Public Interest Groups Say FCC Can Safely Allow Unlicensed Devices To Use TV Guard Bands
New American Foundation's Open Technology Institute (OTI) and Public Knowledge jointly asked the FCC in comments filed Wednesday in docket 12-268 to adopt final rules that will ensure at least three to four 6 MHz channels are available for unlicensed white spaces devices in every market in the U.S. Others said the rules are either too liberal to too restrictive. The FCC sought comment on both the future of wireless mics and of unlicensed operations in the TV bands as part of its work toward rules for the TV incentive auction.
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A market for unlicensed chips, devices and services in the 600 MHz band “is wholly dependent on access to three or more 40 mW, 6 MHz channels in every market nationwide,” OTI and PK said. The FCC’s proposals “taken together and with some minor improvements, can fulfill that promise,” they added.
CTIA said the FCC should adopt tougher out-of-band emissions (OOBE) limits for wireless mics and other devices using the 600 MHz duplex gap and guard band after the incentive auction. OOBE limits proposed by the FCC are too high, CTIA said. The 2012 spectrum law emphasized that the FCC may not “permit any use of a guard band that the Commission determines would cause harmful interference to licensed services,” CTIA said. “Unlicensed operations in the 600 MHz guard band and duplex gap can only be introduced through a regulatory framework that ensures that such operations do not raise interference concerns.” Studies already submitted to the FCC by CTIA and others make clear proposed protections for licensed services in the 600 MHz band “are not sufficient” to protect them from harmful interference, the group said.
But Microsoft said the record is dominated by companies that want to see vibrant unlicensed use of the TV white spaces in the “duplex gap, guard bands of 9 and 11 MHz, and on Channel 37 at operating powers between 40 and 100 mW.” Microsoft criticized tests submitted in the record by CTIA and Qualcomm that purport to show an interference threat to LTE in the TV band after the TV incentive auction. “These supposedly new test results rely on many of the same problematic assumptions that rendered previous technical analyses submitted by LTE proponents inaccurate,” Microsoft said. “The tests themselves also appear designed to achieve a particular outcome and do not reflect real-world operating conditions.” Google said the proposed rules “effectively protect (and sometimes overprotect) licensees” from unlicensed use of the TV spectrum.
Wireless microphone maker Shure said proposed rules are far too restrictive. Wireless mic users, manufacturers and the millions who attend productions where wireless microphones are used “face significant disruption and severe harm if the Commission adopts many of the proposals in the NPRM,” Shure said. It said the FCC’s proposals would “radically reduce the clean UHF spectrum available for wireless microphone use, impose government-mandated redesign of wireless microphone equipment to incorporate database control, impose restrictive new power limits on unlicensed wireless microphones, and render noncompliant a substantial portion of recently purchased wireless microphone equipment across the country.”