There is an additional part of the original document that provides a major impediment to reallocating Ch 37:
"(iii) a channel 37 incumbent user, in order to relocate to other suitable spectrum, provided that all such users can be-relocated and that the total relocation costs of such users does not exceed $300,000,000."
For medical telemetry alone, the costs to re-locate will be about $2 billion,well over the amount allocated for the move. in case there's a question about the estimate, the transmitters alone cost $6,000-$7,000 each which brings that sub-total to $720-$840 million. Add in the reciever redesign, cost to get FDA approval for the new devices, project impact on the hospitals (these systems are all within hospital buildings) and well, the $2B estimate may be low. Then we can add relocating Radio Astronomy...
Assuming that this approach is one of the best for servicing the rural market the trade-off seems worth considering given the FCC's job in managing the airwaves for maximum public benefit. However @Greybeard1 it does seem dicey to plan on moving medical devices UNLESS there is more to that than meets the eye (such as it is a device-transmit region where strength of signal is known to be in favor of the local device in proximity to a local receiver or something along those lines). I'd also wonder if the radio telemetry usage might also be one where there are [too] many remote and nearly in-accessible transmitters (operating autonomously for extended periods of time)... themselves in rural areas.
we are considering whether to relocate existing radio astronomy and wireless medical telemetry systems on channel 37 (608-614 MHz) to new spectrum. In the event that we decide to do so, we also propose to add fixed and broadcast allocations to the channel 37 spectrum and modify the existing land mobile allocation in the UHF band, which is limited to medical telemetry and telecommand, to the more general mobile allocation. Similarly, if we were to make changes to allocations for the channel 37 spectrum, we ask whether we should remove the radio astronomy allocation from that spectrum.
The FCC is not likely to reallocate 608-614. It is not used for television at all but reserved for two other uses. First is radio astronomy, which has several sites across the country.
Additionally, the other co-primary user is the Wireless Medical Telemetry Service (WMTS). These are the patient worn wireless monitors that send vital sign information to nursing stations. There are currently about 120,000 of these transmitters in use throughout the US. It is simply not feasible, and dangerous to patients to 'move' these devices to another frequency. All spectrum is allocated, moving WMTS is a shell game.
Moving WMTS somewhere else simply forces another existing user to move or share. This topic has been the subject of a lot of research and work since Congress first proposed re-allocation. That's not to mention the work done in the late 90's to gain this life supporting technology primary status in the first place (the result of a digital TV station knocking a hospital's monitoring 'off the air')
Disclaimer - I was on the original taskforce that led to WMTS and am working on the taskforce to keep it.
Interesting point of view and a very valid one. I would agree that decision makers all live in houses rather than apartments, just as politicians live in a bubble devoid of reality. Me thinks GetUp would be good to get involved in this so that the correct decisions are made.
I have to admit that I'm completely mystified by the idea of making all this white space and 'formerly white space' spectrum unlicensed.
I think your opinion on this will depend on where you live. I once lived in a crowded apartment and now live in a house. In an apartment, above, below, to the right and left, and diagonal in every direction, was another apartment. And this is Silicon Valley, so most of those apartments will have young engineers with lots, and lots of gadgets.
WiFi was practically unusable. When I did manage to get it to work there was always some clown trying to break into my network or hoping my computer would connect to his network so he could try to break into my computer.
Now that I'm in a house it is like being in a different universe. WiFi works great for all kinds of computers, printers, Roku boxes, DSIs, you name it.
I figure these FCC regulators must all live in houses. They should visit the Wild West sometime and see how the other half lives.
By making this spectrum unlicensed, they've just made another swath of spectrum unusable to apartment dwellers. Though Bert is right in that it will probably work great in rural areas.
Interesting question. My thinking would be that individual homes, mostly out in the boonies, would erect a TV indoor or outdoor antenna, to receive the signal. We're talking about TV frequencies here, at potentially a range of 100 Km. So for those farmhouses far from the base station, not much different from a distant UHF TV station.
The antenna downlead would go to an in-home modem, just like your cable or ADSL modem, and then Ethernet or WiFi inside.
Conceivably, a USB stick could connect to an antenna, for direct 802.22 interface with your laptop, just as you can do now with 3G.
Aggregating multiple channels should be doable, but now you're talking about a college town? Hmmm. Fugetaboutit.
If any user wants to connect over a future white-space network, he or she will probably need something like a USB form-factor modem for "Super Wi-Fi."
Alternatively, there could be a wireless router that connects to the white-space network and provides Wi-Fi connections as a hot spot. But of course, in that case, users will face the same challenges as today -- congestions on WiFi -- especially in a college campus.
The incompatibility of "SuperWiFi" with "WiFi" makes me wonder about how it will be used. Is the concept that the "SuperWiFi" carries a signal to many hotspots which will receive "SuperWiFi" and then rebroadcast in the conventional "WiFi" protocol to users with conventional "WiFi" devices? If so, perhaps multiple unused channels could be ganged together to provide a wider bandwidth for the "WiFi" hotspots. Unfortunately, a college population of wired students can put a lot of pressure on a "WiFi" hotspot ... even without an upstream bottleneck.