Monday, the Association for Maximum Service Television NAB filed Reply Comments
in Wireless Technology Dockets 08-166 and 08-167 regarding low power auxiliary stations (wireless microphones, intercoms, etc.). In the filing, MSTV and NAB asked for a gradual phaseout of wireless microphones operations in the 700 MHz band as an alternative to the FCC's proposed Feb. 17, 2009 deadline.
Under the NAB/MSTV plan, licensed wireless microphone operations in a given 700 MHz band frequency and geographic area must cease upon the earlier of (1) 60 days prior to the date on which the 700 MHz wireless entrant intends to begin service, per a notice sent to the affected wireless microphone licensees, or (2) Feb. 17, 2012.
NAB/MSTV point to Shure's comments that the costs of relocating wireless microphone equipment out of the 700 MHz band range from $50,000 to $250,000. Comments from wireless microphone manufacturers and the Society of Broadcast Engineers point out it is unreasonable to expect all wireless microphone licensees to immediately relocate out of the 700 MHz band after the DTV transition is complete. There is also concern that equipment manufacturers may not be able to meet the unexpected spike in demand for equipment over the next four months.
NAB and MSTV point out that Low-Power TV and TV translator stations are allowed to remain on TV channels above 51 on a secondary basis until notified that the new 700 MHz entrant plans to initiate service.
NAB and MSTV support proposals that would expand eligibility for Part 74 low-power auxiliary licenses to include theaters, live music producers, government bodies, and houses of worship. "Because these new users would be subject to frequency coordination under Part 74 and are unlikely to use wireless microphones in venues where television equipment is located, these entities are unlikely to interfere with full-power television service," NAB and MSTV wrote.
The reply comments respond to comments from Verizon Wireless and V-Comm confusing licensed wireless microphones with white space devices, and disagree with the wireless companies' assertion that all low power auxiliary devices, including licensed wireless microphones, are "nomadic, used intermittently, and difficult to identify and locate." NAB and MSTV say devices typically used in a controlled, professional environment by licensed users "can be located easily in the event of an interference concern."
NAB and MSTV strongly disagreed with the White Space Coalition's assertions that any wireless microphones licensed in the proceeding for theaters, live music producers, government bodies and houses of worship be subordinated to unlicensed devices authorized for operation in the broadcast spectrum. The reply-comments state, "In making this argument, the White Spaces Coalition reveals the intention of white-space proponents to claim, unlawfully, an incumbency interest in this spectrum. Such an interest would turn the Communications Act's longstanding principle that unlicensed devices must 'do no harm' on its head."
All comments in this proceeding are available using the FCC Search for Filed Comments Web page
and entering 08-166 or 08-167 in Box 1 of the search form.