Letter to the Federal Communications Commission on Making Spectrum Available for Unlicensed Use in TV White Spaces

ITIF wrote to the FCC in support of preserving at least three channels for white space devices on a nationwide basis. A guaranteed availability of at least three channels should ensure a large enough market to see the cost of devices come down, diversifying potential connectivity models and lowering the cost of extending broadband in rural areas.

With the incentive auction done, moving to provide sufficient spectrum and certainty for low-band unlicensed services is pure upside. White space devices have the potential to lower cost of last-mile connections, especially in high-cost rural areas, where connectivity is lacking but white space spectrum abundant. The open experimentation allowed by unlicensed spectrum could also support long-distance, low-data rate IoT connections or other non-broadband services even where spectrum availability is relatively limited.

The Commission should favor unlicensed spectrum over Low-Power Television in the limited number of markets that may be affected. The one-to-many broadcast format inherently cannot present as diverse of programming as a robust broadband connection. The public interest overwhelmingly favors a sub-1 GHz unlicensed service over a handful of small broadcast stations, especially when other, superior means to distribute their content are available.