Earlier Work


I presented a paper on September 28, 2013 at TPRC41 with colleagues at RWTH Aachen (http://ssrn.com/abstract=2241609) about Wi-Fi congestion. Some replies to the resulting critique are at http://bit.ly/EmperorQA. We found little hard engineering evidence in the literature that Wi-Fi congestion is a pervasive problem; and there are dueling anecdotes in the trade press. Defining congestion is problematic, and we propose criteria based on user experience and economic considerations to judge claims of congestion. We do not claim that the absence of evidence of congestion amounts to evidence for the absence of congestion. However, we question the argument that congestion occurring somewhere, sometimes is a justification for regulatory intervention.

My paper "Optimizing receiver performance using harm claim thresholds" has been published in Telecommunications Policy: http://dx.doi.org/10.1016/j.telpol.2013.04.008. It's part of the TPRC 2012 special issue.

The Wireless Spectrum Research and Development (WSRD) group held its Workshop IV at MIT on April 23-24, 2013. I participated in a panel 2.3; my slides are online (pdf) and my presentation starts at time code 0:50 in the webcast.

I filed reply comments on the 3550-3650 MHz NPRM (proceeding 12-354) on 5 April 2013.

I filed comments on the FCC's proposed new rules for the 3550-3650 MHz band (proceeding 12-354) on 20 February 2013. For a summary, see this blog post.

The FCC TAC white paper "Interference Limits Policy: The use of harm claim thresholds to improve the interference tolerance of wireless systems" (Version 1.0, February 6, 2013; pdf) has been published on the TAC web site. The paper was written by the TAC's Receivers and Spectrum Working Group; I was the principal author. The FCC published a public notice requesting comment on this report on April 22, 2013 (document DA 13-801, ET Docket No. 13-101).


A paper on regulation, efficiency metrics and the design space of wireless systems that I wrote with colleagues at RWTH Aachen has been published in the December 2012 issue of IEEE Communications Magazine: Mahonen, Simic, Petrova & De Vries, "From protocol stack to technology circle: exploring regulation, efficiency metrics, and the high-dimensional design space of wireless systems" http://dx.doi.org/10.1109/MCOM.2012.6384457.

On November 29, 2012 I testified at the House Committee on Energy and Commerce’s sub-committee on Communications and Technology hearing on the topic “The Role of Receivers in a Spectrum Scarce World.” I blogged a summary of my testimony; see also the written testimony (pdf), video of my oral testimony and video of the the members' questions. Some press here and here.

I organized a conference for Silicon Flatirons in DC on spectrum policy on November 13, 2012. The program and position papers are available on the event page.

A paper I wrote with colleagues at RWTH Aachen about the relationship between engineering practice and technology policy was presented at TPRC 2012. The paper is at http://ssrn.com/abstract=2031656, and the slides at http://bit.ly/TPRC2012EngineeringPolicyRegulation. A version of this work was published in the December 2012 issue of IEEE Communications Magazine: http://dx.doi.org/10.1109/MCOM.2012.6384457

My current take on interference limits is written up as a paper for TPRC 2012, delivered on Septermber 22nd, 2012. The paper is available on SSRN, http://ssrn.com/abstract=2018080. The slide deck I used is at http://bit.ly/TPRC2012InterferenceLimits. (An updated and streamlined version is at http://ssrn.com/abstract=2195330.)

The President's Council of Advisors on Science and Technology (PCAST) released its report Realizing the Full Potential of Government-Held Spectrum to Spur Economic Growth on July 20, 2012 (PDF, Administration’s blog post, webcast). The report recommends that interference limits are used to include receiver considerations in spectrum management. (I was an advisor to the PCAST committee that wrote this report.)

A comment on the FCC's AWS-4 Notice of Proposed Rulemaking (WT Docket No. 12-70), making the case for interference limits and their application in this proceeding: PDF

I made a presentation and participated in a panel at the FCC Workshop on Spectrum Efficiency and Receivers on March 12-13, 2012 (Public Notice PDF). My presentation is at http://sdrv.ms/AwoAZj. My presentation is on the day 2 video starting at time code 36:00 (there is also video for day 1); my opening comments on the subsequent panel are at 86:00, and various times subsequently.

An evolving summary of my proposal on receiver protection limits is available via http://sdrv.ms/ReceiverLimits (first posted 26 January 2012). My thinking started to crystallize in June 2011; the root blog entry has a constantly updated list of subsequent posts. (A more recent document provides an introduction to harm claim thresholds, the current incarnation of receiver protection limits: http://sdrv.ms/1impAKx)

A report by Madelaine Maior (10 January 2012, PDF) has been published on the Silicon Flatirons roundtable I organized on Efficient Interference Management: Regulation, Receivers, and Rights Enforcement on 18 October, 2011.

Reception-oriented radio rights: Increasing the value of wireless by explicitly defining and delegating radio operating rights is now in press (Telecommunications Policy, January 2012, http://dx.doi.org/10.1016/j.telpol.2011.12.009)


A reworked version of the "Internet Governance as Forestry" paper was published in JTHTL, vol 9, Issue 1 as "The Resilience Principles: A Framework for New ICT Governance " (pdf)

We held an invitation-only workshop on wireless interference management, focused on receiver and enforcement questions, on Tuesday 18 October, 2011 at Silicon Flatirons in Boulder. A reading list with relevant resources (PDF) is on the event web site. A report on the meeting is in preparation.

A draft of the paper Reception-Oriented Radio Rights: Increasing the Value of Wireless by Explicitly Defining and Delegating Radio Operating Rights, a reworking of the ideas in the Three P's paper co-authored with Kaleb Sieh, is at SSRN.

I presented the paper The Three Ps: Increasing concurrent operation by unambiguously defining and delegating radio rights, co-authored with Kaleb Sieh, at DySPAN 2011. A pre-print is available at SSRN.

I organized the conference The Unfinished Radio Revolution: New Approaches to Handling Wireless Interference for Silicon Flatirons and co-sponsors in Washington DC on 12 November 2010. At the conferences I presented a position paper, co-authored with Kaleb Sieh. A more detailed treatment is at SSRN, and has been published in JTHTL (PDF) as a package of the papers presented at the conference

My presentation at ISART 2010, "How I learned to stop worrying and love interference: Using well-defined radio rights to boost concurrent operation " is now available in the archive: paper, slides, video (starts at timecode 00:52:41)

My work on the evolution of FCC lobbying coalitions has been accepted in the JoSS (Journal of Social Structure) Visualization Symposium 2010 (link to my entry). Jim Moody of Duke has done a wonderful job collecting a dozen visualizations of social networks. Each is worth exploring; in particular, see the thoughtful comments that the JoSS staff provided to each entry in order to stimulate debate.

On 10 May 2010 I filed a comment on two FCC proceedings concerning ways to improve the way it does business. I argued that transparency and rule-making efficiency could be improved by improving the metadata on documents submitted to the Electronic Comments Filing System (ECFS).

While preparing my paper on new governance and the resilience principles in JTHTL, I worked through the Silicon Flatirons governance events of the last couple of years, and came up with a taxonomy of governance. These ideas won't make it into the paper, so I've put them in a working paper up on SSRN: New Governance for the Internet: Findings, Taxonomy and Model (May 2010).


I've been working out the implications of my TPRC 2008 paper “Internet Governance as Forestry” (SSRN) in a number of settings. I presented the ideas in a panel on "The Governance Challenges of Cooperation in the Internet Ecosystem" at the Silicon Flatirons annual conference in Boulder on February 1st, 2010; my comments can be seen here at time code 01:36:00 (abut 15 minutes). My slides are up on Slideshare.net, and a paper is in preparation for JTHTL. I trimmed the pitch to five minutes for a panel in DC on "An FCC for the Internet Age: Reform and Standard-Setting" organized by Silicon Flatirons, ITIF and Public Knowledge on March 5th, 2010. My introductory comments tried to summary the "resilience principles" in five minutes: the video is available on the Public Knowledge event page, starting at time code 02:04:45. The panel starts at around 01:57:00.


A report (DOC, PDF) on the conclusions of a closed-door meeting of experts about the causes and regulation of inter-channel radio interference, held at the Silicon Flatirons Center of the University of Colorado, Boulder, on 8/9 September 2009.

A slideshow on my analysis of the evolution of FCC lobbying coalitions; a shorter set (18 slides instead of 31) is here.

Notes on Reforming the Federal Communications Commission, a comment prepared for a conference to be held by Public Knowledge and Silicon Flatirons at the National Press Club, Washington, D.C., 5th January 2009. The panels are on Youtube, including mine; some of my comments at 8:50, 35:11, 54:16, 1:04:37.


"De-situating spectrum: Rethinking radio policy using non-spatial metaphors" (17 pages, abstract and download at SSRN) - an attempt to show that there are better alternatives to the spectrum concept for radio regulation. Accepted for DySPAN '08; slides (450 kB PDF).

"Internet Governance as Forestry: Deriving Policy Principles from Managed Complex Adaptive Systems" (56 pages, abstract and download at SSRN); for a short introduction, see the Publius essay for the Berkman Center. Accepted for TPRC '08.

Internet Forestry: A Principles Approach to Governance, an essay for the Berkman Center's Publius Project (May 2008)

Wayne Stark and Pierre de Vries, "Detection of White Spaces in a Cognitive Radio Architecture," Cognitive Radio Oriented Wireless Networks and Communications, 2008. CrownCom 2008. 3rd International Conference on, pp 1-6, 15-17 May 2008. Abstract on IEEE Xplore.

Gary Tonge and Pierre de Vries, "The Role of Licence-Exemption in Spectrum Reform," COMMUNICATIONS & STRATEGIES, no. 67, 3rd quarter 2007, p. 85 (abstract and download at SSRN)

A May 2007 lecture on "Hard Intangibles" at the Annenberg Center for Communication at USC (abstract) has now been posted in a choice of formats. Audio: MP3. Video: QuickTime or Windows Media.

"Imagining Radio: Mental Models of Wireless Communication" (abstract and download at SSRN) - an exploration of the mental models used in spectrum policy. Presented at Dyspan 2007, published in the 3rd IEEE International Symposium on New Frontiers in Dynamic Spectrum Access Networks, 2007 (DOI: 10.1109/DYSPAN.2007.55).

"Gardening the Internet/Web: A Framework for Communications Policy" (60 pages: DOC, PDF) - using the metaphor of gardening as a guide to using complex systems theory to inform internet policy questions. First draft January 2008.


Metaphor Mappings for Wireless - a summary of the mental maps used in thinking about wireless communications; for the context and use, see Mental models of spectrum. (Posted November 2006)

Populating the Vacant Channels - The case for allocating unused spectrum in the Digital TV bands to unlicensed use for broadband and wireless innovation (New America Foundation, August 2006)

Mental models of spectrum - An analysis of why we talk about spectrum the way we do (updated October 2006). Running log of raw metaphors as spreadsheet here

Problems with Basic Access Broadband - Why "basic tier" proposals for broadband access won't work (Mar 2006)

Hard Intangibles - a project to understand the mismatches between our embodied ways of thinking and the abstractions of the knowledge economy (Mar 2006)

Paradigm shift rate and population (spreadsheet) (Jan 2006)

Extending software patents: Those who live by the sword, die by the sword (Jan 2006)


Four scenarios for the future of broadband in the United States (Dec 2005)

Notes on Benkler's Intellectual property and the organization of information production (Nov 2005)

When Dirt and Digits Collide, Annenberg School for Communications (Sep 2005)