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TV White Space Legislation: Proposed Changes and Challenges in Unlicensed Device Operation

This article discusses the TV white space legislation, proposed service changes in the 902-928 MHz band, and expansion of the 5 GHz U-NII band. It highlights the challenges faced in unlicensed device operation and the opposition faced by the broadcast industry. The article also mentions the IEEE 802.22 proposal and proposed service changes at 902-928 MHz.

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TV White Space Legislation: Proposed Changes and Challenges in Unlicensed Device Operation

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  1. National Spectrum Managers AssociationUnlicensed DevicesMay 16, 2006Mitchell Lazarus | 703-812-0440 | lazarus@fhhlaw.com

  2. Topics • TV “white space” legislation • Proposed service changes in the 902-928 MHz band • 5 GHz U-NII band expansion.

  3. TV “White Space” Legislation

  4. Background • Many TV channels in every market are vacant: • co-channel, adjacent channel separations • “UHF taboos” (needed for early receivers) • broadcasting on one UHF channel limits 16 others • Proposal: unlicensed operation on unused TV channels • Need mechanism to protect TV receivers: • unlicensed device can move from place to place • TV channel assignments change over time • TV channels also used for land mobile, wireless microphones, medical telemetry, radio astronomy.

  5. FCC Proceeding • May 2004: NPRM on unlicensed use of vacant channels • fixed: 4 watts EIRP • portable: 0.4 watts EIRP • To protect TV operations, unlicensed device – • looks for “control signal” identifying locally vacant channels, or • uses “detect-and-avoid” (DAA) technology, or • has built-in GPS and channel database • Strong and specific opposition; lukewarm support • Mid-2005: FCC seemed ready to abandon the proposal.

  6. Problems (1): “Control Signal”

  7. Problems (2): DAA in Shadow TV Tower Figure 2: Unlicensed DAA device in shadow can cause interference Unlicensed Device in Shadow TV Receiver Building / Terrain

  8. Problems (3): DAA at Distance Figure 3: Unlicensed transmitter can fail to detect distant signal TV Tower Outdoor TV Antenna Unlicensed Device Misses Weak Signal Great Distance

  9. Problems (4): GPS with Database • GPS works poorly indoors • Problem of keeping millions of databases current as TV channels move and change • Problem of occasional malfunctioning unlicensed device.

  10. Senate Action • February 2006: Senate introduced legislation requiring FCC to allow unlicensed operation in TV bands • Current version of bill* instructs FCC to: • have rules take effect within 270 days of passage • protect licensees from harmful interference • require devices to have FCC certification • require a mechanism for disabling devices remotely • address interference complaints “immediately.” * “Communications, Consumer’s Choice, and Broadband Deployment Act of 2006,” S. 2686, Sec. 602 (May 1, 2006).

  11. Opposition • Broadcast industry vigorously opposes Senate bill • concerned about interference to TV reception • seeks delay at least until end of digital TV transition • Other parties concerned about precedent • Congress created the FCC to make technical decisions • Congress is not well equipped to decide on feasibility of new wireless services • first time in recent memory that Congress would have dictated a specific outcome on a technical issue • message to public: if the FCC does not accept your technical arguments, try Congress instead.

  12. IEEE 802.22 Proposal • Fixed devices only • base station must be professionally installed • programmed for available TV channels • remote can be installed by consumer • but needs enabling signal from base to operate • remote frequencies under control of base station • All devices on network monitor for TV signals • remotes report unexpected TV signal to base station • base station takes remotes off that frequency.

  13. Proposed Service Changesat 902-928 MHz

  14. Present Uses of 902-928 MHz • ISM devices (industrial, scientific, and medical) – unlimited power • Location and Monitoring Service (LMS) – 49 watts • Federal radar – unknown power • Federal fixed and mobile – unknown power (secondary) • Amateur radio – 1,500 watts (secondary) • Unlicensed devices – 0.001-4 watts. • RFID, home security, industrial remote controls, medical devices, home audio and video, more. (Power ratings are not directly comparable.)

  15. Multilateration LMS (M-LMS) • Triangulates from differences in arrival times • Authorized at 904-909.75, 919.75-928 MHz • rules restrict type of service, telephone interconnection • effectively limits numbers of units in use • 1999, 2001: M-LMS licenses auctioned for $4.4 million • 2000: U.S. Gov’t turned off “dither” in GPS • greatly improved accuracy; and prices dropped sharply • M-LMS never constructed • 2002: Progeny asked for “flexibility to offer whatever services the market can support and demand.”

  16. FCC NPRM -- 1 • Drop restriction on type of service • no limitation; allow telephone interconnection, or • add flexibility to location services • Technical proposals: • reduce power to 10 watts EIRP • adopt Part-15-type digital modulation rules • limit number of units operating simultaneously • limit duty cycle

  17. FCC NPRM -- 2 • Eliminate spectrum aggregation limits • Retain current Part 15 protections: • M-LMS licensees must prove lack of interference to Part 15 by field testing. 47 C.F.R. § 90.353(d) • Part 15 devices that meet “safe harbor” conditions are deemed not to cause harmful interference to M-LMS. 47 C.F.R. § 90.361.

  18. Possible Opposition • Part 15 interests • likely concerns: power, density, duty cycle • likely to favor retaining existing protections • Wireless companies may allege unfair competition • LMS auctions: $311 thousand/MHz • PCS auction 58: $17 million/MHz (for partial licenses) • Amateur radio • Federal users (but may have approved NPRM).

  19. Other Proceedings at 902-928 MHz • Amateur spread spectrum, RM-11325 • present rules: • spread spectrum to 100 watts • over 1 watt requires automatic power control • request: drop requirement for automatic power control • Cellnet proposal, ex parte in ET Docket No. 03-201 • full power only for 10% duty cycle or less • power limit drops as duty cycle exceeds 10%.

  20. 5 GHz U-NII Band Expansion

  21. FCC Rulemaking • November 2003: FCC Report and Order (R&O) added 255 MHz to the 5.8 GHz U-NII band • expanded band covers 5.470–5.825 GHz • New requirements across entire band (to protect radars): • dynamic frequency selection (DFS) • transmit power control (TPC) • But compliance test procedure was difficult to specify • implementation dates repeatedly postponed.

  22. 2006 Action • March 30: NTIA filed 47-page compliance test procedure • agreed to by FCC, NTIA, industry panel • April 26: FCC seeks to refresh the record on three requests to clarify original R&O • Comments May 15, replies May 18 • Under current schedule, DFS and TPC rules take effect for: • certification applications filed on or after July 20, 2006 • devices imported or marketed on or after July 20, 2007.

  23. Thank you! Mitchell Lazarus | 703-812-0440 | lazarus@fhhlaw.com

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