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 SEPARATE  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 
 Re:  Facilitating  Opportunities  for  Flexible,  Efficient,  and  Reliable  Spectrum  Use  Employing  Cognitive  Radio  Technologies  ET  Docket  No.  03-  108;  Report  and  Order 
 I’ve  been  fortunate  to  be  involved  in  our  work  on  cognitive  radio  technologies  since  helping  the  Office  of  Engineering  and  Technology  open  its  workshop  on  cognitive  radio  technologies  in  the 
 spring  of  2003.  I  remarked  then  that  cognitive  radios  could  play  a  key  role  in  shaping  our  spectrum  use  in  the  future.  As  we  see  in  our  item  today,  the  enormous  potential  of  cognitive 
 radios  is  being  realized  increasingly  every  day.  I  very  much  appreciate  the  effort  of  OET  and  others  in  pushing  this  forward  –  making  sure  our  rules  keep  pace  with  this  cutting  edge 
 technology. 
 I  believe  that  cognitive  radios  will  play  an  important  role  in  “spectrum  facilitation.”  That  means  stripping  away  barriers  –  regulatory,  economic,  or  technical  –  to  get  spectrum  into  the  hands  of 
 operators  serving  consumers  at  the  most  local  levels.  Cognitive  radios  can  literally  leapfrog  the  technical  and  legal  problems  that  currently  hamper  many  of  today’s  spectrum  access 
 opportunities.  Spectrum  policy  is  a  two-  sided  coin:  a  framework  for  innovation  on  one  side,  with  spectrum  facilitation  on  the  other. 


 These  technologies  should  lead  to  the  advent  of  smarter  unlicensed  devices  that  make  greater  use  of  spectrum  than  is  possible  today.  Cognitive  radios  may  also  provide  licensees  with  innovative 
 ways  to  use  their  current  spectrum  more  efficiently,  and  to  lease  their  spectrum  more  easily  on  the  secondary  market.  I’ve  seen  cognitive  radios  up  close  and  am  just  amazed  by  their  potential. 


 While  we  don’t  tackle  the  issue  here,  I  remain  particularly  interested  in  our  proposal  from  the  original  NPRM  to  allow  higher  power  operation  for  unlicensed  devices  operating  in  rural  and 
 other  areas  of  low  spectrum  use.  I  regularly  hear  from  WISPs  across  the  country  that  they  need  improved  access  to  spectrum.  Higher  power  operation  can  drive  broadband  deployment  deeper 
 and  farther  into  all  parts  of  America. 
 I  also  find  the  discussion  of  interruptible  spectrum  leasing  very  useful.  Such  a  development  may  enable  previously  reluctant  licensees  to  explore  a  technological  fix  to  address  some  of  the  current 
 challenges  of  spectrum  leasing.  It  has  been  suggested  that  interruptible  spectrum  use  could  be  a  tool  for  public  safety  licensees  should  we  decide  to  allow  them  to  lease  their  spectrum  to 
 commercial  providers  in  the  future.  While  I  remain  unsure  whether  such  a  policy  change  is  appropriate  in  light  of  our  Herculean  work  on  public  safety  spectrum  use  in  the  700  and  800 
 MHz  bands  over  the  past  couple  of  years,  I  very  much  appreciate  the  value  in  having  a  discussion  on  the  technical  aspects  of  interruptible  spectrum  leasing. 


 For  these  reasons,  I  enthusiastically  support  this  item. 
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