HD Radio:
Missing in Action
from the
FCC Web Site

You may have heard that HD Radio is coming, but it is unlikely you heard it from the FCC website. Why? Information there is nearly impossible to find and what little you find won't answer your questions unless you happen to own a broadcast station.

So take the famous FCC website search engine and type in "HD Radio". You will get the results shown below:

Note that there are just 2 hits. The second turns out to be totally bogus. The first is a 2005 R&O from ET Docket 04-139 on implementation of WRC-03 where fn. 10 says,

The Commission has previously authorized the use of an In-Band On-Channel (IBOC) Digital Audio Broadcasting system in the AM (535-1705 kHz) and FM (88-108 MHz) broadcasting bands, which was developed by the iBiquity Digital Corporation (iBiquity). The action that we take today is limited to HF broadcasting and in no way disturbs the transition to iBiquity’s technology, which is known as High Definition (HD) Radio, in the AM and FM bands. See www.ibiquity.com for more information on HD Radio.

Turns out the problem is both the FCC search engine and the fact that FCC doesn't call this technology the same thing everyone else does, except in obscure places like the footnote above. This was a problem I had noticed at the Japanese counterpart of the FCC when I worked there in 1999 - they tend to use different terminology than the Japanese public and much of the electronics industry. But I didn't expect this from FCC.

On the search engine issue, if you go to Google and enter

"HD Radio" site:www.fcc.gov

you will actually get 3 more hits on the FCC site that the FCC's obsolescent search engine missed:

1. Remarks of Commissioner Deborah Taylor Tate To the Kentucky Broadcasters Association, October 18, 2007
2. XM Document Request.11.2
3. FCC Media Ownership Study #5: Station Ownership and Programming in ... - Nov 14

So at least Commissioner Tate knows it is now generally called "HD Radio" not IBOC.

But if a consumer wants information, he will strike out. It is not one of the 17 "consumer Center" links on the cluttered FCC home page. It is not on the Consumer & Governmental Affairs Bureau's home page. If you keep digging you may find "Digital radio - The Sound of the Future" but you will never see "HD Radio" mentioned here nor get a hint of where to get further information such as the number of stations on the air.

If you keep digging further you will also find different consumer information on the Media Bureau's "IBOC Digital Radio Broadcasting for AM and FM Radio Broadcast Stations" page. This page is mostly of interest to broadcasting policy junkies and radio station owners. It has information like the following

Where Can I Obtain a Digital Receiver

The pace of development of IBOC digital receivers for consumers depends on a number of factors, including how fast and how many AM and FM stations commence digital broadcasting, and how soon receiver manufactures can produce radio receivers. Check with local electronics suppliers from time to time for digital radio receivers!

But if you go into Radio Shack or Circuit City and say "IBOC Radio", the sales clerk will probably not understand you at all!

So my suggestion to FCC: Start using the terminology that Commissioner Tate and the rest of the world uses on your web site, not just in WRC-related agenda items and speeches by commissioners.

Jobs Openings at NTIA

A former FCC colleague just sent me a copy of a job announcement from NTIA and asked me to publicize it. An organization is only as good as its people. So while working at NTIA may not be "heaven on earth", there are a lot of challenging problems there and some people may find the pay scale attractive.

The jobs that started this are a pair of GS 13/14 positions ($79,397 - 121,967/year) which included the usual federal fringe benefits. (Note individuals a few years from retirement with prior civil service or military time may get huge retirement benefits in proportion to time worked from taking such a job.)

Vacancy Ann.#: NTIA-OSM-2008-0010 (DEU)
NTIA-OSM-2008-0011 (MAP)

Electronics Engineer

SALARY RANGE: 79,397.00 - 121,967.00 USD per year
OPEN PERIOD: Thursday, December 20, 2007 to Tuesday, January 22, 2008
SERIES & GRADE: GS-0855-13/14
POSITION INFORMATION: Competitive Service Full-Time, Permanent
PROMOTION POTENTIAL: 14
DUTY LOCATIONS: 1 vacancy - Washington DC Metro Area, DC
RELOCATION EXPENSES: Will be paid.

Job Summary:
The Strategic Planning Division is looking for a creative, innovative
individual with superb technical, communication, decision making, and problem solving skills who are knowledgeable in the exciting field of spectrum management. We are seeking individuals capable of producing new ideas and technical solutions to the communications challenges our country is facing in the 21st century. As an Electronic Engineer, you will participate on critically important project teams to interpret, recommend changes, and develop policies to address the ever-changing radio communication environment both nationally and internationally. You will have many opportunities to contribute to the team, and also to excel individually.

Major Duties:

Reports directly to the Chief of the Strategic Planning Division.
Overall responsibilities of the division include: 1)Serves as a Project
Lead with full responsibilities for planning, organizing and executing
strategic planning activities for spectrum management as it relates to
the division's strategic planning program. This will include various
technical analyses, planning, coordination, process improvement and
policy formulation activities to develop the broad-
range recommendations associated with the subject of achieving the
efficient and effective management and use of the radio spectrum to
assure spectrum access for the 21st century, 2) Provides technical
advice and management support of both government and contracted
support personnel required to meet operational objectives relating to
strategic planning and long-term strategies of the Division, 3) Conducts outreach and coordinates work performed by division within and outside NTIA, 4) and implements these recommendations within the Federal government's policy and decision-making processes for capital planning and investment control to achieve success in carrying out the President's spectrum policy for the 21st century. In addition, the incumbent furnishes advice, project reviews, and assistance to senior-level policy and decision-makers within NTIA regarding the matter of strategic plans and future architectures for
spectrum management and is required to establish, coordinate and maintain a continuous liaison with senior-level representatives located within and outside the Federal government

If you want to look at it more and possibly apply online, surf over to USAJOBS. You will oddly get a list of all openings in the Commerce Department, but enter NTIA in the "refine" box, and you will zoom into the 15 jobs presently open at NTIA, including these two. Applications close January 22.

At present, there are no high paid jobs available at FCC for outsiders. FCC is always hurt badly by continuing resolutions due to the nature of its budget and that probably explains the lack of vacancies. I suspect more will show up in the Spring. If interested, surf over to FCCJobs.

UK's Ofcom Proposes Unlicensed TV White Space Devices


Yesterday, the FCC's UK progressive counterpart, released a long awaited report entitled "Digital Dividend Review:A statement on our approach to awarding the digital dividend". "Digital dividend" is Eurospeak for what happens to TV spectrum after the end of the DTV transition, analogous to the FCC's 700 MHz auctions.

Ofcom stated (in peculiar UK spelling) the following points that I strongly agree with:

This decision matters for several reasons:

• spectrum is an essential input in the modern world. Its use underpins 3% of the UK’s gross domestic product (GDP) and generates wide reaching benefits for citizens and consumers. But spectrum is a scarce resource, so how it is managed is a critical issue;
• the spectrum presently used by analogue terrestrial television is exceptional because it can readily be used to provide high bandwidth services over long distances and into buildings; and
• the opportunity to put this spectrum to new use does not arise often. Analogue television has been its main use for many decades, under a framework that dates back to 1961.

... Under the Communications Act 2003, our duties are to further the interests of citizens and consumers and to secure the optimal use of spectrum. Our objective for the DDR is to award the digital dividend in a way that maximises the total value to society from its future use. This includes value both to citizens and to consumers.

• 
  

These would be admirable goals in any country. Then comes the real shocker, the UK counterpart of the FCC's Docket 04-186 proposals for white space/"interleaved spectrum" in UK-speak:

1.34 We propose to allow licence exempt use of interleaved spectrum for cognitive devices. Some licence exempt uses are able to coexist successfully with higher power licensed uses. Cognitive radio is a new technology that can detect spectrum that is otherwise unused and transmit without causing harmful interference. It has the potential to support a wide range of uses, including high speed always on broadband. It is particularly suited to operating in interleaved spectrum, where significant capacity is often unused at any one location at least some of the time.

1.35 We see significant scope for cognitive equipment using interleaved spectrum to emerge and to benefit from international economies of scale. But use of equipment in the UK will need to protect licensed users of this spectrum, including DTT and PMSE, against harmful interference. We will not allow cognitive equipment to use interleaved spectrum until we are satisfied on this point.

1.36 We think that allowing licence exempt cognitive use of interleaved spectrum is likely to be justified. Allowing access in this way will overcome the coordination problem they would otherwise face while imposing limited costs on other potential uses. We also think it is likely to encourage more innovation and competition in the provision of services, promoting the interests of citizens and consumers.

... 6.26 In contrast, cognitive devices could make flexible use of interleaved spectrum without causing harmful interference to licensed users. This would allow many of the applications set out above to be delivered at a low opportunity cost, resulting in substantial benefits. Other applications and innovations might also be spurred by the availability of a large pool of interleaved spectrum for licence exempt use.

6.27 Cognitive use of interleaved spectrum would depend on the development of effective spectrum sensing technology that would avoid transmitting in channels used by licensed services. Devices are being developed by a number of manufacturers, including Microsoft, Motorola and Philips. These companies have each submitted devices to the FCC for testing in the US. These devices are primarily designed to detect DTT and wireless microphone signals and, as such, would be suited for use in interleaved spectrum in the UK.

6.28 We therefore propose to allow cognitive technologies to use interleaved spectrum on a licence exempt basis subject to establishing that the probability of harmful interference to licensed users will be low. It is likely that the total value generated would be greater than the opportunity cost of allowing licence exempt cognitive access. The total value would be composed of the private value of foreseen
applications, which we estimate to be approximately £150-250m (NPV over 20 years), as well as benefits that would come from innovation and new services. There may also be broader social benefits. Because cognitive devices do not need to be exclusively assigned rights to spectrum and should automatically avoid interfering with licensed services, the opportunity cost should be low.

6.29 We would need to specify a number of parameters to which equipment would need to adhere. Early measurements made by the FCC suggest that such spectrum sensing is possible but careful certification might be needed.* It may take some years to undertake the work necessary to gain appropriate international harmonisation. (Emphasis added)

* Looks like Ofcom reads the FCC documents differently than MSTV and NAB! - MJM

In UK-speak, wireless microphones are called "programme making and special events"/PMSE and handled on a strictly licensed basis, apparently without the wholesale violations as in the US, by a private coordinator, JFMG, Ltd., who charges fees to all PMSE users based on the amount of usage. Unlike the FCC, Ofcom is making explicit plans for PMSE after the digital transition and they will have to pay for spectrum use, as is the general trend for spectrum access in both US and UK. Oddly, in the US both the legal and (majority) illegal wireless microphones users assume they have a constitutional right to free spectrum use with existing equipment in perpetuity, unlike most spectrum users.

On the PMSE issue, Ofcom states

1.41 We have decided to reserve most of the available interleaved spectrum to meet the needs of PMSE users. PMSE is an existing use of interleaved spectrum. It comprises a large and diverse community of businesses, community organisations and individuals. We think that PMSE users would find it difficult to coordinate a bid for access to spectrum, and we think there is a high risk of market failure as result. However, with a careful transition, they can move to accessing spectrum via market mechanisms in the future.

1.42 We will award a single package of interleaved spectrum to a licensee that will act as a band manager. To help PMSE users with the transition to market mechanisms, we will use criteria designed to ensure that the band manager’s interests are aligned with those of PMSE users. The band manager will pay a charge for the spectrum based on Administered Incentive Pricing (AIP) and will be able to earn revenue by charging its customers for access. But regulation will ensure that it has to meet reasonable demand from PMSE users on fair, reasonable and non-discriminatory terms. So long as these obligations are met, the band manager will be able to allow others to make use of its spectrum.

1.43 We have decided that channel 69 should continue to be available for PMSE use throughout the UK on a licensed basis. We will also promote greater licence exempt use of channel 70 for PMSE, in the interests of community users.

So one TV channel (#69 in the UK channel plan whihc is not the same as the US plan) will be available for wireless microphones through the coordinator independent of any auction. Some of the remaining white space will available to wireless microphones through the coordination.

In another UK development that will be bound to displease the US broadcast establishment, Ofcom has published proposals to squeeze multiple HDTV transmissions into a single DTV transmitter. Remember when we thought TV broadcasters should get one new 6 MHz channel for their old NTSC channel because 6 MHz was needed for HDTV? Ofcom stated,

1.14 We have identified two technical advances that together could result in a very significant increase in the DTT (=digital terrestrial television in Eurospeak) platform’s capacity. These relate to improvements in the standards used (a) for coding (compressing) information, to squeeze as much as possible into a given amount of spectrum, and (b) in its physical transmission.

1.15 The two changes are:

• An improved video and audio coding compression standard called MPEG-4 . This is expected (over time) to operate at up to double the efficiency of the coding standard that is used at the moment on DTT, MPEG-2. This means that a DTT multiplex* could carry up to twice as many services using MPEG-4 as can currently be achieved using MPEG-2, whilst maintaining similar picture quality.
• A new transmission standard, known as DVB-T2. This is expected to deliver an increase of at least 30% in the capacity of a DTT multiplex over the current standard, whilst maintaining the same coverage. This standard is a development of the existing DVB-T standard used in the UK since 1998. DVB-T2 is still undergoing development by DVB in Geneva, but is expected to be finalised in spring 2008.

1.16 It is important to note that MPEG-4 and DVB-T2 differ in one important respect. MPEG-4 can be introduced within a multiplex (so it can offer a mix of services coded in MPEG-2 and MPEG-4). But the introduction of DVB-T2 requires a whole multiplex to be converted from DVB-T. This is, of course, a larger step-change.

1.17 The introduction of these two technologies could, if combined, increase the capacity of a multiplex by up to 160%. This is a very large increase. It is the equivalent of raising the number of Standard Definition (SD) services that can be carried on a DTT multiplex from around eight currently to around 13-15 at DSO, and over 20 in the longer term. HD is generally regarded as unfeasible on DTT in the UK without use of MPEG-4: but with the use of these two technologies combined, a single DTT multiplex could in time offer at least four HD services.

* DTT = digital terrestrial transmission. In UK and many European countries, broadcasters do not own and operate their own transmitter, rather DTV signals are transmitted on multiplexed transmitters owned by a middle man with several signals on each transmitter and channel. Under present UK policy no HDTV is transmitted over the air because it was thought that multiplexing HDTV signals was impossible. Now Ofcom thinks it is possible. - MJM

Now UK channels are different than US channels so all the details don't apply here. But the nagging question is whether the US erred in giving established broadcasters 6 MHz for HDTV and whether we could get our own "digital dividend" by making TV broadcasters double up on multiplex transmitters. I suppose the suggestion will not get me an invitation to the next NAB convention.

Defense Spectrum Summit:

Another "No Show" for FCC

This week is the annual Defense Spectrum Summit in Crystal City, VA (next to National Airport). This meeting is usually held in Annapolis, but this year was closer to Washington. Did FCC show up? No. Even though OET Chief Julius Knapp was listed as a panel participant the first day. There was no explanation of the nonpresence of the FCC, but the most likely explanation is that the Chairman's Office micromanagers who control outside contacts of FCC staffers either didn't get around to approving it or for some odd reason even vetoed it.

It is widely known that under Chairman Martin this is unprecedented review of all outside speaking with approval centralized in his office. Many FCC staffers beg off on any speaking invitations because they don't want the aggravation of even trying to get it approved or don't want to be seen as a "trouble maker" by even asking. Thus the normal healthy dialog between FCC staff and the spectrum community is slowing to a trickle.

Now in this day of homeland security you might think that exchanging ideas and improving mutual understanding with DoD spectrum managers would be a good idea. Furthermore, the military is a major user of spectrum in the US and expanding commercial spectrum use will require an understanding of DoD issues to help search for "win-win" solutions in finding more effective ways to use spectrum.

I came to FCC in 1979 from the "military industrial complex" and it saddened me when I realized that DoD and FCC both usually look at spectrum allocations as a zero sum game - a spectrum band is either DoD's or FCC's. (There are other federal spectrum users, of course, but they don't figure much into DoD thinking.) In truth, civil spectrum use and military use are generally orthogonal in space and time. The greatest demand for more civil spectrum is in the top 30 or so markets. Except for San Diego, there is little military spectrum use in these markets and much of the spectrum lies fallows most of the time. (For example, see the Shared Spectrum Company's report on monitoring Chicago for 24 hours in 2005, especially p. 21.)

With traditional military and civil technologies there was no alternative but to dedicate this spectrum for 24/7 exclusive military use. But the pending upper 700 MHz auction includes a new type of public/private partnership for sharing spectrum subject to preemption. Now sharing has a bad reputation in DoD because of a bad history with simple technologies. Indeed, garage door open use of the UHF aircraft band is always a sore topic because interference-sensitive garage door openers resulted in congressional complaints even though they were less than secondary in allocation and ended up limiting spectrum use at some miltary bases.

But new technology is available and coming that will offer new options that are more likely to be win-win. FCC needs to be involved in this dialog and meet the hands on DoD people who come to DC for such meetings so they can understand what the real concerns are as they try to address them. It is sad to think that 8th floor micromanagement might be blocking this dialog.

Google white space device prototype

Busy Week of White Space Action

It's been a busy week here in Washington, my home town. Down at the lab of our local communications commission there have been all sorts of visitors, like Magi at Xmas time, bearing gifts or promises of gifts. Fortunately, unlike the advocates of the status quo for large affluent TV broadcasters who skirt the Commission's ex parte rules with apparent impunity, these visitors believe in and act in the letter and spirit of transparency. Thus there is a paper trail where we can follow the action.

Actually, a little earlier on November 16 Motorola came by with the first recent present. Motorola described it as follows

"(It) uses geo-location database that is augmented by sensing algorithms to determine which TV White Space channels are available for use. The device also can be configured to perform testing of the DTV sensing algorithms but is not a normal operational mode of the device."

No pictures were included, but I saw the device at the Lab and it is rack mounted in an 18" high rack.

On December 4, Google dropped by.

(The) Google representatives demonstrated broadband spectrum sensing technologies that reliably detect DTV signals well below the noise floor. The broadband DTV sync signals gave reliable power level estimates, even when the pilot is deeply faded, removing the need for large margins. preliminary figures from the initial phase of the testing support an average sensitivity of -120 dBm.

The picture at the top of this post was included in their submission to FCC.

Then on December 5, Adaptrum, Inc , a client of mine, dropped by with its unit.

Dr. Haiyun Tang of Adaptrum and Steve Jones of FCC Laboratory with Adaptrum White Space Device (WSD) at delivery to FCC for testing,

Adaptrum said in its filing

The Adaptrum device is different from others that have been discussed on the public record in that it is not based frequency domain processing and threshold detection of DTV pilot tone power. Rather, it uses the whole 6 MHz of the DTV signal and contains a time domain matched filter. This greatly increased bandwidth permits greater sensitivity than pilot tone detectors.

Note that the Google and Adaptrum filings were made almost simultaneously and that both systems appear to use the same type of time domain processing.

Also on December 5, my former boss, Ed Thomas, met FCC downtown on behalf of both Microsoft and Philips. The filing says

During this meeting, Mr. Thomas made arrangements for Microsoft and Philips to submit devices to OET for the next round of white space prototype testing, and the parties discussed white space testing logistics, including potential dates for laboratory and field tests.

Are Microsoft and Philips now combining forces and working on a common device? The letter is ambiguous so we will see.

FCC staff reports that the "8th Floor" has now said that all submitted devices will be tested in parallel and publicly with observers from the interested public - please don't throw peanuts at the FCC staff. This apparently includes both bench tests and field tests. A problem appears to be how to find homes to test these in where an unlimited number of observers can wander in and out. Stay tuned.

FCC Website:
Does It Violate FCC's Own Privacy Policy on Cookies?

Looking the other day at my web browser's "cookie jar" I noticed the cookie shown at left from wireless.fcc.gov as well as some other "session cookies" that were about to be erased.

I had noticed a similar cookie a few months ago and removed it, thinking it was ancient. But the reappearance of this cookie makes me think that FCC's web site is still putting cookies on users' browsers.

What are cookies and why should this matter? From the Electronic Privacy Information Center's site:

According to Netscape:

Cookies are a general mechanism which server side connections (such as CGI scripts) can use to both store and retrieve information on the client side of the connection. The addition of a simple, persistent, client-side state significantly extends the capabilities of Web-based client/server applications.

To put it more plainly, a cookie is a mechanism that allows a web site to record your comings and goings, usually without your knowledge or consent.

Federal Government policy on this issue is stated in OMB M-00-13, Privacy Policies and Data Collection on Federal Web Sites (June 22, 2000)

Particular privacy concerns may be raised when uses of web technology can track the activities of users over time and across different web sites. These concerns are especially great where individuals who have come to government web sites do not have clear and conspicuous notice of any such tracking activities. "Cookies" -- small bits of software that are placed on a web user's hard drive -- are a principal example of current web technology that can be used in this way. The guidance issued on June 2, 1999, provided that agencies could only use "cookies" or other automatic means of collecting information if they gave clear notice of those activities.

Because of the unique laws and traditions about government access to citizens' personal information, the presumption should be that "cookies" will not be used at Federal web sites.

FCC Privacy Policy echoes the OMB statement

Cookies

Websites may send small pieces of text called cookies along with some of the web pages that you visit. Cookies are typically used on transactional pages as place-holders to retain context and content during individual user sessions, making it easier for you to use the dynamic features of these web pages without having to provide the same information repeatedly as you move from one page to another during your visit.

There are three types of cookies. A session cookie is a line of text that is stored temporarily in your computer’s random access memory (RAM) and is only available for the duration of an active browsing session. A session cookie is not placed on any hard drive, and it is destroyed as soon as you close your browser. A persistent cookie from a website is saved to a file on your hard drive and is accessed whenever you re-visit the website that put it there. This lets that website remember what you were interested in the last time you visited. A third-party cookie is a persistent cookie that is set by or sent to a website different than the one you’re currently viewing.

The FCC website does not use persistent or third-party cookies, but sometimes uses session cookies. Some of the interactive sections of our website may set session cookies in temporary memory in order to provide streamlined navigation. These session cookies are not stored on your computer's hard drive and are automatically erased as soon as you close your browser. Information from these session cookies is not collected or saved.

Then why I am still getting FCC cookies in my "cookie jar"?