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MSTV letter raises red flag over unlicensed devices, interference

The Association for Maximum Service Television (MSTV) sent a letter to Senators Ted Stevens (R-AK) and Daniel Inouye (R-HI) June 21 alerting the pair to “unintended consequences” of a portion of the Communications, Consumer’s Choice, and Broadband Deployment Act of 2006 that will create “significant interference to digital television receivers.”

The letter from MSTV president and CEO David Donovan to the Senate Commerce, Science and Transportation committee chairman and co-chairman points to Title VI of the act, which is intended to bring wireless broadband service to underserved rural areas, as the culprit. According to the letter, the bill as drafted would allow “any type of unlicensed use” and in “many instances… are likely to significantly increase interference with television receivers.”

The letter identifies unlicensed devices in the core TV band, channels two through 51, and whether the legislation “effectively prevents” interference from occurring. As drafted, the legislation will not, the letter said.

According to Donovan, the legislation relies on a “far from perfect” process of FCC certification to prevent devices from causing interference. “In point of fact,” the letter said, “the FCC itself approves less than 10% of all equipment, with the vast amount of equipment approved by industry laboratories.” The legislation does not require testing by independent labs.

The letter identified several major problems with the legislation as drafted, including:

  • Consumers are not allowed to file interference complaints; only “licensees” may do so.
  • All complaints must be verified in the field, which will put the burden on licensees (i.e. TV stations) to track down the source of interference from unlicensed devices in the field.
  • There is no ID code requirement to identify offending unlicensed devices.
  • Remote shut off is not required on all unlicensed devices.
  • There is no provision to preclude unlicensed devices from operating on the first adjacent channel to a TV channel.

The legislation as it stands jeopardizes billions of dollars invested in the DTV transition on the part of broadcasters and the viewing public, the letter said. “Significant, additional real world testing is required before unlicensed operations should be authorized to enter the TV band,” it said.

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