Disagreements Continue at FCC Over Agency's TV White Spaces Rules

Google sought reconsideration of the Part 15 order’s requirement that databases “push” wireless mic reservation information to unlicensed devices. The FCC based it on a “technical misapprehension" and "substituting a ‘fast-polling-channel’ requirement would better serve the public interest,” Google said. But an alternative solution offered by NAB and the wireless mic companies is also bad, Google said. “Wireless microphone interests contend that the FCC should replace the rule with the very proposal the Commission just rejected: high-frequency database polling on all channels,” Google said. “They simply disregard the Commission’s own sound reasoning in rejecting this proposal.”

The commission can make white spaces more commercially viable “by correcting two important oversights,” Microsoft said. The FCC should get rid of its “unworkable” database push requirement and eliminate the “needless” mandate that only low-power, fixed, indoor white-space devices can use high-gain antennas, Microsoft said. “White-space opponents have failed to provide any reason not to correct these errors by requiring ‘fast polling’ … and permitting fixed, indoor [devices] to use unity-gain antennas at a conducted power of 40 mW,” the company commented.

NAB questioned the argument that polling white spaces devices every 20 minutes to ensure they aren't causing interference is an unworkable or burdensome mandate. Companies opposing the polling requirement have a shared goal, “expanding unlicensed operations in the television band at any cost,” NAB told the FCC. “To these parties, the risk of harmful interference to licensed operation is simply irrelevant, because the as yet unrealized benefits of TV white spaces operations are allegedly so significant that they merit increased risks.”

Few are using the white spaces, and arguments for reduced requirements ignore a basic tenet of unlicensed, NAB said. “Instead of brushing licensed services aside because it is convenient, and cheaper than seeking access to licensed spectrum, unlicensed operations in the television band must remain at their core opportunistic in nature and must take place in between and around licensed services without causing interference.”

Various players also are still fighting over rules for channel 37, which white spaces devices will have to share with medical devices.

The Wireless Medical Telemetry Service Coalition said that, contrary to arguments by Google and Microsoft, the FCC has grounds to provide better protections for WMTS companies, including increased separation distances to protect wireless telemetry from harmful interference. “The Coalition has identified significant material errors and omissions by the Commission in determining the appropriate separation distances and how they can be dependably enforced,” the WMTS Coalition said. These errors include “incorrect assumptions about WMTS system characteristics and the environments in which they operate” and fail to take into account “credible concerns” about the reliability of the white spaces database, the coalition commented.

GE Healthcare also pressed for a rule change to protect WTMS. GEHC said it demonstrated in its recon petition that separation distances and other procedures designed to protect medical operations from harmful interference “were arbitrary and capricious because, among other things, the Commission used a faulty methodology to calculate the distances.” The FCC also “failed to address concerns raised by GEHC and others about the dependability of TVWS devices and the geolocation-database scheme as a whole,” GEHC said.

The rules and waiver process “already overprotect WMTS operations, and the lack of clarity in the Commission’s description of its test deployments creates an unnecessary risk that innovators will view the FCC’s Channel 37 as too uncertain to warrant investment,” Google countered in its reply.