
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
22/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
22/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
22/07/2026
Proven managed IP solution helps broadcasters confidently navigate the future of broadcast distribution
LTN announces it has completed successful satellite-to-...
22/07/2026
Today, Chaos announced V-Ray 7, update 4, eliminating the need for asset conversions and tool switching, which slow down media and entertainment pipelines. Arti...
22/07/2026
An AI playground for the Project Indigo camera app
Marc Levoy July 22, 2026
0 Comments
At left is the user interface of our Playground, running on an ...
22/07/2026
Custom Consoles announces the completion of a large technical furniture project for Radio T l vision Suisse (RTS) at the networks recently inaugurated productio...
22/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
22/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
22/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
22/07/2026
Culver City, CA, July 21, 2026 3D streaming infrastructure provider Miris today announced glTF intake, including the binary .glb form, to its spatial streamin...
22/07/2026
Documentary Lo Invisible Captured with Blackmagic PYXIS 6K
Brie Clayton July 21, 2026
0 Comments
Camera's versatile design allowed filmmakers to c...
22/07/2026
AAF Bridge converts AAF and XML Timelines to Ableton Live - and back
Jerome Gardier July 21, 2026
0 Comments
A two-way converter for macOS and Windows...
22/07/2026
From Class to Concert: Explore a Student-Led Production of David Bowies Work Thr...
22/07/2026
Before a healthcare robot can be useful in the real world, it has to learn how the physical world pushes back. Anatomy varies. Instruments bend, press, slip and...
21/07/2026
With winners Spain having already paraded the World Cup trophy through Madrid in front of millions of fans and the dust now settling on an epic tournament of th...
21/07/2026
In a time of disarray in regional sports broadcasting, the league will provide c...
21/07/2026
When NEP designed one of its largest recurring mobile production unit fleets for PGA TOUR
coverage, the leading media services provider faced a familiar challe...
21/07/2026
Warner Bros. Discovery's unbroken lead is interrupted as sports and live mus...
21/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
21/07/2026
Across the TV and streaming ecosystem, industry players face mounting pressure to do more with less. They must simplify operations, protect premium content and ...
21/07/2026
Tuxera, a leading prover of quality-assured file systems and networking technologies, is bringing its latest advances in connectivity performance to the media w...
21/07/2026
COW Jobs: Apple Motion Expert for Custom FCP Rigged Graphics Package
Brie Clayton July 21, 2026
0 Comments
HIRING: Apple Motion Expert for Custom FCP ...
21/07/2026
Cinegy GmbH, the premier provider of software-defined television technology, will use its presence at IBC2026 (stand 7.A01, Amsterdam RAI, 11 14 September) to...
21/07/2026
Calrec will be located in Hall 8, on Stand C47
Beyond bigger
For years, broadcast facilities were built around one assumption: provision for the biggest pro...
21/07/2026
Pebble, the leading automation, content management and integrated channel specialist, will discuss its future-facing developments for the new generation of medi...
21/07/2026
nxtedition returns to IBC2026 with its consolidated production platform, showing how scripting, editing, graphics, AI-assisted tools and automation can work wit...
21/07/2026
C2PA content signing helps broadcasters, public institutions, and publishers give audiences a verifiable record of where their video content came from and how i...
21/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
21/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
21/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
21/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
21/07/2026
New capability centralizes collaboration, feedback, security and status tracking within VIDA, providing a structured, auditable approach to master quality contr...
21/07/2026
Lightcraft Launches Exclusive Spark Story Beta for Filmmakers and Creators at SI...
21/07/2026
Indie Road Movie Where in the Hell Shot with Pocket Cinema Camera 4K
Brie Clayton July 20, 2026
0 Comments
Colorist blends vintage film looks to shape...
21/07/2026
Which USS Defiant Pulse Phaser effect is better?
Graham Quince July 20, 2026
0 Comments
Aargh, ever since @DarkRavenProductions posted a comment ask...
21/07/2026
The AI era runs on AI infrastructure. Many of these advanced systems are built a...
21/07/2026
Every live event starts with a defining moment. A camera captures the game-winni...
21/07/2026
AI has entered the gigascale era.
The world's most advanced AI factories are bringing together hundreds of thousands of GPUs and CPUs to train frontier mod...
21/07/2026
NVIDIA Vera Rubin is here, and it's going gigascale.
Vera Rubin NVL72 produ...
20/07/2026
The former Northwestern broadcast-operations leader is helping train the next generation of live-sports-production talent across the Big Ten
The sports-product...
20/07/2026
By Lucy Spicer
One of the most exciting things about the Sundance Film Festival is having a front-row seat for the bright future of independent filmmaking. Whi...
20/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
20/07/2026
Share
Copy link
Facebook
X
Linkedin
Bluesky
Email...
20/07/2026
Starfish Technologies will use IBC2026 to showcase the flexibility of its transport stream processing software, including the latest versions of TS Splicer (Win...
20/07/2026
Bitfocus, the specialist in media control and monitoring, will show at IBC2026 (Elgato stand 8.D31, Amsterdam RAI, 11 14 September) how its Buttons control la...
20/07/2026
Mediagenix, a global leader in smart content solutions to profitably connect the right content to the right audience, today announced new AI capabilities that e...
20/07/2026
Big Blue Marble's Cloud DRM has been nominated in the DRM/Content Protection category of the 2026 Streaming Media Readers' Choice Awards.
Only four pro...
20/07/2026
At this year's SIGGRAPH conference, running through Thursday, July 23, in Lo...
20/07/2026
Erin Davis calls it the SuperDuperPOD. That's two things in one name: phar...
19/07/2026
Justin Bieber, Madonna, Shakira, BTS make for a diverse lineup, and the venue ad...