[UPDATE: The FCC has released the first Report & Order on the incentive auctions. Further details are forthcoming in yet another Report & Order. The document can be found here.]
At an Open Commission Meeting on May 15th, the FCC finally gave us a glimpse of details concerning wireless microphones and the incentive auctions. This meeting was one that broadcasters and A/V pros have been waiting for with bated breath. The official Report and Order describing the rules for the incentive auctions - and by extension what wireless audio devices will and will not be able to do in the new UHF - has yet to be released, and so this information is subject to change. However, the Commission discussed reports on the incentive auctions and wireless microphones at length, giving us the clearest picture to date on what may, and may not, happen during and after the incentive auctions and repacking process are complete.
The most likely scenario is as follows:
- The two reserve channels are going away. In every market, the FCC reserves two unused 6 MHz television channels somewhere above and below channel 37. Not anymore.
- Licensed wireless microphones will be given 4 MHz of spectrum in the 11 MHz “duplex gap,” a nether-region in the 600 band between telecom services. These 4 MHz will most likely be for exclusive use by licensed wireless microphones. They will also be split in half, with 2 MHz above and 2 MHz below 7 MHz of additional spectrum. Unlicensed wireless microphones may or may not be allowed to operate in the 7 MHz between these two regions.
- There is the possibility that between 14 and 28 MHz of spectrum will become available for shared unlicensed use. This spectrum will be located in guard bands and gaps in between licensed wireless cell and broadband spectrum.
- Public venues using large numbers of wireless audio devices will be allowed to apply for interference protection through a Part 74 License. A Part 74 license enables users or facilities to classify themselves as wireless “stations” and enter their frequencies into a database that instructs TVBDs to avoid those frequencies. Part 74 licensed users are also able to legally dispute infringement on spectrum by unlicensed users. The proposed threshold for licensure was mentioned to be 50 devices. This is a pretty big deal. Previously, the only way to become a licensed user was to work for a broadcasting or film company - everyone else was out of luck. Now large churches, stadiums, theaters, and other facilities using tons of mics can harness the most powerful means of protecting oneself against interference. In fact, a Part 74 license may be the only thing that will allow UHF microphones to keep operating in the UHF broadcast band once the repackings are complete. If you are in charge of a large facility that uses more than 50 microphones, please feel free to contact me for resources.
- Operation will be permitted in the 600 MHz band while the repacking occurs. For how long, is answered below.
A few unknowns:
- Where the 4 MHz duplex gap will be located.
- Which types of users will be allowed to use the reserved 4 MHz of spectrum in the duplex gap. My understanding is that the overwhelming likelihood is that unlicensed users will not be allowed there. It will be open to either all licensed users, or only to ENG (that is live TV broadcast) licensed users.
- Whether the 4 MHz duplex gap will actually be useable. Contamination from cell and mobile broadband services above and below the gap, as well as contamination from nearby unlicensed devices, may make the spectrum useless to professionals.
- If wireless microphones will be permitted to operate in the 14-28 MHz of unlicensed spectrum that was proposed, and if that spectrum will be useable for unlicensed microphones. Professional, licensed, Part 74 users are in agreement that this spectrum will not be suitable for professional use. Unlicensed users will have to contend with RF contamination from mobile broadband links, as well as TVBDs.
- How long microphone operation will be allowed in the 600 MHz band during the repacking transition. One thing is certain; wireless microphones and other wireless audio devices will not be allowed to operate after the repacking is complete. This gives us a maximum of 39 months after the conclusion of the auction. (The auctions are the financial and legal transactions that allow the spectrum to change hands, the repacking is the change in physical infrastructure (towers, antennas, etc) that will allow the new services to begin.) In major urban markets, licensed users will need to vacate as soon as six months after the conclusion of the auctions, since once a new service notifies the FCC, incumbents need to vacate.
What this means.
Hand wringing for broadcasters.
The most vocal wireless microphone users have been and continue to be film and broadcast professionals. They use wireless audio for many tasks in unique and high profile contexts, and maintain an extensive stable of lawyers and lobbyists in Washington that represent their industry to Congress and the FCC.
Although the final word has yet to arrive, the proposed rules have not gone over well with broadcasters. I spoke with Bruce Franca, Vice President of Spectrum Policy at the NAB, and here’s what he had to say:
“One of our principle concerns has been Part 74 licensed wireless microphones used for electronic newsgathering (ENG). Covering breaking news events or storms, like the Boston bombing or tornadoes in the south, can’t be planned in advance and can’t wait for registration in a database. That’s why, with the introduction of the TV White Space rules a few years ago, the FCC set aside two TV channels or twelve megahertz for these uses. In the current item, licensed wireless microphones appear to be relegated to 4 MHz of the 11 MHz duplex gap. Unfortunately, this is in 2 MHz portions of the duplex gap closest to wireless operations with 6 MHz in the middle for unlicensed. In technical discussions that we’ve had with wireless equipment manufacturers such use is simply not possible.”
A death knell for unlicensed UHF.
Unlicensed UHF microphones may very well go extinct over the next few years. As TV stations are repacked from the 600 MHz band down into 500 MHz, and as TVBDs come online, the remaining UHF spectrum between 470-600 MHz will become crowded enough to force microphones completely out of all major urban markets. In rural areas, reception may be unpredictable due to remaining TV stations alongside TVBDs.
A new beginning, not the end.
First, there is still time. Operation of unlicensed wireless audio equipment in the 600 MHz band is still legal, and will continue to be legal up until TV stations have been moved down into the 500 band. Incumbents in the 600 band will not be forcefully removed the way they were in the 700 band a few years ago. 600 MHz equipment will likely be able to operate until 2017, since the auction is only tentatively scheduled for mid 2015, and the repacking procedure could take up to 39 months after that. If the auction fails, operation could be possible up to 2020 - Congress’ deadline - but don’t count on it.
Second, we will only be losing the ability to safely operate in the UHF broadcast band. There are a multiplicity of unlicensed ISM bands suitable for high quality, trouble free operation of wireless audio equipment, as well as VHF.
Third, the incentive auctions will force wireless audio manufacturers to adapt and improve their technology. Until now, they have had the luxury of manufacturing devices in spectrum that no other unlicensed devices could use. Ergo, innovation has stagnated; the industry still uses antique, dumb, spectrum hogging analog radios. Manufacturers simply had no incentive to invest heavily in R&D, and end-users had no incentive to invest in costly upgrades. The next generation of professional and consumer microphones will be low-latency digital, not analog, and they will incorporate sophisticated interference avoidance techniques.
After the last FCC Open Meeting that discussed wireless microphones, we spoke with Henry Cohen of CP Communications, who said: "In no uncertain terms, we have to plan on the UHF spectrum going away." We checked back with Henry to get his take on the Open Meeting on the 15th. “The key point going forward is the new mantra of sharing,” he said. “Microphones in almost all circumstances will have to share with other unlicensed devices.”
So there you go. It's time to get ready for the future.