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Replies to FCC Disagree on TVWS Terrain Models

Parties disagreed on terrain-based models, such as the Longley-Rice irregular terrain model (ITM), to determine available TV channels for white space devices, in replies on an October Further NPRM (see 2010290051), due Monday in FCC docket 20-36. The Wireless ISP…

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Association sought the change. “By now, the Commission should feel confident that it can permit white space database administrators to utilize the point-to-point Longley-Rice irregular terrain model for determining white space channel availability for fixed white space devices without increasing the risk to incumbent operations,” Microsoft said. NAB still disagrees (see 2103290052). Don’t “adopt additional changes that threaten television reception, particularly considering this unlicensed technology has produced few tangible results in the thirteen years since the Commission first authorized [white spaces] operations,” NAB said. BitPath agreed further revisions are “wholly inappropriate” now. The FCC just made “sweeping changes” to the rules, including a 60% increase in power levels and a doubling of antenna height for some fixed devices, “as well as substantial power increases for mobile devices, and authorized a new class of narrowband IoT” devices, BitPath said: “Making further changes to the … rules without the benefit of knowing the real world impact of the recent changes would be imprudent.” But NAB’s initial comments “overstate the potential for harmful interference to protected TV broadcast stations, understate the public interest benefits of using the ITM, and are outweighed by the record,” WISPA said: “The Commission should require the TV white space administrator to add the ITM as an option for TV white space users following Commission testing to confirm the ability of the database to implement the ITM without causing harmful interference to protected TV station facilities.”