Cecilia Kang Is Right: There Really Could Be A Free National WiFi Network (of Networks)

This past week, we’ve had quite the discussion around Cecilia Kang’s WashPo piece describing a plan by the FCC to create a national WiFi network by making the right decisions about how to allocate spectrum between licenses for auction and what to leave available for the unlicensed TV white spaces (“TVWS” aka “Super WiFi” aka “Wifi on steroids”). As Kang describes, the FCC’s opening of sufficient spectrum for TVWS could lead to “super WiFi networks (emphasis added) around the nation so powerful and broad in reach that consumers could use them to make calls  or surf the Internet without paying a cellphone bill every month.”

Needless to say, the article faced much pushback, despite a subsequent Washpo clarification to indicate the FCC was not, actually, planing to build a network. Amidst the various critics, there were some general defenders of the concept. My colleagues at EFF noted that increasing the availability of open spectrum for WiFi-type uses , and my friends at Free Press argued that such a free public wifi network (or, more accurately, series of networks) is in fact possible if the FCC makes enough good quality spectrum, suitable for broadband and usable out doors, available on an unlicensed basis.

I will now go a step further than any of my colleagues. I will boldly state that, if the FCC produces a solid 20 MHz of contiguous empty space for TV White spaces in the Incentive Auction proceeding, or even two 10 MHz guard channels that could nationally produce two decent sized LTE-for unlicensed channels, then we will have exactly the kind of free publicly available wifi Kang describes in her article. Or, “Yes Cecilia, there really is free national public wifi. Don’t let the haters and know-it-alls tell you otherwise.”


More below . . .


“What’s that?” I hear you cry. “Has Harold gone mad, fallen at last into some whacky socialist dream? Has he forgotten everything he ever learned about how hideously complicated and expensive it is to run a network? Who will provide the backhaul? The customer service? Why would anyone do it? Or is Harold talking about one of his evil socialist tax schemes where we either use tax-payer money to build some muni-wifi boondoggle or force poor little innocent carriers (who are making 97% profit margins on their broadband systems) to carry public trafic under some “public interest” theory? No (although I’m not averse to either, as it happens). I mean what I say. If the FCC makes the right spectrum choices, it is reasonable to assume (although not inevitable) that we will eventually get to the kind of ubiquitous and easy to use publicly accessible WiFi access Kang describes in her article. Heck, we are half-way there now even with the small crappy scraps of spectrum available for existing WiFi. The history of the best efforts Internet — that thing you’re using now — points to the kind of “WiFi network of networks” that Kang is talking about.

Forget the “War” Frame And Focus on the “Free WiFi” Stuff

No doubt this seems an odd prediction, given the considerable delight some took in debunking the story as “too good to be true” — and apparently obviously so. “Who would run the backhaul on such a network?” They ask. “Don’tca all realize that the WiFi needs to connect too something so them bits can go back and forth to the cloudy thing? Them things cost money don’tcha know!” It’s also a fair knock, as Karl Bode pointed out, that the plan was not new, nor was the resistance to it. (Indeed, I filed my first filings about this in 2002 with the Spectrum Task Force back in 2002, and I’ve been chronicling the fight against it by the Broadcasters and wireless microphone users, by the telco carriers, and by Cicso, Qualcomm and Intel for years. Also, as my boss Gigi Sohn pointed out licensed carriers — especially more spectrum constrained folks like Sprint — have moved from being enemies to frenemies or even friends as they embrace WiFi offload of data from their own overloaded licensed networks.

On the other hand, it is important to point out that the CISCO/Qualcomm/Intel troika that bet on the wrong products previously are still trying to limit any new unlicensed to “inside only” in the upper 5 GHz (for why see here), and the House Energy & Commerce Rs continue to wage ideological warfare against the concept that the American people deserve anything free — even when doing so actually improves the economy as a whole. (Including this chart, which purports to prove the FCC’s set aside of 12 MHz of guard bands would cost $19.2B, or approximately 99% of what the Congressional Budget Office estimated the entire auction would earn — did I mention that math does not seem to be their strong point?)

But setting all that aside and focusing on the actual content of the article, what Kang actually predicts is that the availability of a sufficient amount of unlicensed spectrum for WiFi in the coveted 600 MHz band will create a bunch of stronger, more powerful versions of today’s WiFi hotspots. Because the 600 MHz band allows you to send signals more easily through solid objects, like walls, and allows the signal to go further for the same amount of power than a signal at the 2.4 GHz frequency most commonly used for WiFi hotspots, a collection of open hotspots could — collectively — cover an entire city.

As Kang acknowledges, “with no one actively managing them, connections could easily become jammed in major cities.” And while this has prompted some skeptics to sneer at the utility of such a loose collection of hotspots substituting for a wireless carrier, these skeptics are not reduced to doing homework at McDonalds to get Internet access for free when the library closes (and it’s too cold to sit in the parking lot and use the library’s free wifi). For these folks, ubiquitous crappy connectivity using cheap chips embedded in every device, like plain old wifi chips are now, looks like a pretty good deal. Sure, most of us would probably prefer a more reliable and nationally available network, but as Jeff Silva (quoted in the article, along with yr hmbl obdn’t blogger) rightly observes: “For a casual web user, this could replace carrier service. . . . Because it is more plentiful and there is no price tage, it could have real appeal to people.”


We Are Already Half-Way There

What most people who scoff at this idea seem to miss is that we are already half-way there. As noted above, we already have a free national wifi network. We call it “McDonalds.” In fact, in some places and for some people, as documented by the Wall St. Journal, it is the primary provider of connectivity. McDonalds manages to do this, and offer it for free, despite all the objections from scoffers and nay sayers about how difficult and expensive it is to provide a network, do backhaul, blah blah.

But McDonalds already does all that managing backhaul stuff for itself, since as a restaurant in the modern day it has a comercial broadband line coming in to handle its own communications. Layering the additional traffic from customers on top of what it already carriers for its own commerce is not that big a deal. It is important to note that most people think hauling bits is expensive because they pay an arm and a leg for residential broadband subscriptions and wireless data plans. But the reality is that the cost of wholesale transport of internet traffic — especially for a giant user like McDonalds — is actually falling, even if you are paying more for the retail service from the carrier.  Leaving aside any other problems with this fact, the point here is that it is not nearly as expensive for McDonalds (or similar companies) to handle the additional traffic generated by maintaining an open WiFi access point as critics assume.

Nor is this one-shot unsustainable corporate altruism. McDonalds offers WiFi access for free because it brings in the customers and it isn’t that expensive for it to do. Every kid stuck doing homework at McDonalds because they can’t afford broadband access at home (and we have plenty of kids even in wealthy counties like Fairfax VA who don’t have broadband in the home to access online homework) is much more likely to order a soda and/or fries than kids who don’t have to come to McDonald’s to do homework. (Yes, our failure to deal with affordable broadband also has implications for childhood obesity — a twofer!)  Sure, some people just come in for the WiFi and don’t buy something, and critics always obsess about this “free rider” problem. But as long as the value of the network exceeds the cost (including the cost of free riders), it is worth it for McDonalds to offer free Wifi access. It is no more crazy for McDonalds (or many other businesses) to offer free WiFi access than it is to offer free “bathroom access” as part of our “national bathroom network.” McDonalds has running water coming into the restaurant. It needs to maintain a bathroom, and customers are more likely to come to a McDonalds with an easily accessible bathroom than if McDonalds did not have one or if they had pay-for-access stalls. Some folks just duck in and use the bathroom without even buying coffee. But the cost of excluding such “free riders” exceeds the benefit of offering a bathroom.

If McDonalds doesn’t suit your fancy, we  also have a national municipal wifi network. We call it “the library.” Most libraries have free WiFi. After the library closes, the WiFi footprint may extend out into the parking lot, giving kids more options for places to do homework. We actually do subsidize this, with something called “E-Rate,” which brings connectivity to our local libraries and schools. Some of that sometimes leaks out.

These are not the only places that offer free wifi networks. For example, Comcast, TimeWarner Cable, and Cablevision each maintain a huge free WiFi footprint and roam with each other, creating a vast free WiFi network — where “free” means “free to subscribers.” Increasingly, businesses are cobbling together such WiFi access point networks to offer something that looks increasingly like a wireless carrier’s coverage.

In fact, we are already so awash in open WiFi hotspots that companies are coming up with ways to take advantage of them. Republic Wireless, for example, offers dirt cheap smartphone service — primarily by finding open WiFi hotspots (and holding the rest together by reselling capacity from wireless carriers). My Galaxy SIII on Sprint has a setting which I use that defaults to any open Wifi hotspot in preference to using Sprint’s licensed network. Pretty much everywhere I walk in most urban areas I get a notice of “open hot spots available.” Not all of them are actually open or available, of course. But a fair number of them are. A lot of times, I can sit on a bench and surf quite happily, using someone’s random hotspot.

Of course, none of this stuff works seamlessly like a carrier does. But it’s free and available and — as the Internet itself proved a long time ago — “best efforts” and dirt cheap often trumps carrier quality and much more expensive.

More to Come?

As it happens, an increasing number of businesses see value in providing folks with alternatives to carriers. Back in December, there was a huge stir when it was thought Google was going to build a national wifi network. Apple has contemplated this in the past as well. Many edge businesses, nervous about the ability of carriers to potentially mess with their traffic or frustrated with the current pathetic state of broadband in this country, have incentive to promote these kind of alternatives. Consider, for example, Google’s recent announcement it would provide free WiFi to the neighborhood surrounding its NYC HQ. The announcement included free WiFi to public housing in the neighborhood as well. It won’t be fancy like carrier service, but it means that kids in those buildings can actually do their homework at home, rather than McDonalds or the library.

Which brings us back to our old friend, Municipal Wireless. The most ambitious plans, like those to surround Philadelphia with a wireless cloud which would offer an ad-supported free service and a pay service, largely failed for a variety of reasons. But that has not prevented municipalities and other local governments from moving ahead with other projects that have learned from the mistakes of their predecessors. As I noted to the Philadelphia Inquirer, the superior propagation characteristics of the  TV white spaces may prompt some localities to revisit the idea of public WiFi. Not necessarily with the “WiFi Cloud Franchise Model” that was tried before, but perhaps with a series of hot spots or offerings to public housing and poorer neighborhoods similar to what Google is doing in NYC. but even now, we are seeing a steady proliferation of open hotspots in public spaces for the same reason we find benches, fountains, parks and other public amenities — they add value and people like them.


Putting It All Together

So let us now extrapolate from existing trend lines. WiFi is a product of two things, open “unlicensed” spectrum available as the necessary input, and freely available open standards fron the IEEE. The combination allowed people to manufacture chips capable of using WiFi cheaply and to experiment with different uses. The more people experimented and found useful things to do with it, the cheaper it got to use and the more benefit came from using it. (This is a combination of the Network Effect and Economies of Scale for those paying attention.)  As a result, we have seen a proliferation of open WiFi access points. Not from a single managed source, but from a combination of apparently unrelated sources that find it — for their own reasons — extremely useful.

Now let us add two new elements. The first is to take the software that is currently used in my phone or in other devices that finds open WiFi access points and kick it up a notch. Instead of the laborious process I have now of manually joining an accessible hotspot, the device does it for me without (noticeably to me)  interrupting anything or reinitiating a session. in other words, “WiFi roaming.” But instead of this being managed by contracts with providers, it limits itself only to accessible open points and is managed by my hand-held device.

The second element we will add to this mix is the proposed 20 MHz of high quality unlicensed spectrum in the 600 MHz band, which makes it possible to have higher throughput and cover larger areas more easily and at less cost.

Simply extrapolating from the already existing trends, the addition of these two elements should produce things — more and better open WiFi access points, and devices that can treat this like a single network in the same way my current smartphone treats the network of accessible (to it) cellular cites as a single network. Or, to translate into English, exactly the kind of ‘poor man’s public WiFi network’ described by Kang in the article. All of the objections about “who will provide the backhaul” and “how will this get financed” get solved the way they are solved today — by a bunch of individual actors each contributing their own resource for their own reason and deriving their own benefit from doing so. True, as Kang and some critics have noticed it’s not going to be the same quality of service  you get from a carrier — which is why carriers are not going to go out of business from this. It will act as something of a competitive constraint in the same way that the availability of free drinkable water acts as something of a restraint on bottled water, but it is not a genuinely competing product. And, if you are already utilizing the McDonalds network or the Library network, this will definitely be a step. up.

A Best Efforts “Network of WiFi Access Networks.”

The critical stumbling point that seems to keep confusing people, and makes this seem like wild Utopian fantasy rather than a rather logical and straightforward extrapolation from existing technology and trends, is that people keep thinking that to achieve a meaningful level of ubiquitous open WiFi access we would need some single giant entity to build and manage it. But we are not talking about a single, carrier grade WiFi network. This isn’t going to be some Verizon-like entity or Google-like entity or some National UberFederal ObamaNetwork. What we are talking about is a best efforts combination of independent networks, made cooperative by voluntary use of common protocols. A “network of networks” if you will.

Hmmm . . . . a best effort “network of networks” voluntarily exchanging traffic through the use of common protocols . . . that sounds vaguely familiar.  Why yes, that’s the Internet! The “network of networks” that runs on best efforts. And some of us are old enough to remember when the idea of millions of independent networks voluntarily agreeing to exchange best efforts traffic would become a meaningful global medium of communications was laughed at, sneered and scorned by the carrier world and the Collective Wisdom generally. “Who on Earth would manage such a system? How could you get connections? Why would people possibly put meaningful traffic on a best efforts and therefore inherently unreliable network? Don’t sell the bike shop Orville, that’s just crazy talk!”

The idea of self organizing networks, where each individual network contributes some resource because it derives benefit of some sort from the contribution, happens around every day. If you are reading this blog post, then you are participating in and using precisely the same kind of network that would emerge from making enough high-quality spectrum available for bigger, better WiFi.


So if we strip away the framing story about the “war” between the wireless world and the tech industry (a rather sad requirement for modern journalism these days — everything is a horse race), it turns out that Cecilia Kang’s article is actually fairly accurate after all. What Kang describes, a saturation of open WiFi access points sufficient enough to make a basic level of Internet access available free to anyone with the right handheld device — does not require any magic. It does not require investment of billions of dollars. It does not require federal support (other than access to the needed unlicensed spectrum) or  some giant entity like Google to run it and manage it. By simply extrapolating from existing trends, as described by FCC Chairman Julius Genachowski and noted in the FCC’s incentive Auction notice of proposed rulemaking, opening up sufficient unlicensed spectrum in the 600 MHz band has the advantage of enabling “free WiFi for the masses” to quote Kang.

No, the FCC isn’t actually building the network. And yes, making available the spectrum merely enables this extrapolation from existing trend lines, it does not guarantee it. But when you think of this as simply an extrapolation of existing trends and existing technology, rather than imagining some single entity building a single network, it seems like an eminently reasonable prediction.

Or, to paraphrase a rather famous text:

Cecilia, your critics are wrong. They have been affected by the skepticism of a skeptical age. They do not believe except they see. They think that nothing can be which is not comprehensible by their little minds. Yes Cecilia, there is a plan for free WiFi for the masses. And it doesn’t take Santa Claus.


Stay tuned . . .


  1. I don’t see how, as stated in the Philadelphia Inquirer article, “You’d need about a quarter of the cell sites to do the same work” at 600 MHz. A quarter of the cells are going to provide about a quarter of the capacity, all else equal.

  2. Excellent piece Harold! You have demonstrated that Cecilia Kang’s article has
    created an opening for raising public awareness about unlicensed spectrum’s
    potential to help create a “third pipe” alternative to the cable-telco

    More importantly, your piece is pointing us to a coherent vision of a third
    pipe that’s comprehensible to the lay public – and worthy of broad public

    Instead of abstract notions of “innovation” spurred by some indeterminate
    amount of unlicensed spectrum, you’ve given us a concrete target of 20 MHz and
    a vision of “WiFi roaming” enabled by a nationwide “network of independent
    networks.” (FYI – I wasn’t aware until a few days ago that the FCC’s target
    is 12 MHz, and I try to keep up with this issue!)

    Your point that we are already “halfway there” via existing Wi-Fi hotspots and
    the “municipal Wi-Fi networks” represented by our public libraries is
    brilliant! Again, you are making the abstract (unlicensed spectrum) concrete
    and comprehensible to the lay public.

    As a rural advocate, I suggest that we further develop your concrete vision by
    citing rural electric cooperatives as an historical analog to the
    “independent networks” which your piece envisions. The nonprofit rural co-op
    complements the urban-centric push for municipal networks, and more
    importantly, opens the door to a more diverse business-model ecosystem.

    Finally, your piece opens the door to how we fund the network of independent
    networks you envision. Enter the Connect America Fund comprised of the $1-$2
    surcharge contributed by ALL of us telephone subscribers in the US. It’s our
    money. Why not make it available to independent community networks?

    But here’s perhaps the most critical question: Can we get Public Knowledge,
    Free Press, New America Foundation, Susan Crawford and the rest of us to agree
    to mount a serious campaign based on the coherent and concrete vision you have
    put forth?

    The time is now.

    Cecelia Kang’s article put unlicensed spectrum in the spotlight. The
    cable/telco framing that unlicensed spectrum is an unfair government
    “giveaway” to Google and Microsoft is getting traction. Relying on
    abstractions such as “competition” and “innovation” as the public-interest
    raison d’être for unlicensed spectrum is not an option.


    Thanks for your excellent work in pointing the way forward Harold!


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