Broadband Access



The issue most likely to impact M/AV-SIS members (particularly those who work in law schools) is that of spectrum reallocation. "Spectrum" in the telecommunications sense most often refers to various radio frequencies on which various devices are authorized to transmit and receive signals. Radio frequencies are much broader than just the frequencies at which radio stations broadcast. Certain medical devices (e.g., MRI machines) operate at radio frequencies, as do TV stations, wireless networks, and many other devices. The FCC maintains a Spectrum Dashboard for readers interested in more detail.

Spectrum reallocaton impacts both operation of wireless microphones and expanded broadband access. Reallocation began in earnest with TV's digital transition and proposals for further reallocations were contained in the FCC's National Broadband Plan . Most recently the FCC initiated the Incentive Auction Notice of Proposed Rulemaking (NPRM) which impacts both areas. The Incentive Auction NPRM is the FCC's implementation of a Congressional mandate to clear additional TV channels for other uses.

The Mechanics of an Incentive Auction

Congress approved incentive auction authority for the FCC as part of the MIDDLE CLASS TAX RELIEF AND JOB CREATION ACT OF 2012. First the FCC will conduct a "reverse" auction to determine how much compensation would be required for a TV broadcaster to voluntarily relinquish its license to a particular TV channel. Then the FCC will conduct an ordinary "forward" auction to award the spectrum to a new licensee. Congress also prevented the FCC from involuntarily relocating a UHF channel to VHF and required the FCC to pay reasonable relocation costs to TV broadcasters.

Impact on Wireless Microphone Operation

Professional wireless microphones operate on vacant TV channels. In 2010, the FCC outlawed the use of wireless microphones operating in the 700 MHz range (corresponding with former TV channels 52-69). M/AV-SIS and other AALL member institutions were among those who had to replace wireless microphones. The FCC also proposed setting aside the first vacant channel above and the first vacant channel below channel 37 for wireless microphone use. Unfortunately, as part of its Incentive Auction NPRM, the FCC now not only proposes forbidding wireless microphones from operating on the additional reallocated channels, but eliminating the guarantee of two protected channels. The additional channel reallocation itself is likely to force institutions to invest in more new wireless microphone systems before the first replacement systems they bought break down. The potential consequences of eliminating protected channels are nearly as bad.

Some wireless microphone users can protect their microphones by entering their frequencies into a TV "white spaces" (vacant channels) database. However, in order to be eligible for entry, one must already be operating in both previously proposed protected channels. Very few, if any, AALL member insitutions own microphone systems that can operate in both channels. Many do not own systems that can operate in one. The risk for interference from white space devices is significantly increased.

Library Use of White Space Devices

While white space devices pose an interference risk to wireless microphones, they also hold the promise of expanding library access to broadband. Alas, the Incentive Auction NPRM potentially undermines their mass market viability. Every white space device must check with the white spaces database to determine whether a particular channel has been reserved before choosing a channel for its own operation. Because the databate was not fully operational until December 2012, the first (very expensive) devices (for small scale, a.k.a "pico" broadcasting or Non-Line of Sight wireless coverage) are just coming to market. Whereas wireless microphones typically operate over a 4-7 channel range, white space devices could theortetically operate over about 30 channels. The FCC gives examples in the NPRM showing as many as 16 channels cleared and reallocated. Half of the potential channels may disappear between the time the devices were authorized and their entry into the general consumer market. Will manufacturers continue to develop them under such circumstances?