Gregory Herman, President and CEO of SpectrumEvolution.org (which advocates the use of extra spectrum from DTV broadcasters for mobile broadband applications) is none too happy about the FCC staff “apparently blocking” an application for an experimental license to test and demonstrate a new technology that converges broadcasting and broadband and can be deployed quickly by broadcasters if they are released from the regulatory constraint of today’s ATSC digital TV technical standard.
Herman says WatchTV, Inc. and SpectrumEvolution.Org are working with a technology that is already deployed in other countries and was created by the same University of Washington professor who was the original developer of the OFDMA technology that is now the core of LTE and Mobile WiMAX. The company demonstrated a simple configuration to OET on November 19, 2010 and provided sample handsets made by most of the world’s major electronics manufacturers, refuting previous FCC Staff suggestions that there is no market-ready approach to combining broadcasting and broadband.
RBR-TVBR asked Herman what might be the possible reasons the license app was turned down. He replied, “Although the application has not been affirmatively denied, we see no reason why a routine request for an experimental broadcast license should be languishing at the FCC. WatchTV and SpectrumEvolution.org took an exceptional step to specifically demonstrate the mature and readily available technology we propose to deploy in our experiment in Portland, OR, to the FCC, to ensure that they understand fully the credibility of the technology and the ability for us to deploy the experiment immediately. Other than what we perceive as a potential fear on the part of the FCC that we will succeed in demonstrating how state-of-the-art, next generation broadcast technology can and will allow broadcasters to participate fully in the National Broadband Plan and potentially confound an ill-advised and ill-defined Auction strategy, we see no reason why our experimental application should have not already been granted.”
Here’s the open letter:
The Honorable Julius Genachowski
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
Dear Mr. Chairman:
I am writing to ask you to reverse the highly unusual action of the Commission’s Staff, apparently blocking the grant of what should be a routine application for a simple experimental license filed by WatchTV, Inc. three months ago. The purpose of the application is to test and demonstrate a creative new technology that converges broadcasting and broadband and can be deployed quickly by broadcasters if they are simply “unleashed” from the regulatory constraint of today’s outdated ATSC digital TV technical standard. The project is intended to further the purposes of the National Broadband Plan, and I cannot understand
why anyone sees it otherwise or thinks that the public interest requires suppressing an experimental effort to advance technological innovation.
I am also asking for an appointment to meet with you during the period January 24-28, 2011, when I will travel to Washington for meetings with other government officials and Congressional offices. When I have asked for access to your office in the past, I have been blocked by Media Bureau Staff. I believe that the Staff misunderstands the implications of my work and that if given the chance to explain it to you personally, I could show you that their actions are contrary to your goals as well as the early and wide deployment of more wireless broadband in both rural and urban areas.
WatchTV, Inc. and SpectrumEvolution.Org are working with a technology that is already deployed in other countries and was created by the same University of Washington professor who was the original developer of the OFDMA technology that is now the core of LTE and Mobile WiMAX. I demonstrated a simple configuration to OET (FCC’s Office of Engineering and Technology) on November 19, 2010 and provided sample handsets made by most of the world’s major electronics manufacturers, refuting previous FCC Staff suggestions that there is no market-ready approach to combining broadcasting and broadband. Denial of my experimental application will help close the door to allowing the United States to have the benefit of advanced technology already enjoyed by other nations with which our nation must compete.
Time and time again, including at last week’s International CES in Las Vegas, you and other FCC officials have said:
1. The early deployment of broadband at lower cost is critical to the economic advancement of the United States, including education, health care, and employment.
2. Broadcasters who are not making effective use of the capabilities of their spectrum should have it put to a higher use for other purposes.
3. We must unleash technological innovation and not constrain how spectrum is used.
4. We are developing rules aimed at letting the market work.
5. We will not require any broadcaster to give up any spectrum involuntarily.
6. If we do not improve our use of spectrum, we run the risk that the next generation of innovation will start in another country.
The experimental work we are trying to do is designed to achieve each and every one of those objectives. If the technology works as well as anticipated, deployment can start within a year, with widespread penetration, including rural areas, faster than any other technology.
Local entrepreneurs will be able to create a seamless nationwide interoperable network, while at the same time enhancing wireless service competition and preserving local media voices and creating local jobs. The efficient use of broadcast spectrum will be enhanced far beyond today’s outdated ATSC standard. Importantly, because the system is dynamically flexible as
to how spectrum capacity is allocated among various services, it will allow the free marketplace, rather than government regulators, to determine how much spectrum capacity is used for which kinds of services at what points in time. And the United States will open rather than shut the door to innovation already deployed in nations with which we compete.
There can be no reason to deny us the ability to do the necessary field test work, but for fear that we might succeed and/or a perception that the government will not profit as much from our technology as it might from incentive auctions that would shut down broadcast services.
Success should never be feared. Moreover, broadcasters must pay 5% of their non-broadcast revenues to the government in perpetuity, and the success of a combined technology will ultimately increase the value of whatever spectrum broadcasters may choose voluntarily to relinquish to an incentive auction.
We are not doing anything different from what every broadband provider knows must be done, though we hope to do it better. The industry acknowledges that a very large percentage of the traffic that is straining mobile spectrum today is video, with Netflix using as much as 20% of outbound capacity. AT&T has purchased 700 MHz spectrum from Qualcomm and says it will be used for outbound video. AT&T said at CES that they need to match applications to the best network, which could be Wi-Fi, cellular, or something else.
Verizon has said they will introduce a broadcast-type service as part of their LTE network. Is it now clear that every wireless carrier is working to offload heavy download traffic to alternative multicast networks. The National Broadband Plan (Footnote No. 105) recognized that any spectrum shortage is exacerbated by an architecture gap that can be resolved only by integrating the efficiencies of some kind of “broadcasting” of the most commonly requested video and broadband media content matched with caching in edge devices.
That is exactly the solution that my technology partners and I are developing.
I am not asking you to approve any new technology permanently. I am asking you to let me test it and explore new business models for the distribution of broadband content and new innovative services. The experimental application proposes use of licensed broadcast stations and will cause no interference to other licensees. Nothing could be more routine!
Yet the Media and Wireless Bureaus and the Office of Engineering and Technology seem all to feel that they must intercede. Dozens of experimental applications are granted by routine Staff action every month. What other technology developer and innovator has been denied the ability to test and prove out its ideas? Denial of the ability to develop new non-interfering technology is unheard of in the annals of the FCC, but it is now apparently happening under
your administration. This situation seems to be in direct conflict with your widely shared passion for innovation and new broadband services.
I believe that broadcasters can achieve your professed objectives better than today’s wireless operators. I ask only that you let me prove my point in a free marketplace, in concert with the objectives of the NBP. Why are broadcasters the only wireless service providers not allowed to make their non-interfering technology selections on their assigned spectrum? If the incentive auction plan is truly voluntary, then why can only future auction winners implement broadband services instead of the entities that are already using that spectrum, and who have a history of advancing public discourse in our democracy and creating local
In effect, the Commission is keeping me leashed, instead of practicing the “unleashing” that you have so widely promoted. Even if you believe that only existing well established wireless companies can deploy broadband effectively, why should the Commission advance this belief by exercising regulatory power to block attempts by others to compete and show that they have a better idea? Most of today’s technology giants were once start-up companies.
The heart of American ingenuity has originated with new businesses, lightly regulated. I am trying to help achieve victory over the perceived problem of insufficient wireless broadband capacity, while also enhancing the value of the underlying spectrum assets, by increasing efficiency and providing flexibility for market forces to work.
Please stop the Commission Staff from insulating you from supportive and factual input to your decision process, and accept a meeting with me while I am in Washington later this month.
Gregory J. Herman
President and CEO
RBR-TVBR observation: The multi-carrier modulation scheme SpectrumEvolution.org needs to have implemented for their system to work is called Orthogonal Frequency Division Multiplexing (OFDM). It has successfully been implemented for virtually every broadband wireless solution over the past decade, with the exception of the U.S. adoption of the 8VSB ATSC single carrier protocol for digital television. It would indeed be a big “change in the system” in place, so to say, but may be able to be engineered. Perhaps the Commission should at least allow the license.