Call to Action: The FCC Needs Your Comments By March 1st

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In their January 14 ruling on microphones in the 700MHz band (detailed in this post) the FCC proposed changes to the rules for operating wireless audio devices in the "white spaces" between TV channels 2-51. Several organizations who did not win space in the 700MHz auction want to use this space for TV Band Devices (TVBD) to provide wireless Internet access.

If you use wireless microphones in your church, the FCC needs your comments by Monday, March 1st.

Yes, that's only one business day away. I apologize for not getting this posted sooner.

What to File

Comments are filed as a letter to the FCC. (These can be filed electronically.) The letter should contain the following information:

  • The name of your organization and type of business.
  • Why you are writing to the FCC? (You are asking the FCC to protect wireless microphones from interference and ensure that wireless microphone users will be eligible for licenses.)
  • How do you use this technology?
  • What kind of cultural, entertainment, economic, educational, spiritual, civic or other value does your production represent?
  • Why are interference free operations critical to your productions and what impact changes may have.
  • What are you asking the FCC to do? (Ensure that any rule changes that the FCC adopts will allow you to obtain an FCC wireless microphone license and continue doing what you are doing now.

How to File

There is no time remaining to mail your letter, but you can still submit your comments to the FCC's Electronic Comment Filing System.

Does this seem like a daunting task? It did to me, too. But Shure is willing to help, and has made this process quite easy. Simply send an email to wirelessmicrophones@shure.com requesting info on filing, and they'll send you back detailed instructions along with a template for your letter. When you're done, you can email the letter back to them and they will file it on your behalf. It appears that they're working the weekend, because I just sent my comments letter to them this morning and have already received a response.

All submitted comments, including these from producer Phil Ramone and veteran Super Bowl wireless RF coordinator James Stoffo, can be viewed on the ECFS for Proceeding 10-24. For highlights and updates, follow (@chris_at_shure) on Twitter.

If you care at all about how these rule changes may affect your ability to use wireless microphones in your church, please take a few minutes and submit your comment before the deadline on Monday.

Thanks,
Micah

Joined: 01/26/2009
User offline. Last seen 14 weeks 2 days ago.
Do I need to File?

I'm a little unclear as to how this applies if the wireless system is out of the 700MHz spectrum. I thought it was required to move out of that spectrum by now...did they change their minds?

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Today's FCC Comments are for operation below 698MHz

Hank,

Comment filings due today are regarding proposed rule changes for operations below 698MHz. A lot of confusion has been generated because the 700MHz topic and "white spaces" debate have gotten thrown together quite a lot, but they're really two different issues.

The FaithTools Podcast had a pretty good discussion about this topic on their latest episode.

The issue here revolves around how new TVBD wireless Internet devices would be allowed to operate in the "white spaces" between DTV channels below 698MHz without interfering with wireless mic operations in the same area. Presently, most wireless mics are unlicensed operation, and part of the proposed rule changes includes making more wireless mic users eligible for licensing. As a film-maker, your business uses most certainly should qualify under Part 74 by today's rules. The immediate question that most of us should be concerned about is whether or not churches would qualify for licensing. (The ultimate question is whether or not the FCC can eventually do something that makes either side happy, but that won't be decided for months, or longer.)

Even with the 700MHz issue behind us, this is probably going to remain a hot topic for at least a year. One of the downsides right now is that churches forced to replace 700MHz gear now don't really have a clear migration path. Rule changes could render the new equipment inoperable at any time. To summarize the FaithTools discussion: for now, if it can be wired, don't buy wireless for it.

If at all possible, you or someone else from your church should file comments today. If you provide rental equipment as part of your business, you'll want to file regarding that as well, although for slightly different reasons.

Micah