TR Daily FCC’s DTS Order Draws Criticism Over Impact to TVWS
Friday, January 22, 2021

FCC’s DTS Order Draws Criticism Over Impact to TVWS

Democratic FCC Commissioners Jessica Rosenworcel and Geoffrey Starks and TV white spaces advocates have expressed concern about the impact of an order modifying the rules governing the use of a distributed transmission system (DTS) or single frequency network (SFN).

In the report and order, which was released Tuesday in MB docket 20-74 and GN docket 16-142, the FCC said, "Consistent with our goal of addressing technical issues that may impede the adoption of DTS technology, we conclude that by modestly easing limitations on DTS transmitters and providing additional clarity in our rules, we can help unlock the potential of DTS at this crucial time when many stations are considering migrating to the next generation broadcast television standard (ATSC 3.0). As the record in this proceeding demonstrates, affording broadcasters greater flexibility in the placement of DTS transmitters can allow them to enhance signal capabilities and fill coverage gaps, improve indoor and mobile reception, and increase spectrum efficiency by reducing the need for television translator stations operating on separate channels.

"Specifically, we update the current restriction that prohibits DTS signals from spilling over beyond a station’s authorized service area by more than a ‘minimal amount.’ As described below, we replace the existing, and imprecise, ‘minimal amount’ standard with a clearer, service-based approach that allows broadcasters greater flexibility in locating DTS transmitters, so long as, for UHF stations, the 41 dBu F(50,50) contour for each DTS transmitter does not exceed the reference station’s 41 dBu F(50,50) contour. Consistent with our current approach, DTS transmissions will not be entitled to interference protection beyond the station’s authorized service area."

The order added that "we anticipate that our approach has the added benefit of reducing potential disruption to other spectrum users as compared to Petitioners’ proposal. In the NPRM, the Commission sought comment on the potential impact of the initial proposal on Class A stations, LPTV stations, television translators, licensed and unlicensed wireless microphone users, NPR FM stations, and white space devices. In response, a number of commenters urged the Commission either to reject the proposal, or at a minimum, ensure that those other types of spectrum users are protected from DTS interference in spillover areas. Petitioners concede that, under the initial proposal, spillover signals likely would cause disruption to other spectrum users."

The order added that "we do not anticipate a significant impact on the availability of spectrum for white space operations or other unlicensed uses, such as wireless microphones."

But Commissioners Rosenworcel, who yesterday was designated acting FCC Chairwoman (TR Daily, Jan. 21), and Starks questioned the order’s conclusion, as did TVWS advocates. The Commissioners dissented in part on the order.

"While I appreciate the effort to modernize our policies, I would have preferred a more fine-tuned approach that would have allowed us to better gauge the effects of these systems on other services that use these airwaves, including low-power television stations and broadband devices using white spaces," Ms. Rosenworcel said. "By not choosing to do so here the agency could be needlessly restricting new broadband services even where there are no broadcast signals to protect. This strikes me as perverse. In addition, we create ambiguities about what level of protection different signals may be entitled to under the new rules, which could harm investment in new services going forward. So along with Commissioner Starks I proposed an alternative approach to unlock the potential of distributed transmission systems by using expedited waivers. Regrettably, that request was denied so I choose to dissent in part."

"I continue to support moving forward to clarify rules of the road that will enable broadcasters to migrate to the next generation broadcast television standard (ATSC 3.0). But we need to proceed with caution to avoid potentially harmful effects to other Commission priorities, including our efforts to authorize and encourage other services in the TV Band such as unlicensed white space operations," Mr. Starks said. "For the millions of Americans who live in areas without any form of broadband service, the use of white spaces as a broadband service option is among the most promising. This Commission has worked long and hard promoting policies to enable the white space community and broadcasters to co-exist in the same spectrum while minimizing the risk of harmful interference from either side. Today’s decision threatens to disrupt that careful balance by moving too quickly to adopt expanded signal spillover limits for full power television stations before it is known whether they will be compatible with other operations in the TV band.

"Although the majority asserts that the revised spillover allowances pose less of an interference risk than what was proposed by Petitioners, several stakeholders believe that any increase in signal spillover allowance, without additional safeguards, will impede the significant progress made to facilitate white spaces and other TV band operations," he added. "I therefore proposed, with support from Commissioner Rosenworcel, a more measured solution that would have streamlined the current approach under which a licensee would need to seek a waiver for signal spillover that exceeds a ‘minimal amount.’ This proposal would have provided the predictability and flexibility that broadcasters have asked for but it was rejected, which means that licensees will no longer have to demonstrate that DTS operations extending more than a minimal amount beyond their authorized service areas are in the public interest. For that reason, I dissent in part. I thank the staff for their work on this technically complex proceeding."

In ex parte filings yesterday, Connect Americans Now commended Commissioners Rosenworcel and Starks for their partial dissents and also criticized the order.

"The updated DTS rules allow broadcasters to transmit beyond their existing service area, without a clearly defined need for such an expansion, and thereby substantially reduce the area available for TVWS device operation. These rules threaten to create regulatory uncertainty that could deter investment in TVWS deployments, leaving more Americans without access to broadband service," according to CAN. "We look forward to working with you to reverse or reduce the negative implications of this order and continuing to work with you to clear regulatory barriers to technology and maximize spectrum resources to completely eliminate the digital divide."

"The order, adopted over the objections of both Democrats on the Commission, seems intended solely to give TV broadcasters more free spectrum to lease to mobile carriers or other providers of services that have nothing to do with so-called Next Gen TV," Michael Calabrese, director of the Wireless Future Program at the New America Foundation’s Open Technology Institute, said in a statement today. "We strongly agree with Commissioners Rosenworcel and Starks that a streamlined waiver process would give local stations flexibility to extend broadcast services, while also protecting low power stations and not undermining the unlicensed use of vacant TV White Space spectrum for rural broadband."

But then-Chairman Ajit Pai and his Republican colleague Brendan Carr touted the order, which was also supported by Republican Commissioner Nathan Simington.

"The new bright-line rule provides regulatory certainty for both broadcasters and for users of TV white spaces," Mr. Pai said.

Mr. Carr thanked "the Media Bureau staff for identifying a path forward from the NPRM that will promote DTS deployment while providing greater protection for other spectrum users, such as LPTV stations and white space devices." —Paul Kirby, [email protected]

MainStory: FCC FederalNews SpectrumAllocation WirelessDeployment

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