
WASHINGTON-NAB, in reply to comments regarding the FCC's TV white space (TVWS) device proposed rulemaking notice, told the commission that consistent with Part 15 rules and as a matter of law that harmful interference from an unlicensed service must not be allowed to cause harmful interference to licensed users.
In the filing, the association said it and Microsoft had worked for several months to negotiate a set of beneficial adjustments to the FCC's existing rules that would allow improvement in TVWS service while protecting TV broadcasters from interference.
Unfortunately, some commenters seek to expand the scope of this proceeding into areas that have already been fully debated and where there have been no new developments that would warrant changes, said NAB in its comments.
The baseline for any adopted rule changes must be that they don't increase the risk of harmful interference, it reiterated.
The association urged the FCC to dismiss what it dubbed extraneous proposals, such as alternative propagation models, power increases and reduced frequency coordination requirements, because the agency cannot conclude they will not increase the potential for harmful interference, the filing said.
PLUS: Senators Push for FCC Action on White Spaces
In opposition to the assertion of the Public Interest Spectrum Coalition (PISC) and the Wireless Internet Service Providers Association (WISPA) that television service is overprotected based on free-space propagation models and worst-case assumptions about TV receiver performance, NAB told the FCC that contour protection is the only reasonable way to protect consumer TV receivers, which operate as hidden nodes.
NAB reminded the FCC that the contours used to protect TV service in an area are from the empirically derived R-6602 propagation curves as codified in the Commission's rules, not on free-space propagation.
Further, it told the FCC that TVWS protection requirements are relaxed when compared to the commission's other broadcast protection rules. It also disputed a WISPA assertion that ATSC 3.0 is more robust against interference, saying there is no basis for the statement.
The Commission should not change its protection methodology with respect to television receivers until a far more substantial technical record based on real world experience with ATSC 3.0 deployments is available, NAB said.
The association told the FCC that it should not permit increased transmitter power for TVWS devices. Doing so inevitably will lead to inadvertent or intentional overpower operation, it said.
NAB also told the commission that it should allow geo-fenced TVWS operation but that restrictions are warranted and that the protection distances for T-Band land-mobile radio protection should be increased.
The association recommended the FCC adopt Microsoft's proposed coordination requirement for TVWS operations where the height above average terrain (HAAT) exceeds 250 meters.
NAB continues to believe that the alternative notification process suggested in the NPRM will lead to interference that will be difficult to identify, it said. However, if the commission favors the notification process rather than Microsoft's proposed coordination procedures, the advanced notice should be longer than 48 hours.
NAB also urged the FCC to maintain rules for first-adjacent channel operation. Microsoft submitted test results it said supported allowing higher power on first-adjacent channels. NAB countered that those tests only used 2018-2019 model TV receivers, which provides no useable information whatsoever with respect to older receivers, NAB said.
Similarly, Microsoft used an ATSC 3.0 dongle costing about $1,000 and marketed as a professional grade receiver to test first-adjacent channels with respect to NextGen TV. The consumer ATSC 3.0 receiver market is plainly in a nascent stage, and without a wider base of tested receivers the Commission cannot draw any conclusions about the susceptibility of future 3.0 receivers to interference, it said.
NAB also asked the commission to reject adjustments to TVWS protections based on the use of directional antennas. While it agrees that directional antennas can reduce the potential for interference, there is absolutely no way of determining whether a directional antenna has been installed properly without the help of a licensed land surveyor, it said.
NAB concluded by urging the FCC to move forward in an expeditious manner with the proposals set forth in the NPRM that are uncontroversial and technically supported.
The NAB comments are available in full online.
North America Stories
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
06/08/2026
At this year's SET EXPO, PlayBox Neo will present recent innovations across its PlayBox Neo Suite and integrated range of broadcast media solutions. By show...
06/08/2026
Live demo at IBC2026 VisualOn Booth, Hall 5, Stand A55
Amsterdam, Netherlands Modern Streaming Solutions Private Limited, a rising force in India's dig...
06/08/2026
How Karukera Studio Built a Media Production Hub with SNS EVO
Melanie Ciotti August 5, 2026
0 Comments
Hero images displays Karukera Studio in Sainte-...
06/08/2026
NHK drama series Rosanjin no Kamado shot on PYXIS 6K
Brie Clayton August 5, 2026
0 Comments
Blackmagic PYXIS 6K and DaVinci Resolve Studio capture the...
06/08/2026
Camera Match: AutoSetup 3d Plugin / script for Photomontages- Cinema 4D
Jamie Cardoso August 5, 2026
0 Comments
If you do any kind of Architectural Vi...
05/08/2026
RSNs, teams, leagues, and streamers explore the present and future of local spor...
05/08/2026
As sports-production workflows generate larger volumes of unstructured data and ...
05/08/2026
Three aspiring broadcasters will contribute on-camera and inside the production ...
05/08/2026
Adam Meeks attends the premiere of his film Union County, an official selection of the 2026 Sundance Film Festival. (Photo by Jemal Countess/Sundance Institut...
05/08/2026
Advertisers invested $53.6 million in the retirement sector in the last 12 month...
05/08/2026
Nielsen CMI and Ad Intel data reveals who's visiting IKEA, where else they s...
05/08/2026
Media buyers and sellers can now compare deduplicated campaign reach across computer, mobile, connected TV and linear TV across all measurable CTV publishers in...
05/08/2026
Stranger Things' Leads All Streaming Titles with 23.3 Billion Minutes in Fir...
05/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
05/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
05/08/2026
QuickLink, the leading provider of award-winning video production and remote guest integration solutions, announces the appointment of Kane Peterson to its Nort...
05/08/2026
XR research reveals marketers believe they have control over production costs, yet budget overruns, campaign delays and creative cutbacks remain commonplace
Se...
05/08/2026
Game On Live Studio Uses Blackmagic Design to Stream Tropical 7s
Brie Clayton August 4, 2026
0 Comments
Every match of world's largest youth rugby...
05/08/2026
Chris Fitzgerald to Head TDC's Experiential Growth
Brie Clayton August 4, 2026
0 Comments
Technical Direction Company promotes Chris Fitzgerald to...
05/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
05/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
05/08/2026
Profuz Digital is set to launch a powerful upgrade to its Profuz LAPIS digital media management platform at IBC this year at Stand 8.A88. France Galop, Canal+ F...
05/08/2026
KRK, a Gibson brand and leader in professional studio monitoring for nearly four decades, launches its new V Series Five Studio Monitors, the latest evolution o...
04/08/2026
Live production in the cloud is a growing trend across the industry, and Major L...
04/08/2026
LAFC co-managing owner will succeed Don Garber on Jan. 1, 2027, as league prepar...
04/08/2026
In 2022, when the PGA TOUR was breaking ground on its new, state-of-the-art broa...
04/08/2026
Provided by POVORA, the new camera angle offers a dealer's-eye view of the c...
04/08/2026
Spiideo will provide the camera setup, with NEP handling broadcast integration and off-site video operations...
04/08/2026
Production team streamed more than 750 youth rugby matches using ATEM switchers,...
04/08/2026
Agreement gives KTC early access to NDI's Advanced SDK for integration across commercial displays, digital signage, and interactive panels...
04/08/2026
Twelve projects across four categories recognize collaborative work in productio...
04/08/2026
Multi-year agreement will introduce SkeleTRACK, semi-automated offside, automate...
04/08/2026
Three mc 56 consoles, dual A__UHD Core engines, RAVENNA networking, and HOME management supported live sound, monitoring, and international broadcast production...
04/08/2026
New contribution products support ultra-low-latency video transport across fixed, remote, and mobile production environments...
04/08/2026
Company will showcase updates across PRIME, Chyron LIVE, Paint, virtual production, newsroom workflows, and venue control...
04/08/2026
Exhibit will feature SilverBack, VersaBrix, VersaFrame, VF-9100, and FiberSaver-10G platforms...
04/08/2026
Platform updates target cloud-based production, high-density ST 2110 monitoring,...
04/08/2026
Live Media Group will take control of Gravity Media's U.S. mobile-unit fleet...
04/08/2026
Blendkit Expands Beyond Blender
Brie Clayton August 4, 2026
0 Comments
Popular 3D Asset Library Launches Alpha Plugins for Maya, Godot, and Rhino
Blend...
04/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
04/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
04/08/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
04/08/2026
Ikegami has chosen the 11-14 September 2026 International Broadcasting Convention in Amsterdam as the European market launch venue for additions to its UNICAM p...
04/08/2026
Appear (IBC2026 booth 1.C61) will showcase new X & VX Platform capabilities that extend broadcast-grade performance from venue to cloud
Appear ASA (OSE: APR), ...