It's pretty clear what Google (NASDAQ: GOOG) thinks of the National Association of Broadcasters' (NAB) "emergency" petition asking the FCC to fix serious design flaws in its TV white space (TVWS) database system. In a word, "preposterous" might sum it up.
The TVWS database system is supposed to keep track of channels in use by TV stations and others so that unlicensed devices using the white spaces do not cause interference. But after flaws were found, the FCC said it was working to correct the issues.
The NAB had asked the commission to consider suspending database operations until flaws could be worked out. But Google wants the FCC to dismiss NAB's rulemaking petition "without further proceedings."
"Despite its theatrical title and overheated rhetoric, the National Association of Broadcasters' (NAB) 'emergency' petition for rulemaking identifies no actual interference or other harm to its member broadcasters, no failure of any FCC-certified television white space database, and no violation of any Commission rule," Google said in its FCC filing.
To hear Google tell it, there aren't any real serious problems--and certainly none that warrant significant changes or suspension of the system. Google explains that the individual database entries that NAB brands as "false" are likely test entries used by device manufacturers and database administrators to ensure that the broadcaster-protection system is working properly.
NAB said it conducted multiple analyses of the TVWS database over the past year, and at various points, more than one-third of the fixed TV band devices in the database contained "patently inaccurate location information," including multiple devices registered in the middle of empty fields or to a single family home, and some were even registered in foreign countries.
Google has an explanation for much of that. It says that none of the fictitious names, addresses and device serial numbers were used by database administrators to determine proper operating channels for unlicensed devices. "These fields are informational only, and have no operational significance," Google said, adding that the contact names, addresses and serial numbers cited by NAB most likely represent "innocent test entries." For example, contact names such as "first_last" or "Meld_test" are clearly tests, it said. Meld Technology is a company in Sunnyvale, Calif., that makes white space devices.
Likewise, serial numbers such as "test" and "SN-0000" are "most likely test numbers." And while it may not have been a best practice to accompany those entries with generic address information, "there is no reason to suspect that these entries represent actual devices in the field that could interfere with reception of TV broadcasts," Google said.
In addition to a request for a rulemaking, NAB asked for the emergency suspension of white space database operations. "The latter request is absurd, as NAB cannot point to a single broadcaster or television viewer harmed by the use of white space devices," the search giant said. "NAB grudgingly concedes that broadcasters and viewers have experienced 'minimal or no impact' as a result of alleged inconsistencies in database entries--and even that is an overstatement, for there has been no harm at all."
Google says that "at best, NAB has cobbled together inconsistencies that could be fixed by better housekeeping on the part of device manufacturers and additional clarification from the Commission regarding database record retention, none of which presents a danger of actual interference to broadcast operations. There is no emergency suggesting suspension of white space database operations."
Google said it is working with other white space database providers and commission staff to develop additional best practices regarding data validation and information exchange. Four companies operate white space databases: Google, Telcordia, Spectrum Bridge and Key Bridge.
Google had previously knocked NAB for its emergency petition, but its May 1 filing takes it a step further.
In an April filing regarding the 3.5 GHz band, Google said NAB's petition identified no actual interference or other harm to its member broadcasters. At that time, Google said the FCC had requested public comment on NAB's petition in another docket, so it didn't need to be considered in the 3.5 GHz proceeding.
- see this Google filing
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