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 SEPARATE  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 
 Re:  Modification  of  Parts  2  and  15  of  the  Commission’s  Rules  for  Unlicensed  Devices  and  Equipment  Approval;  ET  Docket  No.  03-  201 
 The  development  of  wireless  ISPs  and  the  advent  of  so-  called  hotspots  using  unlicensed  spectrum  has  been  one  of  the  Commission’s  great  success  stories  over  the  last  several 
 years.  I  support  this  item  because  it  continues  our  efforts  to  promote  the  development  of  unlicensed  devices  and  services.  The  tremendous  growth  of  WiFi  in  the  2.4  GHz  band 
 was  facilitated  by  the  licensing  (or  more  appropriately  the  “unlicensing”)  approach  initially  adopted  by  the  Commission  for  this  band.  Part  15  of  our  rules  allows 
 manufacturers  to  develop  technologies  for  the  unlicensed  bands  that  anyone  can  use  without  a  license.  We  must  continue  this  policy  approach  so  that  we  encourage  as  many 
 avenues  or  technologies  as  possible  for  broadband  and  other  important  services  to  reach  consumers,  no  matter  where  they  live. 


 My  goal  as  a  policymaker  is  to  maximize  the  services  and  information  that  flow  over  our  airwaves.  A  regulatory  framework  for  innovation  can  provide  the  necessary  conditions 
 that  support  the  growth  and  development  of  spectrum-  based  services,  including  continued  use  of  the  unlicensed  bands.  Such  a  framework  functions  in  a  manner  akin  to  a 
 greenhouse,  in  which  plants  are  protected  from  the  elements  by  a  structure  and  are  nurtured  so  that  they  can  thrive  on  their  own  within  it. 


 I  believe  that  in  the  NPRM  adopted  today,  the  Commission  properly  strives  for  such  an  approach  to  spectrum  management.  We  want  to  enhance  our  existing  Part  15  structure  so 
 that  it  continues  to  encourage  the  growth  of  the  unlicensed  industries,  but  also  controls  the  elements,  like  minimizing  interference  that  may  impact  existing  and  future  operators. 
 Just  as  a  greenhouse  can  support  different  types  of  plant  forms,  our  framework  for  innovation  does  the  same  –  it  must  be  flexible  enough  to  accommodate  all  different  kinds 
 of  technologies,  such  as  those  used  with  the  latest  antennas.  Our  framework  does  not  choose  which  technology  will  survive,  and  which  will  not,  but  it  must  create  an 
 environment  that  allows  the  different  seeds  of  technology  to  truly  have  an  opportunity  to  grow  and  develop  on  their  own.  I  believe  that  we  have  such  an  approach  here,  and  I  am 
 optimistic  that  our  framework  for  innovation  will  enable  new  technologies  in  the  unlicensed  space  to  continue  to  meet  the  public’s  demand  for  broadband  more  efficiently. 
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