Google's Letter to the FCC

The open letter by Rick Whitt of Google is published on the FCC's website. Excerpts:

As Google has pointed out previously, the vast majority of viable spectrum in this country simply goes unused, or else is grossly underutilized. Our nation typically uses only about five percent of one of our most precious resources.

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. As announced last fall, over thirty other companies are working with Google through the Open Handset Alliance to develop a fully open source software stack, including the operating system, middleware, and user applications.

There are many ways to safely and reliably protect DTVs and wireless microphones, not all of which require spectrum sensing. Last fall, Motorola submitted a proposal in this proceeding that relies on a combination of geo-location (to protect broadcast TV) and beacons (to protect wireless microphones). Google believes both concepts, along with a “safe harbor” approach, should be seriously considered for incorporation into the FCC’s service requirements for the spectrum.

In short, FCC rules should specify only what is allowed, not how that result is to be achieved, or by whom. Much like the Internet itself, the agency’s specifications should as much as possible enable “innovation without permission".

It's remarkable that Google proposed more "conservative" approach than spectrum sensing, which switches frequency by geo-location databases.