BROADCASTERS FRET OVER FCC PLAN TO RELOCATE DoD SITES FOR 3G

The FCC in July outlined proposed options for relocating federal spectrum users to help clear 1710-1755 MHz for 3G and other advanced wireless services (AWS). A year ago the Commission adopted an order and proposed service rules for 2 blocs of 45 MHz, including 1710-1755 MHz, which the DoD had agreed to clear by moving incumbents. To achieve that, the FCC had proposed letting DoD use 2025-2110 MHz on a co-equal, co-primary basis with non-federal govt. operations for earth stations at 11 sites that supported military space operations. The proposal also would roll back the creation of Wireless Communications Services spectrum at 2385-2395 MHz, letting federal and nonfederal flight test stations operate in that 10 MHz and no longer making 2390-2400 MHz available for unlicensed PCS. That in effect would let DoD relocate all aeronautical mobile systems out of 1710-1755 MHz.

NAB and MSTV told the FCC that the potential BAS impact was hard to assess because NTIA hadn’t released details on the technical parameters of the 11 DoD systems to be relocated. The broadcasters commissioned 2 studies, one of which aimed to quantify the 2 GHz BAS licensees that would need to coordinate with the 11 DoD facilities, which support military space operations. The other estimated the interference potential of the DoD facilities with BAS operations. “The 2nd study demonstrates that numerous BAS stations will experience harmful interference from the DoD facilities, and under certain conditions, will be completely overloaded and therefore rendered useless,” the broadcasters said. They said BAS was used to transmit live news coverage and special events and had fixed links that let stations in less-urban areas transmit programming to more remote areas. NAB and MSTV said they opposed the proposed relocation of the DoD facilities to the 2 GHz BAS band, at least until NTIA made more data available.

Gannett expressed concerns about the FCC proposal to let DoD operate satellite uplinks in several locations in the BAS band, including Buckley Air Force Base near Denver. Gannett operates KUSA-TV in Denver and said it made “heavy use” of microwave BAS facilities at 2025-2110 MHz. “Engineering data shows, however, that such spectrum sharing in Denver would result in significant interference, rendering the broadcasters’ systems essentially inoperable,” Gannett said. It asked FCC to consider alternatives outlined in the rulemaking, including keeping the uplinks in their current spectrum and using narrower channels or relocating the uplink at Buckley AFB farther from the Denver area. Other options included limiting how low the angle of the main beam of the antenna could be above the horizon.

In a detailed technical assessment, the Society of Bcst. Engineers (SBE) also said moving the 11 DoD uplinks into the BAS band would “pose a serious interference threat to the ability of broadcasters to continue to use these frequencies for electronic newsgathering (ENG) in the vicinity of the DoD uplinks.” SBE said the uplinks would be co-channel to the TV BAS operations, making filters or more selective receivers of little help. SBE said: “DoD, NTIA and the FCC all need to realize that broadcast ENG is an important component of homeland security in terms of reducing public panic during an emergency.”

Cingular Wireless supported the proposal to permit DoD to use the BAS spectrum for earth stations that supported military space operations or tracking, telemetry and commanding systems. But the carrier expressed concern about out-of-band emissions and receiver overload affecting commercial mobile radio service (CMRS) operations in the adjacent 2110-2155 MHz band for AWS, the nearby 1930-1990 MHz for broadband PCS and the PCS G-block proposed for 1910- 1915/1990-1995 MHz. DoD systems in the BAS band at 2025-2110 MHz could affect commercial wireless services through out-of- band emissions that fell directly into a wireless band and through receiver overload or blocking, Cingular said.

CTIA urged the FCC not to allow the formation of rules on the use of the BAS band “to interfere with or delay the clearing of the 1710-1755 MHz band, which is necessary for the successful deployment of AWS.” CTIA said it had no problems with the proposal to allow DoD to operate the transmit earth stations at the 11 sites on a co-equal, primary basis with BAS as long as CMRS operations in adjacent bands were protected.

Motorola urged the FCC to retain the 1915-1920 MHz band for unlicensed PCS use and allow isochronous devices to operate in that band. The company said it opposed the proposed changes in Part 15 rules that would eliminate the designation of 1910-1920 MHz for unlicensed PCS. Motorola cited a Feb. 2001 DoD report acknowledging the potential for interference to AWS receivers as a result of earth station operations’ being introduced into the BAS band. AWS operations would be in the adjacent band of 2110-2155 MHz. Motorola said one possibility for mitigating interference would be to restrict use of the top 12 MHz of 2025-2110 MHz and to adopt filtering requirements. Because the proposed DoD operations that would be moving to the BAS band were limited, Motorola said it might be reasonable to establish coordination procedures that considered the specific operations and propagation loses around each DoD earth station.

Citing the proposed licensing of nonfederal flight test stations at 2385-2395 MHz and the allocation of 2360-2395 MHz for govt. aeronautical mobile operations on a primary basis, Sirius Satellite Radio and XM Satellite Radio sought sufficient limits on unwanted emissions from new aeronautical operations to protect the satellite digital audio radio service (DARS). Satellite DARS operate nearby at 2320-2345 MHz. The companies said in a joint filing that satellite DARS user receivers were designed with a sufficient uplink margin to overcome outages from small or brief blockage, multipath fading and foliage attenuation. “Providing uninterrupted high-quality audio in a mobile environment typically leaves little excess margin to overcome out-of-band interference from adjacent services,” they said. “Because satellite DARS users demand nationwide coverage and the proposed new operators in the 2360-2395 MHz band include airborne transmitters -- which will always be in line of sight of satellite DARS receivers -- any out-of-band interference into the satellite DARS spectrum will be pervasive and continuous.”

Urging the FCC to move swiftly to make the AWS spectrum available, Ericsson said it supported the proposals for relocating DoD users. “In order to support existing and emerging technologies, including implementation of 3G services, it is critical that additional spectrum be made available for use by the wireless industry,” it said.