SBE: 2.5 GHz MSS Relocation Reimbursement Shouldn't Be Limited to Channel A10
April 5, 2004
The Society of Broadcast Engineers (SBE) filed a Reply to Opposition to Petition for Reconsideration in FCC International Bureau Docket 01-185, Flexibility for Delivery of Communications by Mobile-Satellite Service Providers in the 2 GHz Band, the L-Band, and the 1.6/2.4 GHz Bands.
Globalstar filed an opposition to SBE's Petition for Reconsideration of the Docket 01-185 Report and Order. In the Opposition, Globalstar argued that only Channel A10 (2,483.5-2,500 MHz) TV Broadcast Auxiliary Service (BAS) licensees should be entitled for relocation expenses and not TV BAS licensees on the adjacent channel A9 and A8.
SBE said that Channel A10, "plays a vital 'safety valve' role" in allowing licensees to cover events in other TV markets such as golf tournaments, car races, political conventions, and marathons. To maintain the de facto three channel plan for 2 .5 GHz, SBE argues "not only must the Channel A10 'grandfathered' operations be converted from 16.5 MHz wide FM analog video operation to digital operation, so must all TV BAS stations on Channels A8 and A9." This would mirror the decision reached in the ET Docket 95-18 rulemaking for MSS relocation of TV BAS operations on existing channels A1 and A2.
SBE noted that channels A8 and A9 are shared with Part 15 devices and do suffer from interference from these devices. As Channel A10 is not shared and does not suffer from this interference, loss of it "would be all the more devastating." Converting the 2.5 GHz TV Band to all digital operation would reduce the susceptibility of the "re-farmed" digital 2.5 GHz TV BAS receivers to interference from Part 15 devices.
SBE concluded its reply, "Globalstar is wrong when it suggests that only Channel A10 TV BAS licensees need to be converted to digital operation on Channels A8 or A9. To preserve the critical and important present de facto three-channel capability that now exists for 2.5 GHz TV BAS operations, all TV BAS stations on Channels A8, A9 and A10 must be converted to narrower digital operation, to maintain a three-channel capability in a reduced bandwidth of 33.5 MHz. SBE believes that MSS is obligated to do so under the well-established emerging technologies policy adopted by the Commission in the ET Docket 92-9 rulemaking."
Refer to the SBE Reply to Opposition to Petition for Reconsideration for additional information, including certification of grandfathered status.