Posted on September 24, 2010 by David Oxenford

Reconsideration of White Spaces Decision - FCC Approves Unlicensed Devices for "Super Wi-Fi" in TV Band

The FCC's long-awaited White Spaces decision, revisiting its authorization of the operation of unlicensed wireless devices in the television spectrum (see our summaries of the intial order here and here), has finally been released.  The FCC decision and associated comments of the Commissioners promise Super Wi-Fi, or Wi-Fi on Steroids, and a host of other wireless digital marvels, without significantly interfering with the incumbent users of the spectrum (principally TV stations and wireless microphone users).  In this order on reconsideration, the FCC addresses many issues raised by many parties to the proceeding - some suggesting that the FCC has not sufficiently protected the incumbent users, while others arguing that the limitations on wireless users are too onerous.  For broadcasters, some of the highlights of the decision include:

  • No change in the interference protections given to TV broadcasters.  Some had suggested the use of various alternative propagation methods to be used instead of the standard FCC method of predicting the protected contours of television stations.  The FCC rejected these proposals, finding that alternatives would not be more accurate in predicting potential interference.  One minor correction including in the database that will be used by wireless devices to protect stations from interference will be included - information on a television station's antenna beam tilt.
  • No change in the protection of LPTV station protected contours.  LPTV advocates had suggested that greater protection was required for LPTV stations that were still operating in an analog mode.  This was rejected by the Commission, given the impending digital transition for LPTV (see our summary of the LPTV digital transition, here)
  • Greater protection was afforded to cable headends, TV translator receive sites, and the receive locations for Satellite television providers (like DISH and DIRECTV) and other Multichannel Video Providers (MVPDs), so that existing television reception, no matter how it is received will be protected.  The current rules provide that such sites within 80 km from the edge of a television station's protected contour can register in the database to be used by white spaces devices to determine where they can operate.  The Commission recognized that sites beyond that 80 km distance may also need protection.  Such sites can petition the FCC for waiver of the 80 km distance within 90 days of the effective date of this order, and the FCC will seek comment on whether or not to accord the site protection.  New sites need to register within 90 days of being put into service. 

Some of the other issues addressed by the Commission, including a big change in how these devices will operate to prevent interference, are summarized below.

Perhaps the biggest change was in the requirement that these devices use spectrum-sensing technology to avoid interfering with television stations and wireless microphone users.  The original proposals for these devices were premised on this technology, but this technology was also the most controversial, as broadcasters argued that the devices that had thus far been produced were not reliable in sensing the existence of a signal that was to be protected.  Instead of spectrum sensing technology (which the Commission speculates may be included in future generations of white space devices to allow them to avoid actual interference to their operations), the Commission has decided to rely on the database that it will create of existing users of the spectrum.  The white spaces devices will need to be able to determine where they are and what channels are listed in the database of protected channels in that area, so that the devices will use other channels.  Very specific rules for how often white spaces devices need to assess their location and to access the database were also adopted to make sure that these new interference standards are observed.  Security measures to assure that the communications between the devices and the database are not corrupted were also adopted. 

The Commission also rejected requests to increase the permissible power of these devices and the height from which fixed white spaces devices can operate, and for the operation on channels adjacent to television stations, so as to limit potential interference.  Similarly, requests for more protection for "direct pickup devices" (e.g. the connection between a cable box and a television set that uses a television channel to transmit information from one device to another) were rejected, as the Commission found that manufacturers of such devices could provide more shielding for their connections or otherwise engineer around the issues that might be presented by white space operations.  

On the wireless microphone issue, the FCC decided to set aside certain channels in each market to be dedicated to their use, to establish a specific set of frequencies in each location that can be entered into the database.  Provisions for temporary operations outside of those set-aside frequencies were also established so that accommodations could be made for increased use of such microphones when employed for some big event (e.g. a political convention or major sporting event). 

As is clear from the discussion above, the protection of all current users of these frequencies will rely on the establishment of an accurate and up-to-date database that can be accessed by all of the white spaces devices that may be developed.   The Commission reaffirmed rules that allow for the selection of multiple database operators, and required that their information as to FCC licensees, and other information required by FCC rules, be publicly available so that it can be reviewed for accuracy.  Issues as to fees to be charged to wireless operators by the database operators were left to the discretion of the operator.  Certain other technical rules were adopted.  Of course, before any of these operations can be implemented, the database operators must be selected and approved by the FCC's Office of Engineering and Technology  (see our post here on the FCC's RFP seeking applications for database managers).  The FCC delegated the Chief of that office to oversee the operation of these databases once they are put into use.

When will these devices be operational?  At this point, given the need to establish the databases, and to engineer devices to work with the databases that are established, it is safe to say that the operation will not occur overnight.  When the Commission first approved the concept of white spaces devices, many had predicted operations at points that have long come and gone .  As with everything else in the technology world, when it will happen, and the impact that the rule changes will have in the real world, will only be apparent at some point in the future.  We will all see how this new service develops, and its actual impact on the existing users of these channels but we won't see it tomorrow. 
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Posted on November 25, 2009 by David Oxenford

FCC Starts Next Step of TV White Spaces Deployment - Issues RFP for Database Manager to Track Interference Concerns

A year after the FCC issued its order adopting the "White Spaces" proposals (about which we wrote here and here), to allow wireless devices to operate in unused portions of the television band on a non-interference basis, the FCC took its first steps toward actual implementation of that order by issuing a request for Proposals from entities wishing to be considered for the position of Database Manager.  This Database Manager will play a very important role in the implementation of the White Spaces order, as it will identify all of the current operators in the TV band that the new wireless devices will have to protect while operating in a given region.  In its White Spaces order, the FCC concluded that not all of these devices could, on their own, adequately sense where there were TV stations or other spectrum users that needed to be protected.  Thus, the White Spaces devices need to be able to communicate with the database to be maintained by the Manager, to make sure that they are operating on clear portions of the television spectrum.  White Spaces devices need to protect not only full power TV stations, but also Low Power TV stations and TV translators, as well as the path between a full-power TV station and any translator that rebroadcasts that station.  Cable system headends which pick up TV signals must also be protected, as well as land mobile users who use portions of the TV band.  Certain regular users of wireless microphones also need to be protected - so the database will need to be very detailed to give the White Spaces devices access to information about all of these existing users who must be protected.

In its Request for Proposal, the FCC has asked that proposed Database Managers provide extensive information by the January 4, 2010 filing deadline.  Information requested includes the following:

1. The entity must demonstrate that it possesses sufficient technical expertise to administer a TV band database. It must demonstrate that it has a viable business plan to operate a database for the five-year term the rules. To the extent that the proponent will rely on fees from registrations or queries, the proposal should describe the fee collection process.

2. The entity must describe in detail the scope of the database functions that it intends to perform, such as managing a data repository, performing calculations to determine available channels, and/or registering fixed unlicensed devices and licensed services not listed in the Commission’s databases, or how it will have functions performed in a secure and reliable manner by another entity. The entity must also describe how data will be synchronized between multiple databases if multiple databases are authorized and how quickly this synchronization of data will be accomplished.

3. The entity must provide diagrams showing the architecture of the database system and a detailed description of how each function operates and how each function interacts with the other functions.

4. If the entity will not be performing all database functions, it must provide information on the entities operating other functions and the business relationship between itself and these other entities. In particular, it must address how the Commission can ensure that all of the requirements for TV band database administrators in the rules are satisfied when database functions are divided among multiple entities, including a description of how data will be transferred among these various related entities and other databases if multiple databases are authorized and the expected schedule of such data transfers (e.g. real-time, once an hour, etc.)

5.  The entity must describe the methods that will be used by TV band devices to communicate with the database and the procedures, if any, that it plans to use to verify that a device can properly communicate with the database. It must include a description of the security methods that will be used to ensure that unauthorized parties can not access or alter the database or otherwise corrupt the operation of the database system in performing its intended functions. In addition, the entity should describe whether and how security methods will be used to verify that Mode I personal/portable devices that rely on another device for their geographic location information have received equipment authorization, interfaces, protocols) that will be used by TV band devices to communicate with the database and the procedures, if any, that it plans to use to verify that a device can properly communicate with the database. It must include a description of the security methods that will be used to ensure that unauthorized parties can not access or alter the database or otherwise corrupt the operation of the database system in performing its intended functions. In addition, the entity should describe whether and how security methods will be used to verify that Mode I personal/portable devices that rely on another device for their geographic location information have received equipment authorization.

It should be remembered that the White Spaces order requiring that these wireless devices be allowed in the TV band on a non-interfering basis is a proceeding separate and apart from the recent discussions of the re-allocation of some or all of the television band from its current use for broadcast television to instead become spectrum dedicated to wireless services providing wireless broadband services.  While some of the same wireless services might be possible under the White Spaces proposals, given the requirements that primary users be protected, the broadband services envisioned by these more recent proposals would not be as easily implemented through the use of White Spaces devices.

The proposals to be the Database Manager are sure to be scrutinized by broadcasters and other users of the television spectrum to ensure that whoever assumes this important position provides reliable service that allows the wireless White Spaces devices to identify and protect the incumbent users.  The Commission has allowed interested parties to comment on the filings.  Comments are due on February 3, and Replies on February 18.  For television operators, this is an important process to be watched closely. 
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Posted on November 23, 2008 by David Oxenford

Details of White Spaces Decision Released - Don't Look for Them Soon as There is Lots to Do Before Any Devices Will Be Introduced

The FCC this week released the details of its "White Spaces" decision, authorizing the use of both fixed and mobile unlicensed devices within the television spectrum.  In theory, these devices are supposed to be able to sense the existence of television signals so that they can operate on other frequencies and avoid creating interference.  However, as an extra safety measure, the FCC has also required that these devices connect at least once a day with a database of all other protected users of the television spectrum and, by used of geo-location technology, determine what other users are in the area where the "TVBD" (television band device) is being used and operate on frequencies which protect those other users.  Our firm has prepared a memo outlining the full decision.  The Davis Wright Tremaine memo can be found here.  When one reviews the full text of the FCC decision, it becomes pretty clear that we should not look for such devices anytime soon.

While the Commission's order actually discussed in some detail the question of whether these devices should be permitted to operate before the end of the digital television conversion in February 2009, given the issues that still need to be resolved, this discussion really appears to be an academic one.  First, devices that meet all of the FCC requirements have to be designed and built, and type-accepted by the FCC labs.  In a recent article by Shelly Palmer in his well regarded blog on television issues, he suggests that many engineers are convinced that these devices simply will not work.  When one reviews the FCC requirements, one can see why that might be the case.

First, the devices must be designed so that they can determine where they are operating, sense other users of the spectrum, and access the database of other users of the spectrum.  That database has not yet been created, and the FCC has said that it will, by subsequent public notice, solicit private companies to create the database (or databases, as multiple companies may be authorized to maintain competing databases).  The database will list not only full power television stations, but also low power TV stations and TV translators.  And, while in most cases the TVBDs will be required to protect the full-power TV stations only to their protected contour, there will be added protections for stations outside of their protected contours in the path between the TV station and either LPTV or translator stations which pick up these stations off of the air, or cable television system headends which pick up TV station signals.  Thus, the location of cable headends and that of LPTV and TV translators, and the signal paths between them and the stations that they pick up, must all be computed.  In addition, there are Land Mobile radio services that operate in the television band, which will also have to be protected, and entered into the database.  Wireless microphones that operate in the TV band will also be predicted, and sites that regularly use those microphones (e.g. theaters, stadiums, churches) will be eligible for registration in the database.  Even sites that only use those microphones for special events can register for the length of the event.  All of these items will need to be entered into a database that will be accessible by the devices - a project that will obviously take time.

In addition, the devices will not be able to operate in areas near the Canadian and Mexican borders, nor in areas near the "quiet zones" around radio astronomy installations.  The TVBDs will have to be able to determine their locations so, for the most part, they will need outdoor antennas to receive the satellite signals to determine their locations.  Fixed location TVBDs, which can operate at higher power than mobile devices, will also have to register with the FCC so that, if they create interference, they can be located.

With all of these requirements, it will be quite a design feat for engineers to accommodate all of the FCC requirements.  In addition, the FCC will have to complete the regulatory requirements of authorizing the databases.  So don't look for these services to provide broadband access (or any other service) until all of these requirements are met.  And, of course, there still may be legal hurdles to overcome should opponents of the devices appeal the FCC decision.  So stay tuned...
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