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Rick Harnish


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From: FCC NPRM for UHF TV Band Unlicensed Use [mailto:[EMAIL PROTECTED] On Behalf Of Michael Calabrese
Sent: Wednesday, November 02, 2005 5:09 PM
Subject: [TVWHITESPACE] FW: Broadcast to Broadband: Prominent Engineers Dismiss TV Industry Interference Claims in New Paper


Experts Refute TV Industry Claims on DTV Reception Issue

Three Prominent Engineers State that Opening Vacant Channels for Wireless Broadband Will Not Interfere with Television Reception


Last week, on a bipartisan basis, the House Commerce Committee approved an amendment to its digital TV transition bill directing the FCC to complete its proposed rulemaking to open up vacant, unused channels in the TV band spectrum (also known as “white space”) for unlicensed wireless broadband use (Docket 04-186).  


Last year, the FCC issued a proposed rulemaking to allow “smart” wireless broadband devices to utilize empty TV channels between Chs. 2 and 51 on a market-by-market basis.  Opening wasted TV spectrum for broadband in each market will especially benefit rural areas.  Unfortunately, this proceeding has stalled at the Commission under Chairman Kevin Martin. The broadcast industry opposes the House amendment and the FCC’s proceeding, claiming that unlicensed devices operating in vacant TV channels could cause harmful interference to TV signals on nearby channels.


New America's Issue Brief -- authored by three of the nation's most respected spectrum engineers -- demonstrates why the industry’s technical claims are unfounded. “Reclaiming the Vast Wasteland: Why Unlicensed Use of the White Space in the TV Bands Will Not Cause Interference to DTV Viewers,” explains why the interference-avoidance mechanisms proposed by the FCC are sufficient to ensure that DTV  reception is not harmed by unlicensed devices.  The co-authors are: 

  • Michael Marcus, former FCC Associate Chief for Technology, Office of Engineering and Technology
  • Paul Kolodzy, former Chair, FCC Spectrum Policy Task Force
  • Andrew Lippman, founding Associate Director, MIT Media Lab  


- For a more detailed version of the paper’s argument, refer to the Technical Reply Comments of the New America Foundation, et al. in the above-referenced proceeding.


- For more background on the broadcast industry’s spurious claims regarding interference, refer to New America Foundation’s fact sheet 


- For a brief explanation of why utilizing vacant TV channels for broadband is important and feasible, see the statement by former FCC Chief Engineer Edmond Thomas from New America’s September 7th Capitol Hill Briefing. 



Thanks for your interest. 


Michael Calabrese

Director, Wireless Future Program

New America Foundation






Cover Story

Unlicensed wireless advocates after TV white space

By Heather Forsgren Weaver

Oct 28, 2005

WASHINGTON-Advocates of unlicensed spectrum are trying to get their hands on TV airwaves they believe will be available in channels 2-51 following the transition to digital TV.

After the digital conversion there will be unused spectrum in many areas, so advocates for unlicensed spectrum are calling for this white space.

"The TV band has been called a `vast wasteland' of underutilized spectrum. Even after the completion of the DTV transition-and reallocation of TV channels 52-69-an average of only seven full-power DTV stations will be operating on channels 2-51 in the nation's 210 local TV markets. Only a fraction of the 294 megahertz of prime spectrum allocated to DTV services will actually be utilized in most markets," said three prominent engineers in a recent policy paper released by the New America Foundation. "The proposed use of white space TV channels could have a particularly great impact on the growth of information services in rural areas, where such empty channels are readily available. In urban areas, where less `white space' is available, this spectrum would also be useful because the great demand for wireless broadband services and because of the ability of the TV band spectrum to penetrate buildings and objects within buildings better than the higher bands."

TV broadcasters are opposed to this idea, fearing interference, and have been fighting it at the Federal Communications Commission since former FCC Chairman Michael Powell first proposed it.

Since FCC Chairman Kevin Martin assumed his post, the TV White Space proceeding has been dormant-but no more. As part of the House Commerce Committee's consideration of the DTV Transition Act of 2005, language was included directing the FCC to complete its consideration of the TV White Space rules within one year.

Score one for the unlicensed wireless advocates.

"The broadcasters are trying to shut this down either on Capitol Hill with a clause in the bill prohibiting the FCC from acting or by convincing Chairman Martin to let the unlicensed white space proceeding sit on his desk," said Jim Snider, senior research fellow of New America Foundation's Wireless Futures Program, before the House Commerce Committee vote.

The idea advocated by Snider and others is that Wi-Fi devices could be manufactured to detect whether a TV station is using a channel-if it is, the Wi-Fi device can't use the spectrum, but if there isn't a TV station assigned to a channel, it could use that spectrum.

"No local TV stations or other broadcast licensees operate on these frequencies-and broadcasters have no more legal right to use them than a homeowner who occupies a lot next to an adjacent publicly owned lot. The homeowner may covet the lot and believe that development on it will diminish the value of his own lot. But he cannot prevent the government from allowing others to build on it," said Snider.

Going after use of the white space is the consolation prize after it became obvious that all of the spectrum being made available with the DTV transition would be auctioned. The New America Foundation had urged as recently as July that one-third of the spectrum being made available should be allocated to unlicensed uses.

Congress has not specifically decided what to do with 48 megahertz of unallocated spectrum that will be available once broadcasters return the channels to government. Congress already dictated that 24 megahertz be given to public safety and 36 megahertz auctioned to commercial services. Both the House and Senate Commerce Committees have passed bills assuming all of the spectrum, minus the 24 megahertz for public safety, will be auctioned.

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