FCC Commissioner Robert McDowell provides a timely take on spectrum issues in his November 7 remarks to the Global Fund in Brussels, "The Promise of Unlicensed Cognitive Networks." In his remarks, Commissioner Robert McDowell offers insight into the interplay between licensed and unlicensed spectrum use and also offers up a sensible policy perspective on spectrum allocation and auction.
New and emerging utilization of TV white spaces with unlicensed cognitive network technologies has the potential to repeat or even surpass the success of the FCC's 1995 allocation of the 2.4GHz band for unlicensed use in 1995. As Commissioner McDowell recounts: "Among other ubiquitous devices such as digital cordless telephones, utility metering devices, fire and security alarm systems, wireless bar code readers, wireless local area networks and baby monitors, entrepreneurs deployed 'wireless fidelity' or 'Wi-Fi' in the 2.4 GHz band."
Importantly, Commissioner McDowell makes clear the the conditions that make unlicensed use of spectrum desirable. As he explains with regard to the TV white spaces:
Permitting use of the TV white spaces on an unlicensed basis maximizes the efficiency of these smaller scraps of spectrum, which would be difficult, if not impossible to auction. Why? Because the rights to these small patches are not clearly defined, exclusive or easily transferable. Given these parameters, potential bidders would lack the incentive to spend the money necessary to invest in a license and construct a network, comply with FCC regulations, or offer commercial service.
Commissioner McDowell describes the complementary role that unlicensed spectrum can provide to licensed spectrum in delivering and enhancing innovative services:
Unlicensed use provides today's entrepreneurs with a means to develop new and exciting products without the high barrier to entry posed by licensed spectrum use. In addition, unlicensed Wi-Fi has become an important tool for licensed carriers. Cisco recently reported that IP traffic carried over Wi-Fi alone is expected to surpass the amount of traffic carried over wired networks by 2015. A 2011 Juniper Research report states that, by 2015, 63 percent of traffic generated by mobile devices will transfer onto the fixed network via unlicensed Wi-Fi and femtocell technologies. Furthermore, unlicensed networks will pick up 90 percent of this offloaded data at some point in transit.
In addition to calling for the allocation of additional spectrum for commercial use, Commissioner McDowell touches on the ongoing debates over consolidating TV channels and using a voluntary auction process to make more spectrum available for auction. His opposition to the idea "that Congress or the FCC should set aside a large contiguous swath of spectrum within the 700 MHz Band for exclusive unlicensed use" is based on the following considerations:
- "At this early stage, it is not apparent that we should stop the progress well under way in the white spaces arena to create a solution for a problem --an alleged shortage of unlicensed spectrum in the 700 MHz Band --that may never exist."
- "[A] a contiguous swath of spectrum would be clearly defined, exclusive and easily transferable -- everything the white spaces are not."
- "Given today's unprecedented budget deficits, I question whether the U.S. can afford not to auction any and all spectrum recovered in this band."
- "[S]uch designation may jeopardize U.S. efforts to harmonize this band internationally and to reap the associated beneficial economies of scale."
Given the explosive growth in demand wireless services in the last several years and projections for future growth of wireless network traffic, making more spectrum available should be the top policymaking imperative. But it is auctioned, licensed spectrum that can and should serve as the anchor and primary driver of economic growth and technological innovation.
When considered in its complementary context, unlicensed spectrum can enhance wireless network performance and bring added benefits to consumers. The wiser course is to give unlicensed cognitive network use in the TV white spaces a chance to flourish rather than turn over auctionable spectrum for unlicensed purposes. Lead with licensed spectrum and let unlicensed use follow.
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