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President, Maximum Services Television (MSTV) EDITOR’S NOTE: In an effort to allow more Americans to have access to broadband a number of Federal legislators have decided that the best course is to allow unlicensed wireless devices to operate within the future TV band (channels 2-51). The potential impact on the professional sports industry could be devastating, as broadcasters and team personnel will no longer be able to rely on wireless microphone and communication systems. Below are some concerns expressed by David Donovan, president of Maximum Services Television. Mr. Donovan has been leading the charge in Washington, DC, to ensure industry concerns, backed by the professional leagues, teams, and others, are heard. These are talking points that everyone at your organization, no matter whether they’re technical or non-technical personnel, should be able to articulate to their government official. Let me start by stating that the term “white space” is misleading. Licensed wireless microphones occupy most of these so-called vacant channels in major markets. Whether providing coverage for major news stories or the local sports teams, these frequencies are being used. Moreover, as we have documented at the FCC, allowing unlicensed devices to operate of adjacent TV channels will cause interference to over the air television reception. The sports video industry knows the tremendous amount of coordination needed to insure there is no interference when covering news and sports. It takes months to coordinate frequencies for the Super Bowl. It also takes months to coordinate frequencies for the Democratic and Republican Conventions. Moreover, daily news coverage depends on prior frequency coordination among licensed wireless users. Coverage of the regular season including the NFL, Major League Baseball, NASCAR, College Football, the NBA and others all require frequency coordination. Theaters, live music concerts, churches, and other productions all require meticulous coordination to make sure there is no interference to wireless microphones. Such coordination will be impossible if millions of unlicensed devices start operating in the band. It is extremely difficult to begin to try to resolve interference problems from an unlicensed service operating on a portable laptop or a PDA. Imagine providing live coverage of an NFL game or emergency event. Without warning, someone in the vicinity turns on an unlicensed service wireless device. In mid sentence, the wireless microphone goes out. You have no idea where the interference is coming from and there is no way to solve that problem in real-time. But how did we get here, and where are we going? All of this stems from a proposal issued by the FCC several years ago. The FCC proposed using these frequencies for WiFi and WiMax type service. However this proposal ran into engineering problems as it became clear that it was far more difficult to protect incumbent users from interference, including TV sets and unlicensed microphone use than first imagined. Last year’s telecommunications bill, which passed the Senate Commerce Committee, included language to allow these devices in the band. However, the legislation failed to pass. Now enter the perfect political storm. Some members of Congress are pushing for unlicensed devices because it purportedly allows all consumers access to spectrum, without going through the difficulties of getting a license from the FCC. According to this theory, providing free access will liberate the spectrum from the big corporate “licensees.” It is also consistent with Silicon Valley’s desire to create an open and robust market for new chips. Sen. John Kerry of Massachusetts (D MA) has introduced a bill that reflects this position. His bill, S. 234, places unlicensed devices to be placed in the TV band no later than January February 18, 2009. A further example of this approach can be seen in legislation, HR 1597, that was just introduced by Rep. Jay Inslee. (D WA). Some conservatives support the unlicensed approach because it gets the government out of the licensing business, and makes way for a free market for spectrum. A bill introduced by Sen. John Sununu (R NH) (S. 337) best reflects this position. Moreover, many of Congress agree that unlicensed devices are an important vehicle for creating broadband access in rural areas. The extension of broadband services to all America, especially unserved rural areas, is an important public policy objective. In rural areas, providers cannot afford to purchase spectrum at auction. An unlicensed model allows rural broadband band services to obtain access to spectrum for free, thereby reducing the costs of providing broadband services. A funny thing happened on the way to helping out rural broadband. Leading computer companies including Microsoft, Intel, Dell, HP, Google and Philips saw an exploding market for new chips and devices throughout the country. Not content to limit unlicensed spectrum for rural broadband services, these companies seek access to all TV spectrum in all markets. For example, one group argues that there are 24 Mhz of vacant spectrum (that’s the equivalent of 6 TV channels) in the New York City market. These companies seek to place “personal and portable” consumer devices in the TV band in all markets. They claim they can protect TV reception and wireless microphone use. However, these claims have never been proven in a lab or more importantly, in the real world. The FCC has committed to conducting various laboratory tests to see if unlicensed devices will cause interference to incumbent services. The coalition looking to allow unlicensed devices in the band, i.e., Microsoft et al., stated they will submit a “prototype” unlicensed device to the FCC for testing. To date, the coalition has not submitted an actual device. Rather it has submitted a “development plan.” An actual prototype device may be forthcoming later in the month. At the outset, I am not sure the existence of one “prototype” device should be the determining factor as to whether unlicensed devices are allowed in the band. The unlicensed device regime contemplates the operation of a number of different devices and services. Is this device representative of all types of unlicensed devices that will enter the band? In other words, is there a direct nexus between this device and all other devices that would be allowed to enter under the FCC’s rules? It is difficult to evaluate the device as it does not yet exist. However, based on the “development plan” filed with the FCC, the purported device would have a sensing level of -114 dbm . From an engineering perspective, this sensing level is inadequate to protect television service. If this level is approved, there is a significant probability that these unlicensed devices will operate on channels that are being used by local television stations, resulting in significant interference to consumer TV sets. Moreover, the proponents argue that each device, by itself, should be able to sense and turn on without “networking” or “double checking” with to other sensing devices. This “single devise sensing” approach is not sufficient to protect wireless microphones from receiving “on-channel” interference. For these reasons we hope that the FCC will make its testing process transparent. It is critically important that the affected industries have the ability to examine the purported device and the testing procedure. We must make sure testing is done correctly. Unfortunately, the combined lobbying power of Microsoft, Google, Intel, HP, Dell and Philips have brought enormous pressure on the Commission. In a recent hearing before the House Commerce committee, FCC Chairman Kevin Martin changed his position on the issue, suggested that he may be willing to place unlicensed devices in the TV band before the DTV transition date, February 17, 2009. This train is moving. The time has come to take the case to Congress and the FCC. In this respect, we should support the efforts of Rep Bobby Rush (D IL). He has introduced legislation that will not put unlicensed devices in the band until 2009. More importantly, it allows “fixed” unlicensed services in the band that are designed for rural broadband services. Personal and portable devices would not be allowed into the TV band, if at all until 36 months after the DTV transition. This bill places the right emphasis on focusing on the deployment of rural broadband service. I urge you in the strongest possible terms, to contact your Congressman, Senator as well as the FCC. Tell them not to place unlicensed personal and portable transmitting devices in the television band. (Channel 2-51) Your ability to produce live sports, entertainment and new will depend on the outcome of this issue. The time for action is now! David Donovan was named President of the Association for Maximum Service Television, Inc. (MSTV) on July 1, 2001. Founded in 1956, MSTV is a national association of over 430 local television stations dedicated to promoting technical quality of free, local, over-the-air television service and has taken a leading role in the transition to digital television service. Prior to accepting the position of MSTV President, he served for over a decade as the Vice President for Legal and Legislative Affairs for the Association of Local Television Stations, Inc. (ALTV). From 1987 to 1990, he was the mass media legal advisor for the Honorable James H. Quello, FCC Commissioner. Donovan also held a number of key positions at the FCC, including legal advisor to the Mass Media Bureau Chief. © Copyright 2006-2007 sportsvideogroup |
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