Invasion of the TV snatchers? Specially deputized FCC
official Kevin McCarthy inspects "unlicensed device"
found on road.

The debate over "white space" just got a bit more colorful.

On September 19th, a small battalion of state broadcasting association reps met with the Federal Communications Commission to express their opposition to so-called "unlicensed devices"—receivers that can pick up temporarily unused TV spectrum, or "white space," and use it for broadband purposes.

Why, they asked, "would the FCC consider allowing millions and millions of these interference causing devices, like 'germs,' to spread throughout America with the ability to attack the TV receivers in people's homes, apartments, hotel rooms, hospital rooms, dormitories, etc., with no way for the owner of the TV set (the 'victim') to determine who was causing the 'illness' to his or her TV set?"

The group's filing does not record the response of the committee of FCC engineers confronted by this query. The questioners included David L. Donovan, President of MSTV ("Association for Maximum Service Television"), Dale O. Zabriskie, President of the Utah Broadcasters Association, Lou Kirchen, Chair of the Pennsylvania Association of Broadcasters, and officials from similar groups in Nevada and Alaska.

A coalition of big computer firms led by Microsoft are pushing hard for the FCC to authorize this alleged pandemic. Members of their so-called "White Space Coalition" include Google, Hewlett-Packard, Intel, and Philips Electronics North America.

The white spacers won a victory in October of 2006 when the FCC gave the go-ahead to technologies that can take advantage of temporarily unused TV spectrum, more of which will become available thanks to the digital TV (DTV) transition, scheduled to finish in February of 2009.

These devices will use geo-location and other techniques to detect such temporarily frequencies and route them to home entertainment systems, local area networks (LANs), and "community mesh networks" linking neighborhood LANs together.

In February of this year Microsoft submitted specs to the FCC for a small white space receiver, able to access signals for a UHF radio, a CR scanner, and a laptop computer attached to a network processor through an ethernet interface.

But TV broadcasting groups, led by the National Association of Broadcasters, say that these machines will not easily co-exist with digital TV signals.

The September 19th filing goes a little beyond the dry rhetoric that has characterized this comment cycle so far. The broadcasters accuse the FCC of "speeding this proceeding along."

Why, they rhetorically ask:

• would the FCC allow this technology to emerge before the digital transition is concluded? The government has set February 17th, 2009 as the last day of analog broadcasting. "To introduce interference causing devices at this critical stage of the DTV transition makes absolutely no sense."
• would the FCC "want to risk the outrage of America's citizenry" when they buy analog set top box converters "only later to find out that portable, unlicensed devices, whose ownership or locations are unknown, could render their converters useless from time to time?"
• would the FCC take pains to prevent even .05% interference between neighboring digital TV stations "but not seem to care about the interference caused to potentially the hundreds of millions of TV receivers throughout our country?"

Getting back to the germs problem, the filing warns that "even if the developers of these devices are committed to building second, third and so-on generation devices, the first generation of 'germ' devices will remain at large. Where is the accountability under this scheme."

In conclusion, the broadcaster statement all but calls unlicensed devices a threat to national security.

"The entire concept of allowing such devices flies in the face of everything that the FCC, the Department of Homeland Security, State and local emergency management authorities, the broadcast industry, and other stakeholders have worked so hard to preserve and enhance," the comment charges, "namely the reliability of the broadcast service as the premier 'first informer' for the public of emergency circumstances and safety measures."

Several days after this filing, Microsoft and Phillips submitted the results of their latest unlicensed device tests to the FCC.

The September 21st statement claims that tests confirm that it is feasible for white space devices to pick up TV signals at a signal strength "that is far too weak for a television set to produce a broadcast television picture."