The National Association of Broadcasters has renewed its plea for greater FCC oversight of TV white spaces databases as it criticized the results of a 45-day trial of Nominet UK’s database system.
“The errors NAB discovered in a brief review of Nominet’s database, particularly the incorrect channel information, demonstrate that the TVWS database continues to serve as an inadequate foundation for protection from harmful interference for licensed operations,” NAB said in a filing yesterday in ET docket 04-186. “Beyond the specific errors NAB discovered, it is unclear whether any other party bothered to perform an in-depth check of Nominet’s system. TVWS databases continue to contain obvious errors, such as fake names, e-mail addresses, phone numbers and plainly inaccurate location information. NAB has repeatedly urged the Commission to take a more proactive role in ensuring that the primary means of preventing interference to licensed operations actually works. The Nominet database serves as a timely reminder that until the Commission does so, the white spaces experiment will remain an ongoing failure.”
“More than three years ago, the National Association of Broadcasters filed a petition for rulemaking asking the Commission to amend its television white spaces (TVWS) rules to eliminate the so-called ‘professional installation’ option for determining the location of fixed TVWS devices. As part of that petition, and repeatedly since, NAB demonstrated the unreliability of the TVWS database and the insufficiency of professional installation as a method for determining the location of TVWS devices,” NAB said. “Unfortunately, the Commission has taken no further steps to improve the functioning of the TVWS database, apparently because there are not enough white spaces devices to make the effort worthwhile. If the white spaces experiment ever bears fruit, there is a serious question whether the database is capable of functioning as intended. We thus urge the Commission to take a more active role in examining this and other database providers’ applications to ensure that the TVWS database regime is capable of ensuring that licensed users will not experience harmful interference.”
NAB said, “Testing of the Nominet database system revealed several errors, at least three of which appear to still be unresolved: (1) failure to exchange data with other database providers; (2) no fixed TVWS registration utility; and (3) incorrect channel information for full-power television stations.”
“Any of these issues individually would raise serious concerns as to whether or not Nominet is qualified and capable of acting as a TVWS database provider. Together, particularly given that it is unclear if any other party engaged in any similar review, Nominet’s experience calls into question the Commission’s entire approach to the TVWS database,” NAB argued. “It is plain that an unpoliced database may be subject to errors and fundamental performance issues. And it appears plain that no one, including the Commission, is policing the database.”
NAB added that “some previously-authorized TVWS database providers, such as Comsearch, Spectrum Bridge, Key Bridge, Google and LSTelcom, are either no longer providing service or no longer providing the required database extracts. This may leave some registered devices unable to communicate with a database as required. In the event the white spaces experiment ever bears fruit and leads to the deployment of hundreds of thousands or even millions of TVWS devices, NAB and other industry participants simply cannot shoulder the burden of ensuring that database providers are capable of following the rules in every instance. We urge the Commission to take this opportunity not only to more carefully consider Nominet’s qualifications, but to consider a broader review of the means by which it certifies database providers to ensure that the parties in charge of maintaining the database can be relied upon.” —Paul Kirby, [email protected]
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