Overview of Proposed Part 15 White Space Rule Amendments
On February 25, 2016, the Federal Communications Commission adopted a Notice of Proposed Rulemaking (NPRM) and Order (FCC 16-23) in ET Docket No. 16-56 and RM-11745. The proceeding addresses Part 15 Subpart H rules governing unlicensed fixed white space devices operating on unused frequencies in the broadcast television bands (54-72 MHz, 76-88 MHz, 174-216 MHz, and 470-698 MHz, excluding 608-614 MHz) and the repurposed 600 MHz band.
The Commission's proposals aim to improve the accuracy of geographic coordinates and registration data submitted to white space databases, reducing the potential for harmful interference to licensed broadcast stations, wireless medical telemetry, land mobile stations, and other protected services.
Denial of Emergency Motion for Database Suspension
In the accompanying Order, the FCC denied the Emergency Motion for Suspension of Operations filed on March 19, 2015, by the National Association of Broadcasters (NAB). NAB had requested the immediate suspension of white space database operations or the imposition of interim certification measures, alleging data errors, blank contact fields, and discrepancies across database systems.
The Commission concluded that database suspension was unwarranted given ongoing agency oversight, proactive database cleanup, and remedial validation measures already deployed with database administrators. The FCC noted that the databases are synchronized and that administrators now enforce data deletion policies for devices inactive for three months under 47 CFR § 15.715(o).
Mandatory Geo-Location and Elimination of Professional Installers
The Commission proposed to revise 47 CFR § 15.711(c) to eliminate the professional installer option, which previously allowed manual entry of geographic coordinates for fixed devices. The FCC proposed that fixed devices must automatically determine their coordinates via an incorporated geo-location capability, store the coordinates, and electronically transmit them directly to the database.
To accommodate locations where internal geo-location signals cannot be received (such as deep indoor installations), the Commission proposed specific alternative compliance options and sought feedback on operational parameters.
- Permit fixed devices to obtain coordinates from an external, certified geo-location source connected via secure interface protocols (e.g., Ethernet, USB, or serial connection).
- Consider requirements that the fixed device remain within 100 meters of the external geo-location source and cease transmission if the connection fails.
- Evaluate a procedure allowing low-power fixed devices (40 mW EIRP or less) to capture outdoor coordinates and complete indoor registration within a 30-minute window.
- Require fixed devices to verify coordinates daily and report them electronically when requesting available channel lists.
Registration Verification and Transition Timeframes
Under proposed changes to 47 CFR § 15.713(g), white space database administrators would be required to confirm the email address and telephone number of the designated contact person before providing channel lists or sharing registration records across databases.
To allow manufacturers and operators sufficient time to adapt, the FCC outlined a phased implementation schedule and grandfathering framework for existing devices.
- New certification applications for fixed white space devices must incorporate automatic geo-location capabilities beginning six months after the effective date of the new rules.
- Manufacturing and importation of non-compliant fixed white space devices would cease one year after the effective date.
- Marketing of legacy inventory would be permitted for up to 18 months after the effective date.
- Existing deployed fixed white space devices without built-in geo-location would be grandfathered and permitted to operate indefinitely.
- Modifications adding incorporated geo-location capability to previously certificated devices would be treated as permissive changes under 47 CFR § 2.1043.