FCC Acts on Petitions for Reconsideration of New Microwave Rules
October 27, 2003
The FCC acted on petitions for reconsideration of the Report and Order that revised broadcast auxiliary service (BAS), cable television relay service and fixed services in Parts 74, 78 and 101 of the FCC rules. The SBE petition asking that the FCC treat composite, dual carrier analog/digital TV BAS emissions (such as that produced by the MRC Twinstream radios) in a single BAS channel as separate emissions was rejected. The FCC said its decision to treat these dual hybrid TV BAS systems as a "single, aggregate emission regarding emission mask, emission designator, and Equivalent Isotropically Radiated Power (EIRP) determinations in the equipment authorization and station licensing processes" conformed to how it treated similar equipment used by the fixed service under Part 101.
SBE raised concerns that treating the dual carrier systems as one single emission would result in inaccurate frequency coordination due to, among other things, the difference in EIRP between the two carriers. The FCC rejected that argument, saying, "we reiterate that for specific composite systems, coordinators could determine individual technical and operational details and interference protection criteria via the manufacturer and model shown in the individual license record in the ULS or, when necessary, contact the licensee to obtain this information through the normal coordination process, as is appropriate wherever additional technical or operational details are needed. In response to SBE's concern regarding the determination of whether the analog or digital carrier is on the low or high side of the channel, we note that the licensee could similarly be contacted. Finally, because the need to accommodate analog emissions will likely decrease after the transition to DTV, we believe that the utility of these transitional analog/digital systems, as well as any need to obtain additional technical details for frequency coordination, will be relatively short-lived. Accordingly, we do not find that frequency coordination would be unnecessarily complicated by aggregate treatment of BAS emissions within a channel, and consequently deny SBE's Petition. We therefore find separate treatment of analog and digital emissions unnecessary."
The FCC Memorandum Opinion and Order FCC 03-246 also addressed the Nassau County Police Department's concern about use of lower UHF channels for low power auxiliary uses. It confirmed, at SBE's request, that in the BAS RPU 450/455 MHz bands the rules permit the new narrowband channels to be stacked to achieve wider bandwidths, up to 50 KHz. The FCC, however, encouraged "licensees to operate with spectrally efficient equipment and use the minimum bandwidth necessary for their operation." The SBE was also concerned about the use of narrowband digital emissions in the 7 and 13 GHz bands where only wideband (25 MHz) channel plans currently exist. The FCC noted that "if no other deficiencies exist, an application for narrowband emissions within a wideband channel will not be routinely dismissed. In addition, we note that the Commission grants licenses for these bands by specifying a band of operation, not a specific operating frequency. Therefore, a licensee has flexibility to locate its emissions within a channel where it is most advantageous." The FCC said that to promote spectrum efficiency, the rules allow licensees to multiplex multiple signals within a channel. "Under this rule, licensees may provide information using multiple narrowband channels within the larger channel subject to the condition that the composite emissions meet the rules for out-of-band emissions. In these instances, we note that spectral efficiency will be further enhanced if the presence of systems operating on frequencies other than the channel center is accounted for in the frequency coordination process."
The FCC rejected the SBE proposal that licensees be allowed to electively register fixed remote pickup (RPU) receive sites in the ULS database. The FCC said, "At this time, we find that such elective registration is unnecessary. However, if parties continue to believe that such a requirement would be beneficial they may file a petition for rulemaking seeking the imposition of TVPU receive site registration."
More information is available in the FCC Memorandum Opinion and Order FCC 03-246.