Our involvement in the evolution of the so-called "white space" device has been since the original ET Docket 02-380 where we had our opinions on these devices.
After careful consideration of the issues, we feel that many of our concerns are still valid. Let me just run through some of these real quick.
Spectrum allocation
We do not feel that the entire TV broadcast band should be opened up to any kind of non-broadcast device that would be proposed. Channels 2-4 (54-72 MHz) should not be allowed due to the characteristics of this band and the wide assortment of navigation devices in this band. Channels 5-6 (76-88 MHz) will not be endorsed by REC as our spectrum policy advocates this spectrum to be reallocated to sound broadcasting. Channels 7-13 (174-216 MHz) should be assigned with great caution due to it's far separation from the majority of the assignable spectrum. Plus with the other non-licensed devices in this spectrum such as wireless microphones and biomedical devices that are normally coordinated with broadcasting, there would not leave a lot of space for white space devices. As we have seen in DTV channel elections, many high band VHF stations are transitioning back to their old VHF (7-13) channel after February. Channels 14-20 (470-512 MHz) must protect public safety and private mobile services in the metropolitan areas. Therefore, we must stand the ground that devices in this spectrum must be regulated to assure that the spectrum remain clear in the metro areas. Channels 21-51 with the exception of Channel 37 (512-608 & 614-698 MHz) could be candidate spectrum for unlicensed wireless networking devices as long as they do not interfere with DTV and analog facilities including full power TV, Class A, translator, booster and foreign facilities.
Fixed nature of transmitters
I worry that uncontrolled devices, despite the supposed "sensors" or other technologies being proposed to assure no interference that these devices could still cause harmful interference to primary and secondary broadcast users. We feel that specific spacing rules of devices would need to be put in place to assure that a device would not cross into a protected contour of a licensed facility. We feel that this can only be achieved with fixed facilities where paths would be engineered to assure compliance.
International concerns
The use of this spectrum is not internationally accepted. Use of these devices outside the United States would be illegal and subject the user to fines or imprisonment under the other administration's laws. It can also lead to customs and border control issues.
Grassroots implications
We know that the grassroots organizations are supporting the white space devices and REC, which has connections with the grassroots can understand their reasoning for this spectrum as a part of a "give the spectrum back to the people" agenda. REC also believes that private citizens should be able to recover as much of the public spectrum from the large corporations who are influencing our government for their own bottom lines. At the same time, we must assure that the devices are crafted in a way where the big corporate stations and the private citizens can share this spectrum in a fair and equitable manner.
REC does not subscribe to the NAB, MSTV, etc. notions that the days of terrestrial television are numbered.
REC feels that white space devices can work in a controlled environment on coordinated spectrum and should not be a free-for-all. Save the free-for-all wi-fi environment for the ISM bands.
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