NAB Asks FCC To Suspend Use of TV White Spaces Database, Citing 'Serious Flaws'

“We are aware of some inconsistencies in the database and are working with the database administrators to correct these issues,” an FCC official said Thursday. “A plan is in place to ensure that any erroneous data gets corrected as we move through next year’s auction.”

NAB said in the petition that it conducted multiple analyses of the database system over the past year and found device users provided inaccurate information in all nine of the required fields of the database, including invalid FCC IDs, fake serial numbers and false contact information. “Most problematically, the analyses found that more than one-third of fixed TV white space devices in the database listed erroneous, and occasionally wildly inaccurate, location data,” said the petition filed Thursday.

"Whether users are misusing the database because of concerns over providing their actual location, willful circumvention of the rules to operate on more channels than permitted, or sheer laziness, the result is the same: The significant number of false entries undercuts the integrity of the database and defeats its intended purpose," NAB said. NAB even created a fictional carrier, Johnny Interference, to highlight white spaces problems.

“We are not in any way suggesting that TV white spaces cannot be a great thing,” said NAB General Counsel Rick Kaplan on a call with reporters. “It’s something we’ve come to accept.” But the FCC has to get the database right before the use of the white spaces takes off and many devices are in the hands of consumers, he said. One big problem with the current system is that a user in Manhattan can claim to be in Idaho and access the Internet on channels already in use by broadcasters, he said. “We realized very quickly that there’s no way that this regime was ready for prime time if you’re going to expand it, let alone use it for other bands,” he said.

NAB raised concerns at the FCC in August, Kaplan said. But it became clear that FCC officials had “cut a deal” on use of the white spaces after the incentive auction with public interest groups, he said. “We wanted to bring this to more public attention because the flaws are so obvious and the fixes are so clear,” he said. Kaplan also urged the FCC to separate its work on the future of the white spaces from its work on the incentive auction.

In related comments, Janice Obuchowski, former NTIA administrator and U.S. ambassador to the World Radiocommunication Conference, said Thursday big unlicensed players like Google need to “step up” and put more money into sharing technology. She spoke at a spectrum sharing conference sponsored by the Wireless Spectrum Research and Development (WSRD) Senior Steering Group.

“The big players, the Googles of the world, can talk a very attractive story about unlicensed,” Obuchowski said. “I don’t think they’re stepping up and doing the required studies on how these databases are really going to work. How information assurance ought to happen. … They really have to put their money where their mouths are on the white spaces side.” Obuchowski is president of Freedom Technologies and a member of the Commerce Spectrum Management Advisory Committee. Google, a database operator, didn't comment.

Michael Calabrese, director of New America’s Wireless Future Project, also a CSMAC member, fired back at NAB. “NAB’s petition is a very transparent effort to discredit unlicensed access to vacant TV spectrum to pressure the FCC to give the 600 MHz duplex gap to network news microphone use rather than for public unlicensed use, as Congress intended,” he told us. “It’s very odd that NAB bases their petition on inaccurate registrations by some TV white space users, yet they can’t even say this has ever interfered with TV reception. The reason it has not is because absent a willful breaking of FCC rules, which could happen on any band, the TV bands database ensures that devices operate only on locally vacant TV channels no matter what identity or location they put in the database. That said, although it’s no emergency, more could be done to ensure accurate registrations.”

“This development is very troubling,” said David Donovan, president of the New York State Broadcasters Association, of the NAB findings. Donovan represented broadcasters as president of the Association for Maximum Service Television when the white spaces rules were under construction. The FCC settled on the use of a database system to protect broadcasters seven years ago when the rules were being developed (see 0807170161).

“Inaccuracies in the database mean that an increase in the number of TV whitespace devices will result in increased cases of interference to TV reception and licensed wireless microphones across the country,” Donovan told us. “It could also have ramifications in other sharing contexts involving federal and nonfederal users. All of this is occurring at a time when the FCC’s Enforcement bureau is planning to cut back on its field offices, which have been at the forefront in policing interference. These database issues would seem to indicate that more, not less, resources should be devoted to interference protection and enforcement.” The FCC’s proposed changes to the Enforcement Bureau were revealed last week (see 1503110054).

“The issues unearthed by NAB show that the devil is in the details of the maintenance of the database,” said Roger Entner, analyst at Recon Analytics. “The FCC has to spend resources on verifying the new entries and changes in all of its databases, especially ones accessible to everyone, so that they are actually useful."

But former FCC engineer Michael Marcus, now a consultant, said the problems with the database shouldn't be NAB’s biggest worry. “If NAB would sit back for a second, they might realize that the decimation proposed of the FCC’s spectrum enforcement staff is a much greater threat to all broadcasters -- not just TV broadcasters -- than problems with the TVWS database that can be addressed in a less confrontational approach,” Marcus said in a blog post Thursday.

"Unlicensed use of the TV white spaces was premised on having a system in place that would protect both licensees and users of new cutting-edge devices,” said Robert McDowell of Wiley Rein, an FCC commissioner when the white spaces rules were approved. “If indeed the database is so flawed and easily loaded with bad information, it won't work for tech companies or licensees. In the end, consumers will lose the most."

The Wireless ISP Association said it can find "no hard evidence of any real problems​" or interference tied to white spaces devices. "They are complaining about housekeeping issues," WISPA said of NAB. "WISPA believes that that the emergency petition is unfounded and should not merit further consideration."