Before the FEDERAL COMMUNICATIONS COMMISSION and the NATIONAL TELECOMMUNICATONS AND INFORMATION ADMINISTRATION Washington, DC

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1 Before the FEDERAL COMMUNICATIONS COMMISSION and the NATIONAL TELECOMMUNICATONS AND INFORMATION ADMINISTRATION Washington, DC In the Matter of ) ) Model City for Demonstrating and ) ET Docket No Evaluating Advanced Sharing Technologies ) COMMENTS OF THE CITY OF CHICAGO ON THE MODEL CITY FOR DEMONSTRATING AND EVALUATING ADVANCED SHARING TECHNOLOGIES The City of Chicago submits these Comments in response to the Federal Communications Commission (FCC) and National Telecommunications and Information Administration (NTIA) Joint Public Notice published on July 11, 2014 (designated ET Docket No ) seeking comments on establishing a Model City for Demonstrating and Evaluating Advanced Spectrum Sharing Technologies. Introduction The City of Chicago ( City ) applauds the FCC and the NTIA for their efforts to implement the President s Council of Advisors on Science and Technology (PCAST) recommendation to develop a Wireless Model City that would facilitate the initial broad scale deployment of new wireless systems. The City appreciates the opportunity to submit its comments and is committed to helping shape an urban Wireless Model City that will support rapid broad scale experimentation and development of policies, underlying technologies, and system capabilities for advanced dynamic spectrum sharing. The most vital cities in the world enable their communities with leading-edge technology that engages, informs, and empowers. A fully connected and interactive city uses networks, sensors, data analytics, and emerging technologies to become more efficient, productive, and livable. Starting from a position of strength in technology, including world-renowned research centers and universities, robust data-science programs and a fast-growing data center industry, Chicago is well on its way to achieving this vision. In fall 2013, Mayor Rahm Emanuel released the city of Chicago s first ever Technology Plan, a framework for the city to maintain and expand its leadership and build its commitments to modern infrastructure, smart communities, and technological innovation. The Plan highlights initiatives and strategies that together help ensure Chicago is a City where technology fuels

2 opportunity, inclusion, engagement, and innovation. Chicago is committed to building infrastructure and implementing policies that make the City friendly to urban technology experimentation allowing Chicago to become a global leader in environmental sensing, spectrum research, and wireless connectivity, while enabling researchers to develop solutions to city problems. About the city of Chicago Chicago, the third largest City in the Country, contains unique assets that make it an ideal location for a Wireless Model City. FCC and NTIA should consider factors including infrastructure, public assets, track record of collaboration, and supportive policies and processes when developing criteria for selecting Model Cities. The city of Chicago covers an area of 232 square miles, is comprised of 77 community areas, and is home to over 2.7 million residents. Chicago is a major national transportation hub and home to two of the nation s busiest airports with the most extensive freight rail system in the country, the nation s second busiest transit system, and seven major interstate highways. The City possesses public assets and infrastructure that can be leveraged to support urban technology experimentation. Chicago has over 4,000 miles of roadways, consisting of over 1,000 miles of major streets and nearly 3,000 miles of residential streets, as well as over 2,000 miles of alleys. In addition, the City has an extensive network of freight tunnels, water mains, and sewers. The City owns thousands of lights that illuminate major roadways and alleys and an extensive series of fiber optic lines with right-of-way access to expand this coverage as needed. The city is traversed by the Chicago and Calumet rivers, and sits on the southwestern shore of Lake Michigan, the fifth largest body of fresh water in the world. Though on a major water way, the city is outside the range of seagoing naval vessels and their associated high-powered naval radar enabling the testing of devices that might someday need to share spectrum with these vessels, but are free from interference in their initial test environment. Chicago aims to be the technology hub of the nation and is focused on facilitating strong partnerships between all sectors to realize this vision. Chicago has a strong academic and research community and a strong base of innovative companies, ranging from new start-ups supported at co-working and incubator spaces like 1871, TechNexus, and Blue1647 to well-established firms with a history of innovation and new product and service development. The City boasts a historic strength in the wireless communications and networking sector and has best-in-class infrastructure that continues to support advances in this important and rapidly changing arena. Chicago has a track record of convening partners across sectors to meet challenges. UI Labs is a major new shared research organization focused on creating partnerships between industry and research universities to create new technologies and businesses. UI Labs works to meet the everevolving national and international needs for innovative products, systems, services, and the development and manufacturing techniques that underlie these offerings. UI Labs and partners are focusing on bridging technology and manufacturing. This past spring, UI Labs received a $70 million grant from the Department of Defense to establish the Digital Manufacturing and Design

3 Innovation Institute as part of the National Network for Manufacturing Innovation. The proposal involved top research universities led by the University of Illinois and Northwestern University, large companies, including Boeing, Caterpillar, and Microsoft, and venture funds, including Andreessen Horowitz, Lightbank, and New Enterprise Associates. Chicago is also home to the Wireless Network and Communications Research Center (WiNCom), the nation s leading repository of detailed spectrum information. WiNCom, an initiative of the Illinois Institute of Technology s (IIT) Computer Science and Electrical and Computer Engineering Departments, fuses the creative talents of researchers from across IIT and leverages domestic and international partnerships with universities, government agencies, and private industry. WiNCom operates the IIT Spectrum Observatory, which has been creating a continuous record of RF spectrum utilization in Chicago since July 2007 through fixed and mobile spectrum sensors, continuously evolving analysis and visualization capabilities, and massive data storage capabilities. This treasure trove of data and expertise should be of enormous value to those using the facilities of the Wireless Model City. The City is also in the process of establishing policies and governance around the installation and use of sensors by researchers in order to facilitate and inform policy decision making. 1. Establishing Public-Private Partnerships FCC and NTIA can further the Wireless Model City Program by calling for public-private partnership proposals from local government stakeholders and commercial interests that outline assets and plans for developing a Model City. In turn, FCC and NTIA will need to commit to providing needed flexibilities, licenses, and where appropriate, seed funding, to promote projects that test innovative approaches. FCC and NTIA should consider factors including infrastructure, public assets, and supportive policies and processes, when developing criteria for selecting Model Cities. In order to be selected, a Wireless Model City will also need a strong track record of convening and implementing public-private partnerships that solve problems and bring results. 2. Experimental Licensing Rules and Processes The existing experimental licensing rules seem very adequate for larger wireless companies who understand the process and have the resources to secure these licenses. Start-up companies, on the other hand, may need additional support to enable them to access otherwise unavailable spectrum. Therefore, the FCC should consider granting experimental licenses to the Model City itself, with the ability to sub-license this spectrum to local start-ups in an efficient manner while ensuring that the spectrum is used in a manner consistent with the terms of the license. NTIA and the FCC OET could further expedite processes by indicating the spectrum that is of critical interest in current, anticipated, or potential rulemaking activities and make it more readily available to the Model City as a suggested experimental license. This spectrum would in turn be made available under sub-license to the companies operating under the auspices of the Wireless Model City, specifically for use within well-defined local Innovation Zones.

4 3. Management of Model City Program The program should be initiated and facilitated by the FCC and NTIA to demonstrate the seriousness of this effort and its intended benefits at a national level. This coordination should help identify potential funding opportunities and licensing needs, facilitate dialogue between Wireless Model Cities, and measure and publish demonstration and research results to ensure others across the country are learning from these programs. Each Model City should be locally managed by its partners through a structure that suits its needs and should be staffed with appropriate skills. 4. Facilitating the Development of Innovation Zones Innovation Zones will be a critical element of a successful strategy to build and test new, cutting edge wireless services. While the FCC and NTIA can help facilitate this process, cities must work independently to identify these target areas. A successful model will already have a foundation in place or in progress to support technology experimentation through pilots and other initiatives in these predetermined zones. Last fall, the City identified seven key industrial and commercial areas as Innovation Zones and is currently putting in place the additional infrastructure and policies necessary to support further technology testing. Chicago is also considering the development of other zones that meet requirements expressed by researchers, including academic institutions and wireless companies, to test new technologies. These existing or planned innovation corridors can be expanded, and the rules around them refined, to build out a Wireless Model City program. 5. Collaboration to Facilitate Rapid Experimentation The key stakeholders in the Wireless Model City would need as much flexibility as possible to pursue the novel ideas that will allow for enhancements in spectrum usage approaches and the development of new technologies, products, and services. This would include the rapid, flexible licensing described above and ready access to the City s Innovation Zones as well as experimental physical platforms (e.g., light poles, power, and the Internet). Smaller companies may also need access to standard instruments and technical support for performing needed measurements. Finally, and of critical importance, a standardized set of legal agreements especially related to company liabilities, intellectual property will be required. Chicago is already a leader in facilitating collaboration to encourage rapid experimentation by matching academic and industry researchers and developers (including the start-up community). The City is a key partner in entrepreneurial start-up hubs, including Chicago s 1871, and publicprivate research partnerships like UI Labs. 6. Local Government s Role Wireless Model City deployment locations should be identified and selected through an open solicitation process with well identified criteria for selection. The solicitation should provide appropriate financial incentives to encourage participation by not only the City itself, but by a

5 consortium of industry and academic players, who would pledge to ensure the success of the endeavor through the provision of matching funds to support the effort. The Wireless Model City candidates should be able to demonstrate the availability of an Innovation Zone to perform the desired testing at scale. The City should be committed to establishing the needed management structure with appropriate skills and support to make it successful. Further, the Model City should be able to demonstrate the existence of an appropriate skills base in academia and industry and infrastructure to support the deployment of the Wireless Model City Program. As a result of deploying a real-world urban lab environment in the Model City, commitments from participating firms to open offices in proximity to the lab would be expected. This would be important to not only enable the firms to make optimal use of the Model City, but to also meet local economic development goals and enhance the desirability of hosting the Wireless Model City. Economic support for opening these offices in the early days of the program will likely be important to help kick-start the effort. This win-win scenario would be of enormous interest to the local government, and, likely, the state governments associated with the selected Wireless Model City or Cities. Rapid access to city resources is critical, including access to physical assets like light poles, power, tunnels, the wired infrastructure owned by the City, and the drawings that allow designs to be efficiently developed and deployed. Making these available through expedited and assisted permitting processes, as well as direct physical access under City supervision, will be critical to the success of the Model City. In many cases, the City will need to provide resources to support the deployment of the systems to be tested and the resources will need to be deployed in a timely manner to meet the rapid development goals for the Model City. 7. Potential Funding Mechanisms Funding is a critical element of the Wireless Model City program, particularly early stage funding, to establish the needed infrastructure to support the wireless user community. Funding would also be needed to pay for the core resources that would need to be deployed in order to use the Model City s infrastructure to perform experimental wireless systems installations. Host cities should commit to bringing in-kind support. Through our recent UI Labs collaboration efforts, we, as a city, have demonstrated that there is huge incentive for companies and universities to cross-leverage the resources of others to advance their own initiatives. Available federal government funding has been a key component of the equation. Specifically, companies, local government, and universities are collectively willing to provide real and in-kind funding multiple times the funding made available by the Federal government to support these efforts. Participation might also be incentivized with the prospect of government as a customer for the products and services developed and tested in the Model City environment. As a specific example, adding a requirement in appropriate government procurements, and perhaps even in

6 private procurements, that the wireless system in question must have been tested at scale would provide a strong incentive to increase participation in the Wireless Model City program. Finally, wireless businesses will require rapid access to Model City infrastructure (i.e., physical platforms, power, Internet, etc.), personnel to support deployment and testing, and a rapid, efficient permitting process. Special treatment of experimental licenses would also be important. Collectively, the exemplary availability of these elements will be a strong incentive for participation in the Model City program. Conclusion The City of Chicago supports NTIA and the FCC in their initiative to implement the PCAST recommendation to create a Wireless Model City. Chicago s deep experience convening stakeholders across sectors to meet common goals, as well as our experience facilitating the development of advanced technologies, has informed the comments submitted to this joint public notice. We look forward to the development of the Wireless Model City program, and continuing the conversation with NTIA and the FCC. City of Chicago By: /s/brenna Berman Chief Information Officer & Commissioner