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CHIPS Articles: ‘No Change’ Champions

‘No Change’ Champions
By Thomas Kidd - January-March 2020
In this article, we address the exceptional effort required to champion stability and the unsung heroes who prevent unnecessary change. Newton's First Law of Motion states that a body in motion will remain in motion in a straight line unless acted upon by an outside force. The same is true for policy and regulation. These will also remain in place unless acted upon by an outside force. We call that outside force “change.” Change creates new opportunities; change makes the world a better place; change for the sake of change is often seen as good. However, change is not always good when it comes to changing policy and regulation.

How the world uses electromagnetic spectrum all starts with the International Telecommunication Union (ITU) Radio Regulations treaty. Changing this treaty is an arduous process often taking a decade or more. When global frequency band usage is changed, it is done by changing the treaty. Every three to four years a World Radiocommunications Conference is held to finalize these changes. Thousands of delegates from around the world converge at this conference to debate and ultimately ratify changes to the ITU Radio Regulation treaty — or keep the status quo. The global investment in this process is significant. The champions of any changes are heroes within their respective technological communities.

While we should never diminish the accomplishments of those who change the world, it is equally important to recognize those on the other side of the argument: The champions of maintaining the status quo. These champions can be as important as the champions of change, yet we rarely hear good news about their success in resisting change.

The issue of change being positive or negative also applies to Department of the Navy spectrum-dependent technology policy. Spectrum dependent systems may take decades to develop and deploy. They are often highly specialized equipment designed to squeeze every capability from the spectrum in which they operate. Every bit of physics is leveraged to give our warfighters the advantage in battle.

Each military spectrum-dependent system is optimized to leverage the specific characteristics of the spectrum in which it operates. For example, because antennae mounting space on a ship is limited, every spectrum-dependent system is designed to fit within that vessel’s electromagnetic environment.

Changing the ITU Radio Regulations treaty takes many years. Proponents of change will offer several options. The opponent of an option may propose ‘no change’ (to the status quo) as a method to resolve the issue. “No change” is such a common proposal that the abbreviation NOC is a standard term. An advocate for the status quo states their position as “NOC.” They may still be willing to discuss alternatives, but their preference is that that part of the treaty remains as-is.

If an advocate is strongly opposed to change, their position will be NOC, with the addition of an underline, which tells the rest of the world that not only are they opposed to changing that part of the treaty, they are not open to discussing the issue. Because DON systems are highly specialized, it is occasionally necessary for the DON to advocate NOC or NOC for the frequency bands in which we operate.

Why are changes proposed to the ITU radio regulations? A typical example is when entities want to use a specific spectrum frequency band that is already being used by an incumbent system. New entrants into a frequency band must prove their new technology can share with incumbent technology. They perform sharing studies as proof. The new entrant tends to assume the best possible capabilities for their systems and their ability to share. As a result, the new entrant’s sharing study indicates compatibility, yet the incumbent’s sharing studies may indicate otherwise.

Because the electromagnetic spectrum is a congested environment, small differences in assumptions can have major impact in a study outcome. Spectrum sharing studies are complex computer simulations of the electromagnetic environment. Even with advanced computers, these studies are difficult. Thousands of hours are required to program all the parameters. Separate studies may be required to determine specific parameters needed for the sharing study. In total, both the advocates for change and those advocating NOC will invest significant resources supporting their position. If the advocate for change prevails, they are usually written in financial and technical journals. If the advocates for NOC prevail, it is rarely covered. Nothing changes, the status quo remains.

In each case, both sides invested heavily to support their position. In each case, both sides were advocating for their current and future operations. And, in each case, both sides deserve admiration when they prevail.

The DON CIO Spectrum Team will always advocate in the best interest of the Department of the Navy and the United States of America regardless if that advocacy results in dramatic changes in the ITU Radio Regulations treaty or maintaining the status quo. While the former may receive all the headlines, we recognize the latter is equally important.

Tom Kidd is the director for DON Strategic Spectrum Policy in the Office of the Chief Technology Officer, Department of the Navy Chief Information Officer.

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