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My Comments on White Space Devices

Discussion in 'Sound, Music, and Intercom' started by mbenonis, Oct 28, 2008.

  1. mbenonis

    mbenonis Wireless Guy Administrator

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  2. howlingwolf487

    howlingwolf487 Active Member

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

    avare Active Member

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    Thank you for sharing that with us.

    Andre
     
  4. mbenonis

    mbenonis Wireless Guy Administrator

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    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
     
  5. GreyWyvern

    GreyWyvern Apollo Staff

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    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 [user]mbenonis[/user] and I hope that any of us that have not, will do so soon before it is too late.
     
  6. gafftaper

    gafftaper Senior Team Senior Team Fight Leukemia

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    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.
     
  7. waynehoskins

    waynehoskins Active Member

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    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.
     
  8. mbenonis

    mbenonis Wireless Guy Administrator

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    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.
     
  9. museav

    museav CBMod CB Mods Departed Member

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    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.
     
  10. elite1trek

    elite1trek Active Member

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    I don't know if anybody else had problems opening the file, but if you are, try changing the extension (.cgi) to .pdf
     
  11. elite1trek

    elite1trek Active Member

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    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?
     
  12. derekleffew

    derekleffew Resident Curmudgeon Senior Team Premium Member

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    Last edited: Nov 5, 2008
  13. mbenonis

    mbenonis Wireless Guy Administrator

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    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.
     
  14. gafftaper

    gafftaper Senior Team Senior Team Fight Leukemia

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    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.
     
  15. Smurphy

    Smurphy Member

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    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.
     
  16. cvanp

    cvanp Active Member

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    [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.
     
  17. elite1trek

    elite1trek Active Member

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    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 :rolleyes:.
     
  18. museav

    museav CBMod CB Mods Departed Member

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    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.
     
  19. jkowtko

    jkowtko Active Member

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    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
     
  20. mbenonis

    mbenonis Wireless Guy Administrator

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    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.
     
    Last edited: Nov 7, 2008

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