Citing raft of errors, NAB urges suspension, overhaul of database requirements
The television white space (TVWS) database system, intended to increase the efficient use of TV spectrum, is a mess, according to the National Association of Broadcasters (NAB). Because of that, the NAB has asked the Commission to suspend operation of the system until the “serious design flaws” in the system can be fixed. The FCC is thinking about the NAB’s proposal, and has solicited comments on it.
The TVWS database system has been an ambitious undertaking since Day One. The idea, of course, is that there is some TV spectrum everywhere that is not being used at any one time by any licensed operator. Such spectrum can be put to good use by various low-power unlicensed devices (dubbed TV band devices, or TVBDs). But how is a TVBD user supposed to know where, when and what spectrum can be used? Enter the database.
As designed by the Commission, the TVWS database is supposed to include information about all licensed TV spectrum users (a universe that includes TV stations, some wireless microphones and various other users) and all fixed, unlicensed TVBDs. Operators of fixed, unlicensed TVBDs have to provide detailed information about their facilities – including, e.g., the location of the transmitter and contact information for the operator – before commencing operation. Without accurate location information, it would be impossible to determine which frequencies would be available because it would be impossible to determine whether the proposed TVBD would be close enough to a licensed user to cause interference. And without accurate contact information, neither the Commission nor licensed operators encountering interference would be able to reach the unlicensed operator to correct the problem. The other information required for the database is similarly essential to interference-free operation in the TV band.
Maintenance of the database has been delegated to a number of private entities, several of which have already been approved by the Commission to serve as database administrators. But, under the well-established GIGO principle, even the best administrator is only as good as the data it is given. And, according to the NAB, the data coming in from fixed TVBD operators is sketchy at best.
Sites specified by some fixed TVBD operators reportedly include: (a) places 50 miles from Quito, Ecuador, and 500 miles from Cameroon (the latter happened to be in the middle of the Atlantic); empty fields; the middle of the street; a water tower in Peru, Indiana, even though the supposed height of the TVBDs registered at that site was only about six feet. TVBD user identifications aren’t much better: “Sue Q. Public”, “John Doe” and “John Smith” all showed up, along with “NoneNone”, “first_last” and, in the case of 80 TVBDs, “Meld test”. Trying to reach TVBD registrants to get better information is difficult when they list: (a) email addresses such as “firstname.lastname@example.org”, “email@example.com” or “firstname.lastname@example.org”; (b) mailing addresses such as “456 Main Street, Anytown, USA”, “123 Jump Street, Richmond, VA” or simply “addr”; and (c) phone numbers including “232-555-1212”, “408-111-1111” and “999-999-9999”. Some TVBD registrants have apparently provided fake FCC ID numbers and device serial numbers.
Obviously, the available data are less than reliable. That’s the bad news. The good news is that, for whatever reason, the TVWS database is still relatively limited: only about 550 fixed TVBDs have been registered so far. (Sidenote: The fact that the database administrators don’t have a common total for such devices is another indication of the dubious reliability of the system. According to two administrators – i.e., Google and Spectrum Bridge – 558 fixed TVBDs had been registered as of one date; iConnectiv, a third administrator, put the number at 621 for the same date. Since databases are all supposed to be harmonized daily, this discrepancy is obviously problematic.)
Because the TVWS system is so limited, the NAB figures that now would be an excellent time for the Commission to put the system on hold for a while and clean it up with new, more stringent rules. Any clean-up effort will almost certainly be more complicated as the database grows. In particular, the NAB would have the Commission: (a) require all TVBDs, mobile and fixed, to incorporate geolocation capability; and (b) beef up the rules to provide “real and effective accountability” when it comes to data entry. That latter suggestion would involve, among other things, mandatory confirmation, by the database administrators, of at least the “facial integrity” of incoming data. Whether the Commission will agree remains to be seen.
For now, the FCC has invited preliminary comments on the NAB’s proposal. Comments are due by May 1, 2015. Once any incoming comments are reviewed, the Commission may issue a Notice of Proposed Rulemaking, or it may not. If you think that the NAB’s concerns warrant FCC action, now would be a good time to let the Commission know.