FCC 'WHITE SPACE' REPORT REVEALS
CURIOUS DISCREPANCIES

-- NAB calls for public comment period on report --

WASHINGTON, DC -- NAB today questioned whether support for 'white space' devices is contradicted by key findings in a report from the FCC's Office of Engineering and Technology (OET). Specifically, NAB pointed to the stark contrast between the Executive Summary's upbeat endorsement of unlicensed devices that preceded a more pessimistic 149-page report released on Wednesday.

"It would appear that the FCC is misinterpreting the actual data collected by their own engineers," said NAB Executive Vice President Dennis Wharton. "Any reasonable analysis of the OET report would conclude that unlicensed devices that rely solely on spectrum sensing threaten the viability of clear television reception. Basing public policy on an imprecise Cliffs Notes version of a 149-page report raises troubling questions."

The NAB called on the Commission to seek public comment on the report before moving forward. "With the transition to digital television looming and tens of millions of TV viewers at risk, the stakes are too high for this proposal to be rammed through without thoughtful deliberation," said Wharton.

Overall, the optimistic tone of the Executive Summary of the FCC's OET evaluation does not match the actual test results documented in the report, which clearly show that spectrum sensing is not a reliable technique.

During the testing, "the Microsoft prototype sample device began to malfunction and eventually ceased to operate, necessitating the abandonment of further measurement utilizing this device," the report stated. PAGE 20

In the laboratory measurements, the report indicates that presence of adjacent channel signals "significantly degrade detection capability." PAGE 26

In the field measurements, the ability of the devices to properly sense the presence of television signals fluctuated wildly depending on the particular test circumstances. One of the devices "reported a very high percentage of channels occupied that were potentially available." The two other devices tested "did not detect occupied channels with complete reliability." PAGE 115

For wireless microphones, one of the devices "reported all the channels on which the microphones were designated to transmit as occupied whether the microphone was transmitting or not." The other device tested "indicated several channels as available even when the microphones were on." PAGE 141

Joining television broadcasters in expressing concern over the interference-causing devices are sports leagues, Broadway theater groups, cable operators and networks, wireless microphone manufacturers and religious groups.

A July 2007 FCC report concluded that sample prototype 'white space' devices did not accurately detect broadcast signals and caused interference to TV broadcasting and wireless microphones. That setback was followed by a February 2008 power failure, in which a Microsoft representative admitted that their prototype device "just stopped working." In March, another Microsoft device "unexpectedly shut down," according to a Microsoft press release.

To date, 70 lawmakers have expressed concern over the use of unlicensed personal-portable devices in the broadcast spectrum, including:

About NAB
The National Association of Broadcasters is the premier advocacy association for America's broadcasters. As the voice of more than 8,300 radio and television stations, NAB advances their interests in legislative, regulatory and public affairs. Through advocacy, education and innovation, NAB enables broadcasters to best serve their communities, strengthen their businesses and seize new opportunities in the digital age. Learn more at www.nab.org.

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