"As Google has pointed out previously, the vast majority of viable spectrum in this country simply goes unused, or else is grossly underutilized," Google Media Counsel Richard S. Whitt, wrote in a letter filed with the Federal Communications Commission on Friday. "Our nation typically uses only about five percent of one of our most precious resources. Unlike other natural resources, there is no benefit to allowing this spectrum to lie fallow. The airwaves can provide huge economic and social gains if used more efficiently, as seen today with the relatively tiny slices utilized by mobile phones and WiFi services."

The filing wasn't the first time Google pitched using the untapped spectrum, but it was the first time it outlined its plans publicly, and the filing came days after the federal government announced the winners to an expensive auction used to raise revenues by selling off important chunks of the old analog broadcast spectrum that will be phased out in February 2009, when the U.S. TV industry converts to 100% digital broadcasting.

"The unique qualities of the TV white space -- unused spectrum, large amounts of bandwidth, and excellent propagation characteristics -- offer an once-in-a-lifetime opportunity to provide ubiquitous wireless broadband access to all Americans," Whitt wrote in Google's appeal. "In particular, this spectrum can provide robust infrastructure to serve the needs of under-deployed rural areas, as well as first responders and others in the public safety community. Moreover, use of this spectrum will enable much-needed competition to the incumbent broadband service providers."

The letter says Google has already begun working on the "technological groundwork" necessary to utilize the untapped spectrum, and that once coupled with its new "Android" open source mobile communications platform would provide "uniquely low-cost mobile broadband coverage for all Americans."

The move is consistent with Google's mission statement to help manage "the world's information," and to utilize super technology to do it, and reinforces Google's commitment to move beyond its core competency of online search into a broad and ubiquitous communications infrastructure.

Broadcasters Monday said they were pleased by the details of Google's disclosure, but remained concerned about some of the technical aspects of the plan, and in particular, whether use of TV's white space spectrum - located between channels 2 and 51 in the over-the-air broadcast signal - might not cause technical interference with television broadcasts.

"We are pleased that Google now seems to realize that spectrum sensing alone won't protect viewers against interference from unlicensed devices," National Association of Broadcasters Executive Vice President Dennis Wharton stated Monday, adding, "Unfortunately, simply adding geolocation and beacon sensing does not mean that mobile operation is suddenly feasible. Portable, mobile personal device operation in the same band as TV broadcasting continues to be a guaranteed recipe for producing interference and should not be allowed under any circumstances."

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