WASHINGTON, D.C.—Since our founding in 2000, Future of Music Coalition has focused on the creation of a legitimate digital music marketplace that offers artists access to the widest possible audiences while compensating them for their work. Our efforts have focused on identifying and repairing government policies that create unnecessary barriers for musicians. We’ve worked to rein in runaway radio consolidation, expand and protect community radio, end structural payola and establish clear guidelines for net neutrality so musicians and consumers can benefit from new technologies to access and distribute legal content.

Broadband Access Is Essential To The Legitimate Digital Marketplace

We firmly believe that the creation of a competitive market for broadband services is critical for musicians and for music fans. Clearly, artists and songwriters require affordable access to these technologies to manage effectively both their careers and households. Any hope for a legitimate digital music marketplace for artists and songwriters is contingent on ubiquitous and affordable broadband access for the general public. Too many consumers lack any real choice in broadband providers, and many communities have no access at all.

This brings us to the issue of White Spaces, which is the terminology that the FCC and technology companies use to describe the (mostly) unoccupied chunks of frequencies in the existing TV spectrum. These are frequencies that could be used by new, “smart” technologies for a wide variety of purposes, including providing efficient and powerful broadband to areas that have been difficult to service, such as rural communities. White space devices (WSDs) are technologies that automatically detect these open frequencies, giving the public access to an unused but highly viable portion of the spectrum.

Why We Think White Spaces Are Important

FMC supports policies that unlock unused spectrum for a variety of purposes, including the creation of more non-commercial Low-Power FM radio stations in between existing full power commercial stations. Currently, a diverse coalition of public interest groups and technology innovators are encouraging the FCC to move ahead with an initiative to allow the creation of a new generation of wireless devices that can utilize the white spaces. However, the National Association of Broadcasters and some other groups have been telling Congress that these proposed white space devices will cause undue interference with existing TV signals. The NAB is calling for more technical testing, even though engineers hired by the FCC believe these technologies can be implemented without causing interference to existing broadcast signals.

The Wireless Microphone Interference Issue

White Spaces brings up another issue for the arts community. A large number of wireless microphones — the kind employed by performance venues and bands on tour — have been using portions of the soon-to-be vacated analog TV spectrum without permission from the FCC.  All arts advocates are justifiably concerned that the development of White Space devices could have a negative impact on the ability of wireless microphones to operate without interruption.  There are many perspectives in the arts community — some advocates argue that their prior use of this spectrum should take priority over any future implementation of White Space devices and they would like protection from any potential interference from new White Spaces devices.

Our Position

FMC has been working on this issue for over a year in an effort to foster constructive dialog between the White Space advocates and the performing arts communities. Our position can be summarized in four themes:

1. Access to and deployment of technology is a core concern to the music community. Artists require access to high-speed broadband technologies to manage their own careers. And, universal broadband access and a competitive marketplace will grow the number of active consumers in the legitimate digital music marketplace.

2. Implementation of White Space devices should occur in a manner that does not disrupt existing wireless microphones. Technology solutions have been proposed and should be vetted by engineers in the public and private sectors.  FMC encourages constructive dialogue between arts, technology groups and public interest organizations as devices are developed and tested.

3. The FCC should collaborate with performing arts groups to clear up confusion around the legal status of wireless microphones and develop a transition plan to ensure that these groups have continued and uninterrupted access to spectrum, which is crucial to their activities.

4. If implementation of new White Space devices requires end users to invest in new technology, they should be assisted with the cost of new technology. FCC rules are confusing, and if it’s determined that a system upgrade is required to coexist with white space devices, users should not have to carry financial burden.

Future of Music Coalition will continue to work with both White Space advocates and the arts community toward common ground on these principles. We firmly believe the FCC has the capability to manage an orderly process that can lead to thoughtful implementation of these devices in ways that benefit the arts community.