The National Cable and Telecommunication Association today filed a letter with the FCC urging the commission to issue a public notice seeking review of the recently released Office of Engineering and Technology report detailing the results of testing devices that are designed to use the TV band white spaces.

The letter said, in part: "Reports indicate the commission is poised to vote on an item at its Nov. 4 meeting, barely two weeks after the report's release, to authorize unlicensed operation of portable TV band devices at a power level that completely ignores and contradicts the commission's own findings. According to the chairman's press statements, the proposed item would allow devices to operate at 100 mW - 20 times the power that has been shown to cause interference to cable television reception of both analog and digital signals. This is frankly inexplicable.

"We urge the commission not to rush to a decision that would ignore the unique and proven hazards of such devices to cable television viewers. Even assuming a policy that some level of interference has to be tolerated by existing television services in an effort to advance the introduction of new emerging services, it is unreasonable to accept interference at an extreme level that will risk serious harm to consumers by degrading or wiping out their television picture.

"This trade-off would be even more egregious in apartments and other multi-dwelling unit buildings where consumers would have no control over interfering devices in adjacent units, assuming such devices can even be located.

"As a practical matter, the disruption in cable service from interfering white spaces devices will confuse cable customers and result in increased costs.

"There is every reason, therefore, for the commission to more appropriately consider the balance that should be struck in this proceeding and rule on the side of lowering the permissible output power. As experience is gained from the devices in the field, the commission can always permit increases in the power output and other technical modifications. At a minimum, we believe the commission should proceed cautiously by issuing a Notice explaining its conclusions and giving affected services the opportunity to fully comment on the complex technical issues raised in the OET Report."