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Advising the FCC on Invisible Infrastructure

Federal Communications Commission Chairman Julius Genachowski uses the apt term "invisible infrastructure" to describe the radio spectrum over which all wireless communication occurs. "Though you can't see it, spectrum is the oxygen of our mobile communications infrastructure and the backbone of a growing percentage of our economy, Genachowski said in a recent talk at the FCC Spectrum Summit.

At the summit Genachowski also announced that he has set up a Technical Advisory Committee (TAC) "comprised of some of the leading technology and business leaders in our country" to provide "counsel on using spectrum and other communications technologies to drive job creation and economic growth." I'm one of the members of the TAC. [This is volunteer work; your tax dollars are safe.] Although government committees can be waste of time and an excuse for inaction, I'm hopeful about this one because the Chair and the FCC clearly understand both how urgent the need is to make more spectrum available for mobile communication AND the size of the opportunity this can be for the US.

Think cell phones and smart phones in general; think Wifi and Bluetooth; think Kindle, iPhone, iPad, and Android; think of the application markets which have already opened up for these technologies and devices; the services new and old which can be delivered over them. All of this opportunity requires radio spectrum.

The spectrum is a national resource; it belongs to all of us; it is managed by the FCC within parameters set by Congress. If we keep managing it in the traditional way, which evolved when technology was very different, we will run out of spectrum and exhaust radio-based opportunities; our devices will slow down because of spectrum congestion even though we want to use them more. Genachowski says "we are likely to see a 35X increase in mobile broadband traffic over the next 5 years."

He continues:

"It's clear: We are standing at a crossroads. We are looking at two potential futures.

"If we act thoughtfully and execute on a strategic vision to ensure the highest and best use of this precious national resource, we can drive billions of dollars in private investment, fueling world-leading innovations, creating millions of new jobs, and enabling endless new products and services that can help improve the lives of all Americans.

"If we don't, we will put our country's economic competitiveness at risk, and squander the chance we now have to lead the world in mobile."

Under Genachowski, the FCC recently made a decision which will allow "TV white spaces", spectrum which used to be reserved for over-the-air TV, to be used instead for UNLICENSED services like WiFi and Bluetooth and whatever else inventive minds can invent. Just the success of those two technologies, in the small slivers of "undesirable" spectrum so far available to them, demonstrates how much more information can be transmitted over shared spectrum than over spectrum licensed to a particular owner AND how much innovation results when spectrum is made available for innovation rather than earmarked for a specific purpose.

In some sense spectrum is finite like, for example, the width of a fiber used to carry signal. However, evolving technology makes it possible to squeeze more and more information through the same strand of fiber and over the same range of radio spectrum. But the use of radio spectrum is regulated unlike the technologies used in fiber optics. Although some regulation is needed to prevent interference and allocate the right to use this public asset, the "wrong" regulation and the "wrong" allocations will result in spectrum shortages. The "right" regulation and allocation – what the FCC is doing with white spaces – will make spectrum relatively cheap and plentiful.

I'm glad to have the opportunity to help devise a plan for our crucial invisible infrastructure.

Go White Space, Young Person, Go White Space

"Go white space," is the advice Horace Greeley would give if he were alive today. This supersedes previous advice given to Dustin Hoffmann to go into plastics just before his first romantic encounter with Mrs. Robinson as well as Greeley's earlier advice to go west. Use of the "TV white space" will be the new wild west in many ways; there should be a gold rush of innovation.

"White space" is radio spectrum that used to be reserved for TV use. Some has been freed up by over-the-air TV shifting to digital broadcasting which needs less spectrum; some – particularly in rural areas – never was used for TV and now pretty clearly won't be. In a decision two weeks ago, the Federal Communications Commission (FCC) made it practical for this valuable idle resource to be used WITHOUT OWNERS OF TRANSMITTERS BEING LICENSED. This is a big deal. It will lead to enormous innovation; it gives American companies a valuable sandbox to innovate in; and it will also result in much better use of the available radio frequencies.

Radio spectrum is considered a public resource and "belongs" to the federal government which usually auctions off what it doesn't need for its own purposes. These auctions have brought considerable revenue into the treasury. Nevertheless, two years ago the FCC first made the gutsy decision to leave this newly available, highly desirable spectrum for unlicensed use without a fee. I was convinced that this would lead to an immediate burst of innovation then – I was wrong (so maybe you want to take my enthusiasm now with a grain of salt). Just when this innovation explosion was supposed to happen, the recession hit – all we got was a burst of bailouts, not investment.

Moreover, it turns out that the original technical regulations imposed by the FCC then were unnecessarily difficult to comply with. Radios using this spectrum were required to be able to detect all broadcast stations they might be interfering with even if they incorporated location sensing and were able to check a database for licensed users. Now either approach is allowed, but radios don't have to incorporate both. In the interim, technology has moved relentlessly along: the cost of location sensing has gone way down as GPS chips proliferate; radios have gotten smarter and smarter and more and more capable of the kind of agile frequency use required when sharing spectrum with strangers.

We have all seen firsthand what happens when spectrum is left free for unlicensed use – the best example is WiFi. You can install a WiFi radio in your house without a license. Bluetooth, which we usually use to connect our cell phones to other devices, is another example where incredibly useful very inexpensive devices and uses have blossomed. Cordless phone are a third example. All of these uses coexist in some shards of spectrum which were undesirable because various instruments and machinery generate noise at these frequencies. In 1985 the FCC chose to make this spectrum available for unlicensed use. The chart below shows the flurry of innovation which resulted and hasn't stopped yet.



For technical reason, the ex-TV white space frequencies can be used for much longer distance transmission than the frequencies formerly available for unlicensed use. Moreover, transmissions at these frequencies go through walls and usually through leaves. Even though these signals won't go through granite (or brick walls), they bounce well so they effectively go around corners. These are as good as the frequencies which cell phones are on today.

Availability of the white space under new, more realistic regulations, is particularly good news for rural areas since we have less TV channels and thus more spectrum available. This spectrum will be important to the economical delivery of date communication, particularly mobile data communication, in sparsely populated areas with difficult terrain.

Eventually use of the white space may diminish the value of the licenses which carriers like Verizon Wireless, AT&T, and others bought at auction; that's one of the reason it took so long to get this use approved in a meaningful way. Those licenses serve to reinforce the control the telco duopoly has exercised over mobile communication; unlicensed use will open the way to more competition – something we need. White spaces are disruptive; our economy could use some healthy disruption.

Carl Ford, who knows a lot about such things, wrote:

"In other words the White Space decision is the CarterPhone decision of our time. [nb. CarterPhone broke the telco monopoly on devices attached to the phone network. Without it we wouldn't have had modems.]

"The old rules are being honored with the spectrum mapping required, but at least they did not force White Space to adopt costly spectrum monitoring techniques.

"Ideally it would be nice to see Mary and Tom Evslin lead a charge of enhanced service enablers in a regulatory free zone."

Nice of Carl to remember the disruptive days of VoIP. We're retired now but it still makes us feel good; we'll enjoy the charge no matter who leads it.

Related posts:

Fractals of Change: The White Space Opportunity - Priceless

Fractals of Change: White Space Momentum

Fractals of Change: The FCC White Space Regs – Pretty Good at First Glance [I was wrong]

Fractals of Change: The Other Vote on November 4th

Fractals of Change: FCC Vote Results – We The People Won

Fractals of Change: The Importance of the FCC



Ten Telecom Tsunamis

The telecom industry five years from now will be unrecognizable. The creative destruction of the Internet broadly writ will be even greater than it has been in the last decade. The major telcos, the major television networks, and the major cablecos – if they still exist at all – will have very different revenue models than they have today. That's the good scenario. In the bad scenario the old business models are bailed out or saved by regulation to the detriment of consumers and society in general.

Here's a list of ten major drivers of change:


The driver of all drivers will be universal very broadband Internet access. Five years from now we'll all (except for those who choose to live off the net) have a minimum of 25megabit per second download speed (and that'll be the low end) when we're standing still. We'll be connected – perhaps at a slightly lower rate – when we're moving around, especially in our cars but also in planes and trains and on foot. That means that the next generation of communication services whether they be voice, entertainment, power management, information, health or something else can and will all be built assuming this universal connectivity. See here for why government should help accomplish universality sooner rather than later.

End of the Billable Minute

We won't pay for voice calls by the minutes any more than we pay for email by the word. This trend is already well underway, of course, with flat-fee VoIP based services, "free" VoIP-VoIP calls, and unlimited minute plans; but last mile monopolies have managed to keep minutes billable on many international and most mobile calls. Universal IP connectivity for both residential and mobile users will complete the bypass of these last mile bottlenecks. There'll be no incremental charges for voice, just monthly connectivity plans for bits of any sort. Gory details on why we still have billable minutes are here.

End of Copper POTs

The recession is accelerating the abandonment of landline phone service currently running at better than 10% per year. Without a major breakthrough (which could happen), copper-based DSL won't be good enough for the bandwidths we'll all need in a year or two. Line loss along with displacement of voice calls to VoIP (see above) will shrink revenue earned by the copper network, which has served us long and well, so that the carriers can no longer afford to maintain it even though it will still have many users left. That may be a mess. More here.

End of the Channel

The channel is a left over concept from the days of over-the-air TV. It's convenient for marketing reasons but not technically necessary for cable and satellite companies to deliver a set of channels; they could offer single shows or series ala carte. Today they choose not to except for events they can get a good premium for – pay-per-view. But The Internet is essentially ala carte and the Internet will deliver our entertainment, business model tbd. There may be bundles of content available both to facilitate choice and for economic reasons but children will ask "Daddy, what's a channel?" It's likely that the cablecos will convert most of their bandwidth to support generic very high speed Internet access instead of carving it up for channels.

End of Over-The-Air TV

As we know from the recent flap over the now-postponed switch to digital TV, there are people who still watch TV over the air. But the number keeps shrinking and, as more and more of that same content is available on the Internet and more and more people have sufficient connectivity (see above) to receive that content from the Internet, the economics of over-the-air TV will become prohibitive even though the broadcasters don't have to pay for the spectrum they use. It's not that the local stations'll disappear (at least I don't think they will); they just won't have antennas attached to them. The stations may be able to get a boost by subleasing the spectrum they used to use for over-the-air for generic Internet access. We'll probably end up paying people $40 each for boxes to attach their old tv sets to the Internet.

Open Spectrum

After a rocky start, the white space experiment which the FCC decreed this year will be an enormous success. This open spectrum will be extremely valuable both for fixed and mobile Internet connectivity. More open spectrum will be needed and will become available as TV goes off the air (see above). Why open spectrum is so important is here.

Bandwidth Demand

The price of providing bandwidth either over the air or through a fiber goes down roughly with Moore's law. Every year and a half the amount of bandwidth that can be provided at a given cost doubles. This trend'll continue as we all demand more bandwidth partly in order to receive all the entertainment we used to get from dedicated networks and partly for new applications. Today's five meg connections will soon be as useless as yesterday's dialup as new bandwidth-hungry Internet uses are invented and become essential and as websites are built on the assumption of higher and higher bandwidth availability. See here for more on the bandwidth required to receive "television".

Online GPSes

It'll be no more than a couple of years until every car-mounted GPS is online whenever the car is turned on. We'll get and contribute automatically to crowd-based weather and traffic reports. We'll know how long the lines are at a local attraction before we get off the Interstate – and we'll buy our tickets before we get there. The billboards will literally be inside the car. This post is about an early GPS with connectivity.

Latency Intolerance

Latency is the time between when we send something on the Internet and the time when we receive a response. Interactive voice demands low latency; so do modern web pages which build themselves on your screen through a series of interactions. High altitude (geostationary) satellites cannot provide low latency because of speed-of-light limitations so they will not be a significant provider of Internet connectivity. Local Internet providers also have routing problems to and from the Internet backbone which contribute to latency. Some measure of expected latency'll become part of the marketing description of an Internet connectivity service. More on latency and satellite here.

Smart Grid

Electricity will begin to replace imported oil and gas for home heating and transportation and some other applications during the next five years. Our total electric consumption will go up. But the fossil fuel required to create that electricity will go down as the demand for electricity goes up. A smart grid which lets us better use baseline power from hydro, nuclear, wind, and solar will accomplish that near miracle. See The Smart Grid Should be Stupid.

Good and Not So Good News

Julius Genachowski, Obama's nominee to head the FCC, is a friend of Fred Wilson. Fred gives ten reasons why he likes the nominee on his blog. Genachowski was a top technology advisor to Obama during his campaign and reportedly advised the campaign on its superb use of the Internet. He is also a supporter of "net neutrality" although the devil is in the details on that issue. Even though the nominee is a lawyer, he has business experience as a VC, as an Internet executive, and as a board member of various Internet companies – all good reasons to be hopeful about this very important policy post.

That's the good news.

The bad news from several days ago is that the Obama transition team has recommended that the cutover to all digital TV be postponed. That also delays the time that spectrum purchased in the recent 700Mhz auction and spectrum in the socalled "TV whitespaces" can be put to productive uses such as more Internet access and increased mobile access – especially for mobile data. This cutover has been scheduled for February 17th of 2009 since 2005. The cutover date – which affects only those receiving over-the-air television – has been widely publicized and $40 coupons have been available from the government to subsidize the purchase of converter boxes by those who would otherwise lose signal.

The fear – supported by exFCC Chairmen Powell and Kennard – is that some people are not ready for the transition. There has been the kind of government screwup that we've become accustomed to: not enough coupons are available because the legislated funds for coupons are exhausted and, apparently, no one thought to ask Congress for more. Some people have had to wait and are still waiting for coupons. However, since it would take legislative action to extend the deadline, it would seem more constructive to just take legislative action to put a little more money in the pool – the coupons won't cost anything if they aren't redeemed. We're not talking about bailout type sums here.

Anyone who is unaware of the transition hasn't been watching television. How many times have you seen ads about it even though you watch through cable or satellite TV and aren't affected? If people aren't watching TV, they won't be affected.

The truth is that small delay won't matter a lot to the world if it remains a small delay. But uncertainty will slow the flow of investment dollars into the technologies to use the whitespaces; these days it doesn't take much to chill investment. Moreover, this is an areas where the interests of the broadcasters are directly opposed to the public interest: the longer we wait for better broadband access, the longer the broadcasters can postpone the day when we get most if not all of our news and entertainment over the Internet. Prolonging the use of an old technology –analog TV – at the expense of a new technology – availability of the whitespaces as open spectrum – is counter to all that we need to do to make the United States as competitive as it needs to be.

But a friend of Fred's is a friend of mine. If the new FCC Chair acts vigorously to promote the whitespace/free spectrum experiment, if he leads the Commission to moves quickly to retarget the Universal Service Fund to communication broadly writ instead of to obsolete landline phone service, if he helps bring about a competitive communications industry in the US where the need to regulate might even disappear, then whether we delayed the digital transition a few months won't be worth remembering.

Good luck, Julius Genachowski.

Please see here for why the white spaces are so important.

FCC Vote Results – We The People Won

The Federal Communications Commission has just voted to open up the so called TV Whitespaces for UNLICENSED use (FCC press release here). This is incredibly good news for rural America in particular but actually for all of America. It's not as important as the election the rest of us in the US voted in today – but this action is a very, very big deal.

Just a few of the benefits:

  • Within a year there could be new, cheap radios and commercial services that make mobile broadband available with greater bandwidth than cable offers today AND at lower prices.
  • Mobile phones on these frequencies will be much cheaper to use AND will have much better data capability than they have today.
  • Since the US is the first country to make so much desirable spectrum available for open unlicensed use, the door is open for a wave of innovation here and the invention of products and services which will eventually be used around the world.
  • Much of the concerns many of us have had about tollgates on the Internet and an end to open interconnection will evaporate since the barrier to providing Internet access will be much lower and the power of the existing cable-telco duopoly diluted.

This is very, very good spectrum. That's why it's been used for TV. It goes through walls and leaves; it goes long distances.

Unfortunately, those opposed to opening up this spectrum – established broadcasters who fear the competition that a much more powerful Internet will bring and telcos who would like to preserve their domination of Internet access and mobile service - have threatened legal action to slow this innovation and competitive threat.

Making sure we all get the benefits of this FCC decision will be an early task for the new administration. It won't be an easy one but it's important and it's a real test of willingness to stand up to special interests who want to monopolize public assets like the airwaves.

A note of caution: the actual FCC ruling is not posted anywhere I can find it; I just managed to catch the vote at the end of the webcast of the FCC meeting. There could be gotchas in there but I know enough to be reasonably confident that this decision is the second most momentous thing that will happen today.

Special thanks to all of you who e-filed in support of this action.

FCC Extends Comment Deadline on White Space Issue

UPDATE: It happened. The FCC voted to open up the whitespaces for UNLICENSED USE (full post here).

The FCC extended the deadline until this Friday, Oct. 31, at 5:30 PM ET for comments on the proposal to open up so called TV white spaces for UNLICENSED use; the old deadline was Tuesday; so, if you missed it, you still have time.

Despite efforts by opponents to get the issue dropped from the agenda (delay with intent to kill; a post-election FCC might start all over), the issue IS on the agenda for the 11:00 AM meeting on November 4th which the FCC published last night. The meeting itself will be broadcast live at http://www.fcc.gov/realaudio.

Unlicensed access to this valuable spectrum can help the US regain the lead in Internet innovation, strengthen all American businesses, help American students, and go a long way to solving the problem of rural access to the Internet as well as vastly improving urban access. High bandwidth at low prices is not good news either to existing TV broadcasters (who are already worried about content competition from the Internet) nor to existing duopoly providers of expensive slow access. The lobbying against this proposal is fierce but public input appears to be making a difference.

You can sign (or modify) an online petition provided by Google here or e-comment directly with the FCC at http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi – docket 04-186. Remember, the deadline in now Friday at 5:30 PM!

More detail:

The Other Vote on November 4th

Act Now for Better Internet Access

White Space Momentum

Many of you are leaving this blog by clicking a link to either the online petition which urges the FCC to free the TV white spaces for open unlicensed use or by going directly to the FCC e-comment page (docket 04-186). Can't see whether you actually leave a comment or what you say, of course, but assume many of you are filing and are supportive. Thank you very much; it matters a lot to the economy as a whole (see here) and to rural areas in particular (see here).

Critical to momentum are the other blogs and news sites that are also actively featuring the story. I'm sure there are many more that I don't know about. Because of the crosslinks, my post and the blogs linking to it were on the front page of Techmeme over most of the weekend. The post was also stumbled upon, which drove yet more traffic through the post and to the petition. Currently the post is the most active article listed in the Internet Marketing section of BusinessWeek's Business Exchange.

Blogs (Thanks, fellow bloggers).

Fred Wilson's A VC Open Up The TV White Spaces

Brad Feld's Feld Thoughts Encourage The FCC To Improve the Internet

The Jeff Pulver Blog Act NOW for Better Internet Access. Support Technology Innovation in America.

Vermont Tiger Free The White Space

Vermont News Sites

The Burlington Free Press Internet to replace unused TV channels?

The Rutland Herald FCC decision could help Vt.

Seven Days staff blog Blurt Will the FCC Help Vermonters Access Broadband?




Momentum is great but this is no time for complacency. Lobbyists from the National Association of Broadcasters and the Telecom powers that be are working hard to delay with intent to kill. It takes lots of comments to outweigh them, The deadline for comments to the FCC is tomorrow, Tuesday, October 28!

If you haven't already done so, you can help by either e-signing an online petition (provided by Google but you can change the words) or by using the FCC's e-filing system here - be sure to enter docket number 04-186 if you do. It's actually a simple form. There's no need to say much; just let the FCC know you're in favor of a favorable vote on unlicensed use of TV white spaces and that the vote should happen as scheduled on November 4.. The deadline for comment has just been extended to Friday, Oct. 31, 5:30PM ET.

The Other Vote on November 4th

UPDATE: It happened. The FCC voted to open up the whitespaces for UNLICENSED USE (full post here).

The vote that Federal Communications Commissioners are planning for November 4 is not as important as the voting we'll do on that day, but it does matter a lot to the future of the United States. Unless the forces opposed to progress manage to postpone FCC action (which they are trying very hard to do), the FCC could decide to set the stage for another generation of innovative products with which the US will strengthen its competitive position in global markets AND to provide long term help to the whole American economy, which might well be more important than all the short-term band aids being applied in the current crisis.

There is an easy way for you to influence the FCC and it matters so please read on.

This magic bullet which the FCC might decide to fire is regulation which will make currently unused radio frequencies known as TV white space available for open and unlicensed use. As I posted Saturday, this action would be a huge boon to rural America which has lots of white space and too little high speed Internet and mobile phone access. But the advantage to the whole country of opening up this spectrum for innovation dwarfs the substantial benefit to us country folk.

Right now almost all radio spectrum is allocated to specific uses AND specific licensees. Each radio and television station, for example, has a slice of spectrum. Various marine and aviation functions have assigned uses; some spectrum is reserved for mobile phone use and has been auctioned off to carriers. The result of all this earmarking of spectrum is that, at any given time, very little spectrum is actually in use for any purpose and we have a spectrum shortage. However, when the frequency pie was originally sliced up, this allocation was the only method known for keeping users from interfering with each other.

But that's when radios were dumb and computers hadn't yet been invented.

Thanks to the foresight of some FCC staffers, a couple of slices of spectrum – little undesirable scraps, really, that no one else wanted – were set aside for UNLICENSED use. Anyone could build a radio to use this spectrum for any legal purpose so long as the radio was certified to follow certain rules including restrictions on signal strength which gave other players a chance to use the space as well. Owners of radios which use this unlicensed spectrum don't require a license.

You indubitably own several radios which operate in unlicensed spectrum. The WiFi hub in your house is one; the WiFi card in your PC is another; the Bluetooth headset you use with your mobile phone; the Bluetooth connection in your car; even Bluetooth and WiFi in your mobile phone all use unlicensed spectrum. Somewhat to the astonishment of traditional radio engineers, all this unlicensed use of spectrum works very, very well with no formal traffic cops. The little computers in the little radios figure out how to navigate by listening (I'm oversimplifying somewhat) and they recover gracefully when they do bump into each other – come to think of it, that's something like how the Internet works.

Anyway, it turns out that unlicensed spectrum gets filled much more efficiently than licensed spectrum AND that the most innovative recent radio products like WiFi and Bluetooth are all squeezed into these scraps of unlicensed spectrum which they have to share with microwaves and garage door openers. Also turns out that consumers often don't have to pay for using this unlicensed spectrum once they buy the proper radios; you don't pay to use WiFi in your home or Bluetooth in your car. The radios are cheap because they have a mass market. In other cases there are commercial services, like WiFi hotspots, which can be delivered efficiently to a transient audience because people have WiFi radios and because the spectrum is available to use.

Now back to the TV white space. It is very good spectrum; that's why TV stations uses part of the range that it covers. It goes through walls and most trees. There's a huge amount of it available AND CURRENTLY UNUSED. If we got a lot of innovation from just a little unlicensed spectrum, it's reasonable to assume that we'll get a lot more innovation if there's a lot more spectrum available. We could easily get mobile Internet access with much higher bandwidth than cable currently delivers at a much lower cost and with full mobile availability (Google claims gigabyte speeds are easily possible) . Who knows what exciting applications would be built on top of that? I don't. That's what innovation is all about. We could also get much better mobile phone coverage at much lower prices – very important as the functions of phones take on more and more computer functions.

We could get much more entertainment from many more sources over unlicensed spectrum than we do over the proprietary spectrum allocated to TV stations – do you think that may be why the National Association of Broadcasters is so adamantly against the use of the so-called "TV white spaces"?

OK. On to the future of the country and our economy. The US used to dominate Internet innovation because widespread consumer use of the Internet began here. The newest equipment was developed (but not usually built) here; the newest services were developed AND hosted here; at one point most international Internet traffic passed through the US. None of this is true anymore. We lag much of the developed and some of the developing world in broadband penetration. We pay more for less bandwidth than many of our peers. Innovation happens where the early-adopter markets are. Much innovation which requires broad availability of reasonably priced very fast access is happening in Japan and Korea where that access is much more available than it is here.

If we are the first country to free a substantial portion of spectrum for innovation, we will have a huge head start in developing equipment and services which use that spectrum. The world WILL move to largely unlicensed spectrum (says I). We have a chance to lead and all the opportunities that leadership entails; or we can keep our spectrum locked up to protect broadcasters against competition and watch China or India take the lead and the benefits of leadership.

It's not only our tech industry that will benefit if the FCC votes the right way on November 4th. All of our industry will be more competitive if we have better access to information and to each other. We can't afford NOT to have the world's best communication infrastructure. We once did; we can again. We can't afford to have our kids or us lifelong learner adults disadvantaged in access to information. We are now disadvantaged compared to many countries; the disadvantage is growing. Communication infrastructure CAN become America's competitive edge – if the FCC acts to make it happen.

The immediate push by the NAB is to postpone the vote of the FCC on the grounds that not enough time has been allowed to study the issue. In fact the docket has been opened since 2004. This has been going on longer than the current Presidential campaign; we're ready to vote for President and the FCC has enough information to make a decision on white spaces. Delay means that FCC Chair Kevin Martin, who is the main proponent of opening up the white spaces, will be gone. As the NAB well knows, a new Chair and new FCC commissioners will take a long time to familiarize themselves with this tough issue. It's not something that's come up in the presidential campaign (unfortunately) do no quick action'll come from the top.

We could easily lose a year or so by delaying this vote at the FCC. That's plenty of time to lose any chance of taking leadership in this new technology.

You can help by either e-signing an online petition (provided by Google but you can change the words) or by using the FCC's e-filing system here - be sure to enter docket number 04-186 if you do. It's actually a simple form. There's no need to say much; just let the FCC know you're in favor of a favorable vote on unlicensed use of TV white spaces and that the vote should happen as scheduled on November 4..

Please do act quickly. The deadline for public comment is TOMORROW, Tuesday, October 28 Extended to Friday, Oct. 31, 5:30PM ET!

More on unlicensed spectrum from this blog:

Act Now for Better Internet Access

Vermont Files in Support of Using White Space for Mobile Broadband Access

Internet 2.0 is Open Spectrum

Backstory of Open Spectrum Epiphany

Spectrum Serendipity

Google's Gigabit Gambit


Act Now for Better Internet Access

UPDATE: It happened. The FCC voted to open up the whitespaces for UNLICENSED USE (full post here).

There's a good chance that on November 4th the FCC'll do something really good to improve Internet and mobile phone access in the US: on that day the Commission is planning on voting on regulations to open huge swatches of idle but extremely valuable radio spectrum for open UNLICENSED use. There's also a very good chance that special interests will succeed in delaying and/or killing this long overdue action. Your input to the FCC PRIOR TO TUESDAY'S FRIDAY'S [it's been extended] DEADLINE FOR PUBLIC COMMENT could make a difference (simple way to comment provided by Google here if you're already convinced).

The spectrum in question is the so-called TV white spaces: the radio frequencies between existing TV stations. Some spectrum in this band exists in every part of the country, more in rural areas. Vermont's Public Service Department and the Vermont Telecommunications Authority filed in favor of opening up the white space back in March. Here's a quote from their ex parte filing to the FCC:

"First, rural areas like Vermont have relatively fewer TV broadcasters and therefore more unused 'white spaces.' Moreover, rural communities also have the largest geographic areas without access to wireless services. Second, the ability of TV frequencies to propagate over great distances and difficult terrain provides an opportunity to reach locations too economically challenging for existing wireless services. Third, the use of TV 'white space' for the provision of rural broadband is an alternative means of accomplishing the Commission's universal service goal of deploying advanced services to all areas of the nation without requiring additional funding mechanisms. In fact, the use of TV 'white space' could actually decrease the demand for universal service funding at a time when the level of funding is facing heightened scrutiny."

So who could be against such goodness? The principal opponent to the use of these frequencies is the National Association of Broadcasters (NAB). Their ostensible reason for opposition is technical: they're afraid, they say, that use of these frequencies, particularly the open unlicensed use being proposed to the FCC by Chairman Kevin Martin will interfere with adjacent use by TV stations. In their recent filing advocating delay they propose that even more time be allocated for study despite the fact that this docket's been open since 2004 and that the FCC's Office of Engineering and Technology recently reported its technical finding that interference is an issue which can be dealt with by current technology.

It's important to remember that, although this unused a spectrum is referred to as "TV white space", none of it has been paid for by any broadcaster or will be used for any broadcast purpose after the digital cutover this February. It is also extremely unlikely that any more over the air TV stations will pop up and want to occupy this space; and, even if that did, happen, the current proposal would make room for them since it requires that all equipment used in this space avoid broadcast signal – even if the broadcast signal shows up after the equipment is in use.

So why are the broadcasters so concerned? Well now, let's suppose that much of this spectrum was used to deliver low cost, high speed Internet access. Suppose that people used this Internet access to obtain their entertainment on the Internet rather than from said broadcasters. Now wouldn't that be a fine kettle of fish?

It is, in fact, highly likely that a vast array of new services including Internet access at a lower cost and higher speeds than we've so far seen in the US (or the world) will appear if this spectrum is opened for unlicensed use (eg. not auctioned off for proprietary networks). Think of the huge innovation that's occurred in WiFi and Bluetooth which operate in unlicensed spectrum even though these technologies share just scraps of undesirable spectrum with microwave ovens and cordless phones. BTW, devices like your WiFi hub ARE licensed to assure they respect other users of the spectrum; but YOU don't need a license to use WiFi nor does a WiFi-based service provider. More on how the white spaces can make a huge difference to the whole US economy here.

Traditional carriers are also opposed to having you make unlicensed use of spectrum. They would rather that you get your mobile access and Internet access through their proprietary leased spectrum.

Anyway, suppose that opponents manage to get another delay. At the end of that delay Kevin Martin (with whom I certainly don't always agree) is no longer head of the FCC. It IS Kevin Martin, to his credit, who is the leading advocate of all this openness with the FCC. Someday an enlightened FCC or Congress will probably take this action anyway – but it's likely to be a long time from now if we miss this opportunity.

Technology companies like Google and Microsoft are in favor of unlicensed use of the white spaces. Their motives are also commercial – nothing wrong with that. They live by innovation and hope to benefit from the communication opportunities that will open up. Google's Android phone is particularly suited for an open environment. In this case we're lucky to have their lobbying muscle on the "right" side of this issue. The NAB and the telcos are fearsome lobbyists. Moreover, the broadcasters are very influential with politicians who, you may have noticed, like to be broadcast.

Rick Whitt, who is Google's Washington telecom and media counsel, writes in the Google Public Policy Blog: "Just as Wi-Fi sparked a revolution in the way we connect to the web, freeing the "white space" airwaves could help unleash a new wave of technological innovation, create jobs, and boost our economy. But it can happen only if the FCC moves forward with rules that make the best possible use of this spectrum."

He points to an online petition at freetheairwaves.com whose wording you can use or change in order to make your views known to the FCC. If you would prefer, you can also comment directly on the FCC docket by going to http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi and typing the docket number 04-186 in the first box. My comment should show up Monday.

Please comment right away. THE DEADLINE is TUESDAY, October 28th[extended to Friday, Oct. 31, 5:30PM ET].

Vermont Files in Support of Using White Space for Mobile Broadband Access

The Vermont Public Service Department and the Vermont Telecommunications Authority have joined in an ex parte filing at the Federal Communications Commission urging that the Commission “move expeditiously to adopt the necessary technical parameters … and help make this promising technology [use of the so-called ‘TV whitespaces’] a reality.” Given that the docket has been open since May of 2004, a little expeditiousness is certainly in order.

“TV white spaces” is the term used by the FCC but it’s a misnomer; no broadcaster has actually paid for any of the spectrum at issue; no one is using it; in short; it’s wasted. Originally, before cable and satellite TV and before the Internet, it was reasonably believed that this spectrum would eventually be occupied by a proliferation of over-the-air stations. That’s not gonna happen. Vermont has as much radio spectrum “reserved” for over-the-air TV stations as New York City – 50 channels worth. That “reserved” spectrum is not of any use to anyone and won’t be until the FCC promulgates some rules for its use.

The filing explains the many reasons why this spectrum is ideally suited to meeting the needs or rural America for much better broadband and cellular coverage:

“First, rural areas like Vermont have relatively fewer TV broadcasters and therefore more unused ‘white spaces.’ Moreover, rural communities also have the largest geographic areas without access to wireless services. Second, the ability of TV frequencies to propagate over great distances and difficult terrain provides an opportunity to reach locations too economically challenging for existing wireless services. Third, the use of TV ‘white space’ for the provision of rural broadband is an alternative means of accomplishing the Commission’s universal service goal of deploying advanced services to all areas of the nation without requiring additional funding mechanisms. In fact, the use of TV ‘white space’ could actually decrease the demand for universal service funding at a time when the level of funding is facing heightened scrutiny.”

The filing makes clear that the petitioners do NOT think that this spectrum should be auctioned off at a high price. The greatest public good will come from making these public resources available “at low or no-cost to those entities willing to utilize them for such purpose [broadband and mobile access].”

It will take the concentrated political power of rural America to free up this spectrum to meet the rural need for better communication. But this isn’t urban vs. rural; urban areas also have something to gain from better spectrum availability and nothing to lose.

Not to over-dramatize but I see this as the public interest vs. entrenched communications interests. The TV industry would like to sit on this spectrum without paying for it “just in case”; they also may be worried about Internet use of the spectrum becoming a competing “channel” for delivering entertainment. Traditional communications carriers benefit from LACK of competition in the US broadband market; they have no reason to want to see competition growing like weeds (or, more accurately, like WiFi) in fields of open spectrum.

Google and other “Internet” companies do have an interest in keeping their paths to the consumer unblocked; competition would be good for that. This post is about a proposal Google has made for putting the unused white space to work.

Disclosure: My wife, Mary Evslin, is Chair of the Vermont Telecommunications Authority.

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