Shure filed an emergency request Oct. 21 with the FCC asking it to seek public comment on a report released last week by the FCC Office of Engineering and Technology detailing results of prototype white space device testing before moving forward on rules to allow use of the devices in the TV band.
The wireless mic manufacturerâ€™s comments echoed a request submitted last week by the Association for Maximum Service Television, the NAB, the ABC, NBC, CBS and FOX Television Networks, and the Open Mobile Video Coalition, which also asked the commission to open public comment on the report before instituting rules to authorize white space device use. (Editorâ€™s note: see â€śTrade groups, networks file emergency request for comments on WSD report.â€ť)
According to the Shure filing, the OET report â€świll play an instrumental role in the commissionâ€™s decision-making process in the white spaces docket.â€ť As a result, adequate time should be allotted to review and analyze the data presented in the report.
Acting before a thorough review of the data could result in the commission â€śstumblingâ€ť at the conclusion of its lengthy process â€śby issuing new rules based on faulty conclusionsâ€ť from the OET report, the filing said.
â€śIt is incomprehensible why the commission would spend years of testing and extensive resources to reach this point, involving the industry at every step of the way, only to dismiss the input and guidance of the industry at the last and most critical part of the process â€” the interpretation of the testing data,â€ť Shure said in the filing. â€śIt is as if the commission already knew what results it wanted to see and did not want to have any input that might rebut those results.â€ť
In its filing, Shure highlighted several issues raised in the report that did not show up in its executive summary as well as conclusions reached without apparent support, including:
- unfavorable results from adjacent channel lab tests;
- poor DTV field test results where false-positive measurements were given credit as accurate scans;
- heavily redacted test data from microphone tests that are less favorable to sensing than the DTV data;
- minimizing of false detection problems;
- nearly nonexistent commentary on test data from the Broadway and FedEx Field tests aimed at measuring sensing in environments with wireless mic use.