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(February 15, 2007) A white paper was prepared by the Washington, DC legal firm that has worked with PAMA, Shure and other industry leaders. This document presents overview's to Congress and FCC regarding the importance of the pro audio industry and its need for protection when moving ahead on this issue. The reply filing period expires at the end of February. Please review the final page of this paper to find out how you or your company can file comments. Thank you for your support on this issue.

Washington D.C. lawmakers are taking steps that threaten every live event, broadcast, and program content generator.
The U.S. Senate and the Federal Communications Commission are poised to change regulations to allow mass deployment of new unlicensed devices (such as PDAs, cordless phones, wireless laptops, and Wireless Access Points) that will operate on the same channels as professional wireless microphone systems and other audio equipment. These devices risk widespread and devastating radio interference to professional wireless microphone and audio systems rendering these systems virtually useless for delivering the top-shelf audio experience that listening and viewing audiences absolutely demand.

Television, music, theater, movie, sports, and news production stand to suffer significantly. Professional wireless microphone systems and related audio gear, including in-ear monitors, wireless intercoms, wireless video assist devices, (WAVDs) and wireless cueing (IFBs), are extensively used today in the production of content and programming by all of these industries. Virtually all theatrical shows, musical artists and other live entertainers, news reporters, stage and production crews, sports teams -- and of course, the listening and viewing public -- count on absolutely clear, real-time audio transmissions. Such interference will cause a major disruption to the audio channel thereby severely degrading the overall quality of American programming content. This is completely unacceptable for high-quality, real-time programming.

Some policymakers believe that vacant radio spectrum exists between the TV channels and that these “White Spaces” should be put to use for new devices that could promote broadband services, especially in rural areas. They believe that any potential interference to existing users can be handled by “smart radios” that will know to stay away from occupied channels.

But these channels are not vacant at all! Professional wireless microphone and related audio systems operate on these channels pursuant to FCC rules. And, the “smart radio” technology that is supposed to prevent interference has yet to be proven effective. If Congress and the FCC are not careful, mass deployment of new devices on these channels will wreak havoc with audio systems that serve the entire entertainment, theater, sports and news industries.

What has happened?

In the U.S. Senate: Senator Sununu (R-NH) and Senator Kerry (D-MA) have each introduced bills that would allow new fixed and personal/portable devices to operate on the same frequencies currently used by wireless microphones in as soon as 90 days. These new devices stand to cause devastating interference to wireless microphones unless meaningful interference protection is required and proven. While each bill requires the new devices to protect television stations from interference, wireless microphones receive no interference protection. Even if wireless microphones were covered, there is not enough time to develop and test meaningful interference protection given the aggressive timeline these bills establish for deployment of new devices.

At the FCC: Under pressure from Congress and manufacturers eager to sell new retail gadgetry, the FCC is now moving forward to authorize new TV band devices to operate in the unused TV broadcast, also known as the ”White Spaces.”   They are under the belief that the White Spaces are generally not used by other commercial devices such as wireless audio gear and, where other equipment is operating, “smart radios” will solve the problem. The FCC says that new devices may begin operation by February, 2009, under technical rules to be developed that protect existing services from interference. Although the FCC says that it wants to protect the services that currently rely on these frequencies, like wireless microphone and other audio products, the technology has not yet been proven (and may not yet exist) that would allow new devices to operate without causing devastating interference to wireless microphone systems.

What can be done?

The FCC is in the process of developing the technical and operational rules that will regulate the use of new wireless devices allowed to operate in “White Spaces.” The FCC is striving to balance the need to protect existing services, including wireless microphones, against its commitment to open the spectrum to new devices and uses. But, the technical engineering issues are complex and take time to resolve.

Several parties, including the Grand Ole Opry, Guitar Center, the Recording Academy and others, that rely on wireless microphones have urged the Commission to proceed cautiously. Specifically, the FCC should only permit new TV band devices to be used in stationary systems that audio engineers can identify and avoid in the frequency coordination and planning process that goes on for many events that rely on wireless microphones . The group has urged the FCC to adopt specific technical and operational rules that could prevent interference and to require the new device manufacturers to demonstrate through laboratory and field testing that new devices will not harm wireless microphone and audio systems.

The FCC and U.S. legislators need to be educated on the importance of professional audio systems to our industries and the need for protection. It is critical that your voice is heard by the FCC and on Capitol Hill.

FCC Electronic Comment Filing Instructions

Comments regarding the negative impact that proposed unlicensed devices will have on wireless microphones already operating in the TV broadcast band must be filed with the Federal Communications Commission ("FCC") through the Electronic Comment Filing System ("ECFS"). ECFS can be accessed at http://www.fcc.gov/cgb/ecfs/.

Step 1: Convert your comments into an Adobe PDF or MSWord document and save the document on your local drive.

Step 2: Access the ECFS website at http://www.fcc.gov/cgb/ecfs/ (please note that the website is optimized for Internet Explorer).

Step 3: On the right side of your browser's screen you should see several menus. The top menu is titled "ECFS Main Links." The second hyperlink under the "ECFS Main Links Menu" is titled "Submit a Filing." Please click on this hyperlink.

Step 4: You should now see a webpage titled "Electronic Comment File Submission." This webpage contains tables that run down the center of the screen.

The first table is titled "Cover Sheet," and requires basic biographical information. *** In the "Cover Sheet" table under Item 1 "Proceeding" you must input the number 04-186. Your comments will not be entered properly if the number "04-186" is not input in the first field. Please proceed to input the remainder of your organization's biographical information in the required fields within this table.
The second table is titled "Send Comment Files to FCC (Attachments)." This table enables you to upload your MSWord or PDF comments to the FCC. Within the table select the "browse" button to scan your local drive for your comments, and then identify what type of file you are uploading. When you have completed these two steps, hit the "Send Attached File to FCC" button immediately below the table.
-Ignore the third table

Step 5: You should now see a confirmation page asking if you want to complete the process. Please confirm that you want to upload your comments to the FCC. A final webpage that contains a confirmation number will now appear.