The FCC's recent Spectrum Policy Task Force Report endorses the allocation of more unlicensed spectrum. In this notice of inquiry, all four sitting FCC commissioners echo this endorsement. NAF et. al. wholeheartedly agree. Moreover, this new unlicensed spectrum is most needed in the lower frequencies, such as the broadcast band, with the most desirable propagation characteristics.
Fortunately, new spectrum technology, notably advanced digital receivers, is opening up vast swaths of capacity in the broadcast band. This new capacity offers a great opportunity to allocate unlicensed spectrum in the frequencies where it is most needed.
Specifically, commenters request three types of unlicensed allocations: 1) Pure, 2) Shared, and 3) Opportunistic. Pure unlicensed means a dedicated unlicensed band. Currently, more than 80% of TV channels 52-69 are designated guard band. Commenters request that these be immediately allocated for unlicensed, with the balance allocated after the digital television transition.
Shared unlicensed means a combination of licensed and unlicensed applications in the same frequency band. Currently, the broadcast band is largely exempt from low power underlays and other forms of unlicensed shared use. Commenters request that a low power unlicensed underlay be allocated on all broadcast bands, and that as smart receivers make more unused spectrum usable within these bands, this also be allocated to unlicensed.
Opportunistic unlicensed means use of licensed but unused information carrying capacity. Currently, many broadcasters operate below their maximum power levels, do not broadcast during certain dayparts, and otherwise do not fully use the spectrum allocated to them. Commenters request that with smart radios incorporating simple protocols such as "listen before talk," this unused spectrum can be used by unlicensed devices without harming incumbent licensees.
Lastly, commenters endorse minimum digital television receiver standards, with the caveat that the goal of the receiver standards is to maximize the total information carrying capacity of the broadcast band, not just the portion allocated to incumbent licensees.
For the complete document, please see the attached PDF version below.
