Wireless Microphone Proceeding, Notice to Update, Refresh Record
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
Released: October 5, 2012
THE WIRELESS TELECOMMUNICATIONS BUREAU AND THE OFFICE OF
ENGINEERING AND TECHNOLOGY SEEK TO UPDATE AND REFRESH RECORD
IN THE WIRELESS MICROPHONES PROCEEDING
WT Docket Nos. 08-166, 08-167, ET Docket No. 10-24
Comment Date: 30 days from publication in the Federal Register
Reply Comment Date: 21 days after comments are due
and Technology invite interested parties to update and refresh the record pertaining to two specific issues
raised in the Commission’s 2010 Wireless Microphones Further Notice1 – (1) whether the Commission
should provide for a limited expansion of license eligibility that would permit some wireless microphone
and other low power auxiliary station users, which currently operate in the TV broadcast spectrum on an
unlicensed basis, to operate on a licensed basis under the Part 74 rules applicable to low power auxiliary
stations (LPAS); and (2) what steps the Commission should take to promote more efficient use of this
spectrum by wireless microphones.2 We ask that these comments take into consideration recent industry
developments, including advances in wireless microphone technologies, as well as related Commission
proceedings that affect use of wireless microphones, including the TV White Spaces proceeding3 and the
Incentive Auctions proceeding proposing auction of spectrum currently allocated to television
1 See Revisions to Rules Authorizing the Operation of Low Power Auxiliary Stations in the 698-806 MHz Band,
WT Docket No. 08-166, Public Interest Spectrum Coalition, Petition for Rulemaking Regarding Low Power
Auxiliary Stations, Including Wireless Microphones, and the Digital Television Transition, WT Docket No. 08-167,
Amendment of Parts 15, 74 and 90 of the Commission’s Rules Regarding Low Power Auxiliary Stations, Including
Wireless Microphones, ET Docket No. 10-24, Report and Order and Further Notice of Proposed Rulemaking, 25
FCC Rcd 643 (2010) (Wireless Microphones Order and Wireless Microphones Further Notice, respectively).
2 In the Incentive Auctions NPRM adopted on September 28, 2012, the Commission noted that we would be issuing
this public notice to refresh the record on expanding eligibility for licensed operations to specified classes of users,
and on improved efficiency standards. See Expanding the Economic and Innovation Opportunities of Spectrum
Through Incentive Auctions, GN Docket No. 12-268, Notice of Proposed Rulemaking, FCC 12-118, ¶ 224 n.354
(adopted Sept. 28, 2012) (Incentive Auctions NPRM).
3 Unlicensed Operation in the TV Broadcast Bands, ET Docket No. 04-186, Additional Spectrum for Unlicensed
Devices Below 900 MHz and in the 3 GHz Band, ET Docket No. 02-380, Second Memorandum Opinion and Order,
25 FCC Rcd 18661 (2010) (TV White Spaces Second MO&O). See also Unlicensed Operation in the TV Broadcast
Bands, ET Docket No. 04-186, Third Memorandum Opinion and Order, 27 FCC Rcd 3692 (2012).
4 See generally Incentive Auctions NPRM.
BackgroundIn the Wireless Microphones Further Notice adopted in January 2010, the Commission sought
comment on the use of wireless microphones and other low power auxiliary stations on an unlicensed
basis in the current TV bands (Channels 2-51, excluding Channel 37). Noting that the Commission
currently permits such operations pursuant to the waiver granted in the Wireless Microphones Order, the
Commission specifically proposed that wireless microphones that operate on an unlicensed basis pursuant
to that waiver be permitted to operate in the TV bands pursuant to Part 15 and certain specified technical
rules. In addition, the Commission sought comment on whether it should revise the Part 74 low power
auxiliary station (LPAS) rules to provide for a limited expansion of the categories of entities that would
be eligible for licensed use of wireless microphones and other related LPAS. The Commission also
sought comment on possible long-term reform, based in part on technological innovations that would
enable wireless microphones to operate more efficiently and with improved immunity to harmful
interference, thereby increasing the spectrum available for wireless microphones and other uses.5
Subsequently, in the TV White Spaces Second MO&O adopted in September 2010, the
Commission took additional steps to make unused spectrum in the TV bands available for use by
unlicensed TV band devices (referenced herein as “white space devices”) and addressed the operations of
both licensed and unlicensed wireless microphones with respect to unlicensed white space devices. The
Commission generally excluded white space devices from two of the unused channels in the UHF TV
band near Channel 37 so that if these channels were available they could be used for wireless
microphones.6 In addition, the Commission provided that LPAS licensees could register their wireless
microphones (and related low power auxiliary station operations) in the TV bands databases so that they
may be protected from interference from unlicensed white space devices on available channels at
specified times. The Commission, subject to its approval, also permitted certain unlicensed microphone
users (e.g., those operating at major events where wireless microphone operations cannot be
accommodated on channels not available for white space devices) to register their wireless microphone
operations in the TV bands databases.7 More recently, in the Incentive Auctions NPRM adopted on
September 28, 2012, the Commission proposed to repack television stations. Noting that this action may
reduce the spectrum available in the TV bands for secondary use by licensed and unlicensed wireless
microphones as well as for unlicensed white space devices, the Commission sought comment on various
proposals that would affect each of these operations.8 Specifically, the Commission sought comment on
what additional steps it could take to promote more efficient and effective operation of wireless
microphones in the spectrum that remained for TV broadcast.9
5 See generally Wireless Microphones Further Notice, 25 FCC Rcd at 691-704 ¶¶ 107-151 (also seeking comment
on adoption of certain marketing and labeling requirements, and on whether any other rule parts (e.g., Part 90)
should be changed to better accommodate wireless microphone use in other spectrum bands).
6 TV White Spaces Second MO&O¸ 25 FCC Rcd at 18671-77 ¶¶ 25-36; 47 C.F.R. § 15.707; see also 47 C.F.R. §
7 TV White Spaces Second MO&O, 25 FCC Rcd at 18675-76 ¶¶ 32-33; 47 C.F.R. § 15.713(h)(8)-(9).
8 Incentive Auctions NPRM, at ¶¶ 221-239.
9 Incentive Auctions NPRM, at ¶¶ 224-225. To enable more efficient use of the TV broadcast spectrum available for
wireless microphones, the Commission sought comment on various ways it might reduce the co-channel separation
distances between wireless microphones and television stations. Id. at ¶ 225. The Commission also sought
comment on possible wireless microphone operations in the proposed guard bands so long as they use the same
technologies required of white space device operations in these bands. Id. at ¶ 226.
Updating and Refreshing the RecordConsidering the time that has passed since the Commission issued the Wireless Microphones
Further Notice, and in light of the TV White Spaces Second MO&O and the recently issued Incentive
Auctions NPRM, we ask that interested parties refresh and update the record on the following issues.
Expansion of Part 74 eligibility.In the Wireless Microphones Further Notice, the Commission
sought comment on whether to revise its rules to provide for a “limited” expansion of eligibility under
Part 74, Subpart H of the rules to provide additional categories of users eligible for licensed use of
wireless microphones or other low power auxiliary stations.10 In the Wireless Microphones Further
Notice, the Commission noted that wireless microphones and other low power auxiliary station devices
had been recognized as necessary and beneficial to broadcast productions, and had expanded the list of
entities eligible for a Part 74 license over time to include motion picture and television producers and
certain cable television operators, reasoning that these entities had requirements similar to those of
broadcast licensees.11 The Commission asked extensive questions about whether to authorize licensed
wireless microphone use at certain large theaters, entertainment complexes, sporting arenas, and religious
facilities, because these venues might need the assurance of interference protections afforded Part 74
LPAS licensees.12 The Commission underscored the need to balance the needs of potential new classes of
wireless microphone licensees with those of other users in the TV bands and expressed particular concern
that any “broad expansion” of eligibility could undercut that balance by significantly reducing the amount
of spectrum available for other uses, such as by white space devices.13 The Commission also indicated
that it would take into consideration whether it would be practical for any new licensees to comply with
the requirement that Part 74 licensees coordinate frequencies and provide up-to-date information on
venues and times of operations to the TV bands database system on an ongoing basis so that they do not
otherwise block use to others at times when there is no need.14
In the subsequently released TV White Spaces Second MO&O, the Commission determined that
only a small subset of unlicensed wireless microphone users would qualify for registration in the TV
bands database system. Specifically, the Commission stated that “[a]s a general matter, we . . . find that it
would be inappropriate to protect unlicensed wireless microphones against harmful interference from
other unlicensed devices, and in particular TV bands devices” and observed that the “overwhelming
majority” of wireless microphone use does not merit registration in the TV bands database.15 The
Commission noted that in the vast majority of markets, or to the extent that the number of wireless
microphones needed is relatively low, the operator of unlicensed microphones can avoid receiving
harmful interference from TV white space devices by using the two reserved channels as well as the other
channels in each market where white space devices are not allowed to operate. The Commission
nonetheless provided that “[e]ntities operating or otherwise responsible for the audio systems at major
events where large numbers of wireless microphones will be used and cannot be accommodated in the
available channels at that location may request registration of the site in the TV bands databases.”16 The
Commission further indicated that “major sporting contests” and “live theatrical productions/shows” are
10 See generally Wireless Microphones Further Notice, 25 FCC Rcd at 696-701 ¶¶ 124-139.
11 Wireless Microphones Further Notice, 25 FCC Rcd at 696 ¶ 125.
12 See generally Wireless Microphones Further Notice, 25 FCC Rcd at 696-701 ¶¶ 124-139.
13 Wireless Microphones Further Notice, 25 FCC Rcd at 699 ¶ 134.
14 Id. at 698-99 ¶¶ 132, 135.
15 White Spaces Second MO&O, 25 FCC Rcd at 18674 ¶ 31.
16 Id. at 18675 ¶ 32.
examples of major events that might qualify for registration.17 Such entities may request Commission
approval so that they can register unlicensed microphones at particular venues and specified times in the
TV bands database system and obtain the same protection from interference from unlicensed white space
devices afforded licensed wireless microphone operations.18
We request that interested parties update and refresh the record on whether the Commission
should expand license eligibility under Part 74, Subpart H for certain operators of unlicensed wireless
microphones or other low power auxiliary devices at specified venues. We ask that commenters
advocating an expansion of the eligibility requirements for Part 74 LPAS licensing be as specific as
possible. To the extent that the Commission chooses to expand license eligibility only for certain users
that have wireless microphone requirements substantially similar to those of broadcasters, precisely which
class(es) of users and uses would fall into this category? More specifically, which type(s) or class(es) of
entities and which type(s) of venues or events – whether by type of event, level of quality of service
necessary for the event (e.g., “professional quality”), number of microphones needed, number of seats in
auditorium, or some other qualification or measure19 – should become eligible to hold a license. Should,
for example, the Commission expand license eligibility for some or all of the users or entities that are
permitted to register venues for unlicensed wireless microphone use in the TV bands database system?20
Examples might include entities responsible for major production events that take place at such venues as
Madison Square Garden or Broadway theaters in New York City, the Kennedy Center in Washington DC,
and the Grand Ole Opry in Nashville. Consistent with this approach, what other concrete examples would
qualify? If the Commission were to expand Part 74 license eligibility for all of these entities operating at
such venues, how, precisely, would the Commission define or classify such class(es) of entities in our
Should the Commission establish more specific criteria for eligibility for a low power auxiliary
station license at a specified venue? For instance, the Commission could require that an entity applying
for a license establish each of the following – (1) that the specified venue periodically hosts events that
require the same level of “professional” high production-quality audio as the type needed for broadcast
productions; (2) that these events involve a live production, with an audience in attendance, or a rehearsal
for such events; and (3) that the venue size meets specified criteria depending on the type of venue or
event (e.g., for theaters used for professional productions or house of worship venues, a minimum of
1,000 fixed seats; for auditoriums or convention centers, a space capacity-rated for 3,000 people; for
sports venues, a minimum of 10,000 seats for indoors, and 25,000 seats for outdoors)? We ask for
comment on this or similar approaches. If the Commission were to take this type of approach, how would
it determine which entities meet the first criterion regarding a need for “professional” quality production?
To the extent the venue uses a professional production company or professional frequency coordinator,
would this be sufficient to establish that the venue merits licensing? To what extent should the
Commission consider the need to operate at Part 74 technical parameters (e.g., higher power)? As for the
17Id. at 18674-75 ¶ 31.
18 47 C.F.R. § 15.713(h)(9). We note also that OET and WTB have announced the initial launch of the unlicensed
wireless microphone registration system, and have provided guidance on aspects of the registration process. See
Office of Engineering and Technology and Wireless Telecommunications Bureau Announce the Initial Launch of
Unlicensed Wireless Microphone Registration System, Registration Open in East Coast Region: New York, New
Jersey, Pennsylvania, Delaware, Maryland, Washington DC, Virginia, and North Carolina, ET Docket No. 04-186,
Public Notice, DA 12-1514 (OET/WTB, released Sept. 19, 2012) (Public Notice on Registration of Unlicensed
19 See generally Wireless Microphones Further Notice, 25 FCC Rcd at 696-701 ¶¶ 124-139 (asking many questions
about how the Commission might determine whether certain types of entities might merit licensee status).
20 See generally Public Notice on Registration of Unlicensed Wireless Microphones.
third element, we ask that commenters be specific when discussing which categories of venue (e.g.,
stadium or amphitheater) or capacity measurements (e.g., number of seats) would be appropriate. To
what extent should we also require that an entity show that it would have need for a specified minimum
number of microphones (e.g., 100 or more) at a venue? We seek comment on these various proposals.
We also seek comment on which type(s) of entities would hold the license for operations at a
specified venue. Should the Commission only license specific venues? Under such an approach, a venue
(or a responsible party for the venue) would be licensed, the venue could be registered in the TV bands
database system, and the venue operator, or professional audio companies that act as agents under a
venue’s license when carrying out their engineering responsibilities, could then work directly with the TV
database administrators to register the needed wireless microphone channels for particular events and
times. Alternatively, might the Commission license professional production companies for operations at
specified venues? We seek comment on these or other approaches.
Expanding eligibility for operations at nuclear facilities. In the Wireless Microphones Further
Notice, the Commission also sought comment on possible expansion of license eligibility for the special
case involving the use of low power auxiliary station operations at nuclear power plant facilities.
Specifically, it sought comment on the possibility of expanding eligibility to allow nuclear power plant
operators to obtain licenses under Part 90 to operate certain low power auxiliary station equipment,
certificated for use under Subpart H of Part 74 of the rules, inside nuclear facilities.21 We take this
opportunity to allow commenters to refresh the record on expanding eligibility to include such
applications for these operators. For example, commenters may wish to address whether any additional
means of meeting the operational communications needs of nuclear facilities have become available. If
the Commission were to expand eligibility for Part 74 licensing to nuclear power plant owners and
operators, should it restrict operation of the equipment to indoor use or should use be permitted anywhere
within the plant’s security perimeter? If outdoor use is permitted, should it be limited to particular plant
operations such as fuel handling?
More efficient wireless microphones through technological advancements.As discussed
above, in the Wireless Microphones Further Notice, the Commission expressed its intent to develop
longer-term solutions that would help ensure that wireless microphones operate more efficiently and
effectively on spectrum available for their use, and sought comment on potential technological
innovations that would promote more efficient wireless microphone operations and thereby increase the
availability of spectrum for wireless microphone and other uses 22 In the TV White Spaces Second
MO&O, the Commission observed that wireless microphones generally have operated inefficiently, and
noted that while wireless microphone users may believe they need access to more spectrum, any such
needs “must be accommodated through improvements in spectrum efficiency.”23 In the Incentive
Auctions NPRM, the Commission again noted the importance of more efficient wireless microphone
operations, and sought comment on steps it should take to ensure that any broadcast spectrum available
after repacking is used efficiently and effectively by wireless microphones.24 We seek to refresh and
update the record on potential longer term solutions to the operation of wireless microphones.
As the Commission observed in the Wireless Microphones Further Notice, the majority of
wireless microphones that currently operate in the UHF TV bands are frequency modulated analog
devices that operate with a bandwidth of up to 200 kHz. Because of a number of factors, including the
21 Wireless Microphones Further Notice, 25 FCC Rcd at 701 ¶ 139.
22 See id. at 702-03 ¶¶ 145-49.
23 TV White Spaces Second MO&O, 25 FCC Rcd at 18674 ¶ 29.
24 Incentive Auctions NPRM, at ¶¶ 224-225.
need to avoid intermodulation interference among the devices, the maximum number of wireless
microphones that these analog devices can operate simultaneously in a 6 megahertz TV channel may be
as few as six or eight. Accordingly, with the use of these analog wireless microphones, only between 1.2
and 1.6 megahertz of the 6 megahertz TV channel may be used while the remainder is effectively left
fallow. This constitutes very inefficient use of valuable spectrum. As the Commission noted, most other
radio communications services have shifted from analog to digital technology to improve spectrum
efficiency and resistance to interference.25
We ask that commenters update the record on advances in the wireless microphone technologies
that are enabling more efficient use of spectrum. In particular, we ask that commenters provide detailed
information on the use of more efficient advanced digital technologies. We note that Shure recently
introduced digital wireless microphones that operate in the UHF band that can support up to 14-15
systems on a single 6 megahertz TV channel.26 Sennheiser has similarly announced its new digital
microphone for the UHF band, which uses technology that allows operation of up to 12 wireless
microphones on a six megahertz channel.27 We seek comment on the state of development of digital
technologies from these and other wireless microphone manufacturers, and further development that is
anticipated over the next few years. We ask that commenters present information on the production
values, interference implications, and performance impact of these new microphones. What bandwidth
efficiencies are achievable while still maintaining adequate performance for the specific use? What are
the interference implications, particularly as they relate to intermodulation interference on packing more
microphones into less bandwidth? Are there filters available to mitigate these effects? How does the
fidelity and latency of these new microphones compare to existing equipment and are they adequate for
professional musical and theatrical performances?
What steps should the Commission take to require or encourage further development of digital
wireless microphones? For example, to accommodate more efficient use, should the Commission
implement a requirement to reduce the bandwidth below 200 kHz over an appropriate period of time, and
if so what timeframe would make sense from an equipment development and user transition point of
view? We note that the Commission has adopted requirements to promote spectrum-efficient technology
for other operations,28 and we ask that in updating the record in this proceeding commenters address
whether the Commission should adopt efficiency standards for wireless microphones to encourage
spectral efficiency. If so, how should the Commission establish those standards, and what timeframes
would be appropriate to transition to any such standards? We also seek comment on whether and how the
Commission should facilitate a transition to digital wireless microphones.
25 Wireless Microphones Further Notice, 25 FCC Rcd at 703 ¶ 148.
26 Shure has recently introduced digital wireless microphones that support up to 14 to 15 systems on a single 6
megahertz channel. See “Wireless Mic Users Challenged by New Spectrum Limits,” TVTechnology, available at
27 See “Sennheiser lauches Digital 9000 wireless system at IBC,” Performer Magazine, Sennheiser Press Release
(September 10, 2012), available at http://performermag.com/2012/09/10/sennheiser-launches-digital-9000-wireless-
system-at-ibc/, http://us2.campaign-archive2.com/?u=419dcda8b73a1b5e587b76c36&id=36c71d9fe0; see also
“Sennheiser, Digital 9000,” (2012), http://en-de.sennheiser.com/9000-series/.
28 We note, for instance, that the Commission has adopted requirements for private land mobile radio licensees in
the 150-174 MHz and 421-512 MHz bands to migrate to narrowband technology. See Implementation of Sections
309(j) and 337 of the Communications Act of 1934 as Amended, Second Report and Order and Second Further
Notice of Proposed Rulemaking, WT Docket No. 99-87, RM-9332, 18 FCC Rcd 3034 (2003); Implementation of
Sections 309(j) and 337 of the Communications Act of 1934 as Amended, Third Memorandum Opinion and Order,
Third Further Notice of Proposed Rule Making and Order, WT Docket No. 99-87, RM-9332, 19 FCC Rcd 25045
(2004); Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as Amended, Order, WT
Docket No. 99-87, RM-9332, 25 FCC Rcd 8861 (2010).
Other issues. The Wireless Microphones Further Notice raised several other issues (e.g.,
authorizing unlicensed wireless microphone operations in the TV bands pursuant to particular rules, or
taking steps additional to authorize wireless microphone operations outside of the TV band under other
rules).29 To the extent necessary or appropriate, commenters should feel free to refresh or update the
record on other issues raised in the Wireless Microphones Further Notice that have been affected by more
recent developments or by the two related proceedings if this would help ensure that the Commission can
fully address the issues raised in the Wireless Microphones Further Notice.
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with
the Commission’s ex parte rules.30 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419,
interested parties may file comments and reply comments on or before the dates indicated on the first
page of this document. Comments may be filed using the Commission’s Electronic Comment Filing
System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
29 See generally Wireless Microphones Further Notice, 25 FCC Rcd at 691-704 ¶¶ 107-151.
30 47 C.F.R. §§ 1.1200 et seq.
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(braille, large print, electronic files, audio format), send an e-mail to firstname.lastname@example.org or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
For further information, contact Bill Stafford, Wireless Telecommunications Bureau, (202) 418-
0563, or Alan Stillwell, Office of Engineering and Technology, (202) 418-2470.
Action by the Chief, Wireless Telecommunications Bureau, and the Chief, Office of Engineering
- FCC -
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