FCC Rules on 700MHz Microphones - Stop Use by June 12, 2010

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On January 14, the FCC released a Report and Order and Further Notice of Proposed Rulemaking regarding Revisions to Rules Authorizing the Operation of Low Power Auxiliary Stations in the 698-806 MHz Band.

Today the Commission is taking necessary and essential action to complete the digital television transition, by requiring wireless microphone users to exit the 700 MHz Band by June 12, 2010. Our decision will accelerate the buildout of 4G wireless networks, and will prevent interference with first responders who rely on the 700 MHz Band for mission-critical communications.

Note: This post is a follow up to the previous Free the Airwaves and FCC Rule Changes and Wireless Microphones discussions.

The short version:

  1. Stop using 700MHz no later than June 12, 2010.
  2. The battle continues over white spaces in the remaining VHF and UHF TV Bands

Here's the FCC consumer advisory: http://www.fcc.gov/cgb/consumerfacts/wirelessmic_a...

The really long (103 page) version is here: http://hraunfoss.fcc.gov/edocs_public/attachmatch/...

Even if your wireless mics are not in the 700MHz range, you're not out of the woods yet. Rule changes are being proposed regarding devices in the space shared with TV channels 2-51 that may affect you.

Here are some highlights from proposed rule changes:

  • Churches do not appear to be eligible for licensed operation under Part 74, Subpart H. However, we may become eligible under proposed changes. ¶130 discusses eligibility for religious organizations, which "may already be eligible for a Part 74 license if they broadcast or record events at religious venues and they hold a recognized broadcast license or qualify as television or motion picture producers under the rules." (Emphasis mine.)
  • We are generally not eligible to operate for "clergy use" under Part 90, because that is restricted to s specific frequency range that most of us do not use. However, the FCC is reviewing the usefulness of Part 90 and may change those rules.
  • We are probably eligible to continue unlicensed operation under Part 15, particularly on TV channels which have no existing licenses within the 70 mile radius proposed as a rule change in ¶115, and if our existing equipment meets existing Part 74, Subpart H rules for frequency stability and bandwidth requirements as outlined in ¶117. Most consumer equipment used in churches is rated at around 30mW transmitter power to maximize battery life, which falls within the 50mW power limit discussed in ¶116.
  • ¶71 contains a proposal to open up space in the 2020-2025MHz range for Part 15 operation. This is less than ideal because signal strength is not as good in this range, but it's a possible alternative.

The FCC originally set February 24 as the deadline for filing comments, but that deadline has been moved to March 1. Since that is only three days away, I will post info about filing comments in a different thread. I apologize that it has taken me so long to get this posted.

David McLain (@churchsoundguy) has posted a list of additional documentation and resources on his blog at www.churchsoundguy.com.

Ed Ross has mentioned to me that similar changes are afoot in the UK. We plan to cover this topic in detail in the May 2010 podcast.

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Update: September 23 Ruling on "White Spaces"

Just saw this from @churchsoundguy on Twitter:

The FCC opened up "white spaces" frequencies to broadband wireless. CCI has a good whitepaper: http://bit.ly/bzppEl (pdf)

Edit 29-Sep-2010: See also this announcement.

Edit 29-Sep-2010: Shrop emailed me this article from FOH online.

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Rant on wireless microphone manufacturers

I usually try to curtail the amount of public ranting I do about situations like this, but I guess I'm in a sour mood this morning.

We still don't know how this will shake out for our church. We use too much wireless to fit into two channels, and are in the overlap between 3 major and two (or more) minor markets. There's only one TV channel that's 100% free and clear now. Unless the FCC moves stations around and reserves the same two channels for use for all three markets, we might not end up with any protected space to operate in.

We're just going to have to wait and see how this all plays out until the manufacturers move wireless mic technology into the digital realm so we can buy it all again, at a much higher price. We have systems starting to fail from age, but I'm buying as little as possible, even though I have budget for replacements, because I don't know what brand new equipment I'll have to start replacing again next year.

Shame on the wireless manufactures for doing this to us. The shift to digital TV started when the spec was written in 1995. It's not like nobody knew this was coming. Everything else has been going digital at an incredible rate, but pro audio hasn't had any significant innovation in decades. Eventually this situation will deteriorate to the point where the major brands will all be scrambling for new solutions, which will be hastily developed with no chance of interoperability, and wireless customers will be stuck with the bill, which will be a much higher price tag than if these guys had been working towards a viable solution all along.

The sad part is that it's going to be the small churches who get completely hammered on this. Most of them have no clue about how their single lapel mic works, that it's at risk (or even operating illegally, if it's in the 700MHz range), or what to do when it fails on that inevitable Sunday morning. I've been around electronics my whole life and built my first radio (part of the Radio Shack 100-in-one project kit) when I was eight, and I consider myself ill-equipped to manage the wireless systems at my church. I just don't know how some churches are going to get through this.

Micah

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Don't blame the mic people

Not sure I agree with the statement, "Shame on the wireless manufactures for doing this to us." The wireless manufacturers didn't do it. This wasn't decided until last week, and it wasn't even likely until late last year, so they couldn't make changes for a policy that didn't yet exist.

The reality is that the mic people - and Shure in particular - have been working with the FCC to make this transition into something that will actually work, especially for the thousands of small churches that are their customers. It's worth saying it again: Shure was your advocate in this, but they were up against some very heavy hitters.

Not sure if we should blame the FCC who approved technologies that failed all the beta tests, or the "Wireless Innovation Alliance" of Dell, Google, Hewlett-Packard, Intel, Microsoft, Palm, and Philips who waged an extremely intense propaganda battle on the subject. It wasn't a fair fight: the power of money rules supreme in this day & age.

For small churches, there's an out: a couple of channels in every RF market that aren't open to these "White Spaces Devices." Should handle (FCC's guess) 12 - 16 wireless channels. I think they're overly optimistic, but it will be enough for small churches. Big venues get on the national registry. It's the larger campuses (church, school, whatever) that may be hit pretty hard: they don't qualify for the registry, and they need more than 16 channels.

David

(And no, I don't work for Shure! :-D )

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You're right, of course

David,

You're right, of course. (And there's a much more level-headed discussion of this on the ProSoundWeb thread you tweeted earlier.) It just seems that while those manufacturers have been doing a great job of trying to fight this, that the timing of any new technology released to address this is going to be a bitter pill to swallow for anyone who spent money moving out of 700MHz. It was very clear when we purchased new gear last year that we might be moving squarely into the path of TVBD, but we didn't exactly have any alternatives.

You're also right that the small churches are best positioned to take advantage of the "safe harbor" channels. I'm convinced, however, that a lot of those churches don't even know there's an issue with their wireless mics, and many are probably still running 700MHz.

Our church is among the ones that are probably going to get hit hard with this one. At peak, which would be Sundays at 9am and Wednesday evenings, we've got four concurrent worship services eating up to 23 mic and 9 IEM channels. We've purchased or replaced about a quarter of that gear in the past 18 months, even knowing TVBD would be a game-changer. We're in the middle of nowhere, but within a 70 mile radius of three major (Detroit, Flint/Saginaw and Lansing) and multiple minor (Ann Arbor, Bay City and Jackson) TV markets. In that radius, only TV channel 24 is not currently licensed. There are low power licenses or applications for channels 31 and 42, giving us one usable channel in each of Sennheiser's A, B and G ranges. Because of current allocations, I really doubt that all of those markets will get the same "safe harbor" channels. I'm not sure how that will play out for TVBD, but it's not likely that our currently usable channels will be included in those. I'm speculating at this point, but I find it unlikely that we'll have any usable channels once TVBD hits. We're going to need to move to some yet-to-be-unveiled new technology. I can't see that conversion costing anything less than $20,000 unless we cut way back on our number of channels. Still, if that's the cost of doing ministry, so be it.

My beef is that we bought all of our 700MHz gear within about a year of the announcement that it would have to go away. We've bought replacements for all of that, plus some new IEMs, knowing that it will probably be unusable after TVBD launches. And yet the manufacturers don't have any alternatives to offer us at this time. That is the source of my frustration, and the context of yesterday's rant.

Yep, we've had a free ride on Part 74 for decades, and now that's going away. I don't blame anyone for that. It's merely a side-effect of progress, and Internet over TVBD is going to be really, really cool.

But I'm going to be uneasy about this whole situation until a viable long-term solution for wireless audio starts to emerge, and I'm really disappointed that the major manufacturers haven't offered one yet. It implies they've either waited too long to come up with something, or are selling as much of their existing technology as possible first, even though their customers will have to migrate again in the near future. (And yes, I realize that either of those scenarios would be a massive over-simplification of the actual issues those manufacturers face.)

This lack of a present solution what I meant by "doing this to us." I didn't mean to say the whole situation was their fault.

Micah