Thank you very much for the kind introduction. I am very pleased to be here in Seattle for your 19^th General Meeting.

I thought I might begin by telling you about my first real exposure to the topic of Software Defined Radios. I rejoined the Federal Communications Commission about two-and-one-half years ago after having been in the private sector for many years. When I became Chief of the Office of Engineering and Technology, one of the very first email messages I received – literally -- was from Phil Inglis, a very well respected Senior Engineer in the Technical Research Branch at our laboratory out in Laurel, Maryland. I didn’t keep a copy of Phil’s message to me, but the essence of it was that, in my new position, I should be interested in Software Defined Radios. While I had been somewhat aware of the topic from my days in the private sector, Phil’s message really piqued my interest in the topic – an interest that I have maintained ever since my first day on the job.

Before I continue, I need to add the standard disclaimer that my remarks here this morning represent my own views and they may not necessarily reflect the views of the Commission, any individual Commissioner, or any other staff member.

I will divide the balance of my remarks into four parts:

First, it occurred to me that some of you might not be familiar with the Office of Engineering Technology – or OET – so I also thought I would take a moment at the outset to describe our responsibilities.

Second, I want to spend some time describing why there is already a substantial amount of interest in -- and support for -- the concept of Software Defined Radio technology at our agency as a whole. The potential benefits seem clear. We just need to work together through our public proceeding to make sure that the use of the technology will not result in any significant threat of increased interference. The rest is up to you and the marketplace.

Third, and this point reflects my own strongly held personal belief, I want to urge you, in designing and deploying SDR technology, to lean in the direction of employing the same open architecture notions or principles that underly the phenomenal success of the Internet.

Fourth, as you go about developing the technology and the wealth of applications that it can support, I want to urge you to develop systems and services that are accessible to persons with disabilities. As I will explain later, the notion of SDR technology is simply too powerful not to ensure that it's potential benefits are available to all of our citizens.

While I am still in the preamble to the body of my remarks, I might add that the timing of this presentation is a little awkward. As you all know, the first round of comments in our Notice of Inquiry in Software Defined Radio was filed last week. Therefore, I am sure that some of you might be expecting me to offer some preliminary reaction to those comments. Unfortunately, there simply has not been enough time for me to review the filings in any detail -- let alone digest them -- so I will be unable to react to them in any substantial way. However, I was pleased to learn that -- as of last Friday -- we had received comments from twenty parties.

So let me begin by saying just a little bit about the role of the Office of Engineering Technology -- OET. As most of you may know, the FCC is organized into Bureaus and Offices. Generally speaking, the bureaus -- the Common Carrier Bureau, the Wireless Telecommunications Bureau, the Mass Media Bureau, the Cable Services Bureau, and the International Bureau -- have the "line" or operating responsibility in terms of the Commission's regulation of particular segments of the telecommunications industry. The offices -- such as the Office of the General Counsel and the Office of Plans and Policy -- provide support and advice to the operating bureaus and to the five member Commission itself.

Reflecting that rough division, OET provides technical advice to other bureaus and offices and to the Chairman and other Commissioners. In addition, however, our office has the responsibility for administering specific parts of the Commission's rules, namely, Parts 2, 5, 15, and 18. Part 2 of the rules contains the Table of Frequency Allocations. That is, while the individual bureaus have primary responsibility for developing and recommending specific service rules, we, in OET, have the responsibility for general allocation matters. We also issue experimental licenses under Part 5 of the Commission's rules. In addition, we administer Part 15 of the Commission's rules dealing with unlicensed devices as well as Part 18, which deals with certain industrial, scientific and medical equipment. Finally, we are responsible for the Commission's equipment authorization program. Much of that work is done at our laboratory facilities in Laurel, Maryland – the Lab I mentioned a moment ago.

From that quick description, it is pretty clear – I think – why we, in OET, are particularly interested in the topic of Software Defined Radio. We are interested because of our responsibility to stay abreast of important technological developments and to provide technical advice to the other Bureaus and Offices and to the Commissioners based upon our understanding of those developments. For example, we are interested because of the potential for SDR technology to improve the interoperability between and among different radio services and systems.

We are also interested because of our responsibility for the Commission’s equipment authorization process. More specifically, we are interested in any changes that might be required in our equipment authorization program as a result of this technological development.

We are also interested because of our basic responsibility for handling general allocation matters. Equipment -- or apparatus, to use the now somewhat old fashion term -- capabilities and limitations have always been a factor in making allocation decisions. Hence we are interested in how SDR technology might, for example, promote increased sharing of the spectrum resource. Indeed, as a reflection of our interest, we tasked our Technical Advisory Counsel (TAC) with, among other things, examining the technology. The TAC meets in Washington next week and one of the topics on the agenda is SDR.

But, turning to my first point, I want to stress that the interest in SDR technology goes far beyond us "techies" in OET. It goes beyond us -- to the level of the Chairman and the other Commissioners -- because of (1) its potential impact on one of the agency's core responsibilities -- the management of the radio spectrum resource in the public interest and (2) the exploding demand for access to that resource. I can say from first hand experience that hardly a week goes by without someone stopping in my office or filing a petition asking for spectrum to be allocated for some new service or that additional spectrum be allocated to an existing service. It should be no surprise to this audience that we are having increasing difficulties in responding to such requests.

Commissioner Ness called attention to the problem of increased spectrum demand in her speech at the Consumer Electronics Show in Las Vegas in January. And Chairman Kennard, in his speech at the Cellular Telecommunications Industry Association (CTIA) convention in New Orleans late in February, noted that "we are running out of new spectrum, particularly in the valuable range below 3 GHz." At the convention, the Chairman talked about the need to be creative and innovative in our spectrum management policies in order to avoid a "spectrum drought" that could constrain the future growth of wireless services.

In his speech at the CTIA convention, the Chairman suggested the idea that secondary markets in spectrum might facilitate greater use of the spectrum resource. Under this notion, the primary market is represented by the initial distribution of a block of spectrum through auctions, for example. In contrast to the primary market, the secondary -- or after-market -- is represented by the exchange of spectrum after the initial distribution. The exchanges could be facilitated using brokers and dealers as intermediaries. This idea arose in part because we observed the initiation of "bandwidth brokers" in the wired telecommunications market.

One particularly interesting variation of this idea of a secondary market in spectrum is the potential "lease" of under-utilized spectrum on a temporary basis to meet short or medium term demand for a particular service. For example, a licensee holding commercial or private mobile radio spectrum or fixed wireless access spectrum in anticipation of its own growth might lease spectrum to another entity to allow the latter to meet some spike in demand. The spike in demand might be produced by the presence of a major public event in the area such as national political convention or the Olympic Games. Even more dynamic – or shorter term – exchanges have been suggested.

It is easy to see how arrangements such as these could produce a "win-win" situation for everyone involved. The lessor could gain revenues while maintaining control of spectrum that they feel they need to meet their long term strategic objectives while the leasee would be able to make a profit by providing service to otherwise under-served customers. Consumers would benefit from the availability of the service and manufacturers would potentially benefit by the sale of more product. We, as regulators representing the public, would benefit from the greater and more efficient use of the spectrum resource that we have been charged with managing in the public interest.

On May 31, the FCC convened a public forum to gain insight into why there has not been active secondary trading in spectrum and how the FCC could facilitate secondary trading. At the public forum, several panelists addressed possible rule changes that would facilitate the further development of secondary markets. In addition, since the public forum, several groups have come forward with specific examples of situations where a licensee would like to lease spectrum to another entity, but was being frustrated in doing so by our rules. We are currently reviewing the results of the forum and gathering additional information and ideas. We are also actively reviewing our existing rules to determine whether adjustments might be possible and desirable. Depending upon the outcome of that review, I would expect us to move on to a more formal proceeding such as a Notice of Inquiry or Notice of Proposed Rulemaking.

Unless you have been following all of this on a day-to-day basis, you may be asking what does the secondary market for spectrum have to do with SDR. Well one thing that has come clear in our discussions and deliberations is that, for longer-term leases of the spectrum, the lessor would have the opportunity to recover the cost of the necessary equipment -- including specialized equipment that might be required to provide a particular service in an other-than-normal allocation. With shorter-term leases, however, the lessor may not be able recover the cost of such specialized equipment -- or even interest a manufacturer in producing it. That is where the SDR technology could play a major role by reducing the cost (and time) of deploying radio equipment on temporarily under-utilized spectrum. By providing the needed flexibility in equipment, SDR can help enable secondary market applications.

Thus the increased interest in the topic of Software Defined Radio stems from its potential avoid to help alleviate the spectrum drought that the Chairman spoke of in his speech early this year. However, I recognize that our excitement about the potential role that SDR can play in spectrum management has caused some fears in the industry. Let me at least try to allay some of those fears.

First, by expressing interest in SDR, we are not departing from a policy of technology neutrality. Frankly, as long as other services are protected against harmful interference, we don't care whether SDR or more traditional platforms win out in the marketplace. Our interest is simply in making sure that our rules do not inadvertently stifle a technology that promises so much potential benefit.

Second, I sense that some groups in the industry feel that we may have unrealistic expectations about the technology and/or that we will somehow be less diligent in pursuing additional spectrum allocations for their particular service. From where I sit, this is a completely unfounded concern. As I see it, the demand for spectrum is potentially so great that we must carefully investigate, experiment with and, where appropriate, adopt all techniques for expanding its availability. SDR technologies -- and secondary markets for that matter -- are simply one set of tools for accomplishing that goal. If the growth in wireless continues as many expect, we will need all of these tools -- all of our collective ingenuity, if you will -- to meet the demand. On a related point, some people may feel we are moving ahead too fast. But that is why we issued a Notice of Inquiry rather than a Notice of Proposed Rulemaking. It gives us a chance to assess the situation before deciding to move forward with new rules.

I would like to turn now to the network architecture. When I give my standard "stump speech" on telecommunications technology, I point to five major trends or developments in the telecommunications field:

The result of these trends is that we are evolving our telecommunications infrastructure into high performance networks -- or, more properly, a "network-of-networks" -- that promise to allow us to communicate virtually anytime, anyplace, and in any mode or combination of modes -- voice, text, data, image, and video.

Even more important, perhaps, this network-of-networks -- this powerful platform -- is associated with another special characteristic. The characteristic is that, in contrast to most earlier voice and data networks, this platform uses common, open, non-proprietary standards and protocols -- that is, the Internet suite of protocols. Unlike the networks of-old, where the network is intelligent and the terminals are dumb, in the Internet, the terminals are intelligent and the network is dumb. In the Internet, the control of individual calls or sessions and the creation of new services is shifted from the interior of the network to computers and other intelligent devices at the edge of the network. Because the service is created in software as an application running on equipment at the edge of the network outside the control of the carrier or other provider, the opportunity for innovation – and the pace of change it allows -- is truly amazing, as we have seen demonstrated so dramatically over the past few years.

In your deliberations in the SDR Forum, in similar industry groups and within your own companies, you are making important decisions relating to the future architecture of the wireless portion of this network-of-networks. Now I will be quite frank in admitting that I have not examined in any detail the choices of architecture that are being made on the network-side or the terminal-side in the wireless world. However, given the experience we have had with the growth of the Internet -- and the associated growth in the economy that it has propelled -- I would urge you to lean in the direction of openness.

The high-performance, network-of-networks I just described does promise to allow us to communicate anytime, anywhere in any mode. That capability, coupled with powerful, programmable terminal equipment at the edge of the network, gives application developers an extremely powerful set of tools with which to work. As Chairman Kennard said in one of his early speeches, "properly harnessed, these networks and devices create a potent platform upon which to serve the needs of all our citizens, including those with disabilities." Therefore, I would strongly urge you to consider accessibility issues early in your deliberations. I would urge you to do so for at least four reasons.

• First, I sincerely believe that universal design principles not only benefit persons with disabilities, but also result in products and services that are better suited for all. For example, pagers that give us a choice of whether they vibrate or beep allow us all to be more polite during meetings or concerts, while allowing people who are deaf to gain the benefits of the technology as well.
• Second, given the pace of technological change that is being driven by the developments I mentioned a moment ago, new products and services must be designed, developed and fabricated at the outset to be accessible to -- and useable by -- individuals with disabilities. With product cycles of 18 months or 12 months or even less, a new product will have appeared before we can fix or adapt the old one to make it more accessible.
• Third, and most fundamentally, it is the right thing to do. It is only right that the 54 million Americans with disabilities have access to the wondrous benefits of modern telecommunications technology. As the Chairman said last week, we must make sure that the New Economy is defined as an economy with the ability to unlock the potential of Americans with disabilities.
• Fourth, and finally, it is the law. Section 255 of the Telecommunications Act and the rules we adopted last July to implement the law require that telecommunications manufacturers and providers design their products and services so that they are accessible to people with disabilities.

I will closes by thanking you for inviting me and my colleague from our Policy and Rules Division, Hugh Van Tuyl, to attend your 19^th General Meeting here in Seattle. I hope your deliberations are very fruitful because, as I have indicated throughout my remarks here this morning, I believe the technology upon which you are working has tremendous long range potential benefits for not only the industry but for all segments of the public as well.

Thank you.