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License Dolly Parton
by Paul McGoldrick
As I write this the Federal Elections will be underway in exactly a week, choosing a new President for the US. There is another vote planned for the same day...not as important for the world, perhaps, but extremely important to US connectivity. On November 4, 2008, the FCC will meet to vote on the future of so-called White Space, the parts of the RF spectrum that are empty of TV broadcasting – spaces that will dramatically increase on February 17, 2009 when 1754 full-power TV transmitting stations shut down their analog services and free the power grid from a lot of mostly-wasted energy use.
For a couple of years the FCC has been testing wireless devices to use on these white space channels, mostly satisfactorily. Not everyone agrees with the opening of these channels for commercial license-free wireless use, and that includes Dolly Parton. Some 28 congressional representatives wrote a bipartisan letter to the Commissioners urging them to delay a vote because some equipment tests in the summer of 2008 showed that there were failures to determine whether a channel was actually free of TV broadcasting.
The members of Congress cited interference with cable TV systems, and both they and Dolly Parton submitted that the devices would interfere with wireless microphones.
Some of the cable installations in the US are so badly constructed that they may well be interfered with. In the coastal town in Oregon where I lived, signals from the cable system could be picked up with only a simple antenna, probably from all the splices made in the cable! (They are, of course, therefore, broadcasting illegally.) So, it is extremely possible that nearby RF signals could indeed interfere with the cable service. But that interference should be cable systems’ problems not a problem for a legitimate user of spectrum.
On the issue of interference with wireless microphones most people seem to be unaware that a license is required for each device. 47 CFR (Code of Federal Regulations) Part 74 Section 1232 lays out, very clearly, the requirements. In a very intimidating manner the form that used to be required for applying for a license (Form 313) was only available from FCC field offices and the completed form together with the $25 application fee (for any number of devices to be licensed) had to be returned to Washington.
(The FCC recently upgraded its web facilities and you can now apply for all licenses online in a very efficient manner. Form 313 has now become Form 601 and the filing fee has increased to $170 per device. Go here and click on “All Wireless Forms.” Do note that if you are doing a lot of filing, the FCC cannot accept credit cards from you for more than $99,999.99 in any one day…)
In the majority of cases the applications went totally and mysteriously unanswered and those that were considered were rejected. A pattern emerged, users found, that a license would be issued if the material being produced with the microphones was going to be distributed in some way: religious, educational, material for later broadcasting, etc. Otherwise, the FCC was basically saying, use a microphone with a cable attached to it. (If you are actually a licensed broadcaster, then Part H of the rules allows you to use the devices license-free.)
Most users of wireless microphones, even if they know the rules, don’t want to go through the hassles and do not have licenses and are breaking the law. (Senators McCain, Obama, Biden, and Governor Palin, could we see your licenses, please? Dolly, how about yours?) In my opinion, if a user of a licensable piece of RF equipment doesn’t have a license, then they have no right to complain about interference: absolutely none.
There is considerable pressure on the FCC to take action right away and go ahead with the vote on White Space. Not surprisingly, that pressure comes from the likes of Motorola, Dell, Google, Intel, IBM, and HP.
I have no problem with developments going ahead with wireless systems on the White Space channels, as long as the developers are required to fork out some spectrum money for their systems – which isn’t going to happen with the present make-up of the FCC, which is why the vote is being taken before January 20, 2009, when, almost certainly, the Commissioners, and certainly the Chairman, will change.
But there is a technical problem to all of this that nobody seems to take (or want to take) into account. Although February 17, 2009 is an absolute switch-off date for analog service for the nation’s 1754 high-power TV transmitters, it is not for an awfully large number of other spectrum users: about 2200 low-power TV stations, 560+ Class A stations, and more than 4700 TV repeaters. These all tend to serve minority, depressed, racially identifiable, underdog communities. Here we go again - another slap in the face from government for those that really need assistance and hope. “Hello, I’m from the FCC and I don’t want to help you.”
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