Broadcasters, represented by the Association for Maximum Service Television (MSTV) are concerned about interference from MediaFLO and other Part 27 licenses using lower 700 MHz frequencies (TV Channels 52-59). Last month MSTV prepared and submitted proposed engineering methodology for accurately measuring interference from MediaFLO to off-air TV reception. In response to the MSTV submission, Qualcomm said that adopting the new methodology would delay Qualcomm's launch of MediaFLO, as software doesn't exist for implementing the methodology. Last week, MSTV sent a letter to the FCC stating that such software does exist and it is submitting the necessary software to them and Qualcomm.
MSTV is concerned that the OET-69 methodology--as specified by Qualcomm in its request to amend rules to allow its MediaFLO service to create up to two percent new interference to viewers of free, off-air TV service--does not accurately predict interference. OET Bulletin 69, used by the FCC to determine interference between broadcast stations, makes some assumptions to simplify calculations. MSTV is concerned that the OET-69 methodology may not apply to Qualcomm MediaFLO operations, which uses multiple transmitters that aren't necessarily co-located with broadcast stations and are likely to employ antennas with different elevation patterns than those assumed by OET-69.
In the letter, MSTV said Qualcomm has repeatedly refused to make locations of its transmitters public, preventing MSTV or any other party from providing an interference analysis for all affected stations. MSTV said that if Qualcomm made available certain basic information about its proposed service, the FCC could use the software for a reliable estimation of the impact Qualcomm's requested.
"The decision is now in Qualcomm's hands. It can either continue to withhold data and raise spurious procedural arguments against adoption of a reliable interference methodology, or it can allow this proceeding to move forward on the merits," said MSTV.
