Shawn Chang on the Role of Unlicensed Spectrum in Driving Mobile Innovation

April 11, 2016

Written by Shawn Chang, EVOLVE Coalition Spokesperson

Throughout my career working in technology policy, I’ve watched mobile innovation transform our world.

From the smartphones in our pockets to the wearable fitness trackers, mobile innovation continues to transform our lives. Consumers rely on the newest mobile products, services, and apps not only to stay informed and connected, but also to bring classrooms to life, connect rural Americans, improve delivery of health care, reduce educational disparities, and create new opportunities to build and grow businesses.

Unlicensed spectrum has played a monumental role in driving mobile innovations. This is in large part due to the Federal Communications Commission (FCC) wisely applying a light-touch regulatory approach to unlicensed spectrum, making it available for everyone – using any technology – to innovate, research, and experiment. The members of EVOLVE are committed to preserving – and, in fact, expanding – this open and successful platform.

New technologies being developed in unlicensed spectrum, like LTE-Unlicensed (LTE-U) and Licensed Assisted Access (LAA), are examples of what’s coming next. They are designed to give consumers more choices in the unlicensed space to meet their mobile needs and can provide faster, more secure, and more reliable network coverage. Multiple tests have shown that LTE-U can harmoniously share the unlicensed platform with other existing technologies such as Wi-Fi. In fact, it actually improves Wi-Fi performance – it works better alongside Wi-Fi than Wi-Fi does with itself.

EVOLVE members are actively engaged with the Wi-Fi community to conduct joint co-existence testing to further alleviate any remaining concerns. We are unequivocal in our stance that technologies operating in unlicensed bands need to co-exist with and work cooperatively with Wi-Fi and vice versa. Successful co-existence is the golden rule for unlicensed technologies and the wireless industry is well-positioned and motivated to ensure successful coexistence.

Over the coming months, I will be discussing the joint testing plans and results on behalf of EVOLVE and its members. In the meantime, I’m excited to be a part of EVOLVE to help educate consumers, policymakers, and the tech community about the value of unlicensed spectrum and its limitless consumer benefits.

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Mobile Future Echoes Importance of Permissionless Innovation

February 3, 2016

This week, Mobile Future, an association of cutting-edge technology and communications companies and a diverse group of non-profit organizations, released a paper titled “The Importance of Permissionless Innovation in Unlicensed Bands.”  The paper emphasizes the key role that the open regulatory framework for unlicensed spectrum played in establishing unlicensed spectrum as the space where innovators could develop new technologies and ideas that have added significant consumer value and benefits to the mobile industry.  Additionally, Mobile Future credits the current policies governing unlicensed spectrum as playing a key role in the United States’ global leadership in mobile innovation.

The paper highlights how FCC policy encouraging innovation in unlicensed spectrum has spurred innovation for over seventy-five years.

“The tremendous number of devices that are today utilizing the unlicensed spectrum bands is a testament to the wisdom of the Commission’s light touch approach. Data from seventy-five years of experience demonstrate that the FCC’s policy of authorizing unlicensed devices to operate without regard to compliance with particular standards or etiquettes, but instead subject only to limits on power and certain operating parameters, is fostering innovation and critical economic growth. Even in an environment which is crowded with devices that have the potential to cause interference to one another, manufacturers have developed distinct technologies utilizing the unlicensed bands that permit wireless devices to co-exist and flourish. The Commission’s record of success in maintaining its flexible approach should be a lodestar when considering new technologies entering existing unlicensed bands. As shown with earlier iterations of Bluetooth and Wi-Fi, industry has a track record of working together, without Commission mandates, to promote an environment in which the risk of interference is limited and consumers prevail.”

Unlicensed spectrum is available for everyone and to any technology. As evidenced once again by this paper, unlicensed spectrum is crucial to the growth of mobile communications and to spurring new consumer products and services.  The current regulatory framework works.  It has allowed tremendous innovations, investment in new technologies and new consumer benefits.

EVOLVE and its members are working to preserve the current unlicensed policy framework so that new technologies like LTE unlicensed can develop and bring new benefits to mobile consumers everywhere.

You can access the full paper here.

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Former Representatives Waxman and Tauzin Support LTE Unlicensed and Permission-less Innovation

November 16, 2015

Today, former Reps. Henry Waxman (D-CA) and Billy Tauzin (R-LA) touted the importance of permission-less innovation on unlicensed spectrum in an op-ed for The Hill.  The former Chairmen of the House Energy and Commerce Committee raised concerns about calls for the FCC to “intervene and block” a LTE unlicensed technology, saying that would be “a grievous error.”  They went on to say:

When we served together on the House Energy & Commerce Committee, even though we were on opposite sides of the aisle and differed on many issues, we agreed wholeheartedly that federal policy should not stifle innovation in wireless technology and should encourage competition and choice. Keeping a portion of the wireless spectrum unlicensed, and thus not subject to hands-on regulation, was a policy decision designed precisely to further these goals. […]

For these reasons, we strongly urge the FCC to take a hands-off approach to the introduction of LTE-U.

We believe this technology will be a huge plus for consumers and will not cause the harm its opponents suggest. The evidence thus far suggests that LTE-U and Wi-Fi play well together. […]

But the FCC need not take our word for it. Let LTE-U come onto the market and see the real world impact. If it works as its adopters suggest, we’ll all be better off for its introduction. If it doesn’t, the FCC can then step in and address whatever problems have emerged. […]

Rather than stifle innovation in the womb through unprecedented intervention in the unlicensed spectrum, the FCC should continue its longstanding policy and practice of letting competition and creativity work their magic.

Unlicensed spectrum is available for everyone – using any technology – and continues to be crucial to the evolution and growth of mobile communications.  This successful framework has fueled the tech industry and empowered consumers with more choices in products and services.  EVOLVE is working to preserve it so that LTE unlicensed and other technologies developed on unlicensed spectrum can thrive together.

You can read the full op-ed here.

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EVOLVE Member on a Path Forward in the Wi-Fi / LTE Unlicensed Debate

November 13, 2015

Yesterday, AT&T Vice President of Federal Regulatory Joan Marsh spoke out on how new technologies like LTE Unlicensed can co-exist with Wi-Fi in existing and new bands of unlicensed spectrum.  In a post on the EVOLVE member’s public policy blog, Marsh said:

Unlicensed spectrum – which has been called the sandbox for entrepreneurship and innovation – plays an increasingly important role in our mobile and interconnected world.  Unlike licensed spectrum, which comes with high costs and significant regulatory burdens, unlicensed spectrum has long held out the promise of permission-free access with minimal regulatory oversight – an approach that facilitates experimentation and innovation by all and for the benefit of all.  To renege on that promise would be to undermine the core thesis of the unlicensed success story to date. […]

[The] answer to the Wi-Fi / LTE unlicensed debate should not be in new rules or regulations around the use of unlicensed bands – the very existence of which would redefine the unlicensed experience to the detriment of innovators and users.  The answer instead should be found in the FCC’s existing authority to protect wireless services authorized by the 1996 Telecommunications Act from interference that is intentional or malicious. […]

If this country is to take the fullest advantage of the new unlicensed bands being brought forward for shared use, technologies beyond those discussed here will no doubt emerge that will also seek to share the unlicensed commons.  We need a clear framework that will allow those technologies and the innovators behind them to continue to deliver on the promise that unlicensed spectrum offers – to innovate free from burdensome regulatory requirements and exclusionary conduct by incumbents for the benefit of wireless consumers everywhere – while ensuring existing users that all will be required by the FCC to act reasonably and play fair.

As EVOLVE has said before, it is important for all participants and technologies in the unlicensed space to coexist and play well together.  The combination of the unlicensed policy framework and permission-less innovation have been a resounding success, producing a continuously evolving stream of technologies, devices, apps, products, and services that enhance the consumer experience.  EVOLVE hopes to see this success continue for years to come.

Read the full post on AT&T’s Public Policy Blog here.

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EVOLVE Member Collaborates with CableLabs to Test a LTE Unlicensed Technology

November 12, 2015

This week, EVOLVE member Qualcomm released the results of a set of tests it conducted in collaboration with CableLabs to evaluate coexistence between a LTE Unlicensed technology and Wi-Fi.  In a blog post about the testing, Qualcomm said:

Using a test plan developed in collaboration with CableLabs, the R&D consortium for the cable industry, the two parties performed testing over a three-week long period. […]

Qualcomm Technologies followed the guidance of CableLabs in terms of what scenarios to test, the density of nodes, the types and location of test devices, and what Wi-Fi equipment vendors to include.  The performance of Wi-Fi in the presence of LTE-U was comparable to if not better than the examined Wi-Fi to Wi-Fi baseline scenario, demonstrating the effectiveness of LTE-U coexistence protocols. […]

These latest test results are thus fully consistent with all prior tests that were performed in accordance with the LTE-U specifications.

Unlicensed spectrum is meant to be open to everyone – using any technology – and continues to be crucial to the evolution and growth of mobile communications.  For consumers to have the best mobile experience, it is important for all participants and technologies in the unlicensed space to coexist and play well together.  This testing marks a good step in that direction.

You can download a detailed summary of the test results here.

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EVOLVE Adds Nokia Networks to Growing Mobile and Technology Coalition

October 26, 2015

Addition further diversifies membership, strengthens EVOLVE for the future

(WASHINGTON, DC) – Shortly after launching a coalition named EVOLVE to promote the consumer benefits of unlicensed spectrum and new technologies for unlicensed spectrum, the group today announced the addition of Nokia Networks to the coalition. The leading broadband infrastructure, software and services provider joins founding members Competitive Carriers Association, CTIA – The Wireless Association, Alcatel-Lucent, AT&T, Ericsson, Qualcomm Incorporated, T-Mobile, and Verizon in advocating for new technologies to enhance data speeds and improve coverage for American consumers.

“Nokia Networks is excited to be a part of EVOLVE,” said Al Jette, Head of North American Industry Environment, Nokia Networks. “With extensive experience in issues such as this, we fully understand the importance of consumer connectivity and the need for intelligent government policies that do not hinder the consumer experience.”

Nokia Networks’ addition to EVOLVE helps meet the coalition’s promise to grow while educating consumers and policymakers. The news follows a busy few weeks in which EVOLVE launched a new website, populated its blog, held a call with members of the media, expanded its resource page and touted its seven principles in support of unlicensed spectrum and new technologies for unlicensed spectrum.

Most recently, 4G Americas – a leading wireless industry trade association – announced its support for EVOLVE’s seven principles for continued innovation in unlicensed wireless spectrum. “4G Americas supports the principles and rights behind innovation in unlicensed spectrum and understands its importance for meeting wireless data demands,” said 4G Americas President Chris Pearson in a statement. “Our organization encourages the efforts to develop new and creative ways to maximize the potential of unlicensed spectrum for the benefit of connected users.”

Like EVOLVE’s founding members, Nokia Networks supports Wi-Fi and the critical role it plays in connecting consumers online, but believes that new technologies must also be part of path forward.

Launch Press Release

September 27, 2015

September 28, 2015

Contact: [email protected]

New Coalition Launches to Enhance the Consumer Wireless Experience & Encourage Mobile Innovation

EVOLVE will educate consumers and policymakers on the benefits of unlicensed spectrum and new technologies for unlicensed spectrum

(WASHINGTON, DC) – In an effort to constantly meet and exceed the rapidly growing needs of consumers, a mix of mobile and technology companies and associations announced today the formation of a coalition named EVOLVE. Through a series of speaking engagements, dialogue with policymakers, and consumer education, EVOLVE will promote the consumer benefits of unlicensed spectrum and new technologies for unlicensed spectrum like LTE-Unlicensed (LTE-U) and Licensed Assisted Access (LAA). LTE-U and LAA are new technologies that will substantially increase data speeds and improve coverage for millions of Americans. The founding members include Competitive Carriers Association, CTIA – The Wireless Association, Alcatel-Lucent, AT&T, Qualcomm Incorporated, T-Mobile, and Verizon. The EVOLVE coalition believes regulators should reject calls to preemptively interfere with new technologies like LTE-U and LAA that enhance utilization of unlicensed spectrum.

Different from licensed airwaves auctioned by the Federal Communications Commission (FCC) and exclusively held by wireless providers, unlicensed spectrum is open to anyone using any technology to experiment, research and innovate. Unlicensed spectrum is used for everything from baby monitors and garage door openers to Wi-Fi networks, Bluetooth, and soon, LTE-U and LAA.

Like all American consumers, EVOLVE members support Wi-Fi and understand the important role it plays in meeting consumers’ broadband demands. LTE-U and LAA were designed from the ground-up to operate cooperatively with Wi-Fi and other signals. In fact, when tested together, Wi-Fi performed the same or even better with LTE-U than Wi-Fi does alone.

In promotional materials, including a new website, EVOLVE touts the successes of the FCC in overseeing licensed spectrum auctions, as well as the immense consumer benefits of unlicensed spectrum. According to Telecom Advisory Services, LLC, the economic value of unlicensed spectrum is over $228 billion per year in the United States. Direct sales of technologies, services, and applications dependent on unlicensed spectrum – including baby monitors, wireless headsets and keyboards, walkie-talkies, and a host of medical imaging and communication systems, to name a few – results in a Gross Domestic Product of $6.7 billion per year.

EVOLVE’s member companies have coalesced in support of seven principles:

1. Innovation in unlicensed spectrum will continue to fuel the continually evolving high-tech industry and empower consumers with even more choices in products and services.

2. The FCC has designated that unlicensed spectrum is available for everyone – using any technology – and continues to be crucial to the evolution and growth of mobile communications. It is important for all participants in the unlicensed space, both existing and new entrants, to coexist and play well together.

3. “Permission-less innovation” means that new technologies should be encouraged to leverage unlicensed spectrum to drive a competitive mobile marketplace that provides for ubiquitous connectivity in the burgeoning Internet of Things market.

4. Wi-Fi is a critical component of wireless networks and provides important connectivity for consumers. New technologies using unlicensed spectrum need to work cooperatively with Wi-Fi today, tomorrow and into the future. Likewise, current-generation technologies must accommodate new innovative technologies that also operate in unlicensed spectrum.

5. Together, the unlicensed policy framework and permission-less innovation are a resounding success, producing a continuously evolving stream of new technologies, devices, apps, products and services.

6. Consumers depend on unlicensed spectrum for a variety of uses – Bluetooth, Wi-Fi, telematics, consumer electronics, and manufacturing – and benefit when new innovations in the unlicensed space improve and enhance their rapidly increasing digital demands.

7. The best way to address spectrum congestion is a strategy of abundance and sound policy. Unlicensed spectrum is one of several important components to meeting consumers’ demand in broadband, both mobile and fixed. The federal government must continue to make additional spectrum available for unlicensed use.

Representatives from EVOLVE’s member companies will hold a press call at 9:30 am EDT today, which members of the media can join by dialing (800) 230-1093 (if asked for a conference ID, reference EVOLVE).

“Americans need better broadband, and they need it now,” said Dean Brenner, Senior Vice President of Government Affairs, Qualcomm Incorporated. “That is because the Internet is entering a new phase of growth, in which so many more devices are connected and share rich data, making it necessary to increase mobile broadband capacity by 1,000 times. We applaud and join EVOLVE in its commitment to permission-less wireless innovation and the decades-long public policy that has made unlicensed spectrum so successful. We are working tirelessly to develop and proliferate, as rapidly as possible, far more efficient wireless technologies – LTE and Wi-Fi coexisting together – to bring consumers the best possible mobile broadband experience. Policymakers should embrace this approach.”

“Like American consumers, EVOLVE members support Wi-Fi and understand the important role it plays in meeting consumer demand for mobile,” said Steven K. Berry, President and CEO, Competitive Carriers Association. “New technologies and innovations, like LTE-U and LAA, can help all carriers – rural, regional, and nationwide – meet ever-increasing demands for mobile connectivity. EVOLVE and its members are working together to preserve unlicensed spectrum as an open platform, including all spectrum blocks for mobile innovation for the benefit consumers.”

Kathleen Grillo, Senior Vice President of Federal Regulatory and Legal Affairs, Verizon, stresses that openness and cooperation will be essential to ultimately serve consumers. “We look forward to continuing an open dialogue, sharing information and answering questions across the mobile community,” she said. “We know that by working together, the U.S. will remain a global technology leader for decades to come.”


EVOLVE is a coalition of mobile and technology companies and associations working together to promote the consumer benefits of innovations in unlicensed spectrum. For more information, visit