Overview and Procedural Background
On March 19, 2019, the Federal Communications Commission adopted a Report and Order and Order on Reconsideration (FCC 19-24, released March 20, 2019, with an Erratum DA 19-614 released July 1, 2019) across ET Docket No. 16-56, RM-11745, ET Docket No. 14-165, and GN Docket No. 12-268. The order establishes updated Part 15 regulatory requirements for unlicensed white space devices operating in unused television broadcast spectrum and portions of the 600 MHz band.
The actions address issues originating from a petition filed by the National Association of Broadcasters (NAB) concerning data accuracy in white space databases, as well as multiple petitions for reconsideration following the 2015 TV White Spaces Order. The primary objective is to improve the accuracy and reliability of fixed white space device location data while supporting broadband deployment in rural and underserved areas.
- Proceedings covered: ET Docket No. 16-56, RM-11745, ET Docket No. 14-165, and GN Docket No. 12-268.
- Adopted date: March 19, 2019; Released date: March 20, 2019; Erratum issued July 1, 2019.
Mandatory Geo-Location and Database Reporting
Under the revised Section 15.711(c) rules, the Commission eliminated the option that previously allowed a professional installer to determine and manually enter the geographic coordinates of a fixed white space device. All newly certified fixed white space devices must incorporate an internal geo-location capability (such as GPS, Wi-Fi, beacons, or RFID) that automatically determines coordinates and transmits them directly to the white space database upon registration.
To accommodate indoor installations or locations where internal geo-location cannot function, fixed devices may obtain coordinates from an external geo-location source via a secure wired or wireless connection, or use an extender cable connected to a remote antenna. Manufacturers must demonstrate geo-location accuracy and location uncertainty with a 95% confidence level during equipment certification.
Fixed white space devices must check their coordinates daily and report their geographic position when querying the database for available channels. Device registration records in the database must be updated whenever a fixed device moves or its coordinates change by more than plus-or-minus 50 meters from the previously registered position.
- Eliminated the professional installation option for entering geographic coordinates.
- Permitted external geo-location sources via secure wired or wireless links for deep indoor use cases.
- Mandated daily coordinate re-checks and database reporting.
- Triggered database re-registration requirements when coordinates change by more than 50 meters.
Antenna Height Determinations and Manual Entry
The Commission declined to mandate automatic determination of antenna height above ground level (AGL). Noting that vertical GPS accuracy is significantly lower than horizontal accuracy and that transmitters may sit at different elevations than antennas, the Commission allows installers and operators to manually measure and enter antenna height above ground level into the device and registration records.
Applicants for equipment authorization retain the option to incorporate automated vertical height determination mechanisms, provided they submit documentation describing the methodology and precision during the equipment certification process.
- Manual entry of antenna height above ground level remains permitted.
- Automated antenna height determination is optional and subject to technical demonstration during certification.
Registration Responsibilities and Verification
The Commission clarified Section 15.713(g) by designating the device operator as the party responsible for the accuracy of white space database registration records. The operator is defined as the entity with operational control and the capability to deactivate the unit if harmful interference occurs.
The Commission declined to require database administrators to independently verify the e-mail addresses or telephone numbers submitted during registration, concluding that existing format-checking and full-field entry validation mechanisms are adequate without adding procedural delays in remote regions.
- Fixed device operators bear ultimate legal responsibility for database registration accuracy.
- Third parties (such as installers) may input registration data on behalf of operators.
- Proposals for mandatory database contact verification were rejected.
Reconsideration Rulings: Rural Antenna Heights and Technical Parameters
In the Order on Reconsideration, the Commission amended Section 15.709(g)(1)(i) to raise the maximum permissible antenna height above ground level from 30 meters to 100 meters for fixed white space devices operating in less congested areas. Less congested areas are defined as locations where at least half of the television channels in the operational band are vacant.
The Commission affirmed several technical limits established in the 2015 TV White Spaces Order:
Retained the maximum height above average terrain (HAAT) limit of 250 meters for fixed devices.
Affirmed the rule permitting fixed devices to operate at 40 mW EIRP with an antenna height up to 10 meters AGL within adjacent-channel television station contours, requiring a directional antenna with at least 6 dBi gain for maximum power.
Denied requests to increase maximum conducted power for fixed devices operating across contiguous channels with a 3 MHz buffer, maintaining the 100 mW total EIRP limit.
Declined to incorporate antenna directivity patterns into database channel calculations or require devices to report actual operating power back to the database.
- Antenna height above ground limit increased from 30 meters to 100 meters in less congested areas.
- Maximum HAAT remains capped at 250 meters.
- 40 mW EIRP fixed adjacent-channel operation affirmed with 10-meter height and directional antenna requirements.
- Contiguous channel operations remain capped at 100 mW EIRP (50 mW per adjacent 3 MHz segment).
Band Plan Alignment and Transition Timeline
The order updates Part 15 rules to align with the final 600 MHz Band Plan resulting from the close of the broadcast television incentive auction. Definitions for the 600 MHz duplex gap (652-663 MHz), 600 MHz guard band (614-617 MHz), and 600 MHz service band (617-652 MHz and 663-698 MHz) were formalized. White space device operation in Channel 37 (608-614 MHz) was updated to reflect a maximum power limit of 40 mW EIRP.
Additionally, the order restored Section 95.2309(h), requiring Wireless Medical Telemetry Service (WMTS) networks on Channel 37 to register with white space database administrators to receive interference protection.
A transition schedule was adopted for fixed white space devices: all devices approved by Telecommunication Certification Bodies (TCBs) starting six months after the effective date of the rules, and all devices marketed starting 18 months after the effective date, must comply with the new geo-location requirements. Existing legacy devices deployed prior to the operational cutoffs may continue operating indefinitely without modification.
- TCB certification cutoff: mandatory compliance for approvals starting 6 months post-effective date.
- Marketing cutoff: non-compliant device sales prohibited starting 18 months post-effective date.
- Existing deployed devices grandfathered for indefinite operational use.
- Hardware changes adding geo-location require a new certification grant and new FCC ID (not a permissive change).