1. Very large Houses of Worship urge the Commission not to allow unlicensed use of the white spaces. They point out that they have sophisticated systems:
Many houses have footprints larger than multiple football fields and hold pew-seating for worshipers in the thousands. Typical facilities may include a large stage for the pastor, and stages to accommodate hundred-person choirs, full orchestras, praise teams, a praise band, and complex sound systems. Our experienced technical staffs devote considerable time and effort in planning to ensure highquality productions including interference-free wireless microphone operation.
2. The presidents of News Corp., Disney, CBS, and NBC wrote in, suggesting that the DTV transition is a substantial government/industry investment, and that consumer harm through interference with these TV transmissions should be avoided. Interestingly, they cite the upcoming 700 MHz auction in support of their argument, asserting that the vacated spectrum “will be available for multiple uses, including the same types of broadband services envisioned by those who seek to operate on an unlicensed basis in the digital spectrum allocated for free, over-the-air broadcasting.”
That’s bravura for you. The reason these non-contiguous frequencies are called “white spaces” is that they’re not being actively used by broadcasters. And they got extra spectrum for free for use in the DTV transition – these are the soon-to-be vacated frequencies that are going to be auctioned off in January.
The letter suggests that a “‘fixed’ broadband system, which does not operate on a co-channel or adjacent channel, will help expand broadband opportunities without causing interference to digital television receivers.” The practical translation of requiring only “fixed” devices is that investment in mobile, opportunistic devices for internet access will be limited because the market will be too small to pay off.
3. The cable industry weighed in through its trade association, NCTA:
We discussed the high likelihood that personal, portable TV band devices with high output power will cause direct pickup interference to cable customers’ viewing of cable channels. We explained that for cable operations, there are no “white spaces,” as cable systems utilize every channel in the broadcast spectrum. We expressed the need to significantly lower the output power level of proposed devices…
So cable and broadcast are joining on this issue. This is another way of making portable devices unattractive targets for investment — if they’re so low-power, they won’t be able to do anything useful.
4. Twelve Representatives from Texas and Ohio recently wrote in voicing concern over the use of unlicensed personal-portable devices in the white spaces. Their letter is very similar to the letter from News Corp., Disney, CBS, and NBC above.
5. Broadway theatre producers wrote in in May (but the letter just made it to the ex parte files).
We discussed the importance of maintaining the ability to ensure that Broadway and performing houses around the country may continue to use their wireless microphones without fear of interference. We specifically discussed the need for the Commission to incorporate comprehensive interference protections for these important incumbent services in the upcoming rules for unlicensed devices in these so called “white spaces.” We also reiterated the need to perform on site testing on the proposed mitigation devices in areas such as Broadway where the interference is the greatest.
FCC field trip!
5. The Hill reports today that the broadcasters are delighted to have God, Broadway theater, and sports on their side on this issue.
Crossposted from Susan Crawford blog