The FCC recently revised its TV “white spaces” rules to facilitate the use of unlicensed communications devices on spectrum originally allocated exclusively for broadcast television.  Although there is still a long way to go before new unlicensed devices are deployed in this spectrum, the recent revision of the rules has triggered an important deadline.  As detailed in our client advisory issued today and available here, cable headends, TV translators, low power television stations, and other Multichannel Video Programming Distributor (MVPD) receive sites that are located outside a broadcast station’s standard protection zone have until April 5, 2011, to file a waiver request seeking interference protection.

Practically speaking, the vast majority of cable headends, TV translators, and MVPD receive sites that rely on the reception of an over-the-air broadcast signal are located well within the broadcast station’s standard protection zone. Thus, the April 5th deadline applies only to those unique cases in which an existing over-the-air receive site is located more than 80 kilometers (49.7 kilometers) beyond the edge of the broadcast station’s protected contour.

As the filing deadline is less than a month away, we encourage potentially affected parties to promptly review their operations. Television broadcasters, who may not themselves operate a facility eligible for a waiver, should consider if there are cable headends, TV translators, or other MVPD receive sites far beyond their contour that might benefit from a waiver request.  In such cases, the broadcaster should coordinate with the operators of those facilities to ensure a timely submission. 

See today’s advisory for further details on this upcoming deadline, as well as our earlier postings here and here for more information about the white spaces rules and the forthcoming white spaces database.