When my father worked in Regulatory for the phone company, he found himself at the state commission defending the company based on an article in the local paper.  He would always ask himself who is benefitting from the writing of the article before answering the commission’s questions.

In this case, we have two recent written articles that come from a very traditional perspective.

Here is the summary of what the articles said.  First let’s talk about the Motley Fool analysis about the dominance of the tower companies  and the use of the TV White Space to create a national network.

 This analysis is interesting because the real discussion is not about the technology, but about the TV Reverse Incentive Auction aimed at repacking the frequencies.  We made an excellent tutorial about this subject here.  In the tutorial what you learn is there is a scrambling going on by the local broadcasters to figure out the value to them. The repacking may indeed lend itself to a nationwide spectrum opportunity, however it is just as likely not to.  And that brings me to the real point.  In his article Nate Wooley makes the leap that the spectrum will be used in a model like the cellular network with a Radio Access Network (he says regional) collecting the traffic.  However, this is not the only architecture being thought about, unless your entire point is to compete with carrier services.  

With that being his proposition, he makes the point of using the existing tower solutions, which are dominated by a few companies, to deliver services.  Given the height restrictions place on TV Blue spaces and the distance limitations, it is only be awarding the rainbow to the carriers that the height limitations would be removed.  In other words, the plan was not for the cellco’s to use the technology on the towers.  So his premise starts at taking away an opportunity for other types of services. Mr. Wooley correctly points out the strange position the primary carriers are making about wanting to pay for something the Commission was willing to give away, but that has to do with the lobby effort made in Congress to auction the spectrum to help the deficit.  

For many of us this whole question shows how strange the conversations can go.  When SuperWiFi was first talked about, there was a simple goal to have some unlicensed spectrum available that had a better range. The reason Wi-Fi was allowed to become unlicensed was because the spectrum was considered unusable.  Now that spectrum is the primary interface for almost all our devices when at home or in the office.  Defending Chairman’s Genachowski use of the term, SuperWiFi, imagine what is possible with a spectrum that was used for broadcast television. 

This brings us to the guest article on GigaOM by Peter Rysavy, president of Rysavy Research.  Here once again the TV Reverse Incentive Auction is confused with the original intent of the SuperWiFi policy.  Mr. Rysavy suggests that the standards for TVWS are behind the spectrum efficiency of existing Wi-Fi, (so how can it be called super) and that LTE would be a better solution.   This once again confuses the goals and objectives in a number of ways and suggests that the TV Reverse Incentive Auction has any technology embedded in the model. 

The strategy of the TV Reverse Incentive Auction and the whole implementation for TVWS is about finding ways to share rather than sell off massive blocks of spectrum. Combined with the database implementation SuperWiFi has the possibility of enabling, Mr. Rysavy has correctly understood that experimental and local innovation is possible, but comes to some misguided conclusions.

On the business side of the equation, Mr. Rysavy suggests that it is unlikely that any entity will invest billions of dollars in a massive amount of network infrastructure to use unlicensed spectrum, which ignores the roll outs by AT&T and most of the cable operators in Wi-Fi.  In fact, it has been suggested that if the use of Wi-Fi was not available to millions of smartphones and tablets, it would crush entire cellular industry’s capabilities.

On the technology, he points to maturing standards that take advantage of MiMo, but does apply the same capabilities to the “limited peak rate of 29Mbps.”  Additionally, the use of TVWS should be based on 6MHz channels, which are limited to 14-18Mbps.  Using MiMo can exceed 50 Mbps.

Finally on the policy side, his identification of the FCC considering making an additional 30 Mhz available is a misinterpretation of a suggestion by Google and Microsoft (hmmmn pretty big companies interested in this space) as to how to gain more spectrum from the guard bands in TVWS.

In both these articles, I find myself wondering why the authors started with their premise in favor of cellular augmentation.  It seems to me they are deliberately aimed at reducing the value of the Reverse Incentive Auction.

My view is that the carriers’ would be happy to find another block of spectrum available cheaply, but the goal for SuperWiFi should be to foster new business models and not auction away innovation.