On Jan. 21, 2015, The Wall Street Journal reported that Google has plans to become an MVNO by reselling T-Mobile (News - Alert) and Sprint services. Reports are flying around that Google may be delivering a Wi-Fi focused mobile service akin to Republic Wireless, FreedomPop, or startup Scratch Wireless. A lot of regulatory and radio access technology – or RAT – planets are aligning in such a way that might just create a hugely disruptive mobile world, if Google actually implements its reported plans. 

The alignment includes new, extremely low-cost pico and femtocell RATs; the FCC’s opening up new 150mHz of 3.5gHz spectrum with 50 percent of the band open for general authorized access or 75mHz of new unlicensed spectrum; and TD-LTE that is now being used for 3.5gHz in Asia on bands 42 and 43 at 3.4-3.8gHz, with handsets and chipsets for 3.5gHz TD-LTE being manufactured today. What this means is that there will be unlicensed LTE available for Google to use on 75mHz of unlicensed 3.5gHz spectrum.

What is unlicensed LTE, aka U-LTE? Well, that is not as simple a question as one would think. Qualcomm (News - Alert) proposed LTE-Unlicensed as a multi-RAT (I am not making up these acronyms) technology to be used in the 5gHz unlicensed Wi-Fi spectrum. The unlicensed spectrum is aggregated with mobile LTE licensed spectrum and delivers a major increase in bandwidth to mobile handsets. To avoid confusion, the LTE-U name was changed to LAA or Licensed Assisted Access. LAA or LTE-U is not the same as unlicensed LTE.

With LAA, both the LTE licensed spectrum and the LTE unlicensed spectrum would deliver the Internet stream to the handset at the same time. The licensed LTE would be the primary and the unlicensed 5gHz would be the secondary connection – think of it as redundant. Ericsson has been testing the LAA LTE technology and is reporting peak rates of 450mbps on 20mHz of licensed spectrum combined with 40mHz of unlicensed spectrum. It is reported that some in the Wi-Fi community are concerned that LAA will interfere with the use of 5gHz Wi-Fi. Another concern is that to operate effectively in 5gHz, LTE will need to cooperate with Wi-Fi, requiring changes in Wi-Fi technology. These changes in Wi-Fi present technical, standards - IEEE (News - Alert), regulatory, and harmonization (countries have to agree) hurdles.

Google has been an adamant supporter of making 3.5gHz available for unlicensed use. 3.5gHz is not allocated for Wi-Fi, which eliminates the problems that 5gHz has with Wi-Fi cooperation. 3.5gHz, called the innovation band by FCC Chairman Tom Wheeler, is ideal for use by the proven TV white space database technology to assign radios in micro-geographies available spectrum in real time. These cloud-directed agile radios can change spectrum use on the fly, preventing interference with incumbent users like Navy radar or secondary priority users like mobile carriers using 3.5gHz spectrum for small cells. In all, there will be three sets of 3.5gHz users: incumbent access, priority access licenses – PAL spectrum auctioned to mobile carriers; and GAA for unlicensed use. 

Google is one of the few authorized spectrum database providers currently using the database for TV spectrum broadband radios. Google’s successful experience with cloud-directed spectrum sharing will translate well into using the 3.5gHz three-tiered spectrum for TD-LTE pico and femto mobile base stations. The combination of technologies will deliver true unlicensed LTE.  Even if Google (or any other new mobile carrier) builds a greenfield network of macro-towers, the need for purchasing billions of dollars of spectrum will not be required. At $2.70 per mHz per point of presence received in the recent AWS auction, 75mHz of nationwide unlicensed spectrum could be worth as much as $170 billion. Moreover, Wi-Fi spectrum use will not interfere with the new 3.5gHz service. And most importantly, because TD-LTE is being used in Asia today, low cost handsets are already available. All that remains is for the FCC to make a decision on the final 3.5gHz order and the race is on.

To deliver mobile service without building towers, Google could simply deploy TD-LTE picocells and femtocells to customers, just like Comcast (News - Alert) does today with dual-use Wi-Fi modems in customers’ homes. In addition, Google could use the TD-LTE pico cells on its new Google fiber to be deployed in 34 cities, just like Comcast is using Wi-Fi on its aerial fiber to deliver 5gHz Wi-Fi.

Google likes to do things its own way, using unique disruptive methods. It built its own web servers from scratch, built its own scraping software, built its own data centers, and built its own self-driving car. Delivering a mobile service using unlicensed LTE in the 3.5gHz band with existing TD-LTE equipment could be Google’s answer for a new mobile competitor that is not an MVNO.

Barlow Keener (News - Alert) is the principal with Keener Law Group (www.keenerlawgroup.com) out of Boston.