karlw Posted February 24, 2015 Report Share Posted February 24, 2015 If you routinely use mic transmitter power greater than 50 mW (and I know many of you do) then you might want to read then consider filing a comment on Shure's filing here: http://apps.fcc.gov/ecfs/comment/view?id=60001013997 look on p. 31 Shure proposes applying a 50 mW limit on all Part 74, Subpart H transmitters (that means *your* transmitters) in the VHF and UHF bands. Lectrosonics and Sennheiser argue the opposite, not only that we wish to maintain the current 250 mW limit for UHF transmitters, but also to raise the limit for VHF transmitters to 250 mW as well. The deadline for comment is tomorrow, Feb. 25. Quote Link to comment Share on other sites More sharing options...
Jack Norflus Posted February 25, 2015 Report Share Posted February 25, 2015 How do you comment? Quote Link to comment Share on other sites More sharing options...
karlw Posted February 25, 2015 Author Report Share Posted February 25, 2015 To comment, go to the upper left of that page under "ECFS Main Links" click on "Submit a Filing". Proceeding 14-166, filing type is "Comment". Then fill out the form, and upload your comment file (document). Quote Link to comment Share on other sites More sharing options...
LarryF Posted February 25, 2015 Report Share Posted February 25, 2015 I see there are about 20 comments as of right now from users on the filing. Our thanks to those that took the effort. If you would like to have more than 50 mW for the times you need it, this is your chance to influence policy. With 20 comments, just by yourself, you would have a 5% influence. Best Regards, Larry Fisher Lectrosonics Quote Link to comment Share on other sites More sharing options...
Nick Ray Harris Posted February 25, 2015 Report Share Posted February 25, 2015 I looked through the filing and it only seems to mention maintaining an existing 50mw limit on certain VHF devices. Am I wrong? Quote Link to comment Share on other sites More sharing options...
karlw Posted February 25, 2015 Author Report Share Posted February 25, 2015 Nick here's a summary from our VP of engineering: They are proposing to: -- Retain the 50 milliwatt power limit (for VHF), but revise Part 74 Rules to allow output power to be measured on either a conducted or radiated (EIRP) basis. -- Apply the conducted limit to devices with detachable antennas, while the radiated limit would apply to devices with embedded or permanently affixed antennas. -- Apply this rule revision to all VHF frequencies regulated under Part 74 (54-72 MHz, 82-88 MHz and 174-216 MHz) and from 470 MHz to the upper edge of the UHF band. -- Apply this rule uniformly to licensed and unlicensed wireless microphones. Note the application is "from 470 MHz to the upper edge of the UHF band.". They in fact proposing to bring the power limit *down* to 50 mW (conducted or EIRP) for *all* Part 74 Subpart H transmitters! Quote Link to comment Share on other sites More sharing options...
Nick Ray Harris Posted February 25, 2015 Report Share Posted February 25, 2015 I can see how the language can imply that, I commented against doing that just in case. But I feel like you could interpret that the 50mw limit is only to be applied to VHF, hence the parenthesis, and that the rules that should apply to UHF are written after, mainly output power being measured differently. It definitely requires more elaboration, but it doesn't make sense for Shure to want to limit UHF output, they make UHF wireless equipment! I think we need to get Shure on the line to clarify. But either way I commented against any limitation to output power. Quote Link to comment Share on other sites More sharing options...
John Blankenship Posted February 25, 2015 Report Share Posted February 25, 2015 Bottom of page 30: "Shure recommends the following revisions to Part 74 to improve the viability of wireless microphones in the VHF bands, and urges the Commission to harmonize power limits throughout all UHF and VHF television broadcast frequencies regulated under Part 74." (BOLD added.) Quote Link to comment Share on other sites More sharing options...
LarryF Posted February 25, 2015 Report Share Posted February 25, 2015 I looked through the filing and it only seems to mention maintaining an existing 50mw limit on certain VHF devices. Am I wrong? Hi Nick, Go to pages 30 and 31. [snip] "Shure recommends the following revisions to Part 74 to improve the viability of wireless microphones in the VHF bands, and urges the Commission to harmonize power limits throughout all UHF and VHF television broadcast frequencies regulated under Part 74. - Retain the 50 milliwatt power limit, but revise Part 74 Rules to allow output power to be measured on either a conducted or radiated (EIRP) basis. - Apply the conducted limit to devices with detachable antennas, while the radiated limit would apply to devices with embedded or permanently affixed antennas. - Apply this rule revision to all VHF frequencies regulated under Part 74 (54-72 MHz, 82-88 MHz and 174-216 MHz) and from 470 MHz to the upper edge of the UHF band. - Apply this rule uniformly to licensed and unlicensed wireless microphones. These proposed rule changes, although subtle, will help wireless microphones..." [snip] Subtle indeed. Their word not mine. Best Regards, Larry Fisher Lectrosonics Quote Link to comment Share on other sites More sharing options...
LarryF Posted February 25, 2015 Report Share Posted February 25, 2015 No I can see how the language can imply that, I commented against doing that just in case. [snip] As John B. pointed out with his bolding, they have said it twice and used different words. They make low powered gear, even less than 50 mW as standard. Best Regards, Larry Fisher Lectrosonics And Nick, thanks for commenting by the way. Best, LEF Quote Link to comment Share on other sites More sharing options...
Nick Ray Harris Posted February 25, 2015 Report Share Posted February 25, 2015 Thanks for clarifying. Larry, would you be able to speculate as to why Shure would want such limitations? An attempt to level the playing field against the competition? Quote Link to comment Share on other sites More sharing options...
John Blankenship Posted February 25, 2015 Report Share Posted February 25, 2015 Thanks for clarifying. Larry, would you be able to speculate as to why Shure would want such limitations? An attempt to level the playing field against the competition? (I'm not Larry, but I play him in my dreams.) A large part of Shure's market is music and stage performance. In that application, such as on Broadway, cramming a large number of wireless into a small footprint is critical. Toward that end, staying at 50mW and below can help greatly, especially in close quarters to other wireless systems. For wireless systems, we're not Shure's primary, or even secondary, market. (Real Larry, please feel free to correct me if I'm wrong.) Quote Link to comment Share on other sites More sharing options...
LarryF Posted February 25, 2015 Report Share Posted February 25, 2015 Thanks for clarifying. Larry, would you be able to speculate as to why Shure would want such limitations? An attempt to level the playing field against the competition? Fifty mW is probably the sweet spot for their products, is a fairly worldwide power level and is easy to mass produce. We and Sennheiser have different viewpoints because we have units with more output power. Instead of speculating about playing fields with friendly competitors, let me just say we are small compared to Shure so I feel sure they don't need to level anything. That doesn't mean I don't think they are wrong about 50 mW always being sufficient. Best, Larry F Lectro (I'm not Larry, but I play him in my dreams.) A large part of Shure's market is music and stage performance. In that application, such as on Broadway, cramming a large number of wireless into a small footprint is critical. Toward that end, staying at 50mW and below can help greatly, especially in close quarters to other wireless systems. For wireless systems, we're not Shure's primary, or even secondary, market. (Real Larry, please feel free to correct me if I'm wrong.) Too funny. LEF Quote Link to comment Share on other sites More sharing options...
Tim M Posted February 25, 2015 Report Share Posted February 25, 2015 Maybe they should lower it to 10mws and then the only way you could receive the audio would be by using a cart...thereby making reality bag rats like myself having to find a more tolerable environment by sitting at a cart haha Quote Link to comment Share on other sites More sharing options...
Matt Martin Posted February 26, 2015 Report Share Posted February 26, 2015 For those still wanting to comment, here is a link to the express form. At this link you don't have to upload a separate document. You can just type directly into a comment box: http://apps.fcc.gov/ecfs/upload/display If it doesn't automatically show up, the preceding number is 14-166. Quote Link to comment Share on other sites More sharing options...
Scott Smith Posted February 26, 2015 Report Share Posted February 26, 2015 Wow, nothing like getting a heads up on this! Larry, any chance that we might be able to get an extension on the comment period! "I don't care what they're talking about, all I want is a nice fat recording". Harry Caul "The Conversation" Quote Link to comment Share on other sites More sharing options...
LarryF Posted February 26, 2015 Report Share Posted February 26, 2015 Wow, nothing like getting a heads up on this! Larry, any chance that we might be able to get an extension on the comment period! "I don't care what they're talking about, all I want is a nice fat recording". Harry Caul "The Conversation" I think late comments are also read. LEF Quote Link to comment Share on other sites More sharing options...
Mirror Posted February 26, 2015 Report Share Posted February 26, 2015 Done. Quote Link to comment Share on other sites More sharing options...
Scott Smith Posted February 26, 2015 Report Share Posted February 26, 2015 I see the date on the letter from Shure is February 4th. Really a shame that we somehow didn't get more of a heads up on this, I'm sure there are many more individuals and companies that would comment on this if they were aware of what the impact is. Not even a mention on the Facebook FCC Part 74 Users group! (which I don't think has many followers anyway). --Scott Quote Link to comment Share on other sites More sharing options...
Wandering Ear Posted February 26, 2015 Report Share Posted February 26, 2015 This shows the need for more social organizing amongst mixers to voice their opinions to the FCC. All of the filings and comments are publicly available to all of us. Thank you Karl for reaching out and encouraging our community to voice our opinion officially and not just socially. Quote Link to comment Share on other sites More sharing options...
mikewest Posted February 27, 2015 Report Share Posted February 27, 2015 1 I had 3 Sennheiser 2012 channels years ago and 50mW does not necessarily offer much "distance" 2 There was a rumour a few years ago that Australian "FCC" guidelines were to be No radio transmitters on children or pregnant women 3 Hold on what it the transmit power of a cell phone, up to 6 watts?? mike Quote Link to comment Share on other sites More sharing options...
Nick Ray Harris Posted March 3, 2015 Report Share Posted March 3, 2015 Just received this email today: I am a lawyer for Shure Incorporated representing the company on FCC matters here in Washington. I just wanted to reach out and let you know that Shure has never supported a reduction in UHF power levels below 250 mW, and we just filed an ex parte letter with the FCC clarifying our position. A copy of the letter is attached. If you have any questions or concerns, I would be happy to speak with you. My contact information follows below. Best regards, Tim Quote Link to comment Share on other sites More sharing options...
Mirror Posted March 3, 2015 Report Share Posted March 3, 2015 Whaaaat? I am so confused. Quote Link to comment Share on other sites More sharing options...
karlw Posted March 3, 2015 Author Report Share Posted March 3, 2015 Hi everyone, Shure has stepped up to clarify their position with an Ex Parte filing which includes the following: "Pursuant to Section 1.1206b of the Commission’s Rules, 47 CFR § 1.1206b, Shure Incorporated (“Shure”) submits this ex parte communication to clarify comments filed on February 4, 2015, in the above-referenced proceedings (“Shure Comments”).1 Specifically, this ex parte clarifies Shure’s position on maximum output power levels for Part 74 wireless microphones operating on a secondary basis in UHF broadcast television frequencies from 470 MHz through 698 MHz. Section VIII(A)(1) of the Shure Comments contains ambiguous language that may create confusion about the level of maximum output power Shure supports for UHF wireless microphones currently operating under Part 74 rules. Shure does not support rule amendments that would reduce the existing 250 mW maximum output power limit for UHF wireless microphones. Wireless microphones have successfully operated with up to 250 mW of output power in UHF broadcast television frequencies pursuant to Part 74 rules for many years. There is no technical or policy justification for a reduction in the permissible output power of such microphones." Even though Shure did not intend to advocate for a reduction in max RF power for UHF mic transmitters, there were statements in two places in their original filing that could be (and were) misinterpreted to mean just this. We among others were concerned that if the FCC interpreted these statements the wrong way (and Murphy's Law tells us this was very possible, even likely!) we could have had some real trouble when the new rules come out. Kudos to Shure for jumping on this and issuing a clear statement of their position on the matter. And, thank you to those that took the time to comment - it made a difference! Quote Link to comment Share on other sites More sharing options...
Mack Posted March 5, 2015 Report Share Posted March 5, 2015 Nothing like missing the comment period. Just saw this. Quote Link to comment Share on other sites More sharing options...
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