# My Comments on White Space Devices



## mbenonis (Oct 28, 2008)

I thought folks here might be interested in reading the comments I filed with the FCC on white space devices and wireless mics. Here's a link:

http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6520179375


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## howlingwolf487 (Oct 28, 2008)

Umm...the link doesn't work for some reason. Maybe you could post another one?


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## avare (Oct 28, 2008)

Thank you for sharing that with us.

Andre


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## mbenonis (Oct 28, 2008)

The link works on my end. It downloads a PDF file, so you might check to see if maybe it's floating on your hard disk somewhere. It'd be called "retrieve.cgi.pdf"

If not, Google for "Search FCC Comments", and on that page, search for Docket "04-186", and Filed On Behalf Of: "Benonis"

Mike


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## GreyWyvern (Oct 29, 2008)

I may be off on this, but here it is anyway.

The government is giving two $40 vouchers to each household good towards the purchase of a D/A converter box for your TV. This is being done because of the change that is being forced upon us. They are being thoughtful enough to compensate us. However, they are not looking at the fact that the change is going to cause problems for wireless users. If they cannot find a way around the issues and force us to have to change our ways or buy new gear, should they not also compensate us for the cost of a new wireless system or whatever would be nessecary to keep orerating what we have? We are really getting the shaft here.

We all need to take this issue seriously and do what we can to be sure that we are heard and thought of. It may seem silly to write to your governing officials about this issue, but it is really not that different than other issues that would affect the way you work or live. Thank you very much for doing your part mbenonis and I hope that any of us that have not, will do so soon before it is too late.


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## gafftaper (Nov 4, 2008)

HERE is a new article on Live Design's website about the situation and Broadway's organized attempts to get the FCC to reconsider. 

Not a lot of new information in it. Sounds like they are getting organized to protest about 6 months too late to me.


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## waynehoskins (Nov 4, 2008)

gafftaper said:


> Sounds like they are getting organized to protest about 6 months too late to me.



Unfortunately, at least as I saw it, the NPRM came out of nowhere in mid-August, and the industry has pretty much just had time to say "wait, what?". A protest six months ago would've been more ideal, certainly, but this issue wasn't on most of our radars at the time.

In the morning I understand we'll find out how bad it'll be.


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## mbenonis (Nov 4, 2008)

The FCC meeting just started, and I got bumped off of the audio stream server for some reason. It looks like tons of people are trying to listen in. Here's hoping people get bored on items 1-4 and log off, so I can get back on.

EDIT: Back on, and it's a video stream.


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## museav (Nov 4, 2008)

GreyWyvern said:


> I may be off on this, but here it is anyway.
> 
> The government is giving two $40 vouchers to each household good towards the purchase of a D/A converter box for your TV. This is being done because of the change that is being forced upon us. They are being thoughtful enough to compensate us. However, they are not looking at the fact that the change is going to cause problems for wireless users. If they cannot find a way around the issues and force us to have to change our ways or buy new gear, should they not also compensate us for the cost of a new wireless system or whatever would be necessary to keep orerating what we have? We are really getting the shaft here.


I would say that these are two very different situations. The DTV rebate relates solely to receivers and nobody is saying you can't have a 700MHz or whatever frequency wireless mic receiver, it is the transmitters that are the issue and I don't think the broadcasters were given vouchers for their digital transmitters. In addition, the vast majority of the wireless mic system users affected are unlicensed and technically illegal users,, it would be difficult for the FCC to subsidize continued illegal operation. 

However, that is one area where I have a real problem with the white space issues, the FCC 'overlooked' most wireless mic system users not being licensed for years and now they are proposing penalizing those users for this past inaction. But this can be a slippery slope to argue, one option would be to simply prohibit any and all unlicensed transmitters, if that had been done initially this would not be an issue, of course there would also be a much smaller number of wireless mics in use. I think many of the pro wireless propositions have been forced to take the approach that getting something, even if limited, to make such use legal is better than potentially getting nothing at all.


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## elite1trek (Nov 4, 2008)

I don't know if anybody else had problems opening the file, but if you are, try changing the extension (.cgi) to .pdf


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## elite1trek (Nov 4, 2008)

So, mbenonis, you seem to be the wireless/FCC expert. What can we do to fight for the use of our wireless systems? What can we do individually, and as a community?


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## derekleffew (Nov 4, 2008)

OK, now I'm interested. No one told me Dolly Parton had a horse in this race: http://www.nytimes.com/2008/11/04/technology/internet/04wireless.html.

A rather pessimistic story from http://www.stage-directions.com/index.php?option=com_content&task=view&id=1176&Itemid=1.


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## mbenonis (Nov 5, 2008)

So the FCC has approved white space devices, but with a number of restrictions. They have not posted the Second Report and Order, which will contain all of the gory details. I'm going to hold off discussing this until the 2nd R&O comes out because there's no point in speculating.

What I CAN say is that we can do things to protect ourselves, no matter what the FCC does. In no particular order, here are some suggestions to improve performance (with or without white space devices):

- Move your antennas closer to the stage, preferably right off stage. Use good, low-loss coax to get the signal to your receivers (LMR-240, LMR-400, etc).

- Use directional gain antennas, such as an LPDA ("shark-fin").

- If you are replacing your systems, look for systems with good RF receivers. Specs to look for are RF Dynamic Range (>100 dB is good), RF Sensitivity (no more than 2 µV or -100 dBm for 12 dB SINAD), Image Rejection (>80 dB), Spurious Rejection (>80 dB), Ultimate Quieting (>100 dB). Also look for information on the front-end and IF filtering the system uses. Many manufacturers do not spec this information, but it is critical for good RF performance. If you can afford it, buy receivers with tracking filters.

- Make sure your frequencies are coordinated, to avoid causing interference to yourself.

- If needed, put a front-end filter ahead of the receivers to further block noise. In some cases, you may need to use narrower ones if your receivers are spread over a wide band.

I'm sure I'll come up with more later.


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## gafftaper (Nov 5, 2008)

Hey Mike thanks for sharing your knowledge on this. When things shake out a little more can you put together a collaborative article of your recommendations for both new purchases and modifications to existing systems.


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## Smurphy (Nov 5, 2008)

Very nice letter. Ya I have to say the FCC's lack of acceptance of such are large group of wireless users is despicable. This puts production value on the line since audience members blame the audio guy for everything that happens audio wise during the production, especially with static and such, I hate being yelled at for things I can not help although it is ocasionaly a norm. Wow kind of went selfish there for the moment, the problem with this interference is that it will also hurt the show because now I will have so much more static then I do now since I am so close to Disney.


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## cvanp (Nov 5, 2008)

[note - i'm not an audio guy. i'm just guessing here. take what I say with a grain of salt, mmk?]

Wouldn't it be easier to petition the FCC to lock off a block of wireless space for live performance-related audio, and then just redesign/reconfigure devices to work in that spectrum? It would mean expensive replacements on our end, but it would also mean we would be locked into our own spectrum.

At this point, the FCC is not going to reverse this decision. I do a lot of work in the tech world, and they are ecstatic. And they have the money to back up this decision; the live entertainment/theatre/worship/etc. industries don't. So rather than trying to flip the decision, get the FCC to give us our own space. That's far more likely to happen. Costlier for us? Yeah, but if it means locking up our own section of the spectrum, it definitely wouldn't hurt as much.


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## elite1trek (Nov 5, 2008)

cvanp said:


> [note - i'm not an audio guy. i'm just guessing here. take what I say with a grain of salt, mmk?]
> 
> Wouldn't it be easier to petition the FCC to lock off a block of wireless space for live performance-related audio, and then just redesign/reconfigure devices to work in that spectrum? It would mean expensive replacements on our end, but it would also mean we would be locked into our own spectrum.
> 
> At this point, the FCC is not going to reverse this decision. I do a lot of work in the tech world, and they are ecstatic. And they have the money to back up this decision; the live entertainment/theatre/worship/etc. industries don't. So rather than trying to flip the decision, get the FCC to give us our own space. That's far more likely to happen. Costlier for us? Yeah, but if it means locking up our own section of the spectrum, it definitely wouldn't hurt as much.



The FCC is all about money, the only way they are going to give us our own piece of the spectrum is if it is worth it to them. If they were to do that, they would require licenses for use. There are not enough people using wireless audio systems to generate what it would be worth to them. Politics .


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## museav (Nov 6, 2008)

I'll try to keep personal opinion out of this and just make two points. First, as Mike said, what has been approved is more the concept, there are very few specifics yet defined or established and there may still be quite a bit of room to work within the general decisions made.

Second, how many people here are licensed users? How many people are addressing systems that they might not have in the first place, and especially not for the same prices, if the FCC had enforced the rules before? Yes, it is a pain. And yes, by accepting the situation for years the FCC has made this a much more widespread issue now. But the reality is that most wireless mic users have been reaping the benefits of a known questionable situation for years and never seemed to try to change that when it worked in their favor, now we are paying the price for that. Not saying it is right or wrong, it's just the way it is.


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## jkowtko (Nov 7, 2008)

I haven't read this in detail or tried to interpret it very carefully, but in the FCC's "Notice of Proposed Rulemaking and Order" which was published amidst with all this hoopla --

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-188A1.pdf

the FCC implies that the mfgs are at fault for misleading the general public into buying devices that would become illegal, and they might hold them accountable to help correct the situation. Here's the excerpt from secion III.B.21.(2):


_(2) “[g]rant a general
amnesty to all unauthorized users of wireless microphones deceived by the illegal and deceptive
marketing of manufacturers, permit use of the illegal equipment on a going forward basis until the
Commission authorizes” the new GWMS proposed by PISC, and require those manufacturers that
“engaged in illegal marketing to migrate the unauthorized users of Part 74, Subpart H equipment to the
new GWMS [proposed by PISC] by replacing equipment authorized for Part 74, Subpart H;​_
It also goes on to say that they proposed allocating an area of the spectrum specifically for wireless devices:


_(5) “[c]reate a new ‘General Wireless Microphone Service’ (GWMS) licensed by rule
pursuant to Section 307(e) to operate on vacant broadcast UHF channels below Channel 52 on a
secondary basis to broadcast licensees and individually licensed wireless microphone systems,” and
authorized “on a primary basis to operate on the 2020-[20]25 Band currently authorized for broadcast
auxiliary service (BAS) and under consideration .​_
If anyone wants to comment on the above I'd be curious to know if there is any meat to it.

Thanks. John


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## mbenonis (Nov 7, 2008)

jkowtko said:


> I haven't read this in detail or tried to interpret it very carefully, but in the FCC's "Notice of Proposed Rulemaking and Order" which was published amidst with all this hoopla --
> 
> http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-188A1.pdf
> 
> ...


If you re-read the document carefully you will notice that these are REQUESTS made TO the FCC, and not statements made BY the FCC. There is a group, the PISC, that wants to see these changes made, and manufacturers held accountable. I doubt it will happen. Also note that this NPRM was released in August, before the test results came out.

Here is the absolute latest from the FCC: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-286566A1.pdf

Note that the Second Report and Order is not out yet (and I have it on good authority it might be a month or two). Once that comes out, we'll know what we are dealing with.


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## jkowtko (Nov 7, 2008)

Okay, well it is good that someone is thinking of the otherwise powerless consumers ... I certainly think a dedicated frequency spectrum would be good to have, provide it can support the required number of intermod-free wireless channels.

That latest FCC news release unfortunately stays pretty vague. It does seem to be putting the onus on the new devices to "stay out of the way" of "incumbent" services, but it also implies that the incumbent services are registered. If that means every theater needs to register their frequencies with the FCC, I have no problem with that as long as there is little or no cost involved. And this is similar to what we do today with our freq mgmt programs, to stay out of the range of local broadcast stations.

And as far as interference goes, some current wireless frequencies do seem to pick up the edge of cell phone rings, so the curtain speech request to "turn off all cell phones, etc" still holds and could apply to these new devices as well. However in a sports arena or rock concert, I guess you can't ask that of the guests ....


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## mbenonis (Nov 7, 2008)

jkowtko said:


> And as far as interference goes, some current wireless frequencies do seem to pick up the edge of cell phone rings, so the curtain speech request to "turn off all cell phones, etc" still holds and could apply to these new devices as well. However in a sports arena or rock concert, I guess you can't ask that of the guests ....



It is worth noting that cell phone interference has nothing to do with wireless mics, and everything to do with poorly designed audio circuits. Cell phones operate around 850 MHz and in the 1800 and 1900 MHz bands - far above where we operate. What is actually happening is that TDMA cell phones (GSM, like AT&T and T-Mobile) transmit short bursts a few hundred times per second. This literally causes interference in bad audio circuits at the same frequency as the time spacing, plus harmonics (probably odd harmonics, since it looks like a square wave). The good news is that cell phone interference needs to happen pretty close to the audio gear, so an audience member probably won't cause any problems.

These new White Space devices, though, are a completely different ball game, and as they start to come out theatres need to think very carefully about how they will force people to turn off their devices, and keep them off.


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## waynehoskins (Nov 7, 2008)

mbenonis said:


> If you re-read the document carefully you will notice that these are REQUESTS made TO the FCC, and not statements made BY the FCC. There is a group, the PISC, that wants to see these changes made, and manufacturers held accountable. I doubt it will happen. Also note that this NPRM was released in August, before the test results came out.



And it doesn't help that "PISC" IS the New Owners of 700 megs. Google, Verizon, AT&T, those guys. "Public Interest", right.

It's gonna be an interesting ride .. in the same sense as "may you live in interesting times".


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## museav (Nov 7, 2008)

waynehoskins said:


> And it doesn't help that "PISC" IS the New Owners of 700 megs. Google, Verizon, AT&T, those guys. "Public Interest", right.


I don't think that is quite right, I believe the PISC actually a coalition of several other 'public interest' groups, some of which are essentially fronts for Google and special interest groups. But the successful 700MHz bidders actually stand to get screwed on this, they paid big dollars for spectrum to, in some cases, deliver the same type of access that the PISC claimed as the basis for their requesting free spectrum. In fact Qualcomm, one of the firms that did invest millions in the 700MHz auction, submitted a very pointed response to the FCC on just this issue. Let's face it, it is business. I believe that Google and some others drove up the costs for the 700MHz bandwidth, let their competitors invest millions in those auctions and then managed to use the 'public interest' get their own free spectrum access. That may be good business, but I agree that I don't think it was really the public's interest being served.


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## MNicolai (Nov 9, 2008)

mbenonis said:


> It is worth noting that cell phone interference has nothing to do with wireless mics, and everything to do with poorly designed audio circuits. Cell phones operate around 850 MHz and in the 1800 and 1900 MHz bands - far above where we operate. What is actually happening is that TDMA cell phones (GSM, like AT&T and T-Mobile) transmit short bursts a few hundred times per second. This literally causes interference in bad audio circuits at the same frequency as the time spacing, plus harmonics (probably odd harmonics, since it looks like a square wave). The good news is that cell phone interference needs to happen pretty close to the audio gear, so an audience member probably won't cause any problems.
> 
> These new White Space devices, though, are a completely different ball game, and as they start to come out theatres need to think very carefully about how they will force people to turn off their devices, and keep them off.




It's a simple solution. Install jammers. They did it in Russia, and it works great. If you get it to focus on the cell phone bandwidths, it would work great. That does nothing to solve the issue of white space devices though, as they'd be on the same frequencies that you'd want the jammers to not affect.

Mobiles: exeunt after St Petersburg theatre installs jammers | World news | The Guardian


Here's an idea though that could solve all of our problems if it worked well and wasn't outrageously expensive.

http://gizmodo.com/gadgets/gadgets/naturalnano-develops-cellphoneblocking-paint-157991.php


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## elite1trek (Nov 9, 2008)

> It's a simple solution. Install jammers. They did it in Russia, and it works great. If you get it to focus on the cell phone bandwidths, it would work great. That does nothing to solve the issue of white space devices though, as they'd be on the same frequencies that you'd want the jammers to not affect.



Just to add a bit of a side note...If you install cell phone jammers, and somebody finds out, the FCC will fine the crap out of you, your venue, and anybody else that was involved.

This might also be against local and state laws.

Now...Wrapping your building in copper mesh to create a Faraday Cage...that's not so illegal.

Faraday cage - Wikipedia, the free encyclopedia


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## MNicolai (Nov 9, 2008)

That's why people are starting to petition the FCC here in the states to revoke the ban on jamming cell phone signals. The irony is that you can paint your way into a black hole of reception, but if you actively jam, it's illegal.

I don't see why something can't be worked out with all of the different ideas out there though.


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## avkid (Nov 9, 2008)

elite1trek said:


> Just to add a bit of a side note...If you install cell phone jammers, and somebody finds out, the FCC will fine the crap out of you


Not only the FCC, but local cops, the FBI and anyone else who wants to get in on the party.
You may also expect lawsuits from individuals and carriers.


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## MNicolai (Nov 9, 2008)

avkid said:


> Not only the FCC, but local cops, the FBI and anyone else who wants to get in on the party.
> You may also expect lawsuits from individuals and carriers.



Double (or triple) jeopardy, anyone?

It wouldn't be cheap, but consider if each and every theatre was in a Faraday cage. No more annoying phone calls during shows, and there's no risk you'll interfere with anyone and vise versa. People could leave their phones with house management if they would like to be notified of an incoming call. It would be like a coat check for mobile phones.

If the paint w/ nanotech worked, then you could even go as far as to disable the system in between performances and during intermission, and engage it again during the show.

I'm just throwing out ideas though. All of my engineering courses have said that no matter stupid an idea may sound, during a brainstorming session no idea should be left off of the table at first.


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## lieperjp (Nov 10, 2008)

MNicolai said:


> Double (or triple) jeopardy, anyone?
> 
> No more annoying phone calls during shows, and there's no risk you'll interfere with anyone and vise versa.



And people texting!!!!!!!!!


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## deadlygopher (Nov 10, 2008)

lieperjp said:


> And people texting!!!!!!!!!



I don't think I could handle not being able to text in my theater. Occasionally texts can be handy show-saving tools.


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## Sony (Nov 10, 2008)

MNicolai said:


> Double (or triple) jeopardy, anyone?
> 
> It wouldn't be cheap, but consider if each and every theatre was in a Faraday cage. No more annoying phone calls during shows, and there's no risk you'll interfere with anyone and vise versa. People could leave their phones with house management if they would like to be notified of an incoming call. It would be like a coat check for mobile phones.
> 
> ...



The cage isn't such a bad idea and you wouldn't need nanotechnology to turn it on and off. If I recall correctly, in order for a Faraday Cage to work it must be grounded. If you could isolate the Faraday layer in a building from the Ground you could turn it on and off just by connecting it and disconnecting it from Ground. I may be wrong though...I'm not an expert in this field. Just trying to remember what I can from Physics class 4 years ago


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## elite1trek (Nov 10, 2008)

deadlygopher said:


> I don't think I could handle not being able to text in my theater. Occasionally texts can be handy show-saving tools.



Not only that, but can you imagine what that would do to box office sales, directly and indirectly. If people can't text during a show, most won't even go to the show. Its the sad truth about our industry...its dying.


> The cage isn't such a bad idea and you wouldn't need nanotechnology to turn it on and off. If I recall correctly, in order for a Faraday Cage to work it must be grounded. If you could isolate the Faraday layer in a building from the Ground you could turn it on and off just by connecting it and disconnecting it from Ground. I may be wrong though...I'm not an expert in this field. Just trying to remember what I can from Physics class 4 years ago



True in theory..but not necessarily in practice. Even if it wasn't grounded, it would still cause cell phone (and wireless audio) signals to bounce around, and wreak all sorts of unpredictable havoc. And talk about funny ground problems when it was connected.


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## avare (Nov 15, 2008)

It was just released, the latest FCC decision on whitespace. It is a long document. Without having read all of it, the gist of it is that it does not appear to be as bad as it might have been technically. Bureaucratically it ignores the "illegality" of wireless mics and how to legalize them.


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