WASHINGTON, D.C, 20510
June 14,2010
The Honorable Julius Genachowski
Chairman
Federal Communications Commission
445 12
th
Street, SW
Washington, DC 20554
Dear Chairman Genachowski:
As you know, this past May marked the 25
th
anniversary ofthe Federal Communications
Commission's adoption ofrules related to the use ofspread spectrum modulation on an
unlicensed basis. While that might not mean much to most people, what r'esulted from the
Commission's action does. Those rules were instrumental in spurring the development ofsuch
technologies as Wi-Fi, Bluetooth, and several other devices we use on a daily basis. Worldwide
Wi-Fi shipments alone are expected to surpass 770 million devices by the end ofthis year.
The FCC is poised to take similar action that will once again unleash wireless innovation.
The Commission has already taken the first step but we encourage you to move expeditiously to
conclude the TV white spaces proceeding-as recommended in the National Broadband Plan.
Almost two years have passed since the Commission issued a final order in its white spact.s
proceeding and it has been six years since the FCC began the proceeding in May of2004.
Completing all outstanding white space issues quickly and properly will ensure the promise and
potential that has been demonstrated in the past becomes fully realized so consumers and the
marketplace can once again benefit.
The heart ofyour broadband plan focuses on releasing the full potential ofthe nation's
spectrum as a platform for innovation and relatively low cost broadband deployment when
compared with wired solutions. Toward that end, the agency must pursue a harmonized
spectrum strategy ofboth licensed and unlicensed spectrum deployment efforts that will allow
manufacturers and consumers to construct multiple paths to the Internet and utilize new devices
for communications. Completion ofthe "white spaces" proceeding can help build momentum in
that direction.
As you know, spectrum below 1 Gigahertz is both scarce and valuable. Today, the TV
white spaces remain a viable option for unlicensed use below 1 GHz and jump-starting a period
ofinnovation that could equal or surpass what we have seen with Wi-Fi. Due to the prop::>.gation
characteristics ofthe frequencies, unlicensed broadband devices will be able to cover a far wider
service area in rural areas than the range in which unlicensed devices operate today thus
providing an opportunity to narrow the "digital divide" that unfortunately continues to exist.
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The Honorable Julius Genachowski
June 14,2010
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White space spectrum will also provide greater capacity to offload consumer data traffic
in congested cell sites through the use oftechnologies such as Femtocells." A recent Cisco
Visual Network Index report indicated appwximately 60 percent ofmobile data use is done
inside and at least 23 percent ofsmartphone traffic could be offloaded onto fixed wireline
networks by 2014.
The FCC has many difficult issues before it and must ensure that new white spaces
technologies can emerge while protecting licensed users. Wireless microphones pose some
challenges. These microphones are used for performing arts, places ofworship, and schools and
provide a valuable audio tool to users and their audiences. However, a number ofthese
microphones have operated illegally on TV spectrum and such unauthorized behavior should not
continue to be allowed-the FCC must better enforce the rules it implements.
In the evaluation ofproposals regarding the operation ofwireless microphones, these
devices may be best suited to be authorized under Part 15 just like nearly all unlicensed
telecommunications devices. Given the numerous spectrum-based services and cohabitation that
exist today, we urge you to strike the right balance between allowing these and other valuable
devices to operate while ensuring there is adequate spectrum available to facilitate national
markets for white spaces devices or services. Missing this equilibrium would limit the potential
for this technology to contribute to our fundamental goal ofnationwide broadband at competitive
and affordable rates.
It should be noted that geolocation technology coupled with a database should adequately
protect users and additional spectrum sensing capabilities should only be required when
absolutely necessary since such requirement would unduly drive up the cost ofwhite space
devices and deter low cost deployment opportunities.
We request that you prioritize action on white spaces and urge the FCC to adhere to its
Broadband Action Agenda and complete [mal rules in the third quarter of2010.
Sincerely,
Cc: Commissioner Michael 1. Copps
Commissioner Meredith Attwell Baker
Commissioner Mignon Clyburn
Commissioner Robert M. McDowell