So no sooner do we get the 700 MHz auction
reasonably settled when breaking developments start popping out on the broadcast “white spaces” proceeding. To refresh everyone's memory, this proceeding looks at opening up the vacant TV channels between television stations (aka “white spaces”) for low power devices — preferably on an unlicensed basis, but the FCC explicitly left open the possibility it might auction off the white spaces as exclusive licenses instead.
The critical issue is whether it is possible to have unlicensed use of these vacant channels without interfering with people trying to watch TV and — if so — under what set of rules? For example, can the FCC safely allow companies to deploy mobile devices, or should the FCC limit the use to stationary point-to-point uses? Can devices reliably sense the presence of a signal or should the FCC require devices to locate vacant channels in some other way? And can Home Shopping channels be considered vacant for these purposes because no one needs to buy more cubic zirconium? (Oops, wrong proceeding.)
In any event, to help set the standards, the FCC's Office of Engineering Technology (OET) put out an notice last December that it would love to get some prototype “white spaces” devices to test so they could set standards. The “High Tech White Spaces Coalition” (a collection of companies that includes Google, Microsoft, Dell, and Intel) submitted a Microsoft designed device, and Philips Electronics also submitted a prototype.
As an aside, I will observe that us folks in the public interest community in favor of getting more “open” unlicensed spectrum have been plugging away at this for years. But, of course, broadcasters and the news media would prefer you see this as yet another initiative of the Great Google Overlords and Microsoft because then it is ever so much easier to make this a fight about Google or Microsoft rather than actually debate on issues. [You may detect a mild note of bitterness here over the continued idiocy of the media in this regard.] Which is why the fact that New America Foundation did its own experiments to test for possible interference apparently does not count for squat. Nah, the only thing that matters (to the news media anyway, the OET guys actually care about real engineering data) is how the tech company devices did in testing.
So yesterday OET released its report on the two industry protypes and a report on the sensitivity of digital cable tuners to interference. From what I understand, the Reports showed:
(a) The Philips prototype worked pretty well at sensing the presence of DTV broadcast signals and avoiding them in the lab, but it was not field tested because the company said “this isn't ready for field testing”;
(b) The Microsoft prototype which Microsoft claimed was a “release product” according to spec. In fact, it appeared to miss finding DTV signals pretty regularly, although MS promised to correct this with a patch to be released RSN (excuse me, but this is a surprise?)
(c) If you put a low power emitter right up close to a digital TV receiver, it could cause interference. But the range is so small that it is unlikely to cause interference from a neighboring apartment under most circumstances.
OET qualified this last report by observing that the testing on this was real limited and that all it showed was that, even at low power, there was a potential for interference — a fact that nobody disputed (under the right conditions, my cat sleeping on my TV can cause interference with some signals).
And, indeed, so far as I can tell, I have no quarells with the OET guys or their experiments or data. As OET stated in its Public Notice, this is about working with interested firms to develop standards based on these kinds of experiments. They also ask for public comment on the Reports (comments due August 15, replies due August 27) and invite interested parties to come down to the testing lab in Columbia, MD to observe testing, discuss test conditions, possibly play a little Halo, and generally do what research engineers do when not watching Monty Python. (“We are the Geeks who say NI! We command you to build us a white spaces device WITH A HERRING!”)
In the real world, what you would expect to see is a fair amount of prototype testing before you got ready for prime time. Indeed, the usual way the FCC does this is (a) get enough of a positive result to show that achieving the desired result is feasible; (b) set out a rule describing what a device must do to get certified; then (c) wait for industry to set standards and submit devices until somebody gets a certification under Part 15 by demonstrating that the device will actually do what the rule requires. To take a recent example, the FCC set technical requirements for unlicensed devices to share the 5.3 GHz space with the military in 2003 — contingent on the industry working with the military tro develop technology smart enough to avoid interference with military radar. It took three years to develop technology that met the neccessary requirments, but it happened. Why? Because everyone had confidence based on the initial proof of concept that it could be done, and that it was just a matter of good faith efforts and good engineering practices to make it happen.
But, of course, this is not about engineering. This is about politics. So the National Association of Broadcasters promptly released this statement that this proves the entire notion of unlicensed mobile devices operating in the white spaces is madness — MADNESS I TELL YOU! — and that if the FCC does not stop tampering in God's and broadcast television's domain, then terrible consequences will follow. So best to shut the whole thing down now as a bad effort and move along.
Obviously, it would have been much better if the prototypes had leapt fully functional from Microsoft labs like Athena from Zeus, effortlessly sensing and dodging DTV signals and causing no interference even when inserted inside the television set (although I suspect even then NAB would have found the results inconclusive). But engineering stuff from scratch takes time and data and a willingness to keep engaging the process. Contrary to the NAB's statement, this does not “confirm what NAB, MSTV and others have long contended: that the portable, unlicensed devices proposed by high-tech firms can't make the transition from theory to actuality without compromising interference-free television reception.” What it actually confirms is (a) it appears possible to get to where we need to go to make this happen; but (b) we ain't there yet.
So now we go to comments and further testing. Given that FCC Commissioner Robert McDowell has relied on the future approval of unlicensed in the broadcast white spaces as a reason to do jack about our national broadband woes, I am hopeful that the FCC will keep an open mind. No one wants to rush this out before it's ready for prime time (I'M TALKING TO TO YOU MICROSOFT!), because the tech industry understands that if approval of these devices causes interference there will be massive recalls and the efforts to open this up will get set back ten years. But we can expect to see opponents of white spaces use, and opponents of open spectrum generally, pouncing on this report as proof positive that “smart radio” technology will never get any “smarter” than it is today and we better scurry back to find more spectrum to auction. Which, if you will excuse me, I think is a pretty dumb argument.