The RSGB reckons that 500MHz of spectrum, which the Ministry of Fun wants to see sold off by 2020, isn't empty, and hasn't much application anyway.
In an open response to the Ministry's proposals, which explain how it plans to find huge swaths of spectrum with which to meet the insatiable demand for more bandwidth, the Radio Society of Great Britain points out that many of the identified bands aren't empty, that even if they were, hardly anyone can use them, and that it is far from clear if anyone wants such an enormous amount of bandwidth anyway.
The insatiable demand is based on the idea that existing trends will continue, that users will consume an ever-increasing amount of bandwidth. That's obviously baloney: the same process can be used to prove that by 2019 a third of us will be working as Elvis impersonators, if trends up to the year 2000 had continued. Clearly the world has a limited apatite for imitations of The King, and additional value of bandwidth equally suffers from diminishing returns.
In its response (PDF, nice picture of a moonbounce dish at the end) the RSGB points out that 3G-TDD spectrum (held by all the UK operators except Vodafone since 2000) is still empty despite the widely perceived shortage, and that Qualcomm has been sitting on 40MHz of L-Band spectrum (1452-1492MHz) for two years after having shelved its mobile TV plans.
If we were really so desperately short of frequencies, goes the argument, then surely these gaps would have been filled. One would also expect some interest in the 50MHz of digital dividend at 600MHz, which no one seems to want despite its excellent propagation characteristics.
The free-up-500MHz-of-bandwidth plan was inherited by the Ministry of Culture, Media and Sport (aka Fun) when it took over spectrum management from Business, Innovation and Skills, and followed a US paper proposing the same thing. Ofcom wisely distanced itself from the plan when it was announced, saying it is happy to make the arrangements but deciding what to do with government-owned spectrum is a government job.
To understand why radio spectrum got shifted into the Ministry of Fun you have to remember how important the London Olympics are to the government, and how important radio spectrum will be to the Olympics, but the portfolio includes future planning and thus the task of finding some bandwidth to sell off.
The consultation put out by the Ministry (pdf, like an Ofcom one but with pictures) mainly lists Ministry of Defence spectrum as being suitable for reallocation into the open market, which sounds great until one realises what a sharing organisation the MoD is when it comes to radio frequencies. Massive amounts of spectrum are nominally allocated to the MoD, but sublet to other users on the condition they switch off if and when the military needs it. Amateur radio hobbyists (represented by the RSGB) are heavy users of MoD spectrum.
But the thrust of the RSGB's comment is that the Ministry seems to have neglected the widely divergent values of radio spectrum, and that much of the spectrum it has identified as available is next to worthless, if only because the world has decided to make it so.
Radio technologies rise and fall on standards and mass production. The operators who'll be bidding a fortune for the 800MHz band next year aren't interested in 600MHz simply because no one is making equipment which operates in that band: the valuable frequencies are the ones people can use, and use cheaply.
The RSGB's response asks the Ministry to accelerate the release of internationally agreed bands, and hold back on pushing out more spectrum until all the users (not just the allocated holders) have been considered, which makes a lot of sense even if you're not a bearded radio ham. ®