SBE Asks FCC to Modify ULS to Allow Better Documentation of TV Pickup Receive Sites
September 20, 2005
As you may have noticed, more services are sharing spectrum in and around the 2 GHz broadcast auxiliary service (BAS) band. The FCC has allowed Department of Defense (DOD) uplink stations to share the band. Advanced Wireless Services (AWS), PCS and mobile multimedia services such as those planned by Nextel are on nearby frequencies, as are mobile satellite service (MSS) ancillary terrestrial stations and Broadband Radio Service base stations. Some of these stations are allowed effective isotropic radiated powers up to 1,600 watts. ENG receive sites using the 2 GHz band located near these stations will be affected by out of band emissions from facilities in adjacent bands and by on-channel interference from the DOD uplinks.
The Society of Broadcast Engineers has recognized that one way to avoid interference from these facilities is to locate them away from broadcast ENG receive sites. Unfortunately, the heights and locations of these receive sites are not requested when ENG license applications are filed, nor is there a place in the Universal Licensing System (ULS) to enter them. SBE alerted the FCC to this limitation in its July 9, 2001 comments in ET Docket 01-75 rule making to update FCC Part 74 BAS rules. The FCC said the SBE comments were outside the scope of that rule making. The SBE filed a Petition for Partial Reconsideration of the ET 01-75 Report and Order arguing it is within the scope of the rule making. In its response, the FCC denied the SBE's request, but invited the SBE to submit a petition for rule making to make the desired changes to the ULS and FCC Form 601.
On Sept. 6, the SBE filed a Petition for Rulemaking In the Matter of Modification of the Universal Licensing System to Allow TV Pickup Stations and Remote Pickup Stations to Document the Locations and Heights of Their Receive-Only Sites. In addition to the TV pickup receive sites described earlier, the Petition requested remote pickup stations using other frequencies, such as those in the 450 and 455 MHz bands, be allowed to register their receive sites.
In addition to the arguments summarized above, SBE's Petition for Rulemaking includes exhibits showing the potential impact of transmitters on adjacent frequencies and in-band sharing on 2 GHz ENG operations.
Under the SBE plan, registration of receive sites would not be mandatory, but licensees that did not register receive sites would not be protected from interference.
In its filing, the SBE pointed out that as part of the 2 GHz relocation now underway, all 2 GHz licensees will have to modify their licenses to conform with the new band plan and emission bandwidths. This presents an ideal opportunity to update the ULS, if the FCC can move quickly to provide a place in the on-line forms to enter TV and remote pickup receive site location and height data.