Positions and opinions of the Society of Broadcast Engineers are posted here on regulatory and legislative issues that affect our members. Comments and suggestions may be sent to GRC@sbe.org.
FCC Technical Resource Act
Broadcast Auxiliary Services
In 2009, the SBE and the U.S. Department of Defense signed a Memorandum of Understanding regarding DoD shared use of spectrum in the 2025 - 2110 MHz band. A copy of the MOU is available to members of the SBE upon request. Contact SBE Executive Director John Poray at the SBE National Office; 317-846-9000 or email@example.com.
Additional Spectrum for Medical Devices
On November 30, 2011 the FCC adopted a Report and Order in ET Docket 09-36/RM-11404 amending the FCC's rules to allow implanted medical micro devices to operate as a secondary service in the 413-457 MHz band. This band includes Broadcast Auxiliary Service (BAS) frequencies (450-451 MHz and 455-456 MHz). FCC disregarded warnings included in comments filed by SBE and others, and will now allow medical micro-power networks (MMNs) to operate on, among others, audio RPU frequencies.
While advances in medical RF technology are indeed inspiring, SBE continues to oppose the operation of medical, potentially life-sustaining RF devices in spectrum that is not specifically allocated and protected against incompatible incumbent uses. In this case, these unlicensed micro-power devices will operate on a secondary basis to licensed operations. This means that the medical devices must accept interference from licensed services in the band. The society's view is that this presents an unacceptable risk to users of the devices.
SBE is also concerned that operation in this band may eventually result in a situation similar to that encountered by DTV stations during the digital broadcasting transition. Because of RF-susceptibility of Part 15-regulated medical devices, licensed DTV stations were required to notify and coordinate with medical facilities prior to sign-on of their DTV transmitters. Because of the safety implications, licensed operations were in practical terms subjugated to an unlicensed service.
On an ongoing basis, engineers and stations should be cognizant of circumstances in which BAS operation may conflict with a concentration of devices like these. Remote broadcasts (TV live shots or "radiothons" for example) from or near medical facilities may eventually require notification when RPU frequencies are used; perhaps similar to pacemaker warnings posted at stores using microwave ovens.
National Broadband Plan
SBE General Counsel Chris Imlay, has authored a White Paper on the NBP, offering his views on how it will affect the broadcasting industry and more specifically, the broadcast engineer.
In the paper Imlay states, "This is a revolutionary period in domestic spectrum allocations. The White House's National Economic Council stated recently that freeing up 500 megahertz of spectrum for wireless broadband connectivity over the next ten years is a "national imperative." CTIA, representing wireless carriers, has estimated that it is more like 800 megahertz of spectrum needed in order to keep pace with consumer demand for smartphones and tablet computers."
View t he complete text of "Broadcast Engineering and the Spectrum Revolution".
Note: Imlay's paper does not reflect necessarily the views of the Society of Broadcast Engineers, Inc. This paper has not been adopted by or accepted by the Society of Broadcast Engineers Board of Directors. The views expressed herein are those only of the author and are not attributable to the society.
FIRST INFORMER LAWS