Federal Communications Commission FCC 20-156 STATEMENT OF COMMISSIONER MICHAEL O’RIELLY Re: Unlicensed White Space Device Operations in the Television Bands, ET Docket No. 20-36. Making television white spaces available for wireless services – without disrupting the great work of America’s broadcasters – has been a project of mine since well before I came to the Commission. It’s been a pleasure to lead the charge on this effort, even if it faced initial reluctance within the agency, which appears to have dissipated. Utilizing the “gaps” between TV stations provides a unique opportunity to expand wireless broadband services to those Americans without access to them. Foremost, it provides access to frequencies in rural America where there are fewer broadcasters, assisting our efforts to serve the unserved, especially with new broadband offerings, and to use spectrum as efficiently as possible. Everyone should celebrate the recently demonstrated benefits of white space usage, particularly those by Microsoft’s AirBand initiative. Today’s action, which incorporates a collaborative agreement between Microsoft and America’s broadcasters, will allow greater use of TV white spaces by increasing power limits in “less congested areas” and permitting higher antenna heights for fixed wireless equipment, allowing higher power for mobile operations within defined areas, and adopting rules for narrowband IoT operations. These rule changes, along with some other technical tweaks, will enable the provision of a wider variety of wireless services to Americans over a larger geographic area, while not harming incumbent broadcast service. Although these are great developments, there are still some areas that need to be considered further. Terrain-based models are used for determining channel availability in several proceedings and services, such as the incentive auction, 3.5 GHz, and 6 GHz. In this case, it was determined that more information was needed before we could implement the Longley-Rice Irregular Terrain Model for TV white spaces. I thank my colleagues for agreeing to pursue this model and seek comment on its possible implementation, as taking terrain into consideration allows for the greater and more efficient use of spectrum. I also appreciate that my colleagues agreed to changes clarifying certain rules affecting the use of narrowband IoT devices. There have also been continued discussions about whether higher power wireless offerings can be deployed in first adjacent channels. Microsoft has done significant field testing and the results sound promising, but they recognize that more testing is warranted. I hope that other stakeholders will assist such field testing, so that in the future we can make greater use of the TV white spaces. Hopefully, this testing will be completed as soon as feasibly possible, and the parties involved will come to the Commission with a technically-sound plan for expanded use of first adjacent channels, if appropriate. While I will not be at the FCC to push for and resolve these last few issues, I am encouraged that my colleagues agreed to explore them. I look forward to following the developments of TV white space broadband offerings and seeing what other innovative services grow out of this proceeding. I approve.