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PAMA "White
Spaces" Filing
(February 23, 2007) The Professional Audio Manufacturers Alliance(PAMA), acting
on behalf of its members, the leading manufacturers of pro audio gear and microphone
products, has filed an detailed comments document to the FCC on the "White Spaces" Docket
04-186.DOC.
Our organization believes strongly that the FCC must be allowed the time to fully
test and then implement a policy that restricts harmful interference from consumer
devices without disrupting the public and broadcast events that today's wireless
products serve. The public interest must be served by both sides of this white
spaces issue. Our members companies are leaders in technology and encourage the
US and its legislators to move forward in exploring new broadband technologies.
However, on this wireless issue, we feel the FCC must thoroughly and then take
the lead in making recommendations that will result in better utilization of
the bandwidth while protecting the airspace currently utilized by the wireless
community served by professional wireless audio manufacturers.
Before
the FEDERAL COMMUNICATIONS COMMISSION
Washington
D.C. 20554
ET
Docket No. 04-186
In the Matter of Unlicensed Operation in
the TV Broadcast Bands
ET Docket No. 02-380
Additional Spectrum for Unlicensed Devices
Below 900 MHz and in the 3 GHz Band Innovation Test-Bed
COMMENTS
OF THE PROFESSIONAL AUDIO
MANUFACTURERS ALLIANCE
The Professional Audio Manufacturers Alliance, or PAMA, was founded
in March 2003 to be the voice and advocate for a unified professional
audio industry. PAMA strives to promote the growth and well-being
of our members in the professional audio industry, which include
six of the leading wireless microphone and professional wireless
audio manufacturers, representing collectively over 80 percent
of the U.S. market.
1.
Introduction
PAMA's members are profoundly concerned about the
issues raised for wireless microphones regarding proposed introduction
of unlicensed devices ("UDs") in the heavily used TV broadcast
bands ("TV bands")
pursuant to the Further Notice of Proposed Rulemaking ("FNPRM")
released by the Commission on October 18, 2006. The many professional
wireless microphones that already operate in the TV bands are
a ubiquitous and irreplaceable tool for the entertainment and
broadcast/production industries that stand to be rendered unusable
by a rushed introduction of UDs. Because professional wireless
microphones are so reliable and transparent, it has become easy
to overlook the fact that contemporary televised sporting events,
live musical performances, Broadway theater productions, news
programming, religious services, and many other sources of media
content that define American culture cannot be enjoyed by the
public on a large scale without them. Therefore, it is of the
utmost importance that the rules being drafted now by the Commission
provide the express protection that wireless microphones require
to continue functioning without interference before new devices
are allowed in the TV bands. Although the FNPRM has stated that
it will protect "other incumbent[s]" in
the TV bands, it does not provide sufficient assurance that there
will be full protection for wireless microphones from the potential
interference created by unlicensed devices. The Commission must
act now to adopt explicit interference mitigation solutions specifically
designed to protect important wireless microphone operations.
At a minimum, PAMA implores the Commission to set aside spectrum
where wireless microphones will be able to operate free from
UDs, to create a mechanism that will guarantee the availability
of the spectrum needed for crucial wireless microphone operations
at live events such as the Super Bowl or Grammys where literally
hundreds of microphone channels are needed, and to establish
meaningful rules that require UD manufacturers to demonstrate
that spectrum sensing works properly and is more than smoke and
mirrors. Finally, the Commission should defer consideration of
the complex interference issues raised by personal/portable devices
until after positive experience is gained with fixed devices.
2.
Wireless Microphones Serve an Important Public Function to Disseminate
News, Entertainment, Sports, Religious, Educational and Political
Content to the Public
In recent decades wireless microphones
have proliferated throughout the broader entertainment and broadcast/production
industries and are an integral component to bring various events
central to the American culture to the American public. Sporting
events rely on wireless microphones for internal team communications
as well as sideline and courtside reporting. Broadcast programming
and film and video productions make extensive use of wireless
microphones for capturing dialog during outdoor scenes where
boom microphones are impractical, and for audience and ambience
mixing. Television and radio news broadcasters use wireless microphones
for field reporting and news gathering. In addition, wireless
microphones are heavily used at all large venues where presenters
or performers require the ability to move while simultaneously
projecting their voices, including Broadway theater performances,
theme parks, political conventions, religious services, school
events and business conferences. Regardless of whether the ultimate
transmission medium to the recipient of the content is a live
amplified voice, cable facility, over-the-air radio or television
broadcast, or communications satellite, it is increasingly more
likely that the content was created initially with a wireless
microphone. Wireless microphones have in fact become so ubiquitous,
and the entertainment and information industries now rely so
thoroughly on them, that it would be virtually impossible to
return to wired microphones. The prospect of hardwiring the various
professional users noted above has become completely impractical
and would likely prove difficult at best. Forcing the current
class of professional users to rely on wired microphones would
hamper news teams, make sideline or courtside reporting difficult
or impossible, and would greatly diminish the audio quality of
theatrical performances, movies, and religious services. In particular,
live performers that have designed stages and theatrical sets
around wireless microphones would suffer greatly if forced to
revert to wired microphones. Certain live performances that incorporate
acrobatics and place a high priority on mobility might simply
be forced to stop production altogether. There is simply no turning
back the clock and reintegrating wired microphones without inflicting
significant harm on the entertainment, sports and information
industries and the viewing public.
3.
The Commission Does Not Adequately Protect Wireless Microphones
Acknowledging
that incumbents beyond the digital television broadcasters
need protection falls far short of the measures that the Commission
must take to guarantee that wireless microphones continue to
work with the high levels of reliability the entertainment,
sports and information industries and the U.S. public has come
to expect. Wireless microphones are precision instruments with
unique transmission characteristics. Moreover, their transmission
characteristics are dramatically different than other incumbents
in the TV broadcast bands. "Cookie-cutter" rules
will not adequately protect wireless microphones, if they offer
any protection at all. Wireless microphones require express protection
in the FCC Rules with specialized interference mitigation requirements
thoughtfully designed to preserve wireless microphone functionality.
Wireless
microphones have unique transmission characteristics that share
virtually no common traits with the other incumbents in the
TV bands. Wireless microphones are low powered, and typically
transmit with 50 mW of power or less over 200 KHz of allocated
bandwidth. Much of this power is then absorbed into the body
of the microphone user. Further, wireless microphones operate
intermittently, and their light and intermittent radio-frequency
signature will be a challenge for third parties to detect and
avoid. In stark contrast, a digital television station will generally
radiate a constant transmission using thousands or millions of
watts from a large elevated antenna. Due to this enormous discrepancy
in the characteristics of the incumbent services that occupy
the TV bands, a "cookie-cutter" approach for drafting protection
rules will fail to offer wireless microphones the protection
they need. Wireless microphones require particularized interference
solutions to protect their important operations.
PAMA would
like to emphasize that despite the low-powered nature of wireless
microphone transmissions, microphone failures during live performances
are rare in today's
operating environment. This extremely high level of reliability
is due to the painstaking efforts taken to coordinate frequencies
every time multiple wireless microphones are used in a professional
production. At large events, frequency coordinators may begin
the process of clearing channels for individual microphones weeks
in advance of a production. In metropolitan areas, coordinators
typically have intimate knowledge of the exact frequencies where
broadcasters, theatrical productions, news organizations and
other entities have assigned their microphones channels.
This
delicate balance that allows low-powered wireless microphones
to operate with extremely high levels of reliability will be
turned upside down in a world where UDs flood the TV broadcast
bands en masse. If the Commission does not take proactive measures
to protect wireless microphones, thousands of frequency-hopping
UDs could inadvertently threaten mass media as we know it today.
A UD that jumps onto an occupied frequency could disrupt the
national anthem at a major sporting event, the audio at a major
Broadway production, or shut down production on a major motion
picture. The severity of the problem will be significantly increased
due to the inability to coordinate with an anonymous device whose
ability to hop from frequency to frequency is uncontrollable.
The harmful effects from this type of disruption will be widespread
throughout the entertainment and information industries, and
very apparent to the viewing audience. When audio disruptions
occur, even if the problem only lasts for a brief moment, it
is engrained on the audience. Widespread interference to wireless
microphones from UDs would be debilitating for all the industries
that rely on them and would obviously not be in the best interest
of the American public.
4.
Wireless Microphones Require Multiple Interference Protections
to Preserve Their Functionality
In order to fully protect wireless
microphones and ensure that UDs will not render an effective
and highly reliable communications tool completely unusable,
the Commission must incorporate targeted wireless microphone
interference protections into its proposed rules. PAMA emphasizes
that all of the protections set forth below are necessary to
protect the wide range of wireless microphone applications.
Specifically, the Commission must set aside spectrum where
wireless microphones can operate free from UDs, create a mechanism
that will guarantee the short-term availability of the spectrum
needed for wireless microphone operations at live events such
as the Super Bowl, require UD manufacturers to prove conclusively
that spectrum sensing works effectively in real world conditions
when UDs are present, and defer analysis of personal/portable
UDs until it can be shown that introducing fixed UDs to the
marketplace did not harm incumbent services. Without these
steps, UDs will cause harmful interfere to wireless microphones
and disrupt the multitude of productions that rely on their
function.
Wireless microphones need clean spectrum free from
UDs within the larger TV band to ensure that important wireless
microphone productions will be free from interference. Live news
coverage, broadcast television production, and movie production
are a few of the many important applications that are vulnerable
to interference from UDs. One reliable way to ensure protection
from UDs is to designate certain channels in each geographic
area to be a safe haven for wireless microphone operation. Large-scale
productions, however, will require a separate interference solution.
The Super Bowl, the Grammy Awards, major political conventions,
and other nationally televised events regularly utilize hundreds
of microphone channels. Reserve spectrum by itself will not accommodate
such events. PAMA urges the Commission to explore options for
creating a protective zone around such events where UD transmissions
would yield to wireless microphone transmissions. The beacon
system under consideration by the Commission is one option for
such a zone.
Many UD proponents have held out spectrum sensing as
a one-stop-shop for interference mitigation. While PAMA is optimistic
that at some future date this technology will be one individual
element of an interference protection plan for TV band incumbents,
it is unreasonable to assert that this technology is by any means
a complete solution that is currently ready for "prime time." In
the 5.8 GHz band where spectrum sensing tools have been deployed,
there are only a handful of extremely high-powered and fixed
incumbents. There is no comparison with the TV bands where many
different incumbents with varied technical characteristics operate,
many of which are mobile, itinerant and low powered. Further,
no proponent of the technology has shown a working model designed
to operate in the TV bands. To date, there is no evidence that
any manufacturer has even started to build a prototype of a spectrum
sensing device for the TV bands. This is an ominous sign, and
a strong indicator that the technology is not ripe for this application.
Before any UD is certified for the TV bands the manufacturers
must demonstrate through comprehensive laboratory and field testing
that this technology works to protect wireless microphones from
interference.
5.
The Commission Should Address UDs One Step at a Time
The Commission
should also concentrate its efforts on defining interference
protection rules related to fixed UDs. It is premature for
the Commission to split its focus and consider the more difficult
case of personal/portable UD operation while it is grappling
with the simpler, but still complex, interference issues raised
by fixed UDs. Industry through IEEE has devoted over two (2)
years to analysis of fixed UDs, but has not yet begun consideration
of personal/portable devices. Only after the Commission gains
experience with fixed UDs and develops a track record of successful
interference mitigation with the varied incumbents of the TV
band would it be appropriate to proceed to the more difficult
case of personal/portable UDs.
6.
Conclusion
PAMA commends the Commission for its laudable goals
in this proceeding to promote broadband deployment. However,
achieving these goals must not come at the expense of wireless
microphones that serve the informational and entertainment
needs of millions of Americans each day. Wireless microphones
are so reliable and transparent, it may not be apparent that
contemporary televised sporting events, live musical performances,
Broadway theater productions, news programming, religious services,
and many other sources of media content core to American culture
cannot be enjoyed by the public without them. If wireless microphones
are not fully protected, a multitude of productions, both large
and small, will be adversely affected and the American public
will be substantially harmed. Before new UDs are permitted
to operate in the TV bands, it is critical that the Commission
provide express measures designed and proven to protect wireless
microphones so they will continue functioning reliably and
without interference. These measures include designating channels
where wireless microphones can operate without risk of interference
from unlicensed devices, developing a solution for large events,
testing spectrum-sensing technology comprehensively in the
laboratory and the field to ensure it effectively protects
wireless microphones, and deferring consideration of personal/portable
devices until sufficient positive experience is gained with
fixed devices.
Respectfully
submitted,
Paul Gallo
Executive Director
Professional Audio Manufacturers Alliance
260 Fifth Avenue, Suite
600
New York, NY 10001
Dated: January 31, 2007
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