Declaring, “it is high time we give unlicensed spectrum . . . its due,” FCC Commissioner Jessica Rosenworcel challenged her FCC colleagues to develop a “game plan” that ensures enough 600 MHz spectrum is reserved through the incentive auction process to be allocated for Wi-Fi and other unlicensed applications in addition to commercial wireless broadband use. Rosenworcel made her case during a speech at a Washington, DC policy event on Tuesday. Under the draft incentive auction order that is circulating among the FCC’s commissioners and that is scheduled for a vote next week, the agency would make 600 MHz guard band and duplex gap spectrum available for unlicensed use. Depending on how much spectrum is recovered from broadcasters, the size of the duplex gap and guard bands would range from 12 MHz to approximately 20 MHz. (Unlicensed spectrum advocates, however, have pushed for allocations of at least 24 MHz in each market.) While admitting that the task of finding “several contiguous channels” in the 600 MHz band for unlicensed use “may be difficult,” Rosenworcel voiced her belief that “there are creative ways forward.” According to Rosenworcel, such creativity “starts with ditching the tired notion that we face a choice between licensed and unlicensed spectrum” as “good spectrum policy requires both.” While recognizing that “other services striving for white space in the 600 MHz band—like wireless microphones, low power television and medical telemetry—matter,” Rosenworcel told her audience: “if we take these things as a given, I still think we can find solutions.” Among other things, Rosenworcel suggested that the FCC “consider an expanded duplex gap, find new locations for unlicensed microphones, and provide unlicensed opportunities in Channel 37—while also protecting existing users.” Rosenworcel further claimed that “if we do this right, we can increase the value of licensed spectrum without diminishing the number of licenses we sell at auction.” As she lauded the FCC’s decision earlier this year to free up an additional 100 MHz of spectrum in the 5.150 -5.250 GHz band for unlicensed use, Rosenworcel also stressed that “we need to be on the watch for new mid-band opportunities for unlicensed spectrum, especially in airwaves that are underutilized.”