Comments In TV white spaces NPRM Flow To Washington

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The NAB is the latest group to file comments with the FCC regarding a Notice of Proposed Rulemaking about television “white spaces” devices.


The comments from the nation’s biggest voice in Washington for broadcast media asks the Commission to protect licensees first and foremost above unlicensed operations, to accept Microsoft‘s coordination proposal rather than seeking to streamline this proposal, and to not consider higher power operations on first-adjacent channels to broadcaster operations at this time.

“NAB generally supports the majority of the proposals set forth in the NPRM,” top NAB attorney Rick Kaplan notes in a nine-page submission to the Commission.

He notes how the NAB and Microsoft worked together “over many months to negotiate a set of adjustments to the Commission’s existing rules that would enable meaningful improvements for TVWS devices while protecting television reception from harmful interference.”

Kaplan also took the opportunity to stress that the NAB “strongly discourages the Commission from unraveling this compromise or introducing novel interpretations of its
longstanding rules that will jeopardize existing and future television service.”

The NAB focuses its comments on three important points.

  • The Commission should not, and legally cannot, seek to rewrite Part 15 of its rules under the guise of balancing policy considerations.
  • The Commission should abandon its proposal to substitute its own judgment for Microsoft’s with respect to a reasonable coordination process for TVWS operations with
    heights above average terrain (HAAT) exceeding 250 meters.
  • The Commission should not allow higher power operations on first-adjacent channels to TV operations

“There has not been a single development in white spaces deployments or technology that would warrant revisiting the relevant rules at this time,” Kaplan says.

The NAB’s letter to the FCC can be read in full here.

The filing came following that from Connect Americans Now, a coalition of more than 270 members that says it has been “a leading advocate for an NPRM to clear outstanding regulatory hurdles to TV white space technology.”

It supports the TV white space rules, as they will “unleash the full potential of the technology to help bridge the digital divide.”

The FCC on February 28 unanimously adopted a Notice of Proposed Rulemaking (NPRM) on TV white space to address five issues that will expand the pace, scale and cost-effectiveness of hybrid-network broadband deployments in rural areas.