December 10, 2009

Unlicensed Operation in the TV Broadcast Bands, ET Docket No. 04-186

Category: Press Releases

Dear Julie,
I write on behalf of Microsoft Corp. regarding petitions for reconsideration ofthe Commission’s White Spaces Order addressing protection for authorized Part 74 wireless microphones. Thepurposeofthisexparteistoproviderealworlddataandanalysis demonstrating that the existing criteria for both wireless microphone protection radii and white space device sensing requirements are overly restrictive.
As the attached report by Shared Spectrum Company (“SSC”) explains, man-made noise is a significant and frequently dominant factor in wireless microphone operation that should be taken into account when defining white space device operating parameters. Disregarding man-made noise leads to the conclusion that excessively large exclusion zones and extremely low sensing thresholds are required to protect wireless microphone operations. Conversely, accounting for man-made noise permits the creation of significantly less restrictive requirements for sensing thresholds and exclusion zones that will still provide sufficient protection for authorized wireless microphone operations. Specifically, SSC’s analysis demonstrates that exclusion zones of 130 meters and sensing thresholds less sensitive than -Ill dBm would more than adequately protect wireless microphones. Indeed, these parameters are quite conservative.
I hope you will find the attached technical analysis helpful.    We would be pleased to organize a session with you to discuss these findings in more detail. Pursuant to the Commission’s rules, a copy ofthis letter is being filed electronically in the above-referenced docket. Ifyou
require any additional information please con
dersigned.
Cc: Dr. Rashmi Doshi Walter Johnston
1200 18TH STREET, NW I SUITE 1200 I WASHINGTON. OC 20036 I TEL 202-730-1300 I FAX 202-730-1301 I WILTSHIREGRANNIS.COM

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