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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations
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9. The Commission is not increasing the maximum permissible conducted transmitter power as requested by some parties. NAB opposes this request, arguing that greater conducted power levels will inevitably lead to inadvertent or intentional overpowered operation and increased potential for interference.
The Commission finds that increasing conducted transmitter power limits could encourage the use of lower gain i.e., less directional antennas, resulting in less efficient spectrum use and also increasing the potential for causing harmful interference to licensees and protected users. Requiring the use of more highly directional antennas will ensure that less white space device energy is directed outside the main antenna beam than would be the case if higher radiated power were achieved using lower gain, less directional antennas.
Higher Antenna Height Above Average Terrain Limits 10. HAAT limit. The rules currently permit fixed white space devices to operate with a maximum 250-meter antenna HAAT. A white space database will not provide a list of available channels to a fixed white space device with an antenna HAAT that exceeds 250
meters, and such devices are not permitted to operate. The Commission adopted this requirement to limit the distance over which the fixed white space devices would transmit and thus limit the distance at which harmful interference to other TV band users could occur. The antenna HAAT limit also precludes white space devices from operating at certain locations, e.g., those where the ground HAAT exceeds 250
meters. In the White Spaces Order on Reconsideration, the Commission upheld its previous decision to maintain a 250-meter antenna HAAT limit but stated that it might consider increasing the limit in the future if there were a more complete record addressing whether higher HAAT could be permitted without causing harmful interference.
11. In the NPRM, the Commission proposed to increase the maximum permissible antenna HAAT for fixed white space devices operating on channels 235 from 250 meters to 500
meters and sought comment on appropriate procedures that may be necessary to ensure that broadcast operations and other entities in the TV
bands are protected from harmful interference. The Commission noted that increasing permissible antenna HAAT would improve broadband coverage in rural areas by enabling signals to reach greater distances and
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enable fixed white space devices to operate at locations where they are not currently permitted due to the 250meter HAAT limit, such as existing towers located at higher ground elevations. To protect Wireless Medical Telemetry Service and radio astronomy operations on channel 37, the Commission did not propose to permit operation with a higher HAAT in the adjacent channel 36.
12. Several commentersincluding Adaptrum, Broadband Connects America Coalition, Consumer Technology Association, Dynamic Spectrum Alliance, Microsoft, Public Interest Spectrum Coalition, RADWIN, RED Technologies, RTO Wireless, and the Wireless internet Service Providers Association WISPAsupport the proposal to increase the maximum HAAT for fixed devices to 500 meters as a way of promoting expanded coverage.
Broadband Connects America Coalition, Microsoft, Public Interest Spectrum Coalition, and Dynamic Spectrum Alliance also recommend allowing higher HAAT in all areas, not just less congested ones.
13. As proposed, the Commission increases the HAAT limit for fixed white space devices that operate in the TV bands on channels 235 from 250 to 500 meters in less congested areas. As with the Commission decision to increase the maximum power allowed for fixed white space devices, this change will permit fixed devices used in less congested, including rural, areas to reach users at greater distances, thus enabling improved broadband coverage at less cost in these hard-to-reach areas.
This change will also increase the number of locations where fixed white space devices can operate since it will permit white space device operators to use sites where the HAAT of the ground exceeds 250 meters, which would have been precluded under the current rules.
Many parties support this change.
14. While the Commission recognizes that some parties request that it not limit this higher HAAT to less congested areas, the Commission believes that a more cautious approach is appropriate at this time due to the significant increase in HAAT it is allowing and the potential for harmful interference at greater distances, as noted by Smith and Fisher. Therefore, consistent with the Commissions actions increasing the maximum power limit for fixed white space devices, the Commission is restricting operation of white space devices with an HAAT of greater than 250 meters to less congested areas where fewer authorized services and protected entities are expected to be operating in
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the TV bands. Relatedly, because there are expected to be fewer authorized services and protected entities operating in less congested areas, the Commission expects that the separation distances between white space devices and authorized services and protected entities to generally be greater. This combination of fewer potential interactions between white space devices and authorized services and protected entities and greater distance separation minimizes the potential for harmful interference to such services.
Moreover, these white space devices are still required to operate pursuant to the channel availability and power levels provided by a white space database which is designed to ensure that harmful interference does not occur.
While wireless microphone interests express concerns about the impact of increased HAAT on unlicensed wireless microphone operations, restricting higher HAAT operations to less congested areas will serve to limit any impact on users of unlicensed wireless microphones since by definition these areas have multiple vacant TV channels i.e., at least half available for use by other types of unlicensed operations.
The Commission also notes that the rules do not provide harmful interference protection between unlicensed devices. However, because fixed white space device locations are registered in a database, unlicensed wireless microphone users have the ability to check the database and avoid using channels where a higher probability of harmful interference is predicted. In addition to limiting the use of high HAAT to less congested areas, as discussed in more detail below, the Commission is increasing the required separation distances between white space devices operating with higher HAAT and co-channel and adjacent channel TV contours to further minimize the likelihood of harmful interference.
15. Coordination procedure with licensees. The Commission sought comment on whether to require a coordination procedure between white space device operators and broadcast licensees when fixed white space devices operate with an HAAT
exceeding 250 meters. In particular, the Commission requested comment on Microsofts suggested coordination procedure comprised of several steps, including notifying a white space database administrator, notifying broadcast licensees, operating on a test basis on a 30-day trial authorization, as well as a process to submit claims of harmful interference, investigate such
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