Google Data

Posted by Richard Whitt, Washington Telecom and Media Counsel

As loyal readers of this blog know, Google has taken a keen interest in the TV "white spaces" proceeding at the FCC. For many months Google, other high tech companies, and numerous public interest groups have been advocating for unlicensed uses of these unused spectrum bands, which we believe can be used to bring affordable, high-speed wireless Internet to more Americans.

The FCC's engineers now are winding up their bench and field testing of certain test equipment. This proceeding was designed to demonstrate that white spaces devices (WSDs) can use spectrum sensing technologies to prevent harmful interference to digital TV signals or users of wireless microphones. While Google continues to believe that development of rules to ensure incumbent protection can be crafted regardless of how the test equipment performs, the FCC's engineers clearly have taken a thorough and professional approach to the testing process. We remain confident that the technical concepts behind spectrum sensing ultimately are sound, so that FCC-certified WSDs can operate safely and efficiently using this particular protection capability.

Nonetheless, we thought it would be useful to remind everyone that several other protection mechanisms also have been introduced into the Commission's record. These include the Google enhanced protection plan from March, which relies on the use of geolocation databases, beacons, and/or safe harbors. Taken together, these protection mechanisms remain technically unimpeachable, whether or not the Commission's current testing process produces adequate data to validate a spectrum sensing-only approach. Moreover, no WSD will -- or should -- come to market unless the FCC can verify that the device does not interfere with TV or wireless microphone signals.

With this in mind, the Commission should put the currently planned field testing at several sporting and entertainment venues into appropriate context. Regardless of how these tests validate certain technical parameters of spectrum sensing, those venues would be fully protected anyway under Google's March proposal. In particular, standalone use of a geolocation database with a look-up function would offer complete protection to digital TV and wireless microphone signals at major venues. Importantly, under our approach no WSD would transmit, even if it failed to detect any signals at all, without first receiving affirmative permission from a geolocation database look-up. With or without spectrum sensing, it's abundantly clear that unlicensed devices can coexist successfully with licensed services, with no reasonable fear of harmful interference.

Finally, we hope folks continue to watch this space to learn more about our continuing efforts to unlock the public airwaves to create exciting opportunities for consumers and entrepreneurs alike.