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
25/12/2025
Holiday lights are twinkling, hot cocoa's on the stove and gamers are settling in for a well-earned break.
Whether staying in or heading on a winter getawa...
24/12/2025
What is AI good for? Posted by MTI Film on December 24, 2025
What is AI good for?
What is AI good for?
It's been three years since ChatGPT first cap...
24/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
24/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
24/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
24/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
24/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
24/12/2025
Back to All News
The Boyfriend' Season 2 Unveils Heartwarming Trailer, Key...
24/12/2025
Back to All News
Love, Fights, and Everything in Between: Badly in Love' Returns for Season 2
Entertainment
24 December 2025
GlobalJapan
Link copied t...
24/12/2025
Scripps Research study links sleep variability with sleep apnea and hypertension How consumers' digital activity trackers could enable personalized health s...
23/12/2025
How guilas Cibae as Dominican Winter League Games Are Locally Produced for Glob...
23/12/2025
BitFire's Jim Akimchuk on Supplying Scalability and Customization in the Clo...
23/12/2025
CAMB.AI Enables European Athletics to Offer Multi-Language SupportPlan is to eventually offer translation into all languages spoken in EuropeBy Ken Kerschbaumer...
23/12/2025
Analysis: As sports media values trend negative, scarcity and quality are king By Callum McCarthy, Editor-at-Large
Monday, December 22, 2025 - 14:08
Print ...
23/12/2025
ESPN, Disney, and NBA Return to the Animated Altcast Fray With Second Edition of...
23/12/2025
End the Year on a High Note and Donate to the Sports Broadcasting Fund Today! By Ken Kerschbaumer, Editorial Director
Tuesday, December 23, 2025 - 12:25 pm
...
23/12/2025
A Zeus motor is hot fire tested at L3Harris' Camden, Arkansas, solid rocket ...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Lightware will exhibit several major product innovations at ISE 2026, including the new USB-C BOOSTER-V1, Google Meet. integration for various Taurus UCX models...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
23/12/2025
Taking the Stage at Carnegie Hall-On a Global Scale Boston Conservatory Orchestra students reflect on their epic concert marking the 80th session of the UN Gene...
23/12/2025
Back to All News
Netflix's The Great Flood and Culinary Class Wars 2 Top Gl...
23/12/2025
Back to All News
Stranger Things By the Numbers: How the Global Phenomenon Shap...
23/12/2025
Experience the power of WO Automation for Radio's newest service, the System Effectiveness Review. Designed to help you achieve more, a System Effectiveness...
23/12/2025
Back to All News
How Steamy Can It Get? Single's Inferno' Season 5 Pre...
23/12/2025
Back to All News
33 Million Global Viewers on Netflix Watched Jake Paul vs. Ant...
23/12/2025
New technique lights up where drugs go in the body, cell by cell Scripps Research scientists developed a technique that maps drug binding in individual cells th...
22/12/2025
SVG New Sponsor Spotlight: Presidio's Neerav Shah on the Role of Its Captiva...
22/12/2025
Hitting the bullseye: Sky Sports readies itself for the biggest PDC World Darts ...
22/12/2025
Unique skillset: Bringing new directors to the world of darts at The Worlds with...
22/12/2025
Gravity Media prepares for a flight of fancy with the PDC World Darts Championsh...
22/12/2025
One hundred and eighty: Gravity Media on hitting the production bullseye at the ...
22/12/2025
The Famous Group's Jon Slusser on Fascinating Fans Through Immersive Content...
22/12/2025
ESPN's Meg Aronowitz on Continuing High-Quality Broadcasts of Collegiate Spo...
22/12/2025
ESPN Takes Data-Driven Storytelling to New Heights with MNF Playbook with Next ...
22/12/2025
Paramount Scores Largest Share Increase Among Distributors as Paramount and CBS...
22/12/2025
New multi-year deal integrates Roku's data to fuel Nielsen's measurement suite
Roku gains access to Nielsen's streaming ratings, showing The Roku C...
22/12/2025
Share Share by:
Copy link
Facebook
X
Whatsapp
Pinterest
Flipboard...
22/12/2025
Berklee Wrapped 2025: Our Top News and Stories A look back at a year highlighted by faculty milestones, major film and television projects, Bob Dylan's ho...
22/12/2025
The works of Plato state that when humans have an experience, some level of change occurs in their brain, which is powered by memory - specifically long-term me...
22/12/2025
Workflows allow you to create a sequence of planned events which may be added to your template(s) or inserted directly into your sequential or background playli...
22/12/2025
Back to All News
Global Anime Hits and New Releases Take Center Stage at Jump Festa 2026
Entertainment
22 December 2025
GlobalJapan
Link copied to clipboar...
21/12/2025
Back to All News
Legoshi and Haru's Story Reaches Its Finale: BEASTARS Fin...
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.
