GEHC: White Spaces Separation Rules Won't Protect Medical Devices From Interference
GE Healthcare is asking the FCC to “re-evaluate and strengthen” its rules for protecting medical telemetry devices that use TV Channel 37 from adjacent base stations making unlicensed use of the TV white spaces. GEHC filed a petition for reconsideration, saying the agency’s rules don't adequately protect medical use of the spectrum. Hospitals use medical telemetry to wirelessly monitor cardiac and other patients.
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GEHC said its testing shows “building loss” could be much lower than the FCC assumes, which means the signals from TV white spaces (TVWS) devices would cause interference to medical telemetry devices unless the FCC addresses separation distances between the two. The Wireless Medical Telemetry Service (WMTS) Coalition is already asking the FCC to separate its decision on technical rules for the use of Channel 37 by unlicensed TV white spaces devices from the rest of the Part 15 report and order set for a vote at the agency’s Aug. 6 meeting (see 1507230053).
GEHC warns in the petition that even operations in Channels 36 and 38 could have “serious adverse effects” if the rules aren't changed. An industry official told us GEHC believes the FCC assumes too much TV band device (TVBD) signal degradation. "There are a lot of WMTS systems that will likely be line of sight to a TVBD transmitter, where the building loss approaches 0 dB,” the official said.
GEHC tests “have demonstrated that the realistic worst-case building penetration loss value approaches 0 dB,” GEHC said. “The discrepancy between the GEHC field tests and the Commission’s assumption for building penetration loss significantly impacts computation of the separation distances required to prevent harmful interference from adjacent band mobile base stations to WMTS operations on Channel 37, such that these distances cannot reasonably be assumed to exist without requiring coordination.”
Meanwhile, the FCC posted additional comments from medical professionals concerned about protecting Channel 37 from interference from unlicensed devices. The comments come from Memorial Hospital Health Care Center in Jasper, Indiana, and were posted in docket 14-165.
White spaces advocate Harold Feld, senior vice president of Public Knowledge, shot back. “There is an odd delusion among those who do not regularly participate at the FCC that FCC engineers cannot spot baloney when it is dressed up with math,” Feld said. “This may be GEHC's first trip to the rodeo, but [FCC engineers] are quite familiar with what BS smells like. Last minute doomsday predictions that could have been submitted well before the last minute, and thus subject to scrutiny from opponents, are a familiar staple to anyone who has played this game before.” GEHC is only hurting its own case, Feld said. “As a TV white space advocate, I expect the FCC to be unduly conservative when it sets the protection zones,” he said. “The FCC is always conservative on life and safety issues. But conservative does not mean paralyzed. The FCC will evaluate this submission, and I am confident they will see it for what it is.”
"Like other incumbents profiting from a free grant of spectrum, GE has resisted sharing this lightly-used channel from day one," said Michael Calabrese, director of New America Foundation’s Wireless Future Project. "The record clearly establishes that very low-power unlicensed use will not cause harmful interference. The exclusion zones in the FCC's draft order would grossly over-protect medical telemetry. A better policy would require the industry to take simple steps to minimize the risk and promote efficient spectrum sharing."