My Insanely Long Field Guide To Cisco’s War On The TV White Spaces

Will Cisco’s war against the TV white spaces tank incentive auctions? No doubt this question comes as a surprise to the vast majority of people unaware Cisco was running a war against TV white spaces (TVWS). True, Cisco has mostly tried to stay behind the scenes. But as we get closer to the Super Committee deadline, which include negotiations for incentive auction rules that would let TVWS survive, Cisco has become increasingly willing to go public with its anti-TVWS lobbying efforts.

This blog post on the Cisco blog, followed by this letter from the High Tech Spectrum Coalition (HTSC), finally say publicly what Cisco and its allies have been saying privately since debate over spectrum legislation began last January: “Death to the TV White Spaces.” Instead, argues Cisco, open up a new block of 5 GHz spectrum to “replace” the white spaces. But with spectrum legislation in trouble – as evidenced by CTIA’s non-stop radio advertising here in D.C. and it’s recent ‘we love unlicensed, can’t we all get along?’ letter to the Super Committee – Cisco’s continued opposition to white spaces threatens to tank any hope of getting incentive auctions passed either in the Super Committee or elsewhere.

Incentive auctions, while popular as a revenue generator, were always a tough sell because of broadcaster passive/aggressive opposition. Adding D Block reallocation made it even more difficult. Cisco’s war on the TVWS threatens to be the final straw that makes this lift just too heavy. It splits a tech community that would otherwise wholly support incentive auctions, while simultaneously pissing off key members of Congress who helped get TVWS done in the first place.

So the time has come for Cisco, CTIA, and others who really want incentive auctions, to ask themselves whether it’s worth it to risk incentive auctions just so that Cisco can keep Microsoft, Google/Motorola, Dell, and others from bringing a competing product to market. The Hutchison/Rockefeller Bill, S.911, was a compromise that kept spectrum for TVWS, gave Cisco the 5 GHz block it wants, and made sure that a minimum threshold of 84 MHz would be auctioned before allocating any recovered spectrum to replace white spaces lost by auction or repacking. While not great from my perspective as a white spaces supporter (and I’d still like to see it tweaked some), it was at least a livable compromise. Cisco’s anti-TVWS campaign already backfired once, with the Republican discussion draft to require auction for all unlicensed spectrum. Will Cisco and CTIA fail to learn just how easy it would be for them to blow this for everyone? Or will they settle for the compromise that got a bipartisan bill out of the Commerce Committee?

Why Cisco has been gunning for the TVWS, the quiet little war of the last ten months, and how to get out of this quagmire before it’s too late, below. . . .


Bluntly, Cisco missed the boat on TVWS and, for reasons I explain below, has no product in the pipeline. As a result, it faces a bunch of potentially powerful new entrants armed with a super-charged version of its current wi-fi product. By the time Cisco, currently the leading provider of wi-fi equipment, gets its own white spaces product in place, it will have lost significant market share to the new “super wi-fi” (as TVWS is popularly called) routers marketed by the likes of Microsoft and Google. So Cisco is working hard to make sure TVWS has no future, and along the way pick up some additional unlicensed spectrum that fits much more nicely with its existing business model.

How Did Cisco Miss the Boat?

Back around the early 00s, the surprise success of wi-fi for both rural broadband and local networking generated a lot of interest in expanding unlicensed (including TV white spaces). Tech companies like Microsoft lined up behind the new technology, but the wireless industry had a visceral reaction against any more open spectrum. Why is a long and complicated tale, owing in no small part to the fabled clash of ideologies between the “property” and “commons” schools of spectrum management and the hope/fear that unlicensed spectrum might prove a threat to the handful of companies providing mobile services. Suffice it to say that during the eight years it took to get rules approved for the TV white spaces, the licensed carriers fought a heated battle to push the FCC to auction the TV white space rather than open it for unlicensed.

Cisco, for all that it has its origins in Silicon Valley, makes most of its money these days from selling equipment to the big telcos and cable cos. So during the fight for TVWS, they lined up like a good little vendor behind the wireless telcos to push the FCC to auction the TVWS for licensed use. As a result, just when other tech companies like MS, Google, Motorola, Dell and new entrants like Spectrum Bridge were getting behind the new technology, Cisco and other telco-centric providers such as Qualcomm made a decision not only to avoid investment in development for unlicensed in the TVWS, but to make it company policy to actively oppose the concept.

Unfortunately for Cisco and co. (but fortunately for the rest of us), they lost at the FCC. In fact, the FCC approved network architecture for TV white spaces, which requires devices to check in with a central database to know what channels are open, came from one of Cisco’s rivals, Motorola. As a result, not only did Cisco find itself without a product for the new technology, it found itself well behind the development curve for any such product.

Double Whammy

Even worse for Cisco, TVWS technology moves in the opposite direction from Cisco’s business plan. Cisco has developed products on the theory that wi-fi will remain primarily a local, indoor product that extends extremely high-bandwidth video files from your cable/fiber/DSL broadband connection to any screen in your home or office. For example, things like Cisco’s Telepresence video conferencing need a fiber connection to the home/office, then a high-bandwidth way off the fiber to the screen. Cisco routers can now conveniently let you stream video from your Cisco set-top box to your iPad. Cisco also sells gear to help cellular networks do wifi offload. But again, the idea is that the unlicensed is limited to a short bridge from a large network to an edge device.

TVWS threatens to expand unlicensed spectrum from a limited-range indoor networking product that fits Cisco’s business model (although it can do that too, and with fewer routers, because it penetrates walls better), into entirely new territory for which Cisco is completely unprepared. Even worse, the telcos who previously despised unlicensed (except for the little Cisco wi-fi router in the home or coffee shop) have had a complete 180 degree turn since the TVWS rule fight was settled. In the last several years, the rise of iPhone and Droid has shifted mobile phone providers from “fight like Hell to keep customer data on our proprietary network paying per minute charges” to “fight like Hell to push the customer data off our congested networks by offloading to local wifi.”

As an aside, one of the things I like about large, for profit companies is that, at the end of the day, they don’t give a crap about ideological consistency if such consistency conflicts with making money. This makes for profit companies so much more predictable. Unfortunately, big incumbents are rather like large dinosaurs that needed a brain in the tail as well as one in the head to keep its hind-quarters moving. Still, once AT&T-o-saur’s and Verizon-o-saur’s deployment brains finally communicated to its corporate brain that unlicensed was a lifeline, not a competitor, the corporate brain communicated with the Washington lobbyist brain and the telco total war against unlicensed spectrum in general (and TVWS in particular) was over.

Again, this faced Cisco with a double whammy. Not only did Cisco lose the big guns the telcos brought on lobbying, but they might potentially lose them as customers. Telcos need outdoor networking products for their “hot spot offload” strategy as well as indoor stuff for Starbucks, which works much better using TVWS than existing wifi. If Microsoft or Google can penetrate the telco market with Super Wifi products for data offload, Cisco will find itself at serious risk of losing more than just the outside hot spot market.


Cisco and the other tech companies that bet wrong looked like they would take a serious hit, until the debate over spectrum legislation for incentive auctions gave them a fantastic opportunity. What if you could get Congress to pass a law that not only outlawed your competitors’ new product, but gave you a fantastic new product opportunity for free? Converting a double whammy into a game ending double play that shuts your rivals out of the market – and after they spent all that money fighting for the rules and developing the new technology – would earn you a spot in the lobbyist equivalent of Cooperstown.

So Cisco and co formed a new industry trade association, the High Tech Spectrum Coalition, ostensibly to promote the importance of incentive auctions. But in addition to providing support to CTIA and CEA for their lobbying efforts to free up as much broadcast spectrum for auction as possible, HTSC had two other objectives: a) Do everything possible to kill the TVWS; and, b) Free up a block of 5 GHz spectrum perfect for moving data-intensive files like Telepresence and video on indoor networks – and damn little else. And just to make sure the new unlicensed spectrum would fit Cisco’s model, it would be explicitly limited by statute to indoor uses.

A Brief Technical Sidebar On 5 GHz v. TVWS

Unfortunately, I can’t do a sidebar. But let’s pretend I am on a sidebar giving a very oversimplified version of the physics on why 5 GHz works so much better for Cisco’s business model.

There is a trade off in wireless between the amount of information you can fit into a signal and the penetration characteristics of the signal (also the power and antenna size). The higher the frequency, the more information you can fit into the signal. But the higher the frequency, the shorter the distance the signal can travel and the harder for it to penetrate solid objects. By contrast, lower frequency stuff can carry less information, but can go much further on lower power and penetrates objects better. (There are also tradeoffs for things like antenna size, but lets keep this simple.) The “sweet spot” for mobile broadband (using today’s technology, at least) is between 500 MHz and 3 GHz, with the best stuff (sometimes called the ‘beachfront property’) between 500 MHz and 1 GHz. Television sits between 500 MHz and 1 GHz, which is why the wireless industry wants so badly to take it from the TV broadcasters and why we fought like Hell to get the TVWS bands.

To give a concrete example: satellite TV, like DISH or DIRECTV, starts above 12 GHz and can go up to above 40 GHz. This gives you great quality picture (lots of information) but needs, to quote the ads, “a clear view of the southern sky,” since something as thin as a wet leaf can block the signal. By contrast, broadcast television, operating in the 30 MHz-300 MHz (VHF) and 430-approx 700 (UHF), goes through your walls. Also, once we switched to digital, most television stations in VHF moved to the much better (for data) frequencies on UHF.

So the TVWS, living in the open UHF channels, works really well for mobile broadband outside as well as inside. The new IEEE standard will let you [send a TVWS signal *60 Miles*], which opens up whole new worlds for rural wireless broadband networks by making them much cheaper to build than licensed networks. It makes the data offload the wireless telcos need much more efficient and ubiquitous. At the same time, it does everything that existing “regular” wi-fi (which mostly lives at 2.4 GHz and 5.8 GHz, with little patches scattered higher and lower) does, so you can use it for indoor networking as well. But unlike existing regular wifi in the 2.4 GHz and 5.8 GHz bands, this stuff can go through the thick walls in places like hospitals, factories, warehouses, etc, meaning better and cheaper commercial applications.

By contrast, the block above 5 GHz that Cisco wants can pack in a great deal of information in the signal, provided the signal doesn’t have to go very far and it doesn’t have to go through anything like walls or trees. That makes it ideal for the kind of local network use that fits Cisco’s vision of the future and the products it is geared to sell. By contrast, it is utterly useless for the kind of networking stuff Microsoft and Google have been developing for the last couple of years.

Mind you, I will never say no to more unlicensed. What makes Cisco’s lobbying so problematic here is that it is not asking for 5 GHz for unlicensed *in addition* to the TVWS. It wants 5 GHz to *replace* the TVWS. That’s the only way it can shut the potentially disruptive rivals out of the market.

end sidebar

Meanwhile, Back In The Halls of Congress . . . .

To resume our tale, Cisco and HTSC have spent the time since the debate on spectrum legislation began in January busily talking trash about TVWS and offering 5 GHz as a much better and overall more useful alternative. From the start, Cisco would appear to have an uphill fight. After all, the approval of the TVWS was generally hailed by Republicans and Democrats alike as a huge bipartisan success that would create scads of innovation and the jobs that go with that. Developers and venture capital folks desperate for new places to put capital began pouring in money.  Development of the database has gone smoothly, and there appears no reason why Genachowski won’t see his wish that companies bring TVWS prototypes to CES in 2012 come true.

But Cisco had a couple of advantages. First, the vast majority of Congressional members do not follow tech issues very closely and have no knowledge about what is actually happening in the field. With all the evidence that TVWS technology is actually moving faster than anticipated buried in the trade press and among techies, it is simplicity to pretend that the technology is a dead end that no one wants to develop. To the extent members of Congress may have any awareness of TVWS, it goes back to the situation in 2008 when the wireless carriers were violently opposed and saying all sorts of nasty stuff about unlicensed spectrum being generally worthless and probably a socialist plot. Not only does this reinforce Cisco’s overall effort to paint its competitors as somehow vaguely unwholesome, it creates the false impression development should have happened when the FCC allocated the TVWS in 2008, rather than starting when the FCC actually established rules for devices in September 2010.

Second, deficit fever combined with a rather simplistic view of how auctions raise revenue (which, as I have explained way, way too often, is actually much more complicated and counter intuitive) makes it easy to believe that protecting the TVWS somehow costs money, and that the fiscally responsible thing to do is get rid of it and “replace” it with the 5 GHz spectrum Cisco wants. In this day and age, when a not-insubstantial number of Congresscritters question why having free roads contributes to economic prosperity and why don’t we auction them off, it is not hard to persuade them auctioning TVWS for chump change is a better economic policy than making more unlicensed spectrum available.

Finally, Cisco capitalized on the peculiar anti-Google prejudice that exists among Republicans. It used to be that big business was big business and friend to either party. But Google’s previous positions on network neutrality and the 700 MHz auction generally ran counter to the deregulatory agenda pushed by the telcos, who invested considerable time and energy cultivating the “Google is a free riding socialist parasite looking for freebies” idea among Republicans. All Cisco needed to do in some quarters was call the TVWS a “giveaway to Google” (conveniently ignoring MS and everyone else) to ensure a hostile attitude.

As we shall see, however, these prejudices in favor of auctioning all things auctionable and against all things Google are primarily tilted to Republicans. This will become important later in our story.


Cisco made modest progress in the Senate, where it succeeded in getting the 5 GHz block it wanted for unlicensed into the Hutchison/Rockefeller bill (and limited to indoor use by law, just for good measure, but justified as necessary to protect military systems from interference). It also cheered the White House insistence on auctioning 84 MHz of reclaimed TV spectrum before setting aside any spectrum for TVWS use which, when combined with the mandatory protections for the remaining broadcasters, would make it tough to keep TVWS available in major urban markets. Fortunately, a last minute amendment by Senator Mariah Cantwell at the mark up for the bill, officially designated S. 911, gave TVWS some breathing room.

Cisco had much better success with House Republicans, where the twin ideological prejudices of hating anything free and hating anything Google are much stronger and more entrenched. Indeed, Cisco succeeded too well. The House Republicans totally ran with the “no giveaways to anyone” argument and required that all future allocations of unlicensed, including Cisco’s target 5 GHz, get auctioned instead. For awhile, at least, Cisco and HTSC declared a truce with TVWS to make it clear that no one particularly liked the idea of auctioning off all future allocations of unlicensed.

In the meantime, the House spectrum legislation had numerous other points of disagreement between Democrats and Republicans. While whether or not to reallocate the D-Block to public safety or auction it remained the most divisive issue, the parties remained far apart around things like whether to maximize revenue by crapping on the broadcasters or try to keep them sweet with better bribes, and unrelated stuff like trying to rewrite the FCC’s overall wireless rulemaking authority. All this made it extremely unlikely that the House could get a bipartisan bill. But a purely partisan bill would have a hard time getting through the Senate, especially with the Senate Commerce Committee already voting out a bipartisan bill on the subject.

Enter the Super Committee

As if this were not complicated enough Congress created the Super Committee, which is also considering incentive auctions as a “revenue increase” that does not involve raising taxes on anyone. Reid and others made a try to include spectrum auctions in the initial set of deficit reducing measures last summer, but – as I keep telling everyone who insists that spectrum auctions will absolutely end up in the deficit reduction package – this stuff is damn complicated. So Reid dropped the effort to include it in the deficit reduction law last summer and passed the project on to the Super Committee.

The Super Committee puts even more pressure on the House Republicans to come up with a bipartisan approach to spectrum auctions because the Super Committee is divided 6 and 6. House Republicans can get their bill on the table through Rep. Fred Upton, chair of the House Energy and Commerce Committee, who will champion whatever bill comes out of the Telecom Subcommittee. But  Sen. John Kerry, chair of the Senate Telecom Subcommittee, is also on the Super Committee and he will push for S. 911. If Kerry is pushing a bipartisan bill, and Upton is pushing a purely partisan bill, then Kerry has the advantage. As a result, recent weeks have seen fairly intense efforts by Rs and Ds on the House Telecom Subcommittee to come to an agreement.

Nevertheless, the future of unlicensed and the effort to kill the TVWS remains one of the critical sticking points. This broke out into the open last month with Telecom Subcommittee Chair Rep. Greg Walden essentially echoing Cisco’s position and saying that while unlicensed is important, we already have enough of it and therefore we ought to kill off the TVWS. Telecom Subcommittee Ranking Member Anna Eshoo, one of the major champions of the TVWS going back to the early 00s, responded that the TVWS is critical for future innovation and economic growth (go Eshoo!). With the deadline for the Super Committee to make its proposals coming up soon, it does not appear that the House can get a bipartisan bill through before Super Committee must act, giving advantage to S.911 as the bipartisan bill that can actually pass.

Cisco Resumes Hostilities

With TVWS looking like it will survive going into the final stretch, Cisco and HTSC resumed hostilities – this time targeting their anti-TVWS efforts on the Super Committee. Over the last few weeks, Cisco and HTSC began saying openly what they had previously said only as part of a whisper campaign. On its policy blog, Cisco offered its “unique perspective” on how to move past the “unlicensed roadblock.” No surprise, the post waxes eloquent on the virtues of Cisco’s chosen 5 GHz while politely suggesting that ditching TVWS is no big loss because, hey, who knows if anything there will really work out whereas auctioning all of it with no room for TVWS while allocating the 5 GHz block for unlicensed just keeps the good old status quo growing.

The Cisco blog post still showed some restraint. After all, it didn’t explicitly badmouth the TVWS (as Cisco and its friends have done in private). It just suggested that saving the TVWS shouldn’t be the obstacle for major spectrum legislation. Mind you, saving TVWS would not be an obstacle if Cisco and co had not made it an obstacle by trying to kill it. But let’s set that aside for the moment.

But the Cisco blog post did not have the desired effect. Spectrum legislation remained stalled. But again, instead of reaching for the S. 911 compromise, Cisco upped the ante. With its buddies in HTSC, Cisco sent a fairly explicit letter to the Super Committee urging that any space that could be used for white spaces be cleared for auction. While professing to love unlicensed (where we have products to sell), the letter proceeded to make the usual thoroughly debunked claims about how much revenue Congress could get by selling every MHz of broadcast spectrum rather than leaving any for TVWS.

Not content to appeal to greed (or perhaps aware that anyone who seriously looks at this does not take the inflated revenue claims seriously), HTSC went on to trash talk TVWS. For example, the HTSC letter claims that “there are no current unlicensed used in the TV band because no chips, routers, or devices are being commercially developed for the white spaces.” This is at best misleading and at worst simply false to fact, depending on how you want to define “commercially developed.” There has been a great deal of money spent of R&D, a bunch of successful pilot projects, and a successful test of the database. At this point, the hold up is simply getting through the FCC certification process – a necessary pre-requisite for commercial production of products. Given that the rules were only finalized enough to even begin product development a year ago, that’s pretty damn quick – and rather the opposite of the moribund and unproductive picture painted by Cisco and HTSC.

CTIA—Can’t We All Just Get Along?

Once again, Cisco’s efforts to kill TVWS for its own commercial advantage have backfired. Cisco’s rhetoric plays into the current partisan divide on the deficit and maximizing (non-tax) revenues, and the hyper-partisan atmosphere in Congress generally. It also exacerbates the conflict between deficit hawks and white spaces defenders, even though the practical impact on deficit reduction is speculative and fairly minimal even under the most favorable assumptions. In other words, Cisco’s renewal of its anti-TVWS campaign has made the spectrum legislation as a whole more contentious and increasingly partisan, making it much harder to get done.

Which brings us to CTIA, and its recent “can’t we all just get along” letter to the Super Committee. CTIA has practiced a Cisco-leaning neutrality throughout the negotiations on spectrum legislation this year. By this I mean CTIA wants to see the maximum spectrum reclaimed for auction to its members, but does not (as far as I can tell) join Cisco in its trash talk about TVWS or efforts to get 5 GHz. In addition, while CTIA has shifted from anti-unlicensed generally to recognizing the importance of unlicensed along with its members, no one in the organization forgets that for about 5 years CTIA pushed the anti-unlicensed talking points used by Cisco and HTSC to target the TVWS. So while CTIA has not said “kill the white spaces” the way Cisco and HTSC have, no one imagines that CTIA would cry too many tears if Cisco succeeded in getting TVWS eliminated.

Meanwhile, CTIA is having a panic attack that it’s absolutely-totally-sure-thing-completely-gonna-happen incentive auctions might not happen. Everyone has assumed that because (a) Congress wants money, and (b) incentive auctions raise money, that absolutely positively incentive auctions will somehow happen despite the objections of broadcasters. However, while most folks these days pretty much agree in the abstract that incentive auction authority is a good thing (even the NAB goes along with this general proposition), the actual details matter. Further, while CTIA and the other folks who really want incentive auctions benefit from the current deficit fever outbreak that created the Super Committee, they suffer from the dysfunction that created the crisis in the first place. If the Super Committee goes down in partisan flames, it takes incentive auctions down with it. Worse, if incentive auctions move from being bipartisan to hyper-partisan along with everything else in Super Committee, then it will not happen any time soon. This is why CTIA has started to spend big bucks on advertising in the DC area explaining to everyone how spectrum auctions will save America.

Which brings us to CTIA’s letter to the Super Committee, which – while opposing diverting any spectrum recovered from auction—goes out of its way to say nice things about TVWS and assure everyone that, even if you totally auction everything, TVWS will have a future. While agreeing with Cisco that every MHz recovered from broadcasters ought to get auctioned, and Congress should give Cisco the 5 GHz band it wants, CTIA suggests for the first time that there will be “white spaces” between mobile licenses and that – maybe, possibly, if the stars align and you can absolutely promise no interference – TVWS devices could operate in those gaps.

As a substantive matter, I’m glad to see CTIA embrace the value of white spaces as complimentary to their members. I also think the idea of using the white spaces/guard bands in mobile services is a great idea. It is the next logical step for the technology. But it does not substitute for the existing TVWS. The current TVWS provides enough spectrum for developers to make products for urban areas as well as for rural areas. That’s critical for getting the technology launched, because it attracts the folks like Microsoft, Google and Motorola. An incentive auction plan that keeps TVWS viable either needs to give the FCC flexibility on repacking broadcasters to create more space in the unauctioned space, or allow the FCC to allocate some of the reclaimed spectrum to TVWS to ensure there is enough in urban markets to support product development.

But getting back to the politics, the important thing about this letter is that CTIA recognizes that trash talking TVWS risks losing everything. The prospect of several billion in revenue without raising taxes certainly provides lots of incentive for members to work out a deal, but it does not conquer all. Make spectrum auctions hard enough and complicated enough and it doesn’t happen. By saying nice things not merely about unlicensed generally, but about TVWS specifically, CTIA recognizes something that Cisco and HTSC refuse to recognize: creating a war on one sector of the tech industry over spectrum (especially when asking for a spectrum hand out) is a losing strategy.

Importantly, CTIA apparently understands that it can’t blast through TVWS by getting people to devalue it as a technological dead end or a Google plot. Too many people, Democrats and Republicans both, understand that “Super WiFi” looks pretty cool. To get incentive auctions passed, CTIA must at least pretend that TVWS has a future even if you eliminate the existing TV white spaces. While I would call this a change in tactics rather than an “olive branch,” I find it an encouraging sign. Possibly, just possibly, CTIA (and its members) can persuade Cisco and friends to stop screwing up incentive auctions and accept a compromise based on S.911 that allows TVWS to survive.


I have no idea how the Super Committee will work out. Today, everyone predicts no deal on anything — including spectrum. Next week, who knows? But whether Super Committee comes to an agreement or not, the last thing they need is a complicated, partisan fight over what is supposed to be “free money” from spectrum auctions. This is particularly true where the amount of money in play is tiny relative to what’s needed and the cuts made/revenue raised elsewhere. If the spectrum provision of the bill is too damn complicated, it gets dropped. Straight revenue maximization – CTIA’s dream position of freeing and auctioning 120 MHz – isn’t going to happen because the broadcasters will fight it tooth and nail.

So the question for CTIA and other incentive auction advocates is, do you want to keep trying to move this with a tech sector divided? If not, then CTIA needs to take Cisco and HTSC aside and explain that they need to be happy with the 5 GHz half-loaf and stop trying to keep rivals out of the business. This is a critical point. Cisco has already won some goodies of its own. The question is how much it will risk to ensure that its potential rivals get shut out.

At this point, anything that makes spectrum auctions more complicated dramatically increases the odds of the whole effort collapsing. No one is buying subtle nuances about how unlicensed is a technological dead end and a Google give away below 1 GHz, but a shrewd set aside of a government resource at 5 GHz. All Cisco’s efforts to get Congress to reject the S.911 bi-partisan compromise have done is drive Republicans and Democrats further apart. Keep this up, and you won’t be able to bring them back together to pass anything.

Just in case anyone is unaware of my own prejudices, let me make full disclosure. While I have no financial interest in the outcome, I’ve been a supporter of the TVWS for nearly ten years and I want to see it succeed. By contrast, I’ve always been somewhat indifferent to incentive auctions because I don’t see a lot of broadcaster participation as likely. Still, as I testified last summer, I think we can have both a robust TVWS and a useful incentive auction system. All it takes is for the incentive auction advocates to stop trying for a total win and acknowledge the need to have enough TVWS in major markets to keep the technology viable.

We’ll see whether that can happen, or whether Cisco’s push to leverage the legislation to its own advantage brings the entire spectrum reform bill down.

Stay tuned . . . .

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  1. Pierre dV says:

    Thanks, Harold.

    What do you make of the fact the Peter Ecclesine of Cisco is leading (aka the Project Technical Editor) for the IEEE 802.11af “Wi-Fi for TV Whitespace” working group?

  2. Harold says:

    Peter has long been a leader of IEEE standard setting groups, including the somewhat related IEEE standard for the 3.65 GHz band. It goes back to a strong tradition that when engineers are on standard committees, they are supposed to be acting as engineers not simply representing the interests of their companies. Peter upholds that tradition extremely well.

  3. Peter Ecclesine says:

    Hi All,

    Last week I was invited to give a TVWS update at IEEE 802.18

    Good luck,


  4. Harold says:


    There are some significant flaws in the white spaces coverage map. For one thing, you have the border areas as inaccessible. The FCC reversed this on reconsideration in the 2010 Order. Mexican and Canadian broadcasters in the border region can enter their locations in the database, and this will be deemed to meet the treaty requirements on coordination.

    You really need to run a new estimate under the new rules and a cleaned up database. One of the problems with the early maps (including the ones you are using here) is that they scraped bad data out of the FCC’s database. Bottom line, there is significantly more space available for Mode I and Mode II devices than your maps indicate.

    Finally, not sure why this is an exclusive choice. Let Cisco build based on 802.11ac, let MS and Google and the rest build on 802.22. There is no need to try to eliminate TVWS.

  5. Dan L says:

    Amazing… Even the clear vision of Harold Feld seems to be befuddled by the complexity of the TVWS & election year craziness surrounding US spectrum policy du’jour..

    In fairness tho.. who would not be befuddled?. Current US spectrum policy is a mess. “spectrum policy done by congress” = “a mess”) Very large players w/their internal conflicts create mixed signals, craziness created by US budget issues have led to a VERY misguided attempt to auction unlicensed spectrum in response (ie: 84MHz including some 5GHz spectrum), and then there’s the very real struggle over access to “new” TV-band spectrum in the top-50 NFL markets (ie: the TV “repack” & incentive auctions) –and don’t forget that this we’re looking at the 1st time databases will be used to augment spectrum access and use.. Yeah.. its a crazy time for spectrum policy.

    RE your opinion about Cisco’s “slash and Burn” tactics.. find this hard to believe mostly because you are painting with “too broad a brush”.. I would guess that Cisco–like any large multi-national corp–has many competing internal interests.

    This just means that you need to know where to find “friendlies” at Cisco. I’ll bet that if you find them, you might get access to better info..

    Dan Lubar
    Founding Board member, The WRAN Alliance

  6. In full disclosure, I confess that I didn’t read the entire “Insanely Long Field Guide,” but I do wish you’d mentioned some of the companies that *are* advocating for making this spectrum available for unlicensed use and *are* going to be ready with product when the FCC finishes certifying database providers.

    Carlson and many others have also formally urged the Congressional Budgetary Committee to preserve this spectrum for broadband.

  7. Steve Crowley says:

    Most of the wireless trade groups loathe TV broadcasting, and have for decades. Loathe. How much of the spectrum grab (not just Cisco) is just “Get the Broadcasters?” On principle? I’d guess at least half.

    The spectrum doomsayers are forced to use hyped forecasts, ignore moderation from new pricing plans, and ignore offloading to Wi-Fi and femtocells, to contrive a spectrum crunch that disappears, and might someday turn into a spectrum surplus, when those and other factors are properly considered.

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