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Telecordia's "TV White Spaces Database System" Approval Letter

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Released: March 26, 2012
Federal Communications Commission
Washington, D.C. 20554
March 26, 2012

DA 12-465

Mr. John Malyar
Chief Architect
Interconnection Solutions
Telcordia Technologies, Inc.
1 Telcordia Drive/RRC 4F604
Piscataway, NJ 08854
Dear Mr. Malyar,
Approval is hereby granted for Telcordia Technologies, Inc. (Telcordia) to operate its “TV bands database
system” to provide service to the public. This database system will provide support of unlicensed radio
devices that transmit on unused channels in the spectrum bands used by broadcast television (TV bands
devices). As discussed below, we are not providing authorization for commencement of operation by this
database system to provide service to TV bands devices until the Commission completes the development
and activation of its system for approving registrations in the TV bands database systems of venues where
large numbers of unlicensed wireless microphones are used (unlicensed wireless microphone registration
system) and affected venues have had an opportunity to apply for such registrations. We may, however,
authorize operations to serve one or more localized areas prior to the activation of this unlicensed wireless
microphone venues registration system where Telcordia coordinates with local officials and other
stakeholders to ensure that appropriate protection is provided for any such venues.
The Commission’s Part 15 rules (47 C.F.R. § 15.701 et seq.) require that unlicensed radio devices that
operate in the broadcast television bands (TV bands devices) contact an authorized database system to
obtain a list of channels that are available for their operation (i.e., channels not occupied by authorized
radio services) at their individual locations and operate only on those channels. Such devices are required
to provide their geographic location, by means of a secure Internet connection, to a TV bands database
system authorized by the Commission. The database will then return a list of the channels available for
operation by the device for its reported location.
Telcordia, along with a number of other entities, was conditionally designated as a TV bands database
administrator under the Part 15 rules in an Order issued by the Commission on January 26, 2011, 26 FCC
Rcd 12827 (2011). Final approval for each designated database administrator’s operation of a TV bands
database system was subject to compliance with requirements that it: 1) supplement its previous filings
with sufficient information to demonstrate how it will comply with the rule changes adopted in the
Second Memorandum Opinion and Order (ET Docket No. 04-186, 25 FCC Rcd 18661 (2010)); 2) agree
that it will not use its capacity as a database manager to engage in any discriminatory or anti-competitive
practices or any practices that may compromise the privacy of users; 3) coordinate closely with the
agency to ensure competency, consistency, and compliance with the rules; 4) participate in a series of
mandatory workshops conducted by the Commission’s Office of Engineering and Technology (OET) to
address implementation issues and to ensure consistency and compliance with the rules; and 5) subject its
database to real-world testing for a period of not less than 45 days. This public trial is intended to allow
interested parties an opportunity to check that the database provides accurate results before being made
available for actual use by TV bands devices.
Telcordia has provided the required submissions and has participated in the workshops in compliance
with conditions 1 through 4. In addition, it conducted a public trial of its database system as required by

condition 5 from December 7, 2011 to January 20, 2012. In this trial, Telcordia made its channel
availability calculator, as well as its procedures for registering protected facilities, including low power
auxiliary services (principally wireless microphones), MVPD and low power TV receive sites, and
temporary broadcast auxiliary links that are not in the FCC databases available for testing by the public.
Telcordia’s final report on its 45-day public trial was placed in the record of the TV white spaces
proceeding, ET Docket No. 04-186, and comments were requested in a Public Notice (Public Notice)
released February 1, 2012, DA 12-118.
Comments on Telcordia’s public trial and its final report on the trial were submitted by Mr. Patrick Ward.
Mr. Ward submits that while he finds the Telcordia database system to be lacking in some respects, he
also finds it to be quite useful in many respects. He expresses concern that the Telcordia database system
does not properly protect the radio astronomy observations at sites in New Mexico where radio telescopes
are operated. Mr. Ward argues that radio telescopes need certain frequencies set aside and protected
beyond the simple protected radio silence established by the Commission, the International
Telecommunications Union, the International Astronomers Union and the National Radio Astronomy
Organization. In its reply comments, Telcordia submits that its database system provides protection from
TV white space device use on all channels in a contour around the VLA as prescribed by the
Commission. It submits that any request to change the rules now, in comments to the Telcordia Summary
Report on the 45-day public trial is procedurally deficient and amounts to an untimely request for
reconsideration. We find that Mr. Ward’s comments raise issues that are beyond the scope of the Public
Notice, and indeed the trial of Telcordia’s database system and, as Telcordia states, procedurally amount
to an untimely request for reconsideration of the TV white space rules. We therefore will not address
those issues herein. Issues concerning protection of radio astronomy facilities were addressed and
decided previously by the Commission in its Second Report and Order and Memorandum Opinion in the
TV white spaces proceeding, ET Docket No. 04-186, 23 FCC Rcd 16807, 16862 (2008).
No comments were received concerning the Telcordia database systems channel availability calculator or
other aspects of the trial. Given the large number of parties that examined the Telcordia database system
during its public trial, we find the absence of comments on the data base content, channel availability
calculator and registration features to be indicative that the system is satisfactory in those areas.
Based on our own examination and testing of the Telcordia database system, the results of the public trial,
including comments submitted to Telcordia during the trial and Telcordia’s responses to those comments,
and the comments submitted in response to the Public Notice, we find that Telcordia has demonstrated
that its channel availability calculator is able to properly determine the unused channels at a location that
may be used by the different types of unlicensed TV bands devices. We also find that its registration
procedures properly record, store and retrieve protected facilities that are not in the FCC databases. In
addition, Telcordia successfully demonstrated at the February 14, 2012 meeting of TV white spaces
database administrators and FCC staff that its database is able to synchronize registration records with the
Spectrum Bridge, Inc. TV database system using the White Space Database Administrator Group’s
Database-to-Database Synchronization Interoperability Specification, Version 1.01 September 12, 2011.
We therefore find that Telcordia’s TV bands database system is compliant with the Commission’s rules
for TV white space database systems and ready for operation. We will, however, verify that the
synchronization of registration records function of the Telcordia database system is performing properly
when the database system begins operation to provide service to TV bands devices. Also, we have not yet
tested this database system with an actual TV bands device. When an application for a TV bands device
that accesses Telcordia’s database system is processed, we will verify that the database’s provisions for
securing communications between a device and the database are functioning in accordance with the rules
in conjunction with our testing of the device itself.
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As indicated above, the Commission’s unlicensed wireless microphone registration system is not yet
operational. This system is still under development, and we anticipate that it will be operational in the
near future. Until this system is operational and affected parties have an opportunity to register their
venues to obtain protection, we cannot provide a general authorization to Telcordia or any other TV bands
database administrator to provide service from its database system to TV white space devices. However,
we will consider favorably a request from Telcordia to provide immediate service from its database
system in a limited geographic area. For such an area, OET would accept and process any requests for
registration of venues where large numbers of unlicensed microphones might be used and then direct
Telcordia to create a registration record for the venue. We will notify Telcordia when our unlicensed
wireless microphone registration system is completed and inform it of the date on which it may begin
providing service to TV bands devices.
In addition, as the initial implementation of the Commission’s plan for operation of TV bands devices
proceeds, we anticipate that there may be additional changes, generally minor, in various aspects of the
plan. There may also be elements of Telcordia’s database system that will need to be adjusted as
experience is gained with TV white spaces operations by the Commission, the database administrators,
device manufacturers, and device users. We will provide instructions to Telcordia and the other database
administrators to incorporate and test refinements at such time as they may be developed. We do not
generally expect that implementation of the database synchronization facility, the registration system for
venues where large numbers of unlicensed wireless microphone are used, or other changes will
necessitate additional testing through a public trial. We anticipate that operation of these features will be
verified by the OET staff. Nonetheless, we are reserving the option to request that Telcordia undertake
additional public trial testing if we determine that such testing is necessary to ensure that the database
systems properly determine available channels and protect authorized services.
Accordingly, we are granting approval for Telcordia to operate its database system to provide service to
certified unlicensed devices that operate in the broadcast television bands subject to the conditions above.
The Commission will notify Telcordia when the conditions are removed. Authority for this action is
provided in Section 0.241(h) and Sections 15.701-.715 of the Commission’s rules, 47 C.F.R. § 0.241(h)
and §§ 15.701-.715 and Sections 4, 5, 303, 304, 307, 336, and 554a of the Communications Act of 1934
as amended, 47 U.S.C. Secs. 154, 155, 302a, 303, 304, 307, 336, and 624a.
Sincerely,
Julius P. Knapp
Chief, Office of Engineering and Technology
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