[opendtv] More Opinions on "White Space" Sent To FCC

Federal Communications Commission
445 12th Street, SW
Washington, DC 20554 
        Re: Ex Parte Comments, ET Docket No. 04-186; Introduction of 
Unlicensed Devices into the "White Spaces" Television Band
Dear Chairman Martin and Commissioners Copps, Adelstein, Tate and 
McDowell: 
I am writing you today as the State Chair of the Emergency Communications 
Committee for the State of Nevada because I am concerned about the impact 
of the apparent rush to judgment decision to allow unlicensed, 
radio-frequency emitting portable devices to operate in the so-called 
“white spaces” of the television broadcast spectrum. These devices have 
the potential for further improving our quality of life and I am not 
opposed to the manufacture and distribution of them so long as they do not 
cause harmful interference to television stations and so long as they can 
be identified and their owners be held accountable if such interference 
does occur. During this time of economic challenge, I understand the 
pressure to get these devices to the market. However, the rush to place 
new technology on store shelves should not displace the common-sense need 
to determine whether these devices will operate as intended and not 
interfere with existing technology. 
In the past year, Nevadans have depended on the Emergency Alert System and 
local broadcasters to warn them about such life threatening-emergencies as 
flash floods from broken levees to hazardous materials spills to severe 
weather to AMBER Alerts. But if interference from “white-space devices” 
degrades television reception our residents and visitors won’t be able to 
depend on local broadcasters for this critical information. And if people 
have to spend money on dedicated warning systems that are not vulnerable 
to interference from white space devices, we run the risk of seeing our 
society divided into two classes: the informed and the uninformed. 
In addition, our broadcasters have spent a lot of money upgrading their 
equipment to provide their audiences with the new, high quality, digital 
signals. And after spending their hard-earned money on products and 
services like converter boxes, cable subscriptions and new televisions, 
viewers will be not be happy when they find out that those high-quality 
digital signals are subject to interference from the new white space 
devices and there’s no way to tell them the specific source of that 
interference. They will surely want to know why the FCC did not take 
adequate steps to safeguard their ability to receive interference-free 
reception on their television sets. 
For these reasons, I am asking the FCC to delay any vote and decision on 
white space devices until the public, in Nevada and other states, has the 
opportunity to review and comment on OET'S engineering report on which 
such vote depends.  In addition, the FCC should have adequate time to 
consider those comments, especially those related to the impact of these 
devices on public warning and emergency communications.  While this issue 
involves issues of physics and technology, where physics controls, and 
technology cannot not adequately accommodate competing spectrum uses, 
interference-free spectrum used by broadcasters must be considered sacred 
so that we do not lose lives because unlicensed, portable "white spaces" 
devices impede emergency information to the public.
Adrienne Abbott-Gutierrez, Nevada Chair
State Emergency Communications Committee
MGM MIRAGE
On behalf of MGM MIRAGE and our 64,000 employees, I am writing to express 
our strong opposition to the proposed order under consideration in the 
“White Spaces” proceeding as reported in the Commission’s recent press 
conference and media accounts.  Our Company, along with our colleagues 
from Harrah’s Entertainment, The Walt Disney Company and The League of 
American Theaters and Producers is alarmed by recent reports suggesting 
that the Commission is considering a “White Spaces” proposal that will 
impair wireless microphone operations and seriously jeopardize our ability 
to provide first-class audio production. The justification for this 
proposal is based on a 400-page technical report that was released to the 
public just a few days ago. Our technical staff and consultants have 
significant concerns about the analysis and conclusions drawn in this 
report, but neither the Commission, nor the people affected have had the 
benefit of any public input on this document.
MGM MIRAGE has an established and trusted brand that combines an enticing 
blend of entertainment and luxurious resort amenities to every corner of 
the world. This “blend” of entertainment is increasingly weighted less on 
gaming and more on the many offerings our resorts have to offer, such as 
live entertainment, weddings, concerts, corporate conventions, and first 
class theater. While these offerings range in scope, they all share one 
thing in common: they all incorporate the use of wireless microphones in 
their productions, exhibiting the diverse functionality of this type of 
equipment.  The audio production of a modern show on the Las Vegas Strip, 
or anywhere live entertainment is hosted at large venues, is premised on 
the availability of wireless microphone systems operating in unassigned TV 
channels. The very first day producers design a show it is decided how 
many systems are needed, how many channels are needed to host those 
systems, and what frequencies are available in those channels to meet the 
show’s demands. If these proposed new devices fail to protect wireless 
microphone operation, virtually every convention center, concert hall, and 
wedding chapel across the country would be negatively impacted.
That is why it is critical that we have a thoughtful review process of the 
Office of Engineering and Technology’s testing results report. Allowing a 
public review and comment period, as well as appropriate peer review 
process, will not undermine, but rather improve the Commission’s 
decision-making process. If the data is appropriately
extracted, and fundamental sound policy is developed based on that data, 
the extended comment period and independent peer review process will only 
add legitimacy to the claim that unlicensed devices can peacefully coexist 
with wireless microphones in the TV Band.
That is why we ask that the Commission not proceed to a final decision on 
such a controversial and important item that stands to affect a wide range 
of established businesses, including enterprises like MGM MIRAGE, without 
a 60-day formal comment period and an independent peer review process.
Sincerely,
J. Terrence Lanni
Chairman & CEO

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