I don't see the big issue with this.....  Inline....

Marlon K. Schafer (509) 982-2181 wrote:

From another list a few of the board members are on.

Can someone take a look at this and see if they can come up with a filing? I can help but don't have time to do the whole thing. I can probably also put you in touch with people that can help you with details/understanding of the issues.

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----- Original Message ----- From: "Michael Marcus" To: <    >
Sent: Wednesday, December 21, 2005 8:41 AM
Subject: [TVWHITESPACE] Noteworthy FCC PN and filing deadline

If you check the FCC OET website, there is a
sleeper" there that may have a big impact on the whitespace proceeding:

I don't see this "sleeper".....

Office of Engineering and Techology seeks comment on a Petition for Waiver of Part 74 of the Rules, filed by Nuclear Energy Institute and United Telcom Council.

PN: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-3216A1.pdf
Petition: http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518190717

Just in time for the holidays my former colleagues released this PN, perhaps hoping this group would miss it.

Comment Date: January 17, 2006
Reply Comment Date: January 30, 2006

The PN responds to an 7/20/05 petition from the nuclear power trade association, NEI, and the better known UTC asking for permission to use Part 74 wireless 2 way systems in nuclear power plants. Reading between the lines, one gets the impression that, like many of the wireless mikes, these systems have been used illegally for a while and they are now trying to legalize their de facto use.

They have not been used illegally.. They were granted experimental special temporary authorizations (STA's) similar to the ones the Commission is granting for 3650 MHz..

The petition states on p. 14 (p. 18 of the Acrobat document) "Accordingly, Petitioners contend that, today, there is no viable alternative equipment that would provide the requisite performance features necessary to assist in complying with the NRC’s ALARA mandate." There is no discussion of why readily available Part 90 equipment can not be used for this function.

I disagree....they explicitly state they need handsfree, full duplex communications. There are no portable Part 90 devices that will do that.

Since what they are seeking if hands free wireless connectivity, it would appear that many Part 90 systems would meet their need and that Part 90 licensing should be easy in the needed locations. I suspect the part 74 equipment is being used because it is cheaper or perhaps more readily available.

Well...The Telex stuff is not cheaper that's for sure. And hands free equipment uses VOX (voice activated transmit) technology which has a habit of cutting off the first or several words of a transmission. The Telex system transmits from the time it is turned on. It transmits on one channel and simultaneously receives on the other. Because it is transmitting all the time there is no "dropping' of words.

So why is this important? The FCC has a habit of giving UHF TV spectrum use to special interests without ever looking at the issues in 04-186. 3 years ago there was a sweetheart deal to give Hollywood interests special UHF TV spectrum access. See Section 74.870 if you missed it.

I don't see an issue here with this....

After a few more of such giveaways, there will either be no whitespace or it will be pockmarked with high priority special interests that should have been accomodated in Part 90.

No more whitespace?? I don't think so. How many nuclear power facilities are there in the US? 104??? OK...How many of them are going to be an issue with 50 mw of tx power?? I think its a moot point....

I urge the TVWhitespace community to meet the January 17 filing date and tell the FCC that the petitioner has failed to justify why other alternatives are not available. Alternatively, any access to TV spectrum should be limited to channels 14-20 - already encumbered by public safety sharing.

Well....Two things....

1. I don't agree that they have not justified their reason for the waiver. I also believe that they have justified that there are no other alternatives available.

2. I do agree that it may be a possible requirement to limit them to the present Public Safety hold backs that are presently in place.

You may also wish to point out to FCC how the granting of this petition would complicate 04-186 proposals when there are other alternatives available for the petitioner.

I don't feel this will "muddy the water". Again, the use of 50 mw radios is not going to throw the whitespace project into a tailspin.....Especially at the nuclear power plant on some river in Utah.....

I personally don't think this requires a WISPA reply. In addition, having delt with Jill Lyon in another association...she is probably just going through the motions to pacify everyone...


Best wishes to all for a happy holiday!

Mike Marcus

Bob Moldashel
Lakeland Communications, Inc.
Broadband Deployment Group
1350 Lincoln Avenue
Holbrook, New York 11741 USA
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