This story appeared on Network World at

This story appeared on Network World at
http://www.networkworld.com/columnists/2008/102208bradner.html

White space and the FCC: a chance to do the right thing

Opening wireless spectrum to unlicensed use could be boon to technology

'Net Insider By Scott Bradner , Network World , 10/22/2008

One of the few unqualified success stories in recent U.S. spectrum policy has been the unlicensed spectrum used by devices ranging from car door openers to Wi-Fi. If the current schedule holds, the FCC may vote on Nov. 4 (the U.S. Election Day) to expand this spectrum considerably. Such a vote might upset traditional broadcasters but would clearly be a big win for most of the population.

The spectrum in question is the unused "white space" between licensed broadcast channels, and if the FCC enables its unlicensed use it will be with major restrictions. But even with those restrictions, we could be on the brink of a major expansion of useful technology.

As is too often the case, the arguments against changes in spectrum licensing policy have been distorted by hyperbole. For example, David Donovan, head of the Association for Maximum Service Television, which appears to be a TV industry lobbying group, was quoted by the Broadcast and Cable Web site as saying the FCC proposal will "decimate over-the-air TV."

My dictionary defines decimate as "kill, destroy, or remove a large percentage of." I doubt that the FCC would permit this to happen and its report on testing of sample devices does not show that the death of broadcast TV is in the offing.

Donovan is not the first person to overstate his case in spectrum policy discussions (See "What are they so worried about?") and he is not likely to be the last. But the discussions would be a lot more productive if some modicum of reality were the norm rather than the exception.

Restrictions proposed by the FCC include limiting devices using this spectrum to low transmitter power, requiring that they be able to figure out where they are and, based on that information, look up in a database what channels are unused in that area before deciding what frequency to use. While these restrictions are a reasonable stopgap approach, a far more flexible approach is that taken by cognitive radio and examined in the FCC tests. A cognitive radio listens to the world around it to determine what frequencies are unused and then communicates on them. The FCC tests indicated a lot of promise for such approaches but also showed that they are not yet ready for prime time.

The FCC proposal opens up some additional unlicensed spectrum, but its benefits are nowhere near what a general cognitive radio approach would yield. Most of the allocated spectrum is unused most of the time. An aggressive cognitive radio approach could open up all of this spectrum for alternative use.

If history is any guide, permitting the same type of essentially unlimited use by approved devices — which has been the case with the current unlicensed spectrum — would be a huge, but largely unpredictable, boon to technology development. The existing unlicensed spectrum supports a much wider range of devices than was expected in 1985 when the experiment started.
(See "Unlicensed and Unshackled: A Joint OSP-OET White Paper on Unlicensed Devices and Their Regulatory Issues" here.)

I have not been all that nice to the FCC in this column, with good reason, but this is a case where they just might make a next step along a path that could lead to a far better use of spectrum, and to a new explosion of technology development.

Disclaimer: I know of no stated Harvard opinions on the FCC and its ability to not get things right, so the above hope is mine alone.