5/4 FCC TV White Space Comments On Behalf of the Broadband Connects America Coalition

New America's Open Technology Institute filed comments in tandem with the Broadband Connects America coalition (BCA) calling on the Federal Communications Commission (Commission) to move forward on rule changes regarding the use of TV White Spaces to improve and expand broadband access in rural, tribal, and other hard-to-serve regions. Access Humboldt, the California Center for Rural Policy, the Center For Rural Strategies, the Institute for Local Self-Reliance, the National Digital Inclusion Alliance, Tribal Digital Village Network, the South Carolina Office of Rural Health, Palmetto Care Connections, the Schools, Health & Libraries Broadband Coalition (SHLB), the National Hispanic Media Coalition, MuralNet, Public Knowledge, and X-Lab signed the comments as well. A summary of the comments is available here:

BCA generally supports the TV White Space (“TVWS”) rule changes proposed in the NPRM. BCA supports these changes, but we also urge the Commission to go further to update and strengthen the utility of TVWS technology to help narrow the digital divide in rural, tribal and other hard-to-serve areas.

First, BCA strongly supports the authorization of real-world, terrain-based propagation models as an option for calculating the allowable channels, power and height above average terrain (“HAAT”) for TVWS operation at a particular location. The unrealistic assumption of free space propagation both limits the benefits to rural areas and wastes spectrum capacity. The Commission today has far more experience and recent precedent that justify updating the rules to allow more intensive use of available TV band capacity. As the Commission recently decided in its 6 GHz Report and Order, White Space Databases should be authorized, or even required, to use propagation models that take real-world terrain and clutter losses into account.

Second, BCA supports the Commission’s proposals to increase both the power limit and the allowed height above average terrain (HAAT) limit for fixed White Space Devices (“WSDs”) operating with at least 6 megahertz separation from local TV stations, at least in “less congested areas.” These modest changes would allow TVWS operators to cover more customers with a given amount of investment, a critical factor in the availability and affordability of rural broadband.

Relatedly, BCA recommends that the Commission not limit the higher transmit power and HAAT proposed in the NPRM to “less congested areas” defined as a percentage of TV channels that are vacant. If the Commission authorizes (or even requires) terrain-based propagation modeling, White Spaces Databases will be able to rely on power, height and terrain to accurately determine whether the fixed WSD can operate in that location without causing harmful interference. The existence of greater or fewer vacant channels on other, non-adjacent frequencies in the band become irrelevant to the interference calculation, making the congested-area constraint unnecessary.

Third, the Commission should modernize the TVWS rules to allow a White Space Databases to factor into its calculation whether a WISP or other operator is using a directional antennas and sectorization to coordinate a fixed point-to-multipoint (“P2MP”) deployment that poses no risk of harmful interference in a location where an omnidirectional antenna might do so.

Fourth, BCA supports allowing fixed WSD operations in the first adjacent channel at a power level substantially above the current, overly-protective 40 mW limit. This revision is critical now that the TV incentive auction has greatly reduced the number of contiguous vacant channels, even in rural areas.

Fifth, BCA strongly supports the Commission’s proposal to authorize the operation of fixed WSDs on mobile platforms (such as school buses, library bookmobiles and farm vehicles) in geofenced areas calculated by the White Space Databases. This should not be limited to “less congested areas” as currently defined, particularly if the Commission authorizes or requires terrain-based propagation modeling.

Finally, BCA supports the Commission’s proposal to create a new class of narrowband WSDs specifically crafted to support the Internet of Things (IoT), with appropriate technical and operational rules that both protect licensees and facilitate robust use for a wide range of valuable applications.