White Spaces Update – an Interview with Shure's Mark Brunner
Mark Brunner is the Senior Director of Global Public Relations for Shure Inc., a legendary manufacturer of audio equipment for more than 80 years, and a pioneering innovator in wireless microphone technology. From his pivotal position at Shure, Mr. Brunner is able to comment on and participate in that company's crucial lobbying efforts before the FCC concerning the White Spaces issue, on behalf of the entire wireless mic industry. We're honored that he so graciously took the time from his frantic schedule to answer some questions we thought important to all of us in the wireless microphone community.
Shure's highly proactive participation in the White Spaces debate dates back to late 2004 and you're still on the front lines. How did Shure get involved in the first place?
Actually, our first actions related to this proceeding were in 1997, when we filed formal comments to the FCC to allow wireless microphones to continue to operate in the 700 MHz spectrum slated for public safety assignment until after the DTV transition was completed. Fortunately this was granted, and as the DTV transition lumbered forward – it will be completed in February, 2009 – the FCC issued notices of inquiry and proposed rulemaking related to utilizing the TV "white spaces" for additional services. As the pending loss of 698-806 MHz to public safety and auction became a reality, we focused our attention on FCC docket 04-186 – the White Spaces – which remains open, because this spectrum would become critical for the industry post the DTV transition.
Has the FCC's position on unlicensed White Space devices changed significantly from 2004 until now?
Yes and No. The ultimate goal is to make more efficient use of this precious resource, because it is now recognized by an increasingly wide sector of the economy as an enabler of communication, information, and commerce. The most tangible form of this is in broadband internet services, which can reach more places through the air than through wires. As a geographically large country, the US still has underserved rural areas, with regard to broadband. Solving this problem was the initial primary intent of 04-186. However, as spectrum is made available for new services, opportunities also present themselves in urban areas where large populations can consume new products that benefit from wireless connectivity. So the FCC wanted to determine how much spectrum could be made available to enable these opportunities while being careful not to significantly disrupt current users of the UHF band – television broadcast and professional audio. I believe they are still attempting to be true to these goals.
How heavily involved is Congress in this debate?
Over the course of the debate, proposed legislation related to the White Spaces has appeared in both the House and Senate, and it has represented both sides of the issue – opening up new services and protecting incumbents. As sessions end these bills need to be reintroduced, so if you look at the currently active House bills, I am pleased to say that new co-sponsors continue to be added to HR1320, which was introduced by Congressman Bobby Rush of Illinois to protect incumbent operations from interference by new devices, and the number of HR1320 co-sponsors more than doubles that of HR1597, introduced by Congressman Jay Inslee of Washington, which calls for opening the band to new services immediately. Congressional involvement goes beyond bill sponsorship, though, because many bills do not make it through Committee and on to the floor for vote. One of the most powerful actions is a letter to the FCC Commissioners, because this reminds them that their policy decisions have an affect on the citizens in a legislator's district. We have seen some very powerful communications come from members of Congress representing the entertainment and sports centers of the country, and they factor in to the decision making process. Ultimately, the FCC is accountable to Congress and the legislators can reverse the FCC's actions if they believe it is in the public interest to do so.
Do consortiums such as the White Space Coalition and the Wireless Innovation Alliance carry any real clout with the FCC?
Absolutely. Let's face it, the Wireless Innovation Alliance contains some of the world's most powerful companies, and although some of them are new to the business of radio frequency (RF) products, they are viewed as technology leaders. Our mission with the FCC and with these companies is to educate them on how our products function technically and on the elements of culture and society that are enabled by their use. Only through highlighting these points can we achieve a concern for preservation of our industry's access to spectrum and a technical approach to co-existing with future products and services.
What exactly is cognitive radio functionality and how may it be implemented successfully in White Space device technology? Is the FCC any closer at this time to approving a White Space device based on the prototypes submitted to the OET for testing?
While the technical parameters and definitions may vary, in general, a cognitive radio is one that knows a frequency is open to use, and if a higher priority transmission (such as an incumbent user of the spectrum) enters that frequency, the cognitive radio will move. The action is autonomous and occurs without human intervention. The cognitive radio notion has been at the heart of the White Space debate, with the proposed new entrants relying heavily on this functionality as the key to new services co-existing with incumbents in the TV band. The FCC is still in the process of evaluating prototype platforms intended to demonstrate the first basic function of cognitive radio – spectrum sensing, or detection of an occupied frequency. Shure has held high hopes for cognitive radio, but we are also aware of the challenges. Our personnel have been on hand to observe the spectrum sensing tests when performed with wireless microphones, and while in our view the prototypes have not produced the results we would expect, it remains to be seen whether the FCC will feel it has obtained enough data to proceed to rulemaking. Ongoing data collection on prototypes has been a contributing factor to the proceeding extending beyond its original intended deadline of October, 2007.
What is a disabling beacon? Can you explain how a "smart" beacon system works and how it affects wireless microphone systems? You stressed in a May 7 statement that the purchase of a disabling beacon and the accompanying procedures necessary for its successful deployment placed an unfair financial burden and inconvenience upon wireless microphone customers. How so?
Shure initially proposed the concept of a beacon device that could be deployed in large-scale events to provide additional interference protection against white space devices. In addition to spectrum sensing capability in the new devices, and dedicated clear spectrum for wireless microphones, we viewed the beacon as a third layer of protection for use in mission-critical live productions with large audiences – think Super Bowl or the Academy Awards. The concept is that a beacon could transmit a unique signal that indicates particular frequencies are in use, and the nature of this transmission would make it easily detectable by a portable device. The technical parameters for this new beacon device have been under study by the Institute of Electrical and Electronics Engineers (IEEE), a body the FCC routinely relies upon for input on solutions, and of which Shure is a participant.
Unfortunately, as the primary protection mechanisms of dedicated spectrum and spectrum sensing technology ran into challenges, some of the parties pushed the beacon concept to the forefront as the primary protection solution for wireless microphones – meaning all users would have to obtain and deploy one. There were other complexities with the proposals as well, such as registration in a nationwide database and limited access to certain classes of users. Therefore, as the definition and use case for the beacon concept began to drift from Shure's original concept, we voiced our specific concerns. Shure still believes in its original proposal, however, that beacon technology could be useful when deployed at large-scale events in conjunction with other protections.
Shure has repeatedly stressed the concern that the technology that would allow for interference-free coexistence between wireless mics and WSD's just isn't there yet. Why is the FCC even pursuing unlicensed White Space usage if the interference issues are so dire, and so much licensed spectrum is available for development? What's the rush?
Economics. The companies interested in this spectrum believe that innovation will result if they are given the opportunity to create new wireless devices without the burden of paying for spectrum. If you remember where we started, the primary goal was to deliver greater broadband access to rural America. It has been stated by some White Space Coalition members that filling this need alone does not provide the economies of scale that make it an attractive investment, and this is where the situation gets sticky with the incumbent users, because the potential for interference is greatly increased when we consider new devices in populated areas.
Do you find the FCC's spectrum reallocation to be fair and of a long-term public benefit?
We still hold high hope that if the FCC makes changes in the TV spectrum allocation that these changes will be fair and of benefit to the public. We recognize the complexities of the issue, and that's why we have been working constructively with the FCC all along the way – in order to ensure that any new uses don't come at the expense of existing ones. Shure believes in wireless innovation. We're a wireless company. A cornerstone of our efforts has been to remind the FCC and these enthusiastic technology companies that our relatively small industry has been operating successfully in the TV spectrum for more than 20 years, that we have created significant benefits to society by doing so, and that wireless technology is not simple science. It takes work to perfect.
Mark, from of all of us at the B&H Pro Audio Newsletter and our thousands of wireless microphone customers, thanks so much to you and your company for your time and effort on behalf of the wireless microphone community. Who says there aren't any heroes left?
Thanks to Mark Brunner and all at Shure Inc. for permission to use the charts shown in this interview.