The Open Technology Institute and the Wireless Future Project at the New America Foundation, Consumer Federation of America, Public Knowledge and the National Hispanic Media Coalition (collectively, the “Public Interest Spectrum Coalition” or “PISC”) submitted these comments in response to the Public Notice released by the Federal Communications Commission regarding: "Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions".
In addition to incentive auctions for exclusively-licensed spectrum, PISC believes the Commission can best optimize TV band spectrum for broadband deployment, job creation and economic growth by ensuring that unlicensed access to substantial amounts of TV White Space spectrum will continue to be available in every local market and nationwide, with a portion of that spectrum being contiguous nationwide. To a far greater degree than was perhaps imaginable when the Commission initially approved unlicensed use of the TV white space channels, the unlicensed economy is thriving, creating jobs, delivering broadband to unserved areas, and meeting the explosion of consumer wireless data demand with low-cost and small cell spectrum re-use. Unlicensed spectrum increasingly serves as an incubator of wireless innovation.
In order to facilitate this access to sufficient unlicensed spectrum, PISC recommends:
- Making channel 37 available for unlicensed use, while protecting the Radio Astronomy Service and wireless medical devices with protection zones that can readily be enforced using the TV Bands Database.
- Designating the guard bands for unlicensed use and to add to the guard bands any “remainder” spectrum in any market that cannot be auctioned in standard 5 megahertz blocks.
- Requiring and authorizing wireless microphones to use non-TV whitespace channels first, to use TV whitespace channels only as needed, and to coordinate that use via a TV Bands Database to ensure efficient channel placement and geographic spectrum re-use.
- Requiring secondary broadcast licensees to co-locate and share a single 6 Mhz channel where
feasible without reducing their free over-the-air broadcast service to the community.
- Requiring all new 600 MHz licenses to include a condition that permits unlicensed white space devices to continue to operate on a localized basis until such time as the licensee notifies the Commission and a TV Bands Database administrator that the licensee intends to commence service.
- Permitting the operation of personal/portable white space devices on channels 14 to 20 in the markets and on the channels where they are not being used by Private Land Mobile Radio Service (PLMRS) or Commercial Mobile Radio Service (CMRS) licensees.
- Requiring, as a general license condition applicable to all forward auction bidders, a separate aggregation limit for the 600 MHz auction that accounts for the entirety of an entity’s holdings below 1 GHz.
For more, read the full text of the comments.