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Sennheiser Petitions FCC for Compensation from Spectrum Loss


Scott Smith

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Sennheiser announced today that they have filed a petition with the FCC to compensate owners of wireless equipment which will be made obsolete due to the coming auction of the 600 mHz band. Some of you may be familiar with how this was handled in the UK, where the government compensated individuals whose equipment was rendered unusuable due to re-allocation of spectrum.

 

Don't know if this will fly in the good 'ole US of A, but you never know. Press release here:http://en-us.sennheiser.com/news-sennheiser-petitions-fcc-to-compensate-owners-of-wireless-microphone-equipment-as-spectrum-faces-repacking-for-second-time-

 

--S

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Interesting proposal. I think this is the document Sennheiser submitted (link to PDF):

http://apps.fcc.gov/ecfs/document/view?id=7520955639

 

But note that it appears to be one of 910 filings on the issue:

http://apps.fcc.gov/ecfs/proceeding/view?name=12-268

 

Lots of reading for someone...

 

I've just glanced through Sennheiser's document. This bit looks to be the core proposal for calculating compensation:

 

post-286-0-32976500-1385605637_thumb.png

 

 

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Agreed. Im not entirely concerned with my old G2s and G3s, theyve lived a useful life and Ive made my money back from them, but my SMQVs, SRb's, UCR411a's, UCR211s, etc etc... those are all quite pricey, and would seriously impact any one of us and our business if we all of a sudden had to throw them away and replace them with other models that will eventually end up in the dump too due to the same problem we face in auctioning off spectrum.

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"Lots of reading for someone... "

but certainly not for the folks who will end up imposing this stuff...

remember the 3k pages of Obamacare ..?

 

" If anyone at Sennheiser is pay attention to this thread: "

as I don't recall any official input from Sennheiser here, perhaps you ought to call them in Olde Lyme..?

 

" How big a bite is this going to be?  Are we talking pretty much everything between 600-700mhz?  And when is this scheduled to take place? "

you'll have to pay attention, as they are still deciding the specifics;

there would seem to be two possibilities for you:  either it will affect you, or it will not.

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FYI: I have already been in contact with Sennheiser, and will pass along info on the best way for us to support their petition sometime next week. This will be in the form of letters supporting the petition, which will be submitted to Sennheiser, who in turn will have their law firm submit them as "ex parte" comments (you cannot address communications directly to the FCC. This helps keep the law firms and lobbyists in business). Action on this will probably take place before the end of the year, so it's coming up quickly.

 

Impossible to say how big a chuck of the 600 mHz band we will lose-it's all dependent on the auction. However, the current thinking is that we stand to lose everything from ch 51 down to 37 (86 mHz worth). Happy Holidays to you from the FCC!

 

--S

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(you cannot address communications directly to the FCC. This helps keep the law firms and lobbyists in business). 

 

Perhaps I'm misreading your comment, Scott. But my understanding is that just about any person or group (e.g, CAS) can submit comments about this proceeding by filling out the form and attaching a document here:

http://apps.fcc.gov/ecfs/upload/display?z=tk361

 

An example, I think, is this letter from Lectrosonics (and signed by Karl Winkler) supporting Sennheiser's effort:

http://apps.fcc.gov/ecfs/comment/view?id=6017476787

Karl or Larry or someone can probably correct me if I have this wrong.

 

Maybe having Sennheiser present your comments to the FCC will be helpful. But you can communicate with the FCC directly. At least, I have both as a citizen and a journalist.

 

Again…I could be missing something here.

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Jim:

 

I will have to check on this. Based on previous conversations I've had with Shure Inc. and others, it has been recommended that letters of support be submitted through legal counsel. I don't know if it's because letters submitted this way carry additional weight with the FCC (as opposed to simply filing comments), or if's just an easy means to gather together all documents in support of a petition. Will get further clarification and report back.

 

--S

Perhaps I'm misreading your comment, Scott. But my understanding is that just about any person or group (e.g, CAS) can submit comments about this proceeding by filling out the form and attaching a document here:

http://apps.fcc.gov/ecfs/upload/display?z=tk361

 

An example, I think, is this letter from Lectrosonics (and signed by Karl Winkler) supporting Sennheiser's effort:

http://apps.fcc.gov/ecfs/comment/view?id=6017476787

Karl or Larry or someone can probably correct me if I have this wrong.

 

Maybe having Sennheiser present your comments to the FCC will be helpful. But you can communicate with the FCC directly. At least, I have both as a citizen and a journalist.

 

Again…I could be missing something here.

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There is a deadline for submitting comments on this proceeding. I don't know what it is (I thought it expired, but it looks like the NAB filed some stuff earlier this week). So consider if you have time to wait for a response from Shure or Sennheiser.

 

It looks like the form for 12-268 is still active. But again, I don't know how much longer it will be.

 

A FCC contact for this docket who might be able to answer you questions, but would probably do so in a CYA way (note that I've interacted with several helpful FCC people, but they do work in Wash DC):

Paul Murray

(202) 418-0688

Paul.Murray@fcc.gov

 

Or the general comment filing help email:

ecfshelp@fcc.gov

 

 

Based on my past experience covering the FCC, they take comments seriously. And it seems they like comments from organizations (such as CAS). They also take face-to-face meetings, conferences, and hearings seriously. So if you can get a clear answer from Shure, Sennheiser (and perhaps Karl from Lectro since he's filed and is of course concerned about this proceeding) about why not submitting your own comment directly with the FCC is a good idea, then hold off.

 

Otherwise, my non informed opinion is it wouldn't hurt to file a comment directly, then tell Sennheiser, Shure, or whomever that you did so. Then they can say something like "XX individuals and YY groups representing ZZZZ people using wireless microphones have directly expressed concern about this topic." Or whatever.

 

At this point, I don't have an opinion on these matters…the proceeding, Sennheiser's proposal, and how you can best communicate you concern to the FCC...

 

Good luck.

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You can sell your units in 600-700, to other countries such as Australia.

Sennheiser gear I don't know, but with Lectrosonics and Zaxcom it's worth re blocking if the units are new enough. Zaxcom and Lectrosonics will re block current gear for a reasonable fee. That's a service you can get done now, not just at FCC Armageddon.

For example if this started in a month, I would re block a SMQV / 411 set, but would sell (overseas) an older 200 series set. The downside to selling off the gear is that the market is really flooded. Places like rental houses use it as a reason to shift the upgrade cycle of their gear so a lot goes into the market at once. Also news stations. After the 700mHz sell off, most of the Philly news stations switched to block 26 Lectrosonics. Those guys will probably also see it as an upgrade time too. Those companies own a LOT more units than a bunch of us. It'll be a super sale for our overseas buddies.

All that said, there was a rumor that the 600mHz sell off might take 10 years to become a ban on our gear. *IF* this happens, and *IF* we get 10 years, then our gear will have had a good life. 10 years would also give us a good warning when buying new gear from the point this is official.

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Jim:

 

Yeah, I was a bit concerned when I looked at the public notice letter posted by the FCC 10/31/13. which indicated they had extended the date for public comments to 11/14/13. However, the docket is still open, and there have been quite a number of comments filed after the November 14th cutoff, so apparently it has been extended. I have over the years dealt with the FCC directly as well, but it can sometimes be a frustrating experience  :-[

 

As you stated, they do prefer to receive comments from companies and organizations on these matters, as opposed to individuals. I have already been in contact with the CAS, although I don't know how quickly they can move on this.

 

Will know more tomorrow.

 

--S

There is a deadline for submitting comments on this proceeding. I don't know what it is (I thought it expired, but it looks like the NAB filed some stuff earlier this week). So consider if you have time to wait for a response from Shure or Sennheiser.

 

It looks like the form for 12-268 is still active. But again, I don't know how much longer it will be.

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As you stated, they do prefer to receive comments from companies and organizations on these matters, as opposed to individuals. I have already been in contact with the CAS, although I don't know how quickly they can move on this.

 

Oh gosh. I didn't intend to say the FCC <<prefers>> comments from companies and organizations. I really don't know if they do. Obviously there's some money/clout/other political battles/future-employment issues. But I think at least some people at the FCC appreciate comments from real individuals. I'm reminded of a FCC hearing in Rapid City, South Dakota about 10 years ago.

 

I was covering the fight over Low-Power FM. The FCC commissioners held a series of hearings around the country. And in the hopes of getting some "vox of actual pop" input, a couple commissioners didn't want all of the hearings to be held in DC, NYC, and the like. So there was a hearing in Rapid City. I flew out with a camera guy to cover the it. Alas, as we disembarked our plane at the tiny Rapid City airport, we saw the usual gang from the "against LPFM" side (NAB and friends) and the "for LPFM" side (Prometheus Radio Project).

 

Both sides stacked the public-comment session with speakers well-prepped in the respective side's talking points. Ya, that's politics. But the commissioners and their staffers were visibly bummed (and told us they were bummed). IIRC, one of the commissioners said ever so politely, "WTF?" I'm paraphrasing, but that was the gist. So during and after the hearing, we noticed the staffers paying special attention to the few public commenters and others who shared what appeared to be their own genuine opinion. That was both staffers for commissioners leaning against LPFM and those vigorously for it. 

 

So I think FCC staffers and at least some commissioners really do care about how their decisions affect individuals. And I could envision some FCC people having mixed feelings about Sennheiser et al's efforts in this matter: they seems to represent the concerns about a lot of people, but they may also be seen as a request to have auction winners basically subsidize wireless manufacturer's future sales. I could envision some FCC people being interested in a genuine small-businessperson (ie- a mixer) who can say something like "I have a dozen wireless systems, six in the 600MHz range…I gross about $XXX/year…replacing those six systems will present me with an unexpected $18,000 expense. That's a big hit. Please help my business remain viable."

 

Who knows if my envisioning is accurate or not…. I don't. I'm being a little weasly because I might be covering some FCC issues in 2014. 

 

But don't discount the power of a lone voice crying in the wilderness.

 

OK, I'll stop now. :-)

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I just want to add that Sennheiser and Shure both have done a very good job of lobbying the FCC on behalf of all of us. They spend considerable time and resources doing so, and they are also good at communicating with us and other manufacturers about it.

 

I do think it is worth your time to at the very least contact your government representatives and apprise them of this issue. If we can at least get this issue into the public spotlight for a decent discussion, we may make some progress.

 

My only advice is to put this into economic terms because that's what government officials understand. And I'm not talking about $25,000 here or there, even though this is what you personally are dealing with. This is about the macro economic equation between content producers (you and your customers) and content distributors (Apple, Google, etc.) IN other words, if Warner Bros, Fox, the NFL, Disney, ABC, NBC, etc. care about how this issue will affect their ability to produce content, they might weigh in on our side.

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  • 5 months later...

here is another thread on basically the same topic of FCC actions affecting our wireless mic's...

 

...however it speaks specifically to Sennheiser's petition which deserves it's own thread for more attention to their petition.  

 

Senator, please go about merging all topics related to microphones to one topic, all recorders to one topic, etc. Get to work and good luck with that.

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Dan: " it speaks specifically to Sennheiser's petition which deserves it's own thread for more attention to their petition. "

pardon me, but please park that animal somewhere else...
You make ever new article you see a new thread, so we have threads all over the place, and I believe this is a discussion that deserves to be in a single encompassing and contiguous thread....

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As this is an important issue and will be updated often, maybe a topic should be pinned .  I'm just trying to provide some information to everyone but as usual you have to turn it into something less helpful, counterproductive.

 

Jeff - to eliminate Senator's constant pestering, would it be possible to pin a topic for the 600mhz spectrum auction?  

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