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Dan Ostroff

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  1. Thanks for sharing that Jose. Interesting conversation is whether to post a rate card or not. I've always opted not to as you often get productions just shopping around, if they have your rates they may have no reason to call and speak to you, thus losing your opportunity to convince them you would be a good hire.
  2. The 788 headphone amp issue has been discussed before (), I agree with those concerns. Compared to the other SD products I've used (442, 552, 744, 664, 633), the 788 headphone amp seems to lack headroom and headphone peak red LED (indicating headphone clipping) seems to trigger on at a relatively lower level IMO than their other products.
  3. Worth considering 664 has very little RF spray, better with power consumption (much better), I like the 664 limiters a lot better, and 788 headphone amp leaves a lot to be desired IMO. Just my $0.02. Sent from my iPhone using Tapatalk
  4. Hey Dave - 633, thanks for the input! Sent from my iPhone using Tapatalk
  5. Point taken although just seeing the bags (loaded or unloaded) directly next to each other is helpful, just as it was/is to see all of the mixer/recorders stacked on each other. I don't have the option of seeing them in person before purchase so just trying to get a look at them next to each other.
  6. Thanks very much for compiling those Jose, appreciate it! I'd still like to see them side by side if any of the vendors want to chime in here too...
  7. Was wondering if anyone had posted a side by side picture of the Orca OR-30 and Stingray for 633 bags next to each other for size comparison? I searched around but wasn't able to find a picture. Pardon if it has been posted as I may have missed it. Thanks!
  8. Long but here goes... FCC Spectrum Update - September 30, 2014: **************************************************** FCC ADOPTS UNLICENSED, WIRELESS MIC NPRMs, TV COVERAGE DECLARATORY RULING The FCC today unanimously adopted a notice of proposed rulemaking seeking comments on proposals for rule revisions governing unlicensed part 15 operations in the TV bands, new 600 megahertz band, and on channel 37. The agency also unanimously adopted an NPRM exploring the future spectrum needs of wireless microphones. At today’s monthly meeting, a third item adopted, on a 3-2 vote, was a declaratory ruling clarifying how the repacking approach that the FCC adopted in its incentive auction order meets the mandate of Congress to make all reasonable efforts to preserve the coverage areas and population served of TV stations. All three items follow up on the incentive auction order, which was approved in May (TRDaily, May 15). “Following the incentive auction, with the repacking of the television band and the repurposing of current television spectrum for wireless services, there will be fewer frequencies in the UHF band available for use by unlicensed fixed and personal/portable white space devices and wireless microphones,” the FCC noted in a news release on the unlicensed NPRM. “The proposed changes to Part 15 rules are designed to allow for more robust service and efficient spectral use in the frequency bands that are now and will continue to be allocated and assigned to broadcast television services, while continuing to protect authorized users from harmful interference.” Among the closest watched portions of the NPRM were those dealing with which devices would be permitted in the 600 MHz band duplex gap and guard band spectrum and on channel 37. As circulated Sept. 9 (TRDaily, Sept. 9), the item proposed to allow Mode 2, but not Mode 1, personal/portable devices in the duplex gap and guard band spectrum because Mode 1 devices do not have built-in geolocation capabilities, according to agency sources. The item also had proposed to allow fixed, but not personal/portable, operations in channel 37, which is used by medical telemetry and radio astronomy incumbents. The item as adopted proposes to allow fixed and portable devices in the duplex gap and guard band spectrum but seeks comment on whether the FCC should limit personal/portable devices to Mode 2 units. Regarding channel 37, the updated item seeks comment on whether to permit personal/portable devices on channel 37, striking a sentence proposing to allow only fixed devices. Unlicensed spectrum proponents Google, Inc., Microsoft Corp., and Public Knowledge had pushed back against the original duplex gap and channel 37 proposals in the original draft NPRM, arguing for greater access for Mode 1 and personal/portable devices. The NPRM proposes a division of the 11-megahertz duplex gap of 6 MHz for unlicensed devices, including unlicensed microphones, at the top of the duplex gap, followed by licensed mics in the next 4 MHz and a 1 MHz buffer between the duplex gap and wireless downlink spectrum. Comments are due 45 days after “Federal Register” publication and replies are due 20 days after that in ET docket 14-165 and GN docket 12-268. AT&T, Inc., and Qualcomm, Inc., have reiterated their concern that unlicensed operations in the duplex gap would limit use of the licensed frequencies due to harmful interference. The National Association of Broadcasters also has criticized the duplex gap plan, calling it “completely unworkable” due to interference among users. NAB also has criticized the FCC’s plan to revisit its TV “white spaces” rules only four years after they were adopted and “based on no apparent changes in the technical facts.” The wireless mic NPRM is designed to consider the future of the devices and the best bands for them to operate. “Most wireless microphones today operate on unused spectrum in the UHF television band frequencies currently allocated for TV broadcasting. Wireless microphones also operate in other bands, both on a licensed and unlicensed basis, depending on the particular band. Following the incentive auction – with the repacking of the television band and the repurposing of current television spectrum for wireless services – there will be fewer frequencies in the UHF band available for use by wireless microphone operations,” the FCC noted in a news release. “The Notice of Proposed Rulemaking seeks to address the needs of wireless microphone users, both licensed and unlicensed, in a comprehensive fashion,” it added. “The Notice examines wireless microphone users’ needs and different technologies that can address them, including digital technologies. In spectrum bands where wireless microphones currently operate, the Commission seeks comment on potential rule revisions that could accommodate better performance and increased use of wireless microphones. The Notice also seeks comment on authorizing wireless microphone operations in additional spectrum bands, consistent with the Commission’s overall spectrum management goals. Through this Notice, the Commission intends to enable the development of a suite of wireless microphone devices and applications over the long term that can meet users’ needs efficiently and effectively.” Comments are due 45 days after “Federal Register” publication and replies are due 20 days after that in GN dockets 14-166 and 12-268. In the declaratory ruling adopted in GN docket 12-268, the FCC seeks to clarify how the repacking approach it adopted in its incentive auction order complies with the statutory requirement that it make all reasonable efforts to preserve the coverage areas and population served of TV stations. “We take this action in order to remove any uncertainty regarding the repacking approach we adopted in the Incentive Auction R&O,” the FCC said in the declaratory ruling. “We are concerned that the Incentive Auction R&O left some uncertainty regarding how we intend to carry out the statutory preservation mandate in the repacking process,” the FCC added, citing the NAB legal challenge, which questioned whether the Commission was complying with Congress’s dictate to make all reasonable efforts to protect TV stations’ coverage area and population served as of Feb. 22, 2012, when the Middle Class Tax Relief and Job Creation Act of 2012 was enacted. “We now clarify that we will independently protect each eligible station’s ‘coverage area’ and its ‘population served’ as defined in the Incentive Auction R&O,” the FCC said. “In doing so, we will seek to preserve each station’s coverage area as determined using the methodology described in OET-69. If the station is reassigned to a different channel, its coverage area on its original channel will be replicated as closely as possible, using the same antenna pattern and other technical parameters and allowing power adjustments as necessary to enable the signal to reach the same geographic area at the same field strength as before the repacking process. As we explained in the Incentive Auction R&O, this ‘equal area’ approach will enable a station to ‘replicat[e] the area within the station’s existing contour as closely as possible using the station’s existing antenna pattern.’ Consistent with OET-69 and our rules, we will seek to preserve coverage area without regard to interference from other stations or population. “Independent of our efforts to preserve each station’s ‘coverage area,’ we also will seek to preserve its population served, again as determined using the methodology described in OET-69, by prohibiting any channel assignment in the repacking process that would cause one station to interfere with 0.5 percent or more of another station’s population served,” the FCC added. “As ‘population served’ by definition excludes unpopulated areas and areas where a station’s signal cannot be received due to existing interference from other stations, we will not protect such areas from new interference in the repacking process.” But Republican Commissioners Ajit Pai and Mike O’Rielly dissented, complaining about the process the FCC used to adopt the declaratory ruling, which was peeled off an inter-service interference order that the FCC plans to consider at its Oct. 17 meeting. The Commissioners said the agency was violating the Administrative Procedure Act (APA) by not seeking comment on the item and was rushing it out to help its defense of the order in response to a court appeal filed by NAB, which also has argued that the declaratory ruling violates the APA. “Substantively, there is merit to the reasoning in this declaratory ruling,” Mr. O’Rielly said. “In the repacking process, protecting the unpopulated areas covered by a broadcast station’s signal makes little sense. In fact, under current procedures, a broadcast station does not receive interference protection in these unpopulated areas. Whether this entire issue is consistent with the statute, OET-69, and Commission precedent is now in the hands of the D.C. Circuit Court. “Procedurally, I have problems with the process used to generate the item,” Mr. O’Rielly added. “Therefore, I dissent to this declaratory ruling. During consideration of the incentive auction item earlier this year, I raised deep concerns that the speed by which we were moving left the Commission exposed to legal challenges. Now, the Commission attempts to clarify a portion of the previous item posthaste. In doing so, it sidesteps normal Commission procedures for questionable gain. … What is the rush? The answer is that the Commission is attempting to strengthen its litigation position in the D.C. Circuit Court over a recent challenge of certain incentive auction rules posed by the National Association of Broadcasters (NAB). More specifically, this item is in response to a filing by NAB and some now are scrambling to address their arguments, even though others believe the existing language is sufficiently clear.” “Apparently worried about its chances of prevailing in court, the Commission decides at this late date to offer up additional arguments for its already-made decision not to protect the unpopulated portions of stations’ coverage areas against interference when repacking,” Mr. Pai said. “I must respectfully dissent from this highly unusual procedural maneuver. … Once an FCC order has been challenged in court and the deadline for its reconsideration has expired, the time for deliberation is over. Rather, the Commission should exit stage right and allow its able litigators to defend its position.” But Mr. Pai added, “It’s still not too late to turn things around. Even after today’s vote, the Commission and broadcasters can still rise above the disputes of the past, set aside the ill will that has built up over the past year, and meet each other halfway. Most importantly, if the parties were to settle the litigation, we would take a big step towards holding a timely and successful incentive auction. I hope that happens soon.” Commissioners Mignon L. Clyburn and Jessica Rosenworcel supported the declaratory ruling, with Ms. Rosenworcel saying, “I felt that the Commission adequately explained” its repacking rationale in the incentive auction order, “but I appreciate that sometimes, we want to update our explanations.” FCC Chairman Tom Wheeler took a jab at Messrs. Pai and O’Rielly, noting that they had voted against the incentive auction order. “Only in Washington is it possible to get wound up on whether something is a modification or a clarification,” he said. “Noteworthy in this discussion, this appears to be a renewal of dissent by parties that were not supportive of the approach being taken to follow the statutory requirements created by Congress for the spectrum incentive auction. So let’s be clear: This does not modify the treatment of coverage areas. This does explain how the report and order meets the statute. One would think that cleaning up a misunderstanding is a good thing. That’s what we’re doing here.” Mr. Wheeler added that the use of declaratory rulings for such purposes is “a common practice” at the FCC and not “highly unusual.” There was general agreement, however, on the unlicensed and wireless mic NPRMs, although Mr. Pai only concurred in part on the first item, citing the FCC’s decision in its incentive auction order to permit white spaces devices to operate in 600 MHz band guard band spectrum. “As I noted at the time, my preference would have been to seek comment in a neutral manner on whether we can permit those types of operations without causing harmful interference to licensed services before we decided to allow them,” Mr. Pai said. “But that is now in the past, and I am pleased that today we are asking many of the right questions. The record developed in response to this notice will hopefully shed light not only on why we made the choices we did, but whether we got them right. “And while we won’t be able to answer the latter point until all of the engineering studies and comments are in, I do think there is reason for concern,” he added. “The Commission’s proposals carry a risk of creating impaired spectrum licenses, depressing auction revenues, and deterring auction participation. But since we are at the beginning of the process, I am reserving judgment until all of the studies are in. As a result, I will be voting to approve in part and concur in part.” Regarding the wireless mic item, Mr. Pai said he was pleased the FCC was considering a “wide range of bands” where the devices might be able to operate and that the Commission plans to issue an order in that proceeding before the incentive auction begins. “At the heart of both of these items is science and fact, or at least it should be. I am generally pleased by the work of the Office of Engineering and Technology to focus on the technical side of the equation in preparing these two items,” Mr. O’Rielly said. “While I may not agree with every outcome or proposal, the NPRMs have been drafted in way to allow parties to provide comments, including contradictory evidence and technology studies, to frame our work going forward. I expect an ample record that includes the granular data necessary to fully inform our decision making. I am particularly interested in hearing about tests of the technical aspects of the various ideas and proposals. Let’s find out, to the best of our abilities, what works and what does not.” He added that he wants to explore “opportunities for mobile unlicensed operations in Channel 37” and noted that he has “heard from many industry participants that the current proposal regarding wireless mics and unlicensed wireless use in the duplex gap may be infeasible. There are strong views on this, and I am not sure whether all the information needed to make a decision is available yet. This issue needs to be fleshed out further, and I trust the NPRM will allow everyone to debate the merits fully.” Ms. Clyburn said she is pleased that the unlicensed item stresses the need to protect incumbents and that the wireless mic item considers the future spectrum needs for the devices. She also said that both items make clear that “all parties will have to learn to live together in a spectrum constrained environment.” She also said that “now it’s time to kick the lawyers out of the room and let the engineers rule.” Commissioner Rosenworcel stressed the importance of both licensed and unlicensed services while also saying that the FCC needs “to recognize that key services striving for space in the 600 MHz band—like wireless microphones, low power television, and medical telemetry—deserve attention under the law. Wireless microphones are critical for newsgathering, essential for Broadway productions, and widely-used in churches and schools. These microphones deserve a home. Low power television and translators also play an important role in communities across the country—and can extend the reach of television in rural areas. Plus, lives depend on medical telemetry. So we need to pay heed. We also need to be creative.” “Both of these items reinforce the importance of unlicensed spectrum in the wireless ecosystem, and they are also both witness to the importance of spectrum sharing in the new wireless world,” Mr. Wheeler said. “They are a glimpse into the future.” Outside parties had generally positive reactions today to the three incentive auction order follow-on items adopted today. But in response to the declaratory ruling, Dennis Wharton, NAB’s executive vice president-communications, said the group “believes the FCC's procedure here is quite suspect. The court will have to decide if it passes legal muster." “We’re pleased the Commission is making significant progress on the incentive auction process,” said Steve Berry, president and chief executive officer of the Competitive Carriers Association, commenting on the declaratory ruling. “Giving clarity to broadcasters who may want to participate in the auction as well as wireless providers who desperately need spectrum, especially low-band spectrum, is a necessary step in the process.” “CTIA is encouraged by the FCC’s adoption of three additional incentive auction-related items at today’s open meeting,” said Scott Bergmann, vice president-regulatory affairs for the trade group. “Countless studies and bipartisan policymakers recognize the need for additional spectrum to meet growing consumer demand and the integration of mobile broadband into important sectors of our economy, including education, health and transportation. A successful 600 MHz Incentive Auction is critical to meeting that need, and these proceedings will an important role in ensuring we maximize the amount and usability of the spectrum repurposed for mobile broadband services.” Julie Kearney, VP-regulatory affairs for the Consumer Electronics Association, said that “CEA applauds the commission for its continuous hard work to ensure a successful auction. By considering proposals that allow for more robust use of unlicensed spectrum without increasing the risk of harmful interference to other users, the FCC is helping to pave the way for future mobile innovation.” “Today the FCC follows through on the commitment made last May to strike the proper balance between our need for more open spectrum for innovation and next generation wifi, preserving traditional services such as wireless microphones, and protecting the exclusive licenses the FCC will auction to wireless carriers,” said Harold Feld, senior vice president of Public Knowledge. “The FCC’s item asks right questions. As Public Knowledge has insisted since Congress passed the Incentive Auction statute in 2012, we can make this a rare win-win-win by staying grounded in firm engineering analysis and working together on creative solutions to share our increasingly crowded public airwaves.”-
  9. FCC Spectrum Update - September 25, 2014 - **************************************************** NAB CRITICIZES FCC’s PLAN TO CONSIDER DECLARATORY RULING (excerpt) In its filing, NAB also “expressed its concern that the FCC’s plan for the duplex gap is completely unworkable. As currently constructed, LTE, unlicensed devices and wireless microphones will each interfere with the other. The best plan – one that provides a meaningful place for ENG [electronic newsgathering] operations while not interfering with LTE – is one that places only wireless mics in the duplex gap, with evenly-spaced (or close to it) guard bands between the uplink and downlink.” NAB added that “the FCC’s current duplex gap approach will depress auction revenues.” As circulated, an unlicensed NPRM to be considered at the Sept. 30 meeting proposed a division of the 11-megahertz duplex gap of 6 MHz for unlicensed devices, including unlicensed microphones, at the top of the duplex gap, followed by licensed mics in the next 4 MHz and a 1 MHz buffer between the duplex gap and wireless downlink spectrum, according to agency sources. The item also seeks comment on revisiting the FCC’s TV “white spaces” rules, which also drew the NAB’s ire. “The current rules were adopted in 2010, following several years of intense, highly technical debate,” it said. “Yet, just four years later, based on no apparent changes in the technical facts, the Commission is considering comprehensively re-examining fundamental aspects of now TV White Spaces devices can operate without causing harmful interference.”
  10. FCC Spectrum Update - September 23, 2014 **************************************************** FCC TO CONSIDER PART 15, WIRELESS MIC, TV COVERAGE, SATELLITE ITEMS SEPT. 30 The FCC announced today that it plans to consider part 15, TV station coverage, wireless microphone, satellite, and sports blackout items at its Sept. 30 meeting. The meeting is scheduled to start at 10:30 a.m. The part 15, TV station coverage, and wireless mic items are follow-up items in GN docket 12-268 to the incentive auction order that the FCC adopted in May (TRDaily, May 15). As TRDaily reported last week (TRDaily, Sept. 19), the Commission added a declaratory ruling to the “sunshine” notice concerning TV coverage that was not on the tentative agenda released Sept. 9 (TRDaily, Sept. 9). In the part 15 item, the FCC said it will consider a notice of proposed rulemaking “to revise rules for unlicensed operations in the TV bands and new 600 MHz Band, including fixed and personal/portable white space devices and unlicensed microphones. The proposed changes and new rules are intended to allow more robust and spectrally efficient unlicensed operations without increasing the risk of harmful interference to other users.” The NPRM as circulated proposed a division of the 11-megahertz duplex gap of 6 MHz for unlicensed devices, including unlicensed microphones, at the top of the duplex gap, followed by licensed mics in the next 4 MHz and a 1 MHz buffer between the duplex gap and wireless downlink spectrum, according to agency sources. The item also proposes to allow Mode 2, but not Mode 1, personal/portable devices in the duplex gap because Mode 1 devices do not have built-in geolocation capabilities, a source said. The item also proposes to allow fixed, but not personal/portable, operations in channel 37, which is used by medical telemetry and radio astronomy incumbents, a source said. Google, Inc., and Microsoft Corp. have pushed back against those duplex gap and channel 37 device proposals, while AT&T, Inc., has reiterated its concern that unlicensed operations in the duplex gap would cause harmful interference to licensed services. Regarding an NPRM on wireless mics, the FCC said the item will “address the needs of wireless microphone users, while recognizing that they must share spectrum with other wireless uses in an increasingly crowded spectral environment.” The declaratory ruling “clarifies that the Commission intends to preserve both the ‘coverage area’ and ‘population served’ of eligible broadcast television stations in the repacking process associated with the Incentive Auction,” according to the sunshine notice. That item was peeled off from an inter-service interference order that circulated Sept. 9 for consideration on circulation, according to agency sources. Also on the agenda for the Sept. 30 meeting is a further notice of proposed rulemaking in IB docket 12-267 “to streamline and update Part 25 of the Commission’s rules, which governs licensing and operation of space stations and earth stations for the provision of satellite communication services. These proposals will streamline, clarify or eliminate numerous rule provisions and reduce regulatory burdens.” Commissioners also plan to consider a report and order in MB docket 12-3 eliminating the Commission’s sports blackout rules. The elimination of the sports blackout rule would not prevent private agreements between rights holders and other parties to black-out games and other sporting events. Late last year, the Commission unanimously proposed eliminating the nearly 40-year-old rule, which gives sports leagues or other holders of exclusive distribution rights in sports events the ability to prohibit cable and satellite TV operators from importing a distant broadcast channel’s coverage of an event if the local broadcast station is not carrying it, such as when an event does not sell out (TRDaily, Dec. 18, 2013). The NPRM noted that the rule was adopted in 1975 not to ensure “the profitability of organized sports, but rather [to] ensur[e] the overall availability of sports telecasts to the general public” by eliminating the incentive for rights holders to refuse to license coverage rights to distant stations. The NPRM also pointed out that in 1975, “ticket sales were the main source of revenues for sports leagues.” In an op-ed piece in the Sept. 9 “USA Today,” FCC Chairman Tom Wheeler said that the NFL “should no longer be able to hide behind government rules that punish loyal fans” and that the FCC should no longer be “complicit in preventing sports fans from watching their favorite teams on TV.” He would appear to have the votes to end the sports blackout rule, because FCC Commissioners Ajit Pai and Mike O’Rielly have both called in recent months for elimination of the rule (TRDaily, June 19 and Aug. 12).
  11. FCC Spectrum Update - September 22, 2014 **************************************************** MICROSOFT, GOOGLE PRESS CASES ON FCC’s UNLICENSED NPRM Microsoft Corp. and Google, Inc., have had numerous meetings with FCC officials in recent days on the unlicensed notice of proposed rulemaking that the FCC plans to consider at its Sept. 30 meeting, according to an ex parte filing in GN docket 12-268. “In these meetings, we discussed the importance of adopting technical rules that would permit the use of three 801.11af channels in the 600 MHz band,” the filing said. “To accomplish this goal, we discussed: (1) enabling operation of Mode 1 and 2 personal/portable unlicensed devices in the duplex gap, lower guard band, and Channel 37; (2) allowing the database to determine unlicensed device operation based on the device’s location-accuracy capabilities so that devices with better accuracy can operate in appropriate locations, rather than preserving the current rule, which mandates that all devices establish location within +/- 50 meters; (3) allowing databases to use the Longley-Rice propagation model to calculate interference protection for broadcast operations; (4) permitting unlicensed systems to determine areas where devices may operate in the broadcast band by using both the database and sensing approach; and (5) allowing Mode 1 and 2 personal/portable unlicensed devices to operate below Channel 21.” Regarding the duplex gap, the draft NPRM proposes a division of the 11-megahertz block of 6 MHz for unlicensed devices, including unlicensed microphones, at the top of the duplex gap, followed by licensed mics in the next 4 MHz and a 1 MHz buffer between the duplex gap and wireless downlink spectrum, according to agency sources. The item proposes to allow Mode 2, but not Mode 1, personal/portable devices in the duplex gap because Mode 1 devices do not have built-in geolocation capabilities, a source said. The item also proposes to allow fixed, but not personal/portable, operations in channel 37, which is used by medical telemetry and radio astronomy incumbents, a source said.
  12. FCC Spectrum Update - September 16, 2014 - Sennheiser files petition.... **************************************************** PUBLIC TV STATIONS, WIRELESS MIC MAKER SEEK AUCTION ORDER CHANGES Public TV stations asked the FCC today to modify its incentive auction order to ensure that no community in the U.S. will be left without a noncommercial TV station after the auction and subsequent repacking of stations. Meanwhile, a wireless microphone manufacturer asked the FCC to reserve more spectrum for their use and to require wireless carriers to cover the costs of replacing mics. “The Report and Order adopting rules for the broadcast spectrum incentive auction overturns more than six decades of Commission precedent protecting reserved spectrum for noncommercial educational service, contrary to the statutory requirements of the Administrative Procedure Act and frustrating the congressional goals embodied in the Public Broadcasting Act of 1967,” the Association of Public Television Stations, Corporation for Public Broadcasting, and Public Broadcasting Service said in a petition for reconsideration filed in GN docket 12-268. “For over 62 years, the Commission has reserved spectrum in the Table of Allotments for exclusive noncommercial educational use, but the Report and Order reverses this well-settled policy sub silentio by making the continued existence of noncommercial educational reserved spectrum subject entirely to market forces. The Commission did not provide the required notice or reasoned analysis for this unprecedented reversal of longstanding policy.” The petitioners urged the FCC “to reconsider and revise its incentive auction rules so that a noncommercial educational station operating on a reserved channel may relinquish all of its spectrum usage rights only if at least one such station remains on-air in the community or at least one reserved channel is preserved during the repacking process to enable a new entrant to offer noncommercial educational television service in the community. This balanced approach would continue the Commission’s long-established reserved spectrum policy, while also enabling the success of the incentive auction.” Meanwhile, Sennheiser Electronic Corp., a manufacturer of wireless mics, filed a petition for reconsideration seeking more spectrum for wireless mics. It said that “given the slow roll-out of TVWS [TV white spaces], channel 37 (assigned exclusively to TVWS) and the ‘naturally occurring’ vacant channel (shared with TVWS) may never see much TVWS use. We ask that both channels be made available exclusively for wireless microphones. Alternatively, noting that TVWS has particularly promised service to rural areas, the Commission could reserve the naturally occurring channel for wireless microphones in urban and suburban areas, and maintain TVWS with database registration in rural areas, where registration is likely to be infrequent. “If none of these options is feasible, then we ask the Commission either to reserve two separated 6 MHz channels on the TV side of the boundary for wireless microphone use, or (less preferably) to keep for wireless microphones an unauctioned 5 MHz pair on the wireless broadband side, adjacent to the guard bands,” Sennheiser said. It also asked the Commission to reconsider its rejection of the company’s proposal to require wireless carriers that win spectrum in the auction “to compensate displaced wireless microphone users for the expenses of replacing their equipment. … We estimate that total reimbursement costs should not exceed $50 million.” Today was the deadline for petitions for reconsideration of the incentive auction order, which was adopted in May (TRDaily, May 15). Last week, the Expanding Opportunities for Broadcasters Coalition filed a petition asking the FCC to modify its rules to facilitate channel sharing between TV stations (TRDaily, Sept. 12). The National Association of Broadcasters is challenging provisions of the order in court, which has granted a request for expedited consideration (TRDaily, Sept. 5). NAB argues that the FCC violated the Middle Class Tax Relief and Job Creation Act of 2012, which authorized the FCC to hold incentive auctions, as well as the APA. Specifically, NAB says that the FCC ignored Congress’s dictate that the agency make “all reasonable efforts to preserve, as of February 22, 2012, the coverage area and population served of each broadcast television licensee” and that it use the methodology outlined in OET-69 to calculate the stations’ coverage areas and populations served. Adoption of new TVStudy software was arbitrary and capricious and also violated the APA, NAB argues. The trade group also complains that “the Commission chose to ignore ‘fill-in translators’” in its order.
  13. FCC EXPANDS LICENSE ELIGIBILITY FOR CERTAIN WIRELESS MICROPHONE USERS TO ENSURE INTERFERENCE PROTECTION, HIGH QUALITY SOUND FOR LARGE EVENTS http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db0515/DOC-327108A1.pdf
  14. That being said… an update as well. An hour in the point of interest…ironically RF interference at the start of presentation (1:02:45). http://www.c-span.org/video/?319385-1/fcc-meeting-net-neutrality-wireless-spectrum
  15. FCC Spectrum Auction Update - May 12, 2014: **************************************************** WHEELER PROPOSES UNIFORM DUPLEX GAP IN 600 MHz BAND PLAN FCC Chairman Tom Wheeler has circulated a new draft of the incentive auction order to be considered at the May 15 meeting, agency sources said today. The new draft proposes a uniform 11 megahertz duplex gap, according to sources. Previously, FCC staffers had recommended a duplex gap between 6 and 11 MHz depending on how much TV broadcast spectrum was recovered, with guard band spectrum also in that range. The new draft order was circulated May 9. The details of how the duplex gap could be divided would be decided in the future. The FCC plans follow-on proceedings soon to both consider technical rule changes for unlicensed devices and to consider spectrum and other issues related to wireless microphones. A contemplated proposal is to reserve 6 MHz of the duplex gap for unlicensed devices and 4 MHz for wireless microphones. The FCC has said that staff proposed allowing licensed use of wireless mics by broadcasters for news-gathering purposes in the duplex gap. Broadcasters and other wireless mic interests and unlicensed spectrum advocates have been battling over spectrum in the 600 MHz band, as FCC staff has proposed auctioning the two channels reserved for wireless mic use in the 600 MHz band. Wireless mic advocates have urged the FCC to reserve the duplex gap for wireless mics, a proposal opposed by unlicensed spectrum interests. “The item appears to be a step in the right direction,” Dennis Wharton, executive vice president-communications for the National Association of Broadcasters, said of the new duplex gap proposal. “We are pleased the Chairman and his staff recognize the need for wireless mics to have some small slice of exclusive spectrum for newsgathering. The only issue is that the proposal won’t work from a technical standpoint, because as Qualcomm has demonstrated, the unlicensed allocation for Google and Microsoft will cause harmful interference to LTE operations. The ultimate compromise solution is to keep the FCC’s unlicensed expansion in channel 37 and the new guard band and then reserve the 11 MHz duplex gap for mics.” “The upshot is that the FCC is trying to accommodate both unlicensed use and wireless microphones, and is relying on the parties to figure out how to share the spectrum between now and the auction,” said Harold Feld, senior vice president of Public Knowledge, which has advocated for more unlicensed spectrum. “Given that wireless mics and unlicensed have gotten along like cats and dogs, this creates something of a challenge. But the FCC is making it clear to all parties that when they say ‘sharing is the future’ they mean it. “The last few weeks have been marked by a lot of hard work and tough trade offs on all sides. Chairman Wheeler deserves a lot of credit for forcing everyone to keep going back to the drawing board to come up with workable proposals that take into account the sometimes conflicting goals of the auction to come up with a way to keep the TV white spaces usable in urban areas when no one can predict how much spectrum will ultimately be reclaimed,” Mr. Feld added. “Commissioner Rosenworcel deserves a lot of credit as well, for continuing to push for viable TV white spaces when things seemed bleakest some months back. “All that said, we still have a lot of work ahead going forward. The FCC has pushed most of the technical details on how all this will work, while still protecting both broadcasting and the licensed mobile broadband providers from interference, for another round of rulemakings over the summer,” Mr. Feld said. “This could all end up being for nothing if we can't get a good set of rules that works for everyone. But the FCC has really worked extremely hard to find a way forward that returns plenty of spectrum for auction, protects broadcasters who don't want to participate in the auction, and keeps both TVWS [TV white spaces] and wireless mics working. It makes me hopeful we can continue to thread the needle on this as we work the details over the summer.” “The unlicensed community has been adamant that Congress intended a balanced policy that would ensure useable unlicensed spectrum for broadband devices in every market nationwide, including the largest cities. This is critical for the Wi-Fi ecosystem, including the affordability and availability of Wi-Fi chips and devices for rural broadband,” said Michael Calabrese, director of the New America Foundation’s Open Technology Institute. “What we have been hearing about the Chairman’s proposed changes would be a clear win-win for both consumers who use unlicensed devices and for broadcast news operations that need very narrow but guaranteed channels for breaking news.” Last week, Commissioner Jessica Rosenworcel said that the Commission should make sure there are plenty of opportunities for unlicensed spectrum use in the 600 MHz band, but that it doesn’t have to come at the expense of other users (TRDaily, May 6). Also, a May 9 ex parte filing by NAB in GN docket 12-268 responded to a Google-Microsoft filing that had fired back at an earlier NAB submission that suggested the companies want access to “free spectrum.” “NAB continues to support the Commission’s drive to find opportunities to develop spectrum that does not require a license. We also understand its importance to successful companies such as Google and Microsoft, as it lowers costs for them when they develop consumer products and services,” the group said. “However, if Google and Microsoft believe they need more access to spectrum as part of their business models, NAB is aware of no financial or legal limitations that would prevent these companies from bidding in the incentive auction, raising revenues and increasing the likelihood of a successful auction.” Meanwhile, 10 House Democrats have written the FCC to support an incentive auction proposal to reserve up to 30 MHz in each market for bidding by companies with less than one-third of sub-1 gigahertz spectrum in that market. “As the Federal Communications Commission moves to finalize rules for the first-of-its-kind incentive auction of broadcast television spectrum, it has indicated its intention to propose rules to ensure every carrier has the opportunity to bid and win this beachfront spectrum and consumers, including those living in rural areas lacking sufficient mobile broadband coverage, enjoy the benefits of competition,” the lawmakers said in their May 9 letter to FCC Chairman Tom Wheeler. “These goals are one key part of the Middle Class Tax Relief and Job Creation Act of 2012, which granted the FCC authority to conduct an incentive auction. We commend you for your work in support of the Act and its goals.” “The FCC has crafted a transparent auction structure that accurately recognizes the unique value of low-band spectrum,” the lawmakers added. “We are heartened to hear that the FCC intends to ensure sufficient auction revenue to accomplish public interest objectives identified in the Act, including the full funding of the First Responder Network Authority, or FirstNet, as well as sufficiently broad-based and robust competition to protect consumers’ interests in innovation and expanded wireless broadband service in urban and rural areas alike. In particular, we believe that a proposal to reserve a portion of the available licenses for carriers with limited nationwide low-frequency holdings will stimulate auction competition and revenues, ensuring opportunity to bid and win spectrum to enhance and extend rural build out and improve coverage in all areas, while guarding against excessive concentration of spectrum resources.” Signing the letter were Reps. Doris Matsui (D., Calif.), Peter Welch (D., Vt.), Henry Waxman (D., Calif.), Anna Eshoo (D., Calif.), John Conyers Jr. (D., Mich.), Michael Doyle (D., Pa.), Zoe Lofgren (D., Calif.), Ben Ray Lujan (D., N.M.), Jared Polis (D., Colo.), and Adam Smith (D., Wash.). Six of the lawmakers sit on the House communications and technology subcommittee, including Reps. Eshoo, its ranking member, and Waxman, ranking member of the full Energy and Commerce Committee. Meanwhile, a May 9 ex parte filing in GN docket 12-268 and WT docket 12-269 urged the FCC to auction an uneven number of spectrum blocks in the unreserved group. The filing said that “competition would be enhanced if the Commission reserved more licenses for competitive access by allocating an odd number of unreserved licenses, which would force carriers that already control excessive low-band spectrum to compete with each other and would increase the likelihood of generating more revenue in both the reserved and unreserved blocks. At 70 MHz of broadband clearing, for example, dividing seven available licenses into three unreserved licenses and four reserved licenses would force AT&T and Verizon to compete to determine who gets two licenses and who gets only one—an outcome similar to the dynamic in Canada’s 700 MHz auction, which led to higher revenues. At 60 MHz of broadband clearing, preserving the three unreserved licenses is critical. Decreasing the reserve blocks from three to two at 60 MHz of broadband clearing would not only discourage competitive bidding between the two dominant licensees, but also frustrate the auction’s clearing targets by establishing a perverse incentive for AT&T and Verizon to clear less, rather than more, spectrum for broadband use.” The filing reported on meetings with FCC officials and representatives of the Competitive Carriers Association, Sprint Corp., T-Mobile US, Inc., C Spire Wireless, Inc., Comptel, Dish Network Corp., the Computer & Communications Industry Association, the New America Foundation, Public Knowledge, and the Writers Guild of America, West.
  16. Better a general (one!) pinned I think. Sent from my iPhone using Tapatalk
  17. 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?
  18. ...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.
  19. Your stance on this has been stated over and over and over again.... Frankly, I find it easier for a new thread to be created for current updates (new news if you will and why I included the date the news occurred in the subject line) rather than be buried in a long thread that may or may not be precisely on topic.
  20. **************************************************** ROSENWORCEL CALLS FOR ‘CREATIVE’ UNLICENSED 600 MHz BAND APPROACH FCC Commissioner Jessica Rosenworcel said today that the government should develop a “game plan” for unlicensed spectrum, including creatively ensuring that enough spectrum in the 600 megahertz band is made available for Wi-Fi and other unlicensed applications. Ms. Rosenworcel spoke to a Washington event sponsored by WifiForward at a time when unlicensed spectrum advocates are urging the FCC to reserve enough spectrum for such use in an incentive auction order that Commissioners plan to adopt at their May 15 meeting. Unlicensed advocates have expressed concern that the Commission will short-change their priorities in the order. As circulated, the draft FCC order would make guard band and duplex gap spectrum and channel 37 available for unlicensed use, with the size of the guard band and duplex gap spectrum ranging from roughly 12 MHz to a little more than 20 MHz, depending on how much spectrum is recovered from broadcasters. Unlicensed operations would be permitted on channel 37 by using exclusion zones to protect medical telemetry and radio astronomy incumbents. The staff also proposed allowing licensed use of wireless microphones by broadcasters in the duplex gap. Staffers proposed auctioning the two channels currently reserved for wireless mics. Unlicensed spectrum advocates have sought at least 24 MHz of spectrum in each market nationwide. Meanwhile, the National Association of Broadcasters has urged the Commission to reserve the duplex gap for wireless mics, which unlicensed advocates oppose, while the Wireless Medical Telemetry Service Coalition is worried that the FCC will allow unlicensed devices to share channel 37 before determining how the WMTS devices can be protected. The coalition is skeptical that geolocation databases can ensure adequate protection. In the text of her remarks today, Commissioner Rosenworcel said that “it is high time we give unlicensed spectrum—airwaves open to all under technical rules—its due. Because it is an essential part of the wireless ecosystem, a critical part of wireless service, and an important input into the modern economy. … So I think it is time for an unlicensed spectrum game plan. It should no longer be an afterthought in our spectrum policy. It deserves attention upfront, in policy prime time.” “So let me sketch out what an unlicensed game plan looks like,” Ms. Rosenworcel said. “It takes high-band, mid-band, and low-band spectrum.” Regarding 600 MHz band spectrum, she said that “while finding several contiguous channels for unlicensed service may be difficult, I believe there are creative ways forward. “For my part, I think that creativity starts with ditching the tired notion that we face a choice between licensed and unlicensed spectrum. This is a simplistic relic from the past that we should have long since retired—because good spectrum policy requires both. Moreover, we need to discard the conceit that Wi-Fi comes only at the expense of others who wish to use the airwaves. Because new technologies like dynamic databases can allow several services to co-exist harmoniously,” Ms. Rosenworcel said. “We also need to recognize that other services striving for white space in the 600 MHz band—like wireless microphones, low power television, and medical telemetry—matter,” she added. “Wireless microphones are critical for newsgathering, key for Broadway productions and widely-used in churches and schools. These microphones deserve a home. Low power television and translators also play an important role in communities across the country—and can extend the reach of television in rural areas. Plus, lives depend on medical telemetry. So these services need protection. “If we take these things as a given, I still think we can find solutions. Let’s be creative. We can consider an expanded duplex gap, find new locations for unlicensed microphones, and provide unlicensed opportunities in channel 37—while also protecting existing users,” Ms. Rosenworcel said. “Moreover, if we do this right, we can increase the value of licensed spectrum without diminishing the number of licenses we sell at auction. In short, if we are creative, I think we can honor the constraints in the Middle Class Tax Relief and Job Creation Act, but also free up new unlicensed opportunities in the 600 MHz band. That’s win-win.” Regarding high-band spectrum, the Commissioner said “that the FCC has made terrific progress in the 5 GHz band,” including recently freeing up an additional 100 MHz in the 5.150-5.250 GHz band. And she reiterated that “we can take the policies we are developing for managing exclusion zones for service in the 3.5 GHz band and use them as the blueprint for making more unlicensed spectrum available in the 5.350-5.470 GHz band.” Ms. Rosenworcel noted that 2.4 GHz mid-band spectrum is crowded “o we need to be on the watch for new mid-band opportunities for unlicensed spectrum, especially in airwaves that are underutilized.” Michael Calabrese, director of the New America Foundation’s Open Technology Institute, praised Ms. Rosenworcel’s remarks. “Commissioner Rosenworcel made the critical point that just like licensed spectrum, the most productive ecosystem for unlicensed must include bands with different propagation characteristics and capabilities,” he told TRDaily. “Unlicensed at 5 GHz is great for capacity, while unlicensed access in TV band spectrum below 1 GHz is critical for difficult coverage cases – both in rural areas, but also to penetrate better into buildings. She is absolutely right to characterize TV White space as the ‘super spectrum’ that can leap buildings in a single bound. Public interest groups are heartened to have Commissioner Rosenworcel as a champion for unlicensed broadband coverage and innovation.” In response to Ms. Rosenworcel's speech, Dennis Wharton, executive vice president-communications for NAB, said, "We strongly agree with Commissioner Rosenworcel that there should be a viable place for both unlicensed and wireless microphones in the 600 MHz band. NAB is a supporter of unlicensed spectrum and applauds the FCC on the incredible progress it has made to free up spectrum for that purpose on 2014 alone. We look forward to continuing to work with the FCC to find the best solutions possible to allow broadcasters to cover breaking news while continuing to foster new unlicensed uses." In earlier remarks at today’s event, Rep. Darrell Issa (R., Calif.) also said he is bullish about the future of Wi-Fi and other unlicensed uses. “There has never been a more important time to free up huge amounts of spectrum for use by people who want to make it available to everyone for free, or in a business model that is based on that low cost, public interest,” he said, according to excerpts released by his office. Panelists during an afternoon session also stressed the importance of the FCC making more spectrum available for unlicensed use – particularly in lower bands. Rob Alderfer, principal strategic analyst for CableLabs, said Wi-Fi “has some growing up to do,” adding that it needs more spectrum and more reliability. He said such reliability could occur in the 3.5 GHz band. But Mr. Alderfer said the FCC should adopt rules for the 3.5 GHz band that involve smaller exclusion zones to protect federal operations. Those exclusion zones would put off-limits 60% of the U.S. population. The zones were included in a report that assumed higher-power operations, rather than lower-power ones, he said. Julie Kearney, vice president-regulatory affairs for the Consumer Electronics Association, said she was pleased that the FCC made more spectrum available in the 5 GHz band, although she noted that more work needs to be done to free up additional frequencies. The panelists also defended why the FCC should make unlicensed spectrum available for free rather than auctioning those channels, as some carriers argue. The level of economic benefit to the U.S. economy from unlicensed spectrum dwarfs auction revenues to the U.S. Treasury, Mr. Alderfer said. In brief closing remarks, Blair Levin, a communications and society fellow at the Aspen Institute who led the FCC initiative that drafted the 2010 national broadband plan (NBP), said he agreed with Ms. Rosenworcel that unlicensed applications need access to a variety of bands and that people should not pit licensed vs. unlicensed, noting the use of the latter by wireless carriers to help manage their networks.
  21. FCC / Spectrum update - April 28, 2014 - FCC SHOULD RESERVE DUPLEX GAP FOR WIRELSS MICS, NAB SAYS The FCC should reserve the 600 megahertz band duplex gap for wireless microphones, according to the National Association of Broadcasters. The trade group’s push comes as FCC staff has recommended auctioning the two 600 MHz band channels currently reserved for wireless mics. However, staff has recommended allowing licensed use of mics used by broadcasters in the duplex gap, which would share the spectrum with unlicensed devices. In an ex parte filing today in GN docket 12-268 reporting on meetings with FCC officials, NAB said that the Commission should consider continuing to reserve two channels for wireless mic use. “While NAB continues to believe that the ability to squeeze more and more broadcasters together should not trump all other values implicated by the incentive auction, in the continued spirit of looking for solutions to identified problems, NAB has offered a ‘Plan B’ to address the problem. Rather than continuing to reserve the two channels, the FCC could simply designate the duplex gap that will be created in the new 600 MHz wireless band plan as exclusive for wireless microphones,” the group said. “In order for this plan to work, however, the duplex gap must be at least 10 megahertz. This should not be an issue, as not a single party has suggested in the record that the duplex gap can feasibly be any less than 10 megahertz. The draft order, however, includes potential band plans with a duplex gap as little as 6 megahertz wide, which would render it unusable for any service. If the Commission wants to avoid having to reserve two channels for exclusive wireless microphone use in every market, it must rework the proposed band plan to include at least a 10 megahertz duplex gap, and then reserve it for wireless microphone use only. At the end of the day, NAB believes that 4-5 megahertz of a 10 megahertz duplex gap will be useable for wireless mics.” NAB added, “This solution is elegant, as it is a strong compromise among many competing interests. The wireless carriers and chip and handset makers will support it because it will help avoid impairing the high end of the downlink and low end of the uplink. In addition, if some service must go into the duplex gap, wireless mics are a far better neighbor from an interference perspective than unlicensed devices. While Google and Microsoft will lament not having access to the duplex gap, they still walk away will new nationwide spectrum that covers major markets. Moreover, in relation to the draft order, they don’t lose anything, as a 6 megahertz duplex gap offers them no ability to offer meaningful services.” But Michael Calebrese, director of the Wireless Future Project at the New America Foundation’s Open Technology Institute, blasted NAB’s proposal. “The Public Interest Spectrum Coalition strongly supports the NAB’s position that the FCC should continue to reserve two vacant broadcast channels for priority use by licensed wireless microphones. These channels could be designated post-auction in each market and therefore would not in any way reduce the Commission’s flexibility during the auction,” Mr. Calabrese said. “However, we also believe that NAB’s alternative proposal allowing mics to make reservations that block unlicensed use of the duplex gap that will separate LTE uplink and downlink bands would be a death sentence for unlicensed broadband and innovation post-auction,” he said. “Congress clearly intended that the FCC authorize unlicensed use of the duplex gap. In addition, the TV Bands Database would allow unlicensed devices to share any channels set aside for mics and protect them from interference in the 90 percent of the places and times those channels are not in use.” In its ex parte filing, NAB also reiterated its concern with the Office of Engineering and Technology’s plan to use new TVStudy software to implement OET-69, which is used to measure TV interference. “Given that there is little or no practical reason or justification for making changes to OET-69, that Congress expressly directed the Commission to use it as is and the major procedural defects in the manner in which these changes have been proposed, the Commission should take this opportunity to shelve TV Study,” the filing said. “The staff’s time and effort is better spent on completing the repacking model, which has been under construction for at least four years. OET-69 is fully capable of producing accurate inputs into the long-anticipated repacking model, and thus the Commission should set aside this distraction before it becomes a threat to the auction.” And NAB urged the FCC “to include in the item a mechanism that treats the TV Broadcaster Relocation Fund as a budget, and not a mere open-ended half-measure. The auction should not move forward unless the staff first determines its repacking headroom under the $1.75 billion budget and takes every step it can to minimize repacking in the context of a successful incentive auction.” Meanwhile, the Expanding Opportunities for Broadcasters Coalition said in an ex parte filing today reporting on a meeting with Commissioner Mike O’Rielly and aides that the FCC should not use any “adjustment factors” to consider the enterprise value of TV stations.
  22. I don't see an issue starting a new thread with a current update. And although this posting refers to Sennheiser's petition, this post highlights individual users responses directly to the FCC with regards to the impacts of the spectrum auction. Not everyone is up on every on-going thread.
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