New America Foundation Pushes for Unlicensed Device UHF Spectrum

In an Ex Parte presentation filed last week, the New America Foundation, a non-profit, non-partisan public policy institute and think tank, called on the FCC to ensure that spectrum would be made available for operation of unlicensed devices following any repacking and band plan creation following the proposed incentive auction.

Michael Calabrese, director of the Wireless Future Project, New America Foundation "expressed grave concern in the public interest community that the incentive auction team’s reported recommendations, apparently designed solely to maximize auction revenue, represent an unbalanced and misguided approach that, if adopted, would constitute a decision to kill off the Commission’s longstanding goal--a goal reiterated in the NPRM--to facilitate national markets for unlicensed innovation and connectivity in the low-band spectrum below 700 MHz."

The filing continues: "I emphasized that the public interest is best served by band plan, auction and repacking policies that strike a balance between broadcast stations, licensed mobile operators and ensuring at least four useable channels of 6 MHz of unlicensed access in every market nationwide."

The Ex Parte filing lists the policies that New America says are "necessary to avoid killing the anticipated benefits of a nationwide market for unlicensed broadband connectivity, chips, devices and services incorporating the now-complete 802.11af standard."

These include:

• Establishment of a duplex gap at least 12 MHz wide

• Restriction of use of the duplex gap to unlicensed devices

• Retention of one or both channels currently designated for wireless microphones

• Permitting unlicensed access to TV Channel 37 subject to the TV Bands database (to protect radio astronomy)

• Maintaining the status quo with respect to unlicensed access to 600 MHz spectrum (adopt the use-it-or-share-it approach proposed for GAA access in the 3.5 GHz band).

New America says the same principle should apply to the wireless microphone channels--if they aren't being used for wireless microphones, they should be available for unlicensed use.


We should find out whether the FCC takes New America's comments into account when the FCC announces rules for the incentive auction, band plan and repacking. From all indications, this will happen in May.

Doug Lung

Doug Lung is one of America's foremost authorities on broadcast RF technology. As vice president of Broadcast Technology for NBCUniversal Local, H. Douglas Lung leads NBC and Telemundo-owned stations’ RF and transmission affairs, including microwave, radars, satellite uplinks, and FCC technical filings. Beginning his career in 1976 at KSCI in Los Angeles, Lung has nearly 50 years of experience in broadcast television engineering. Beginning in 1985, he led the engineering department for what was to become the Telemundo network and station group, assisting in the design, construction and installation of the company’s broadcast and cable facilities. Other projects include work on the launch of Hawaii’s first UHF TV station, the rollout and testing of the ATSC mobile-handheld standard, and software development related to the incentive auction TV spectrum repack.
A longtime columnist for TV Technology, Doug is also a regular contributor to IEEE Broadcast Technology. He is the recipient of the 2023 NAB Television Engineering Award. He also received a Tech Leadership Award from TV Tech publisher Future plc in 2021 and is a member of the IEEE Broadcast Technology Society and the Society of Broadcast Engineers.