural markets or provides an extension for fiber companies in rural markets.
Craig Corbin:
Because that is the most rapid way of expanding the footprint of service to those that are either unserved or underserved, regardless of physically where they are. You made mention of a concept in that last remark, that I’m intrigued with. The use it or share it concept, and especially in light of the fact that so many of these licenses have been languishing for two decades. That really makes an awful lot of sense. What’s been the response to that concept?
Noah Campbell:
Well, we’re like I was saying before, we’re in the middle of it, right? So the way this works, since you got initial comments and everybody lays out their arguments. We, I think have extremely good arguments. I can tell you that to your point earlier, we worked very, very hard on the technical elements. We’re the only company that filed many technical comments in this initial comment cycle whatsoever. Which considering some of the other companies that are involved here, I thought was incredible. But so then what happens is, reply comments, people respond to initial comments. And then there’s effectively a complex negotiation and decision-making process after reply comments to decide what should be done. So I think that people right now are starting to see, “Okay. Well, how will this actually work?” Right?
Noah Campbell:
And in terms of the rural use of the spectrum or the user share it type of approach to this, one of the many interesting things about this band is that there’s this inside out element to it too, right? Like where is capacity needed? And capacity is needed for mobile networks and for fixed networks for predominantly from mobile networks, right now in the urban areas and suburban areas where you have just lots and lots of users, dense users, a density of population. And so that’s where you really need, you get the most bang for your buck with the spectrum. And so just like every other iteration of a wireless build or a lot of other industries, it starts in the cities, it starts in the suburbs, and in migrates its way up. So after a few years, you may end up having a more robust mobile service in a rural area.
Noah Campbell:
During that time, it may be that their companies could access or other entities could access this frequency. And until it’s built out in a mobile capacity, utilize it for fixed services on an opportunistic basis. And that’s something that I think that some of the folks in our coalition are advocating for. And then there’s this particular administration and this FCC, have been very… I mean, the last administration of FCC to be fair, very, very interested in how to get advanced services to rural areas. And we are all for that. The coalition is for that, and my companies for that as well. This is a huge component of it.
Craig Corbin:
And if I’m correct, looking at the submission on this petition, that there is precedent that you address. Because conceptually, it’s an approach very similar to what the FCC did with the authorizing part of the unused spectrum and at a different part of the spectrum map that was utilized during the global pandemic. And I think that was the 5.9 GHz band. So there is precedent for taking action and doing so fairly rapidly. Does that give you any hope that the FCC will look favorably on this petition?
Noah Campbell:
Well, absolutely it does. I think that the FCC recognizes and the industry recognizes that, because of what I was mentioning before, the nature of the finite nature of frequency and just the huge demand for capacity. We need to be very nimble, and we need to move quickly and we need to be very creative. The days of having Greenfield spectrum that can just be sitting on the shelf at the FCC or with the government and just saying, “Oh, let’s just auction this. And that’s fine. There are no users.” Those days are gone. So there needs to be a multi-entity approach. There needs to be a collaborative approach, and we need to be creative in terms of how we bring frequency to market. Because it’s just extremely in demand, and it’s very precious. And so I think the FCC is on par.
Noah Campbell:
I mean, look, the FCC is the best at doing this in the world. The FCC leads the world and the rest of the world looks to the FCC as to how to undertake these complex processes and the economists, the FCC economists, and the private economists who manage the television broadcast auction won Nobel Prizes because of the complexity of how they brought that spectrum to market.
Craig Corbin:
Sure.
Noah Campbell:
And so we’re totally confident that the FCC will continue to lead the world and making these types of decisions. And that this is right in line with the decisions they’ve made in the past.
Craig Corbin:
When we referred to earlier in the conversation, the fact that this was an extremely timely effort. Anytime that you are talking about modernizing the utilization of the spectrum, it’s important. But when you talk about the tremendous that quantum leap between what it was initially envisioned for two decades back and what it can be utilized, for now, that’s as big a jump as I can remember in any previous conversation. And I’m curious about, from the FCCS perspective, knowing what has been an unused, underutilized portion of the spectrum. And then looking at the tremendous benefit in the very near future that could be realized with a positive response to this. I would be shocked if there were not a very substantial shift toward providing a positive response for this. In a best-case scenario, if the FCC does make movement along the lines that are hoped for by the coalition, how quickly could we see something change as far as the actual utilization of the spectrum?
Noah Campbell:
The FCC as their task has been very deliberative in the way that they have approached this band. And because of the built-in sharing nature of this band right now with this conditional Low-Earth-Orbit, the ability to access the spectrum and DBS and existing service there. They’ve really said, “Look, this is really the core of the NPRM, let’s figure out if we can get a win-win-win here, right? If we can have a 5G service that can be very robust while not harming the existing DBS, and while possibly accommodating potential Low-Earth-Orbit. Then, of course, that’s what we want. We want to have all three services, and if we can have them simultaneously or one is phasing out or one is phasing in, and we can have lots of robust usage of the band, that’s what we want.” And my company took that mandate very, very seriously.
Noah Campbell:
And we went and we hired the best RF engineers in the world to undertake an analysis of how this would work. And I think we’ve definitively proved that what the FCC is contemplated here is something that’s eminent. Not just possible, but it’s actually pretty straightforward. It’s more straightforward than people anticipated. So having proved that out from a policy standpoint, we think this is really clear. And in terms of how quickly the FCC can move, and the FCC responds to industry, right? And the industry is saying loud and clear, “We need more spectrum.” We’re looking at five years over the horizon and we’re looking at demand and we’re looking at the number of subscribers, the number of services that are going to be operating in the wireless space. And we’re maybe a little bit scared. It’s a difficult thing to predict it, but demand is, to your point earlier, it’s proceeding unabated, and it’s actually it’s amazing to watch.
Noah Campbell:
It’s been amazing to watch over the last for me in the last 17 years of my career. So the FCC can move really quickly. We saw that with the C-band, we saw now with 3.45 and 3.55, which should be auctioned next. And when you look at the spectrum horizon, you look over other horizon and then figure out what’s coming next, there really isn’t anything else. This is really what’s next. So I think that as there’s more awareness of that and as we see the end counter process play out, I think that people will start to say, “Well, this makes a lot of sense. It’s a win, win, win for the industry, for regulators, for global, for us 5G leadership. And this is just tremendously reasonable, and we should proceed with this very rapidly.”
Craig Corbin:
You talk about the references to the fact that this spectrum has just sat unused, it’s languished. Is there a school of thought out there that those who were successful in the auctions back in ’04/05 are just sitting on them looking for a repeat of the C-band auction and have their auction again?
Noah Campbell:
That’s a really interesting question because there’s this interplay between technology and policy. And there’s always this sort of push-pull around investment and how people participate in this space and what people are doing with what’s… I mean look, like I said, if you had this conference, and I did have this conversation when I started doing this in 2004, trying to explain even what spectrum was. But because it’s gotten very valuable and because there are so many uses for it, there’s this inclination to say, “Oh, what has been going on with the spectrum and who will benefit from this and how will they benefit from this?”
Noah Campbell:
And the fact of the matter with regard to this specific band that… And I know because my company and I personally have traveled around to all our locations in the country where we build this out over 28 states. And when you have… So to the point of we didn’t even talk about this, I should have mentioned it before, the power limitations in the spectrum from the base station side are 1/10th of what you have in a handset, 1/10th of what you have in a headset.
Craig Corbin:
Wow.
Noah Campbell:
Even with that, we can get a mile, a mile, and a half range through careful engineering and careful path planning. You can get some decent range and we can get a lot of capacity. I mean, that’s an amazing thing about it because you’ve got five per MHz here. You can do two, 250 MHz channels. I mean, we’re trying to architect a 21st-century system using restrictions that are basically 1990s with 5G system with 1G rules. and so without rule changes, it’s very difficult to utilize the frequency because the restrictions are antiquated, that is putting it lightly.
Craig Corbin:
And that’s why I referred to it as coming out of the stone age because literally, that’s the transition that you’re talking about. So much we’ll go into this as it moves forward, and we were anxious to see how it evolves as we wind down this particular conversation. We always like to ask our guests on the Broadband Bunch, our back to the future question. If you can hop into the DeLorean and take yourself back X number of years and whisper something in your own ear that would change the trajectory of, in this case, the efforts of the coalition or RS Access and how decisions are made, when they were made, that would bring up a more positive response or result. What would that be?
Noah Campbell:
It’s a great question. I mean, because it puts you in a position. I mean, look, I was just starting out in spectrum when these auctions happened. And I think anybody in the spectrum space in 2003/2004, right around there or beforehand, I think everybody would probably answer this question in a similar way. Which is to say, it’s like Grays Sports Almanac, right? When the DeLorean is, you put a diagram of an iPhone and you say, “There’s this thing designed by a brilliant visionary, a genius that is going to just devour spectrum in all of these ways that you can never imagine. It’s going to just voraciously gobble spectrum. And it’s going to need a lot more of it than you ever could have anticipated that any of these other devices need that are voice only, or text only, or just your basic 1G or 2G handsets.” And this thing is going to be incredible. And it’s going to…”
Noah Campbell:
When you’re thinking about spectrum policy, you need to be thinking about this thing. You don’t need to be thinking about exterior-mounted radio that sits on the outside of your house that talks to a tower one way from a mile away, two miles away, and delivers linear television.
Craig Corbin:
And we need to make sure that the flux capacitor is in full operation as well on that.
Noah Campbell:
Yeah. It’s like in Terminator 2. It’s like Terminator’s arm. It’s a multi-band chipset, it’s a multi-band chipset.
Craig Corbin:
There you go.
Noah Campbell:
The flux capacitor, it’s a multi-band chipset from 2021 and you brought it back to 2001/2002, and the rules were made for this band. You said, “This thing has 30 bands in it.”
Craig Corbin:
Yep. Blow their mind.
Noah Campbell:
Yeah. It’s my work, right? “Why would you need 30 bands in a chip? Why would you need that?”
Craig Corbin:
And the flip side of our back to the future question would be pulling out the crystal ball, looking into the future, obviously with the hope that there is a positive response to this petition and the efforts of the coalition. What do you see transpiring over the next five years in this regard?
Noah Campbell:
I think that, and you know I was going to mention this earlier, not to belabor it. But I think one thing that industry has gotten very, very good at this. I mean, they’ve gotten really good at. That’s incredible. Nobody really talks about it. But the one thing they’ve gotten really very good at is chipset handset, radio integration life cycles. So they’ve gotten very good at very rapidly integrated new bands in the new chips. And I think looking five years in the future, my guess would be, if I was looking back and say, “The FCC will move pretty rapidly on this, it just makes too much sense not to.” There will be a way that this… Spectrum is like water, right? It flows to where it wants to be. And this spectrum doesn’t want to be where it is right now. It wants to be in 5G.
Noah Campbell:
So let’s say there’ll be some decision-making that will lead to this frequency being in 5G. I think the industry will adopt it very rapidly. And I think in five years, you’ll have a handset that you walk around within your pocket. I mean, looks like you see these ads on TV, “Oh, was such and such network now enabled with 600 MHz spectrum.” That was unthinkable when I was a kid. Nobody would know what that means. With that then, I think you’ll see, “Now enabled with 12 GHz spectrum,” and it’s going to be a major difference to how people experience their devices. And devices will be coming in. 5G devices that we can’t even envision right now. Because it’s going faster.
Craig Corbin:
Well, and it shows no signs of slowing down. We eagerly await the result of these efforts. Can’t thank you enough for what you’re doing in this regard with the coalition and anxious to hear good things. We’ll look forward to scheduling another visit down the line to see developments and how they have gone. But to greatly appreciate you being part of the Broadband Bunch today.
Noah Campbell:
Thank you. Yeah. I like being one of the grapes in the bunch and really appreciate your time and I’m happy to come back anytime. And this is a really exciting time for us. And we’re looking forward to seeing how it plays out.
Craig Corbin:
We will count on it. And on behalf of everyone here, thanks to our sponsors, UTOPIA Fiber, DxTEL, and ETI Software Solutions. I’m Craig Corbin. Thanks for letting us be a part of your day. We’ll see you next time right here on the Broadband Bunch. So long everyone.
