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
06/12/2025
In a live broadcast from the Reagan National Defense Forum, L3Harris Chair and CEO Christopher Kubasik joined Morgan Brennan on CNBCs Closing Bell: Overtime. Ku...
06/12/2025
FORT LAUDERDALE, Fla. A new survey from Pixitmedia by Datacore revealed a major shift in the Media & Entertainment industry in media archiving, with 85% of resp...
06/12/2025
HACKENSACK, N.J. LiveU has announced that the national public broadcaster Czech Television has completed one of the largest LiveU live production deployments fo...
06/12/2025
NEW YORK The National Academy of Television Arts and Sciences (NATAS) presented the Excellence in Production Technology Emmy Award to NASA+ and Dr. Tom Leight...
05/12/2025
2025 Sports Broadcasting Hall of Fame: Curt Gowdy Jr. - Master Storyteller, Nati...
05/12/2025
SVG Sit-Down: Veritone's Sean King on the Power of Mining Video, Audio DataThe company's Data Refinery offers users total control and governance over da...
05/12/2025
Platinum White Paper: Inside the Nashville Predators' Unified, Flexible, Sca...
05/12/2025
Netflix Reaches Agreement To Acquire Warner Bros. Following Planned WBD SplitThe deal does not include WBDs sports assets like TNT Sports (US, UK, LatAm), Euros...
05/12/2025
FOX Sports Returns to Indianapolis for Primetime Broadcast of Big Ten Championsh...
05/12/2025
SVG Summit 2025 Preview: Digital Engagement & Monetization Workshop Tackles the ...
05/12/2025
Atlanta United Lights Up New Emory Healthcare Studio With First Live Broadcast f...
05/12/2025
As Messi Takes the Pitch, MLS, Apple, NEP Roll Out Largest MLS Cup Production Ev...
05/12/2025
ESPN Enters College Football's Most Intense Month With Elevated Workflows fo...
05/12/2025
It's about that time! Awards season is in full swing, and the Film Independe...
05/12/2025
LOS ANGELES Netflix announced it has entered into an agreement to acquire the assets of Warner Bros. for $82.7 billion....
05/12/2025
NEW YORK Nielsens Gracenote has launched Gracenote Content Connect, a new ad platform that provides agencies, brands, supply-side platforms (SSPs) and demand-si...
05/12/2025
NEW YORK In an most important update to the workings of deal-based programmatic advertising, IAB Tech Lab has released version 1.0 of its Deals API for public c...
05/12/2025
NEW YORK Pass the turkey. Pass the stuffing. Pass the cranberry sauce. All are common requests of Americans celebrating Thanksgiving Day with family and f...
05/12/2025
NEW YORK Iris, the new cloud-connected camera control platform, has officially launched with features that turn virtually any PTZ camera into a software-connect...
05/12/2025
HOLLYWOOD, Calif. Netflix announced today that it has entered into an agreement to acquire the assets of Warner Bros. for $82.7 billion....
05/12/2025
NEW YORK Iris, the new cloud-connected camera control platform, has officially launched with features that turn virtually any PTZ camera into a software-connect...
05/12/2025
WASHINGTON The Federal Communications Commission has approved AT&T's $1.02 billion acquisition of spectrum from UScellular in a decision that was issued sho...
05/12/2025
The Best Coldplay Songs: 21 Tracks That Shoot for the Stars From Yellow to Viva La Vida, Fix You to Paradise, this playlist goes back to the start.
December ...
05/12/2025
Zafris Lecture Series Brings Nabil Ayers to Berklee The 32nd annual James G. Zafris Distinguished Lecture series was held on Thursday, November 13, with guest...
05/12/2025
Back to All News
Netflix Unveils the First Look for Land of Sin' - Premier...
05/12/2025
Introducing New Perks to Help You Get Even More from LinkedIn Premium Published on Dec 5, 2025 Categories: Company News, Product News
LinkedIn Corporate Co...
05/12/2025
Back to All News
Don Lee, Lee Jin-uk, and Lalisa Manobal to Star in Netflix Act...
04/12/2025
SVG Sit-Down: ProximaVision's Claudio Lisman on Why Tethered Drones Could Be...
04/12/2025
SVG Campus Shot Callers: Imry Halevi, Senior Associate Director of Athletics, Co...
04/12/2025
Platinum White Paper: LiveU Lightweight Sports Production: A Step Change in Spor...
04/12/2025
London to Riyadh: DAZN brings the boxing glamour to new production levels for Be...
04/12/2025
Analysis: Paramount bets on the battering ram' with Champions League play By Callum McCarthy, Editor-at-Large
Tuesday, December 2, 2025 - 10:12
Print ...
04/12/2025
Space City Home Network Launches SCHN DTC App for Astros and RocketsThe Rockets and Astros were previously the lone NBA and MLB teams without a DTC appBy Jason...
04/12/2025
SVG Summit 2025 Preview: Content Workflows Workshop Spotlights Evolution of Spor...
04/12/2025
New Sponsor Spotlight: Geotech's Patrick Wambold On the Unreal Engine Revolu...
04/12/2025
Curt Gowdy Jr. - Master Storyteller, Nationally and RegionallyBy Jason Dachman, Editorial Director, U.S.
Thursday, December 4, 2025 - 1:52 pm
Print This Sto...
04/12/2025
(L-R) Rebecca Lichtenfeld, Mohammadreza Eyni, Sara Khaki, and Judith Helfand att...
04/12/2025
Coronal mass ejections caused by eruptions on the surface of the sun can have fa...
04/12/2025
Gracenote Content Connect enables media ecosystem to precisely align ad campaigns and programming based on rich content signals
NEW YORK - December 4, 2025 - N...
04/12/2025
Lightware, a global specialist in AV connectivity, is looking back on a year defined by new advancements, strong collaboration and continued growth. Across the ...
04/12/2025
Riedel Communications today announced a new partnership with Haivision, a leading global provider of mission-critical, real-time video networking and visual col...
04/12/2025
Harmonic (NASDAQ: HLIT) and Normann Engineering today announced a major milestone in their strategic collaboration, celebrating 20 successful broadband deployme...
04/12/2025
Creative software developer Foundry today announced Mari 7.5, the latest iteration of its artist-friendly paint toolset that can handle large, detailed assets w...
04/12/2025
Professional Wireless Systems (PWS), a leading provider of wireless audio solutions and RF management, was on site at Dreamforce 2025 in San Francisco providing...
04/12/2025
LTN's purpose-built IP video network brings all-movie diginet to over 100 stations and streaming platforms in just three months while eliminating satellite ...
04/12/2025
Bitmovin, the leading provider of video streaming solutions, today announced a strategic partnership with ThinkAnalytics, the global leader in AI-powered data a...
04/12/2025
The HELM, a global expert in cinematic live broadcast and high-end production workflows, has signed a partnership agreement with Keslow Camera, one of North Ame...
04/12/2025
At ISE 2026, LiveU will showcase its expanded IP-video EcoSystem, enabling broadcasters, sports, production companies and pro-AV professionals to share their st...
04/12/2025
Since the beginning of commercial television, advertising has been a key part of broadcasting. Over the years, the technology for inserting ads into programs ha...
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.
