FCC Grants Adjacent-Channel Waiver for Meld White Space Device

WASHINGTON — The Federal Communications Commission has granted a waiver of the restriction on adjacent-channel operation for a fixed white space devices manufactured by Meld Technologies. The Meld devices are intended primarily for streaming TV to displays in retail stores.

“We find that granting this waiver would serve the public interest by increasing the potential opportunities for innovative use of the TV white spaces while satisfying the rules’ underlying purpose of providing protection for incumbent operations,” the Order stated.

Commission rules outline two types of white space devices for unlicensed operation in the TV spectrum—fixed and mobile (or portable). Mobile devices have to ping a database to locate unoccupied frequencies within their area of operation. Fixed devices can either ping a database or have their geographic coordinates determined and programmed by a professional installer. They are permitted to operate with up to 1 watt transmitter output power and may use an antenna that provides up to 6 dBi of gain, which yields a maximum of 4 watts EIRP.5

Fixed TVBDs may operate on Chs. 2-51 (except 3, 4 and 37). Only fixed devices may operate below Ch. 21 and only personal, portable devices with a power level of 40 mW or less may operate within the service contour of adjacent channel TV stations.

MeldTech has a fixed device approved to operate with a maximum transmitter power level of 14 mW and a maximum antenna gain of 2 dBi, which produces an EIRP of 22 mW. The device does not incorporate a geo-location capability and therefore requires professional installation. Spectrum Bridge, one of the database administrators, filed a request on behalf of MeldTech asking that the commission waive the restriction on adjacent-channel operation for devices to be manufactured and installed by MeldTech.

Specifically, Spectrum Bridge asked that the commission allow the MeldTech fixed device to be treated as a professionally installed personal, portable device so it can operate on channels available at the 40 mW power level. It states that the device otherwise meets the rules for personal, portable operation as it operates only on Chs. 21 and above with a power level not to exceed 40 mW EIRP.

The device would stream video content to digital television receivers in commercial locations such as big-box stores and would not be sold to consumers. The device would contact the Spectrum Bridge database at least once every 30 minutes to confirm that the channels assigned by the database continued to be available.

Spectrum Bridge said that because the device would be used indoors, adding GPS to the device would not provide a practical or reliable way to determine its location. Spectrum Bridge requests a waiver for a period of one year to permit the marketing, manufacture and installation of the subject equipment while other, more reliable geo-location solutions are developed for the environments in which the device is intended to operate.

The FCC Office of Engineering and Technology released a Public Notice on March 25, 2013 seeking comment on the waiver request. Six parties replied. Engineers for the Integrity of Broadcast Auxiliary Services Spectrum opposed the waiver, arguing that it was inappropriate for Spectrum Bridge to file the request since it’s responsible for ensuring that devices operate in accordance with commission rules, and because there is no evidence that Spectrum Bridge has authority to act on behalf of MeldTech.

EIBASS further argued that the MeldTech devices would cause adjacent-channel interference to mobile DTV receivers within the same building, that the waiver request does not indicate that operation would be limited to big-box stores, and that users may be able to enter incorrect coordinates to get the device to function at locations where operation is prohibited.

The National Association of Broadcasters supported the grant of the waiver with conditions: 1) devices must be professionally installed on a fixed mounted rack, only used within a commercial or business establishment, and not be offered for sale to the general public, 2) devices must be limited to a maximum of 40 mW EIRP, 3) devices must be required to contact the Spectrum Bridge database at least once every 30 minutes, and 4) the waiver is limited to one year.

Shure opposed the waiver, but asked the commission to impose even more conditions than the NAB requested should it grant the waiver: 1) MeldTech and Spectrum Bridge each be required to specify the name of the designated person with 24-hour contact information and make this information publicly available and include it on the devices, 2) MeldTech be required to specify the measures it will adopt to prevent sales to the general public, 3) MeldTech and Spectrum Bridge be required to implement a process to monitor the distribution, placement and operation of the devices and maintain a public record of that information, 4) MeldTech devices be required to be installed in such a way that the power supply can be easily disconnected by third parties since there is no power switch, 5) MeldTech and Spectrum Bridge be required to advise the FCC of any incidences of interference, 6) MeldTech devices not be allowed to operate after the expiration of a 12-month waiver and must be recovered by MeldTech for modification or replacement with compliant devices, 7) MeldTech devices be required to be labeled with a statement that operation is prohibited after a certain date, and 8) the manufacture and sale of any new noncompliant devices be prohibited after the expiration of the waiver.

The commission granted the waiver with the NAB’s, but not Shure’s, conditions.

“We decline to add additional conditions to the grant of the waiver as requested by Shure, because we believe conditions beyond those we imposing are not necessary,” the Order stated. “We are requiring the MeldTech devices to be professionally installed with the geographic coordinates set by the installer and not changeable by the user, limiting their use to within commercial or business establishments, and not permitting sales to the general public. We believe that these conditions address many of Shure’s concerns. In any event, we believe that there is a low probability the MeldTech devices will cause interference to wireless microphones because they will operate at low power levels and be used in indoor commercial locations such as big box stores where they are unlikely to be in close proximity to wireless microphones.”