Sascha Meinrath on M2Z Application for Nationwide Spectrum Rights.

This posting comes out of months of discussions with telecommunications lawyers and wireless developers, FCC and congressional staff, implementers and integrators, municipal representatives and community organizers -- people with a high degree of experience and expertise in the realm of wireless networking. Part of the reason for the posting stems from a recent resurgence of interest in the M2Z application on several important virtual groups I participate in, part of the reason is that this has been sitting on my to-do list for quite some time, and part is because the M2Z application is both innovative and problematic, which is a rare and intriguing combination.

From M2Z's September 1, 2006 (amended) "Application for License and Authority to Provide National Broadband Radio Service in the 2155-2175 MHz Band":

M2Z Networks, Inc. (“M2Z”) hereby submits its license application to construct and operate a nationwide broadband wireless network in the 2155-2175 MHz spectrum band (the “Application”). Expedited acceptance and grant of the Application will enable M2Z to rapidly make available free, high speed broadband access to nearly every consumer, business and non-profit and public safety entity in the United States without relying on the Universal Service Fund or other taxpayer dollars. Grant of this Application would promote broadband deployment; yield near ubiquitous broadband access within 10 years of license grant and commencement of operations; and serve the public interest, convenience and necessity

...M2Z will transform the broadband marketplace by creating a nationwide, free broadband alternative for most Americans within an exceptionally short time frame. M2Z, therefore, requests that the Commission act expeditiously on the instant Application so that current and would-be consumers of broadband services can benefit from the increased availability and competition that M2Z’s service will bring to the broadband marketplace.

On the face of things, this is a wonderfully exciting development. But delving deeper does raise a number of concerns, not only with the spectrum use proposed, but with the current state of wireless regulation and it's disregard for pending technological innovations that make most spectrum policy obsolete.

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It is true that the 20MHz of spectrum isn't overly useful onto itself (at least not yet) for unlicensed use; however (and this is really what's really important for all spectrum reform), the technology of single-band/frequency radios is rapidly coming to a close. What is means is that the 20MHz here and the 60MHz there (and the 700MHz band and the 3650-3700MHz band) will very soon all be accessible by the same device (we're talking 5-10 years out or less). The 20MHz that M2Z is asking for would remove an incredibly valuable resource for current and future wireless networkers.

Meanwhile, the only way that M2Z can get away with calling its service "broadband" is because of the ridiculously out-of-date definition utilized by the FCC to describe "broadband" -- that being 200kbps in a single direction. M2Z barely clears even this ludicrously low bar, proposing to "make a family-friendly and free nationwide broadband service (384 kbps downlink/128 kbps uplink) available to consumers and public safety entities." In other words, the free part of what they're offering will probably be completely inadequate for any sort of meaningful Internet access by the time the network is actually deployed (you might be able to check your e-mail via the proposed M2Z network, assuming none of your friend decides to send you any sort of multi-media files).

Then one has to look at how one accesses this "free" "broadband" service -- "all a consumer needs to do is purchase a relatively inexpensive M2Z-certified reception device available
from various established competitive vendors." Basically, M2Z is going to lock you into purchasing their proprietary equipment (and who knows what that will cost) in order to access their network.

The more I delve, the more concerned I become -- here's the 5-point plan for what M2Z is providing:

M2Z is committed to: (1) provide nationwide broadband service with no recurring costs to all users that purchase and register an M2Z certified device; (2) construct its network so that at least 95% of the U.S. population – in urban centers and rural communities across America – can avail themselves of the service within 10 years of license grant and commencement of operations; (3) block access to indecent content for all free access service users; (4) provide public safety officials with access to an interoperable secondary data network, with appropriate consultation with such officials as to their needs; and (5) submit a voluntary payment to the U.S. Treasury of 5% of gross revenues generated from the subscription services that it will offer in addition to the free National Broadband Radio Service.

Let's take a look at each of these points in turn (from M2Z's executive summary):

1. The "broadband" service they're providing maxes out at 384kbps -- they can only call it "broadband" because the FCC uses antiquated definitions that are completely out of whack with a growing number of international standards.

2. Their coverage promise is 95% of the population -- one would have to be both completely naive and ignorant of telecommunications history not to see this as the ruse it is -- the same rural residents who are un(der)served currently will be the same ones who get left out by M2Z.

3. They promise to "block access to indecent content for all free access service users" -- wait a second -- you mean that if I use the free service, M2Z will decide for me what Internet content I can see and access and distribute? You betcha -- remember, it's not just what you consume, it's what you want to send out via the M2Z network as well. And who determines this censorship regime? And what sort of surveillance will M2Z use to enforce this provision? These are exceedingly important questions.

4. Public safety officials will have "access" -- but not "free access" -- in essence, M2Z promises to make itself available for public safety officials to buy services from them... just like every other company providing communications services.

5. What is a "voluntary payment" -- does this mean that they don't really have to give over this payment? And what's this "5% of gross revenues generated from the subscription services" -- you mean, if I want something beyond the craptacular "free broadband" I need to pay for it? Yes, that's exactly right. Meanwhile, the 5% will simply be tacked onto the price of M2Z's services and passed along as a quasi-tax to network users.

So where's all the great things that M2Z is offering?

While I would agree that what M2Z is offering is better than some of the other stuff we've seen, it's still the wholesale giveaway of the public's airwaves. Given current and pending changes in technology this use is neither the most efficient nor the one best serving the general public. Until ample wireless access exists in enough frequencies to provide a robust wireless networking tool-set, I cannot help but be against the continued "privatization" of any further frequency bands -- it'll just be tying our hands in the coming decade.

But one can't really fault M2Z -- if I were a (rich) savvy businessman, I'd be buying up adjacent spectrum wherever unlicensed exists (in fact, unlicensed devices have inadvertently made this spectrum extremely valuable) -- here's why:

With a software-defined radio (SDR), I can switch frequencies on the fly -- SDRs are already here (pretty much all Atheros-based radios -- which are the norm in many wireless networks today -- are SDRs). If I'm using an unlicensed device (for example, my laptop or a wifi phone) in the 2.4GHz band (i.e., 802.11b/g), and things get too congested, one simple solution would be to switch to a relatively uncongested frequency. If I'm that rich savvy businessman and I have a band right next to the unlicensed band, I can sell services that use the unlicensed band whenever possible, but can fail over to my own band, using the same radio, and with almost no extra cost. In essence, I'm selling a service that freeloads on unlicensed while providing a premium service (that costs end-users money) caused by the artificial scarcity of unlicensed spectrum. If we remove that scarcity, we all save money, which is exactly why we should demand that the spectrum that folks like M2Z are asking for be made available for unlicensed use.

In the end, I think that M2Z is utilizing an incredibly savvy marketing campaign that obfuscates the incredible limitations to their free services and mislead a tremendous number of people into thinking that what they're offering is far more useful than it actually is. I would love to see groups like M2Z create innovative models that are not so fraught with first amendment, sub-standard service provision, and profit-motive problems. Until that happens, however, we have to be exceedingly weary about trading our precious airwaves away for a song and a dance.