STATEMENT OF 
COMMISSIONER MEREDITH A. BAKER
Re: Unlicensed Operation in the TV Broadcast Bands, ET Docket No. 04-186; 
Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz 
Band, Second Memorandum Opinion and Order, ET Docket No. 02-380
I am excited about today’s TV White Spaces item.  I believe it represents real 
progress in enabling and empowering innovation and entrepreneurship in cutting edge 
technologies. Today’s item is a solid building block for spectrum policy.  It is a win for 
American leadership in the wireless space that has the potential to transform the way we 
use congested spectrum, to take the “mobile revolution” to new levels.  I hope that the 
pioneering work that has been done to engineer TV Band devices will lead to similar 
approaches for other spectrum bands.  There are “white spaces” in all parts of the 
spectrum and we need to use them more effectively.
Today, we clarify the conditions under which unlicensed devices can use TV 
white spaces.  It is a defining step in a process that began many years ago.  The ample 
record reflects the wide range of views in this complicated area.  I take them all very 
seriously.  The item before us reflects the staff’s hard and careful analysis and strikes an 
appropriate balance.
There is still work ahead of us.  I hope other users of the TV Bands, like wireless 
mics, will make every effort to ensure that the technology solutions they develop and 
deploy use the spectrum, which is necessarily constrained in certain parts of the country, 
as efficiently as possible.  In this regard, in particular, I believe there is much that can and 
should be done.
There are three areas in this item where I hope we will take additional action in 
the near future to advance our spectrum policy and ensure its alignment with the needs 
and requirements of the millions of people across the country that use wireless 
technologies every day.
First, I support the approach we are taking today with respect to the development 
of a TV Band geolocation database.  A robust, reliable and secure database is critical to 
the successful deployment of TV Band devices.  We are giving appropriate latitude to the 
Office of Engineering and Technology to develop the regulations and requirements that 
will govern the TV Band Database.  I hope Julie and his team can complete their work on 
a timely basis. I look forward to working on the details with them.  It is important to 
define an approach that includes adequate safeguards to ensure that the database is as 
accurate, user-friendly and accessible as possible.  Setting appropriate standards for 
database maintenance while leaving the database architecture open for customization and 
advanced services fosters the twin goals of empowering innovation and ensuring that 
novel uses of white spaces don’t harmfully interfere with incumbent users.
In this regard I reiterate my view that for this and any form of dynamic spectrum 
access to work, our guiding principle must always be that we do not harm legitimate 
incumbent operations.  Broadcasters’ rights, in particular, must be respected and 
protected.  We must ensure oversight and enforcement of our rules applicable to the band, 
including the rules governing the operation of the database.
Second, I hope that equipment developers and device manufacturers will continue 
their work on sensing technologies and take advantage of the flexible approach outlined 
in the item.  I appreciate the well-articulated concern that requiring both sensing and 
database consultation could have a chilling effect on the initial deployment of white 
space devices.  However, I am hopeful that the widespread commercial deployment of 
sensing technologies will play a critical role in increasing access to spectrum not only in 
the TV white spaces but in other spectrum that from time-to-time or in certain locations 
lies fallow.  Sensing technologies have shown great promise in other contexts, including 
Department of Defense research, and I look forward to finding ways to encourage and 
advance their deployment for commercial purposes.
Finally, it is important that we address additional proposals to set aside TV 
channels in rural areas for fixed licensed backhaul in the very near future.  The ability of 
both new and incumbent wireless providers to provide 4G wireless services ubiquitously 
is dependent upon a robust wireless infrastructure that is too often lacking in rural areas.  
The prospect of fixed licensed backhaul in the TV bands holds great merit and I would 
hope that we could move forward along the lines that have been proposed as soon as we 
have completed our official analysis of TV spectrum availability.
I would like to add my thanks to Julie and Ruth and their teams who have been 
working on this item for so many years.  Today we have taken a real step forward.