Google to FCC: give us free white space spectrum that is “grossly underutilized”

By Ken Kerschbaumer

Google lost the 700 MHz spectrum auction to AT&T and Verizon last week and by week’s end they had an even more innovative proposal to the FCC: give Google white space spectrum for free and make the world a better place. AT&T and Verizon, who laid out a combined $16 billion for 700MHz spectrum, have not reacted to the proposal.

The letter, sent to the FCC last Friday by Google General Counsel Richard Whitt, claimed that White Spaces spectrum is “grossly under-utilized” and is spectrum that should not be allowed to “lie fallow.”

The spectrum, however, is not grossly under-utilized or lying fallow. It instead serves a critical role preventing interference for TV viewers and serving as safe haven for the use of literally tens of thousands of wireless microphones at broadway theater, sporting events, political speeches, and church services.

“Given Google’s approach not to pay a market price for spectrum in the 700 MHz band, it is not surprising that it is turning its attention to the TV band,” says David Donovan, Maximum Service Television president. “While we applaud Google’s recognition regarding the problems with ‘sensing technology,’ it has the burden to demonstrate that these other approaches will work. It is ironic that while we continually debate this issue, Canada is already providing fixed rural broadband services on TV spectrum in rural areas as a licensed service.”

The letter comes on the heels of some bad testing news of white space devices built by Microsoft and others. In a follow-up call with media on Monday Whitt said he thought testing was going well and that, if approved, there would be a second round of testing to put consumer devices “through the wringer.”

“We are happy Google recognizes that relying on sensing will not protect consumers from interference to their new DTV sets and government subsidized converter boxes,” he says. “Hopefully, this will put an end to the current ‘sensing’ approach advocated by Microsoft and others.”

The letter has picked up mainstream press coverage as being news but Donovan says the letter offers nothing new. “It recites the same laundry list of possible ‘protections’ that have been debated for some time,” he says. “The letter provides no new technical information demonstrating that its proposals will work.”

The letter and a follow-up call by Google with the media on Monday, were long on promise and short on specifics. Android is an open-source platform that Google believes can compete with Microsoft’s Windows Mobile platform. “Coupled with the ‘Android’ open source platform for mobile consumer devices, TV white spaces can provide uniquely low-cost mobile broadband coverage for all Americans,” wrote Whitt. “Android-powered handsets should begin appearing commercially later this year, and would be an excellent match for the TV white space.”

At first blush Google’s request for free white space spectrum from the FCC would appear to be a brash, arrogant move (and once again point to the company’s sense of self-importance). Google’s letter attempts to dissuage any fears of corporate welfare by claiming that it would provide technical support to third parties to “make these plans happen.” Intellectual property and reference designs for underlying technologies, open geo-databases maintained by Google, and other supporting infrastructure would all be provided.

What remains unsaid in the letter is that Google and other third parties would build subscription-based and revenue-generating services on that spectrum. In addition, those services would directly compete with services AT&T and Verizon paid $16 billion to deploy on the 700MHz spectrum.

To help protect against interference, Whitt said a combination of “spectrum sensing” with two technologies previously proposed to the FCC by Motorola: geo-location for safeguarding broadcast TV, and beacons for wireless microphones should do the trick. Google also proposed a safe harbor between channels 37 and 39 that would be set aside for wireless microphones Wireless microphones could also be outfitted with “inexpensive” beacons that would send out a signal to white-spaces devices that says ” don’t come here,” by Whitt’s description.

Donovan, however, says the letter says nothing about interference caused by operating on a channel adjacent to an occupied channel. “The claim that there is a vast quantity of vacant spectrum in major markets, however, assumes that these adjacent channels would be used for unlicensed devices,” says Donovan. “As FCC data documented, however, operating on an adjacent channel will interfere with consumer’s TV sets in more than 84% of a TV station’s service area.”

Proposals for geolocation systems are also disingenuous. “They must prevent unlicensed operation on both the co-channel and the adjacent channels inside a station’s contour, something that white spaces proponents have not been willing to do,” says Donovan. “Moreover, the beacon approach designed to protect wireless microphones will not work for mobile electronic newsgathering operations.”

Aside from Google and Microsoft, other major vendors belonging to the 24-member Wireless Innovation Alliance include Hewlett-Packard and Dell. The eight members of the White Spaces Coalition, on the other hand, include Google, Microsoft, HP, Dell, Intel, Philips, Earthlink, and Samsung.

“Vague promises about “no interference” are not sufficient to protect consumers, who are spending billions of dollars on new digital equipment, or to protect wireless microphones used in live on-the-spot coverage of news and sports events,” adds Donovan.