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Jules Genachowski thoughtfully questioned the House bill to auction some broadcast spectrum. It would hurt the U.S. effort to use spectrum efficiently. Technology has changed and spectrum monopolies are increasingly inappropriate. Shared spectrum - think WiFi and white space super WiFi - typically supports 3-10 times as much wireless traffic as traditional telco mobile networks.

     The more I learn about wireless networks as I consult on one the more I realize that heterogeneous networks are a crucial part of capacity design. The best engineers at Ericsson, Alcatel, and the networks themselves are very strong on this. LTE Advanced is built around "heterogeneous networks" with WiFi and femto offload playing a crucial role. Hetnets are a key part of the 3GPP LTE Advanced standards and both Ericsson's and Alcatel's roadmap.

     The few experts on wireless in D.C. are starting to make themselves heard over the din of lawyer/lobbyists. If wireless capability is important, shared spectrum is the way to go.

     Here are Jules comments, presumably authored by staff.

Over the last weeks and months, we have conveyed to Members of Congress and  their staff concerns about provisions that would reduce FCC flexibility to maximize the overall value of freed-up spectrum, enhance spectrum efficiency, and promote robust innovation and investment.  Several provisions of the House bill would tie the agency’s hands in ways that could be counterproductive, reducing economic value and hindering innovation and investment.  One important example is the legislation’s seeming limitation on the Commission’s ability to accommodate new technologies, including those that use unlicensed spectrum, like super WiFi or machine-to-machine Internet connected devices.  I encourage Congress to leave no doubt that the FCC can continue its policies to promote unlicensed spectrum use alongside licensed uses.

   These policies to promote unlicensed spectrum contribute tens of billions of dollars to our economy each year. Wi-Fi hot spots across the United States increase the value of licensed broadband service by an estimated $25  billion a year. Wireless providers rely on Wi-Fi to “off-load” nearly 40 percent of traffic from their networks, resulting in a reduction of the cost  of wireless broadband service by at least another $25 billion each year.
    Unlicensed spectrum stimulates innovation, investment, and job creation in  many ways, including by providing start-ups with quick access to a testbed for spectrum that is used by millions, bringing new technologies to consumers in a rapid fashion. Wi-Fi, Bluetooth, cordless phones, garage door  openers, wireless car keys, and baby monitors—industries generating billions of dollars of revenue—would not exist without unlicensed spectrum. As CTIA, The Wireless Association, recently explained in a letter to Congress,  licensed and unlicensed should be accommodated in any spectrum legislation and should be viewed as “complementary rather than an either-or proposition.

    Precluding the FCC from adopting innovation-enhancing policies around unlicensed spectrum could threaten U.S. global leadership in spectrum-related innovation.  The same is true for the bill’s restrictions on the Commission’s ability to construct band plans and structure auctions in ways that maximize the value of licensed spectrum. Ensuring that the  Commission retains the flexibility to determine the optimal band plan for new spectrum that becomes available, including the creation of guard bands and other interference safeguards, will enhance the value of the new commercial mobile licenses, as will ensuring that the Commission can conduct auctions in ways that will best further innovation, investment, and competition in the wireless space.