Exclusive licensing with an underlay is an appropriate paradigm for TV and other
broadcast applications. Although further research is required on the viability of
the more sophisticated forms of opportunistic access to insure the protection of
TV signals, there are ways that a secondary device could safely use a broadcast
band today. Thus, the FCC could move incrementally forward, allowing the
underlay with sharing techniques that are known to be safe. This submission also
suggests that the FCC consider certifying radio traffic signals as a viable
approach. Underlay applications should also be reconsidered. We are more likely
to see wireless last-mile connections than Wifi-like applications emerge in a
broadcast underlay.