Overview and comparison of recent spectrum sharing approaches in regulation and research: From opportunistic unlicensed access towards licensed shared access

This paper reviews recent spectrum sharing models under study in the spectrum regulation and wireless communications research domains. An overview of different spectrum regulator forums and directions is presented and their activities related to the development of spectrum sharing models are reviewed. Special emphasis is put on the recent European and US regulatory approaches for spectrum sharing. In particular, Licensed Shared Access (LSA) and Collective Use of Spectrum (CUS) models from Europe and Three-Tier Hierarchy Model from the US are analyzed in detail. A comparison is made between these approaches to identify similarities and differences in the regulatory developments. Factors for developing a successful sharing model are also discussed. For a dynamic spectrum sharing model to be adopted, it must protect the rights of entrant users without impact to the legacy systems. It must also create a reasonable straightforward opportunity for an entity that wishes to access a shared spectrum to do so in a manner that is neither overly complex nor costly to implement. The practical implementation of dynamic spectrum sharing models is likely to require different national implementations because the regulatory approaches and the incumbent spectrum uses are different in various countries.