TV White Spaces Foundering Seven Years After FCC Approves Initial Order

In recent remarks at an International Symposium on Advanced Radio Technologies conference (see 1505150020), Office of Engineering and Technology Chief Julius Knapp said that uncertainty about the future of the TV band hasn’t helped deployment. Knapp conceded that only a handful of TVWS devices have been certified. But he said the FCC approved the first rules that led to Wi-Fi in 1985 and it took more than a decade for the first deployments.

One critic of the white spaces said the FCC doesn’t seem to notice that the white spaces have been a failure. “One of the biggest problems I’ve found with the unlicensed crowd is that it is driven by theories and theorists -- those who love the concept of white spaces but have no practical experience,” said a former FCC spectrum official. “If I were the FCC, I would be very worried about bending over backwards for something that has been an abject failure to date. As they say, the proof is in the pudding, and this pudding is made up of nothing so far. How long before we demand results and not excuses?”

Ex-Commissioner Robert McDowell, who voted for the 2008 order and a follow-up 2010 order on the TV white spaces, blames the “shifting sands caused by the Spectrum Act of 2012,” which gave the FCC authority to hold a TV incentive auction. McDowell is now at Wiley Rein. “Right after its passage, chipmakers specifically told me that they couldn't design white spaces chips until they knew more about the final outcome of the TV incentive auctions -- what frequencies would be available and where,” McDowell said. “Unlicensed uses of the airwaves offers unbounded potential consumer benefits -- whether in 3.5 GHz, or higher, or below 1 GHz -- where operators, app designers and innovative entrepreneurs can all prosper. But having certainty regarding who is going to be operating where 'on the dial' is key.”

McDowell also blames the so-called flawed white spaces database, an issue raised by NAB in a March petition to the FCC (see 1503190056). "Having such a high error rate has undermined confidence that any device using those frequencies could work,” he said. “Its garbage in, garbage out construct needs to be fixed ASAP or entrepreneurial white spaces will continue to be frozen in a crouched position on the starting blocks."

“The success of Wi-Fi in the traditional bands used for unlicensed devices is due in large part to the facts that those bands are harmonized internationally and offer significantly more bandwidth than the licensed bands traditionally used for mobile services and the TV white spaces,” said ex-Wireless Bureau Chief Fred Campbell, now Center for Boundless Innovation in Technology executive director. “The advantage offered by TV white spaces devices is their potential for longer range than ordinary Wi-Fi devices, but it’s not clear that consumers are willing to pay more for longer range, and the lack of international harmonization and interference challenges in the TV white spaces are factors that tend to increase the cost of wireless chipsets.” Businesses that use spectrum for their internal operations might find the white spaces attractive, “but based on past discussions with electric utilities interested in deploying wireless smart grid solutions, the lack of interference protection can be a deal-breaker,” Campbell said.

The 3.5 GHz band, also targeted by the FCC for sharing with unlicensed devices, likely faces similar challenges “with respect to the cost and performance issues associated with sharing spectrum among different uses and users,” Campbell said. “I expect it will take some time before we know whether the FCC’s command-and-control approach to sharing in the 3.5 GHz band effectively mitigates those challenges.”

Michael Calabrese, director of New America’s Wireless Future Project and a member of the Commerce Spectrum Management Advisory Committee, said it's critical that the white spaces rules allow for a minimum of three or four unlicensed channels in every market. “The market for fixed, higher-power use by [wireless Internet service providers] WISPs, utilities, agriculture and other industries in rural and small town areas was never going to be massive in scale,” he said. “The assumption was always that the TV white space would be part of a diverse ecosystem of connectivity built into a Wi-Fi chip, allowing smartphones and other mobile devices to connect through multiple walls and over larger distances than ordinary Wi-Fi.”

Major chipmakers say they're willing to invest in adding 802.11af TVWS connectivity to Wi-Fi chipsets for mobile devices but they've been waiting to see that there's adequate spectrum in the TV band for unlicensed use, Calabrese said. “Resolving the remaining issues around the incentive auction duplex gap, guard bands, the sharing of Channel 37 with hospitals and the designation of a shared channel with microphones are the key remaining obstacles to the certainty needed to boost the unlicensed economy.”

A Rural Technology

“Bluntly, what is impressive is that anyone has built equipment at all, given the massive uncertainty around the future of the band,” said Harold Feld, senior vice president at Public Knowledge, a member of CSMAC. “The major chip providers are not going to make TVWS chips until they know what the future is of the band.” The growth so far is consistent with what happened after the 3.65 GHz band was opened, Feld said. Large exclusion zones meant it was limited to deployment by wireless ISPs, he said. “In TVWS, the only certainty is that there will be space in rural areas. So we are seeing a similar deployment pattern until the details of the band get settled.”

The TV white spaces “are in a strange place,” said Doug Brake, telecom policy analyst at the Information Technology and Innovation Foundation. “The uncertainty with the upcoming incentive auction and repacking certainly does not help. Users, especially users who would be looking at larger deployments, are hesitant to invest. There is also some undue complexity and limitations in the rules, especially when compared to the direction some other countries are headed.” The TV white spaces will be a technology for rural America, Brake predicted. “At least in rural areas, the spectrum is there,” he said. “I'm hopeful that we will be able to leverage white space spectrum, especially for new wide area IoT applications, as uncertainty clears and we hopefully gain international economies of scale.”

The construction of new ecosystems to make use of new spectrum often takes about a dozen years, “which includes building the antennae and receivers and setting the standards,” said Larry Downes, project director at the Georgetown Center for Business and Public Policy. “There are added complications with the TV white spaces, including errors in the FCC database, the added complexity of sharing, the concerns of adjacent licensees, and the fact that white spaces are most useful in rural areas, where spectrum demands aren’t as urgent as urban areas, where the white spaces aren’t as attractive.”

Investment in the white spaces only makes sense for operators that can “justify the cost of towers on the basis of their use with licensed spectrum systems, because in such scenarios white spaces is simply an add-on,” said Richard Bennett, network engineer and visiting fellow at the American Enterprise Institute. “The FCC’s goal would be better achieved by creating and auctioning lower cost licenses shared by a limited number of operators in each locale. The technology that would potentially make white spaces practical hasn’t been invented yet.” When it does, it will look a lot like LTE-unlicensed, he said.