Engineers for the Integrity of Broadcast Auxiliary Services Spectrum (EIBASS) submitted comments
in response to the FCC April 28. 2011 Public Notice (DA 11-803) seeking comment on Microsoft's proposal to be designated as a TV Bands Device Database Administrator
EIBASS gives three reasons for denial of the Microsoft proposal:
- • The request was filed 15 months after the deadline for applying to become a WSD [White Space Devices] DBA [Data Base Administrator].
- • In its proposal, Microsoft missed Part 74, Subpart F, TV STL/TV Relay/TV Translator Relay stations operating on UHF TV channels.
- • The performance of Microsoft with regard to its Experimental Special Temporary Authority (STA) WE9XUO obtained "to test and demonstrate white spaces technology" at the NAB Show in Las Vegas.
The EIBASS filing notes that Microsoft requested use of television channels 21-36 and 38-51, even though "the most basic frequency coordination study would have revealed that TV Channels 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 34, 35, 36, 40, 41, 42, 43, 44, 45, 47, 48, 49, 50 and 51 had operating, on-the-air TV, Class A TV or LPTV stations..."
The group also flagged the fact that even though the STA for WE9XUO included the "SBE Clause," which called for operation subject to prior coordination with the SBE, the EIBASS filing said "as best it could determine, Microsoft never contacted either the SBE executive director, or the Las Vegas Broadcast Auxiliary Services (BAS) frequency coordinator, Jack Smith, at KVVU-TV in Las Vegas.
It was not until the WE9XUO experimental STA was circulated on the SBE frequency coordinator's reflector that the Las Vegas frequency coordinator became aware of Microsoft's planned operation.
The EIBASS comments noted that the posting also alerted LARCAN, which held an experimental STA (WE9XSY) for Ch. 46 at the NAB Show, to the Microsoft's planned operation. The group was then able to put the LARCAN representative in touch with Microsoft to make sure that Microsoft didn't operate on Ch. 46 inside the convention center LVCC, thus causing interference to the LARCAN experimental operation.
The group stated that "As a result of this almost-missed frequency coordination, Microsoft avoided using TV Channel 46 for its LVCC operation, and thus, as far as EIBASS can determine, a frequency coordination 'train wreck' was avoided."
In its conclusion, the filing states:
"EIBASS believes that Microsoft has demonstrated that it is unqualified to manage a WSD database due to its untimely filing, coupled with its inability to identify all categories of FCC licensed stations entitled to protection. This is an indication to EIBASS that due diligence was not done, despite the extra time a late filing provided to Microsoft to do its homework. In EIBASS' view, these failures demonstrate that Microsoft lacks the necessary regulatory awareness to manage a critically important database."
Dane Ericksen and Richard Rudman, EIBASS co-chairs, raised the question:
"If Microsoft assumes that its reputation alone will win them the WSD DBA mission, yet fails on these relatively simply issues, where else will it fail?"