Update New Rules Of The Wireless Road Final FCC ruling includes protection for wireless microphones By Chris Lyons In November, the Federal Communications Commission released the full text of its Second Report and Order approving the use of the white spaces the TV channels that are not actually occupied by a broadcast station by unlicensed consumer wireless devices. The FCC now refers to these as TV Band Devices or TVBD s. The 130-page document provides details of the technical, operational, and regulatory requirements that the new devices will be subject to. The FCC s attention to the needs of wireless microphone users is clearly evident throughout the ruling; in fact, the term wireless microphone is used 162 times more than once per page. The FCC recognizes that some wireless microphone use is preplanned and occurs at scheduled events (think concerts, plays, sports events, or business meetings), while some is itinerant, meaning that it occurs at random times and places (think TV news crews covering a breaking story). Accordingly, they have established multiple interference avoidance measures designed to protect the broadest possible range of wireless mic users. The Order defines two different types of TVBD s, which will have slightly different operating characteristics. Personal/Portable TV Band Devices could include next-generation mobile phones and mobile broadband cards for laptop computers in other words, devices that move around. These will be limited to 100 milliwatts of transmit power on most TV channels, but will be further restricted to just 40 milliwatts when operating on a TV channel that is adjacent to one occupied by a TV station. Fixed TV Band Devices could include equipment installed at a home or business (with an outdoor antenna at least 10 meters above the ground) that could transmit or receive wireless broadband internet service or other data. Fixed TVBD s will be permitted to operate on TV channels 2, 5-13, 14-36, and 38-51, while Portable units will be limited to channels 21-36 and 38-51 only. (Channel 37 is reserved for radio telescopes and medical telemetry systems; TV stations, wireless microphones, and other devices aren t allowed.) Because Fixed TVBD s will be allowed to transmit at up to four watts of power, they will not be allowed to operate on the adjacent channels at all. TV Band Devices are allowed to go on sale after the transition on February 18, 2009. Considering the mandatory certification testing required for each new product (which the FCC hopes will take less than six months), it will probably be early 2010 before any products reach the market. The Order makes it very clear that TVBD s are not allowed to operate on TV channels that are being used by other authorized users at or near the same location. These include TV stations, Public Safety and municipal agencies (who are allowed to operate two-way radio systems on selected TV TV Channels 2 3-4 5-13 14-20 21-36 37 38-51 52-69 (700 MHz Band) Users Fixed TVBD s Fixed TVBD s Wireless Mics & In-Ear Monitors Portable TVBD s Radio Astronomy Fixed TVBD s Portable TVBD s Wireless Mics & In-Ear Monitors New Commercial Services & Public Safety The TV band after the transition in February 2009. Fixed TV Band Devices will be permitted to operate in TV channels 2, 5-36, and 38-51; Portable TVBD s will be limited to TV channels 21-36 and 38-51. 28 Live Sound International January 2009 www.prosoundweb.com
channels in 13 US metropolitan areas), and low power auxiliary stations (which includes wireless microphones, in-ear monitors, and production intercom systems that operate in the TV band). To prevent interference, the FCC has devised a clever triple-layer protection scheme that serves both small and large users, who may use wireless mics at scheduled events or operate randomly. People who only need a moderate number of wireless mics or who use them at random times can operate on the channels that will be off-limits to TV Band Devices. Since the Portable TVBD s aren t allowed below channel 21, and the Fixed TVBD s aren t allowed to use the channels on either side of one occupied by a TV station, there will be (in many cities) a few TV channels between channel 14 and channel 20 that are entirely clear. In the 13 metro areas where a few of those channels are designated for Public Safety use, the FCC is reserving two additional TV channels for wireless microphone use. These will be the first available channels on each side of channel 37. So in Chicago, for example, TV channels 16, 18, 20, 35, and 39 will be clear, which would accommodate up to 30 professional-grade wireless mics. But what about large touring shows that need dozens of wireless mics, in-ear monitors, and intercoms? And what about special events like the Super Bowl, where hundreds of wireless audio, video, and control devices are in use? To accommodate this kind of use, the FCC will require all TVBD s to determine their location within 50 meters (using GPS or some other method) and then consult an online database. The database will send the TVBD a list of available TV channels that are safe to use at that particular location; the device can t transmit until it receives this list. A wireless mic user just needs to register the date, time, and location (in latitude and longitude) of their event along with the TV channels being used by their wireless gear in the database, and any TVBD within one kilometer will stay off of those channels. The Order is quite liberal in TV Channel 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Status Public Safety Public Safety Radio Astronomy UHF TV channel usage in Chicago after the transition in February 2009. Note that some stations may change their channel assignment before the transition. January 2009 Live Sound International 29
defining who will be able to register in the database, referring to sites with significant wireless microphone use at well defined times and locations. This is further defined as instances where one or more microphones are in operation for a period of time not less than one hour. For outdoor events that cover a large area such as a racetrack or golf course, multiple sets of coordinates can be registered in the database to create a larger protected zone. The database will be created and maintained by a third party, after proposals are solicited and reviewed by the FCC. There could even be multiple providers, but the FCC will require them to synchronize their data every day. The database administrator can charge TVBD s a fee to access the database after all, someone has got to pay for this, right? but the Order does not mention any fee for a wireless mic user to register. The Order also requires a remote kill switch that can be used against devices that are determined by the FCC to be causing interference. The database administrator would be instructed to send a message of no channels available to a single device or to all devices of a particular make and model. As a third layer of interference prevention, all TVBD s must utilize spectrum sensing to detect and avoid wireless microphones, TV stations, and other authorized users nearby, whether or not they are registered in the database. A TV Band Device must scan the spectrum for at least 30 seconds every time it is powered on, and then re-check the channel it is operating on every 60 seconds to make sure that no new microphones have been turned on. If a new mic is detected, the TVBD must cease transmitting on that TV channel within two seconds. A couple of important issues were not covered in the White Spaces Order. The question of when wireless microphones must cease operating in the 700 MHz Band (actually covering 698-806 MHz, or TV channels 52-69) was not addressed. In August, the FCC proposed that this should occur as of the transition date on February 18, 2009. Given that some wireless microphone users will need to replace significant amounts of equipment in order to comply, many consider this to be an unreasonable if not impossible timeline. The next logical date for the FCC to announce a final decision on this issue would be at their December 18th meeting, but at press time the 700 MHz matter was not on the meeting agenda. Nevertheless, wireless mic manufacturers have rapidly created programs to help wireless mic users to comply with the transition, which will occur sooner or later. The White Spaces Order also does not deal with what some users consider to be the most worrisome issue still hanging: licensing. As most readers are probably aware, the FCC Part 74 Rules created in the 1970 s required wireless microphone users to have a license, and limited 1/2 H 30 Live Sound International January 2009 www.prosoundweb.com
eligibility to broadcast stations, TV and film production companies, and cable TV networks. Decades of problem-free operation with no record of complaints may have allowed the FCC to miss the rapidly expanding use of wireless audio equipment, as well as the fact that most users did not attempt to navigate the incredibly complex 26- page licensing form. The fact that the FCC intends to allow very liberal access to the database of registered users with no stated requirement for a license would seem to indicate that the licensing topic will continue to lay dormant. A final decision in the 700 MHz issue could give the FCC an opportunity to address the licensing issue, but there have not been any announcements of this so far. There s no question that using wireless mics will become more complicated as new types of devices begin sharing the television band. Here are some operating tips that will help live sound engineers to maintain stellar performance: Know the terrain. Before working at any venue, find out what RF transmitters are operating in the TV band nearby. This includes TV stations, Public Safety radios, and Fixed TV Band Devices. Most major microphone manufacturers offer a frequency finder on their website, along with free software that can help to identify these users. A high-quality scanner that interfaces with your laptop can also help to analyze the real conditions inside a venue, whose steel and concrete may reduce the strength of signals coming from outside. Get registered. Once the new database is up and running, use it. TV Band Devices need to download the database every day, but that means that you need to pick your TV channels (although not the exact frequencies) at least two days before the show. 1/2 ISLAND Take inventory. Make sure that the wireless gear that you plan to use covers the TV channels that you need to be in. Virtually all professional wireless mics are now frequency agile, but having the widest possible tuning range gives you the most flexibility to take advantage of clear channels. If you re renting gear, make sure that the provider knows that it may not be okay to substitute the same product in a different frequency range. The good news is that wireless microphone users have become an important blip on the FCC s radar. The cultural and financial importance of live entertainment content helped to emphasize the importance of protecting wireless audio systems from interference. Working together, wireless manufacturers and live sound engineers have ensured the ability for wireless microphones to continue as the reliable, great-sounding tools for live sound. Christopher Lyons is Manager of Technical and Educational Communications at Shure Incorporated. He can be reached at lyons_chris@shure.com. 32 Live Sound International January 2009 www.prosoundweb.com
Glossary Of Terms Adjacent Channel: A TV channel that is adjacent to one that is assigned to a TV broadcast station. Authorized User: A type of device that is authorized to operate in the VHF or UHF TV band. Includes TV stations, Public Safety or municipal agencies, wireless microphone users, Offshore Radiotelephone users, Broadcast Auxiliary Link users, and radio astronomy installations. Available Channel: A TV channel which is not being used by an authorized user at or near the same geographic location as the Television Band Device. Fixed Device: A TVBD that transmits and/or receives at a specified fixed location, with an outdoor antenna that is at least 10 meters but no more than 30 meters above the ground. Geo-location: The capability of a TVBD to determine its geographic coordinates with an accuracy of +/- 50 meters. Licensed Broadcaster: A radio or television broadcast station that is licensed to transmit on a particular frequency or TV channel at a particular power level in a particular location. Occupied Channel: A TV channel which is being used by an authorized user at or near the same geographic location as the TVBD. Operating Channel: The TV channel used by a TVBD for transmission and/or reception. Personal/Portable Device: A TVBD that transmits and/or receives while moving or at varying locations. Examples could include mobile phones or wireless broadband cards used in laptop computers. Spectrum Sensing: The capability for a TVBD to automatically detect and avoid TV stations, wireless microphones, and other authorized users nearby. Television Band Device (TVBD): An unlicensed wireless device that operates on available channels in the broadcast television spectrum. Unlicensed Device: A device that does not require the user or network operator to obtain a license, such as a Bluetooth headset, wireless Local Area Network, etc. Licensed Device: A wireless device that must be licensed by the FCC to operate. The license may be issued to an individual user (as with a wireless microphone or two-way radio) or to a network operator (as with a cellular phone). 1/3 H 34 Live Sound International January 2009 www.prosoundweb.com