White Space Database Clean-up

FCC opens rulemaking to address white space geolocation questions.

Everybody interested in 600 MHz - whether broadcasters sweating the repacking process, carriers planning to bid on new spectrum, or one of the many other current spectrum users wondering what the future will look like - share a common concern: How will the FCC ensure that the millions of unlicensed wireless devices expected to operate in the band won't cause havoc? In a Notice of Proposed Rulemaking and Order (NPRM) the FCC is proposing a number of measures aimed at reducing the likelihood of any problems.

The Commission devised a plan in 2008 to allow unlicensed wireless devices to operate on spectrum referred to as "white spaces" - that is, available channels in the television bands where television stations are not operating. (Those in need of a refresher can consult my colleague Peter Tannenwald's 2010 blog post here.) Fearing interference, broadcasters challenged this idea, but after much-publicized testing by the FCC's Office of Engineering and Technology, the Commission eventually adopted Part 15 rules for white space device operations. A key requirement is that devices send their geographic location to an FCC-authorized database administrator, which will look at the spectral environment and tell the devices which channels they may use to operate at that location. (Go here for a description of how that works, and here to see how the rules were tweaked in 2012.)

As the Commission says, "Accurate location information is the linchpin for minimizing the risk of harmful interference in the white space spectrum sharing scheme." The Commission authorized a number of administrators to operate the database that will do this work. However, the technology never became well established. To date, the only unlicensed transmitters authorized to operate in the white space bands are fixed stations, and few are actually installed and in operation.

Meanwhile, as part of its Incentive Auction work, last year the Commission again tweaked the rules, looking toward a future where manufacturers could develop white space devices for indoor use (connecting products for the Internet of Things) or for outdoor use (to provide wireless broadband in less populated outdoor locations). A number of parties raised concerns, including the National Association of Broadcasters (NAB), which filed an Emergency Petition and Request for Rulemaking challenging the accuracy, integrity and continued use of the database system.

The Commission now says that it has worked with the database administrators to clean up errors and misunderstandings in the system. And it is further addressing the NAB's concerns by proposing a number of measures, including some first advanced in a joint plan developed by NAB and some device manufacturers. The proposals, all designed to reduce the potential for introduction of inaccurate data into the system, would:

• Eliminate the "professional installer" option for fixed white space devices, which presently allows the manual input of a device's location into a database;
• Require that fixed devices re-establish their position and re-register with the databases if they are moved;
• Require daily database "recheck" only for fixed devices that are in operation;
• Require that all fixed white space devices incorporate geolocation capability either within the device or by connecting to an external geo-location source; and
• Have the Commission seek comment on what party should be responsible for ensuring the accuracy of information in the databases.

As always, those interested in the proceeding should review the NPRM closely to consider the fine print. Dates for filing comments won't be set until the NPRM is published in the Federal Register, which hasn't happened yet; we will let you know when it does.