Wetmachine: Harold Feld's Tales of the Sausage Factory

Follow Up On Medical Devices: Smarter Devices And Smarter Policy, Not More Bandwidth

So I've been following up more since initial post yesterday. As a general matter, I recommend interested readers start with this piece from the FDA's website, followed by the FCC's Office of Engineering and Technology (OET) FAQ on wireless medical telemetry devices and the digital transition. OET does not see this as likely to cause a big deal because there's plenty of empty “white spaces” out there after the digital transition and users can adjust their devices as digital televisions come online.

Well, I hope they are right about that, although I'd feel a lot better if someone were responsible for actually keeping track of this and making sure that users get informed. Under the rules, there are notification requirements for when a station goes live with its digital signal so hospitals can make changes. That works as long as folks are paying attention, of course. In any event, in case OET is looking for more work (or someone on the Hill wants to step up), I would suggest that it would be awfully nice to know what the state of the industry is. But I suspect the right place to do that is really the FDA not the FCC, or perhaps the U.S. Department of Health and Human Services.

But there is a broader lesson here. As with wireless microphones and a host of other specific low power applications, the real problem is not capacity. The problem is that we have a legacy system that slices spectrum uses into these discrete little services rather than allowing general low power unlicensed use and using cognitive radios to avoid interference.

Hospitals provide a particularly useful environment for smart devices, because they have so many noisy devices, sensitive devices, and such an expanding need for wireless devices for medical telemetry. Imagine a device that works equally well in all locations of the hospital without putting other systems at risk because it senses and adjusts for its radio frequency environment in a real-time basis. If another doctor starts up a device in a neighboring bed that is noise generator, the device monitoring my patient will move to a clear frequency. Devices and systems could even be tagged for priority, so that a mobile monitor attached to a patient knows that it must give the “right of way” to the cardiac ward systems if they come into conflict.

But more specifically here, there is nothing that existing wireless medical telemetry devices authorized in the band do that could not be replicated more flexibly and at lower cost by authorizing generic low-power white spaces devices. This is essentially the same problem as with wireless microphones. If wireless microphones had never received a special dispensation to function in the broadcast white spaces as a licensed ancillary service, you could replicate these systems with unlicensed white spaces devices. But, like the QWERTY typewriter, they are an embedded technology. And they have a constituency that, quite logically, resists change and argues that it plays an important role that generic devices could not replicate.

We thus have the irony of everybody agreeing there is “plenty of white space” for existing secondary users like wireless microphones and medical telemetry, but supposedly no room for the next generation of devices that could do the job of both technologies and bring us a host of other applications besides. We could cure this with more powerful cognitive radios, but the same natural conservatism by incumbents against any intrusion in “their” spectrum makes any movement in that direction politically difficult (as demonstrated by the FCC terminating two promising proceedings last year).

We therefore have the classic political and collective action result of fixing the wrong problem, at least from a public policy perspective. Rather than expanding wireless use generally, we make the new, more useful generic technology subordinate to the existing stakeholders. It is rather like what would have happened if harness makers and farriers had been able to demand that automobiles must protect their industries before being allowed to share the road with the horse and buggy.

Hardly a new problem or an original observation, I recognize. This has been the lament of spectrum reformers since five minutes after the first licenses were issued and the rest of us got cut off. Still, I keep hoping that this time around we'll manage to get the right result and not let the embedded old technology trump the next generation of users.

Stay tuned . . . .

posted at 14:07:26 on 04/30/08 by Harold - Category: Spectrum

Comments

Ian wrote:

“users can adjust their devices as digital television comes online”

That assumes quite a bit about the devices in question, never mind the hospital IT staff. I don't know much about hospital hardware, but while your cordless phone might have a channel button, your microwave doesn't. How many of the wireless devices in your home can YOU adjust?

04/30/08 15:07:06

Ian wrote:

Ok, obviously all the devices in your home are Part 15 or whatever, but I think my point is a good one anyway.

04/30/08 15:08:24

Henry Cohen wrote:

“This is essentially the same problem as with wireless microphones. If wireless microphones had never received a special dispensation to function in the broadcast white spaces as a licensed ancillary service, you could replicate these systems with unlicensed white spaces devices”
Really? I've yet to hear of any new WSD, spectrally efficient digital technology(ies) that can deliver the very high audio fidelity and ultra-low latencies that legacy FM technology delivers, and that is expected/demanded by the consumer when they attend a concert, theatrical production, corporate presentation or turn on their HD DTV.

That said, I'll readily admit that this isn't a good situation, and new cost effective technologies for wireless mics/intercom/IEMs/IFBs need to be developed. But to say the coming WSDs are a suitable replacement for current professional level wireless production equipment is folly.

05/01/08 08:59:24

Harold wrote:

Henry:

You are absolutely right in the short term. And I would also agree that we can't displace wireless microphones NOW, because there is a substantial user community that relies on them. My point is that if we were starting with a blank slate, we would do this very differently and the benefits of access to the available spectrum would be more broadly distributed.

05/01/08 11:33:25

Henry Cohen wrote:

Not to be too pedantic, but I'd like to ensure everyone understands it's not just the large user base of wireless production equipment, but the *very* large consumer market that expects high quality audio (iPod/MP3 crap not withstanding) for their ticket/monthly subscriber price.

05/01/08 12:44:42

Rich Brown wrote:

It's worth noting here that TV stations are among the biggest users of UHF wireless microphones out there.

05/01/08 14:48:23

Harold wrote:

Rich:

Biggest _authorized_ users of wireless microphones.

One of the problems is that the number of authorized users is relatively small compared to the number of unauthorized users — and the intensity of unauthorized use. For example, Broadway theater companies are not authorized to use wireless microphones licensed as BAS service under Part 74. But they do, and very intensely, with (I am told by these folks) dozens of wireless microphones used to pick up stage action and distribute it through the theater's sound system (ah for the old days when folks relied on acoustics).

There are two problems here. One, it has created a huge problem where the FCC essentially is being asked to provide protection not merely for the authorized user community, which is relatively identifiable and coherent, but for the much larger unauthorized user community. It is a political reality that you can't go fine 1,000,000 or so people — from megachurches to business conference centers to musicians in coffee houses — or tell them to stop using wireless microphones. At the same time, the FCC cannot require that authorized Part 15 white spaces devices protect unauthorized users.

Worse, as I pointed out awhile ago, these devices are functioning in what will become the public safety and commercial wireless bands after February 2009. With so many unauthorized users out there, most completely oblivious to the physics, odds are good there will be random pockets of interference (especially in places where use is intense). But because the unauthorized user community is this huge white elephant that nobody wants to talk about, we can't even begin to address this problem.

05/01/08 15:40:28

Henry Cohen wrote:

“Biggest _authorized_ users of wireless microphones.”
Unfortunately, a huge number of wireless mics/coms/IFBs/IEMs used by legitimate broadcasters are *not* licensed.

“But they do, and very intensely, with (I am told by these folks) dozens of wireless microphones used to pick up stage action and distribute it through the theater's sound system (ah for the old days when folks relied on acoustics)”
I can't tell you how frustrating it is for theatrical sound designers and mixing board operators that most actors don't know how to project. If you'd like a backstage tour of a large scale Broadway musical's wireless equipment and sound system, let me know.

“Worse, as I pointed out awhile ago, these devices are functioning in what will become the public safety and commercial wireless bands after February 2009. With so many unauthorized users out there, most completely oblivious to the physics, odds are good there will be random pockets of interference (especially in places where use is intense). But because the unauthorized user community is this huge white elephant that nobody wants to talk about, we can't even begin to address this problem.”
The entertainment production industry has for about a year now begun a migration out of the 700MHz band (698-806MHz) precisely because we know we can't compete with higher power mobile WB and NB services, despite the current rules which still state Part 74 devices will be allowed to operate in that spectrum. (I believe however the FCC will change that once the 700MHz auction winners and the PS community yell loudly enough.) Despite NAB and MSTV protestations, the entertainment production industry as a whole is more than willing to discuss this problem (as long as the the only topic isn't a universal shut down of Part 74 devices ).

05/01/08 17:54:26