The FCC's Wireless Bureau has issued a declaratory ruling clarifying that a frequency coordination is required for Broadcast Auxiliary Service (BAS) microwave applications above 2110MHz whenever a change could affect other licensees. This requirement applies regardless of whether the change is “major” or “minor.”
New BAS fixed microwave links and major changes in existing links must go through a formal frequency coordination process. This procedure allows existing licensees and applicants who may be affected to protest, before a license application is filed with the FCC.
What constitutes a major change
Major changes requiring prior coordination include changes in:
location of more than five seconds of latitude or longitude;
area of operation;
frequency tolerance and transmission bandwidth;
emission type (including conversion from analog to digital);
EIRP (power), if increased by more than 3dB;
antenna beam width or polarization; and
antenna height, if increased by more than 3m.
Thus, if a change affects the extent to which a signal can cause interference to others, the change generally is major, and the applicant must always coordinate before filing for a license. Several engineering firms offer coordination services. The coordination process takes 30 days or more.
Policy for minor changes
Until the FCC's recent ruling, minor changes — which have less impact than the major change categories noted above — could be implemented as a matter of right. However, under the prior policy, if a minor change involved any change in operating parameters, the FCC had to be notified through the filing of a license application within 30 days after the change was made.
To head off interference, the engineering community asked the FCC to require coordination prior to implementation of even minor changes. The FCC agreed, but ruled that coordination of minor changes would be required only if the proposed change “could affect or be affected by” anyone else's facilities, in which case an applicant must coordinate before implementing a minor change and filing its license application.
In spite of this change in policy, the FCC is not requiring applicants for minor changes to include evidence of coordination as part of their Form 601 applications. But minor change applicants nevertheless have to complete such studies before filing if another station might be affected. In those cases where a minor change by one facility will lessen interference to another, the applicant must, as in the past, file a license application within 30 days after the change is made, so that the FCC can update the database used by coordinators.
Who is not affected
The formal coordination process, described in Section 101.103(d) of the FCC's rules, is not required for fixed or mobile stations below 2110MHz (including 2GHz ENG systems), mobile stations in higher bands, or short-term operation of 30 days or less under Section 74.24. In those situations, informal coordination is required with all licensees in the area. Informal coordination entails contacting a local frequency coordinating committee if one exists, or otherwise contacting anyone you can find who might be affected by the proposed operation.
Harry C. Martin is a member of Fletcher, Heald and Hildreth, PLC.
Noncommercial TV stations in Arkansas, Louisiana, Mississippi, New Jersey and New York must file their biennial ownership reports by Feb. 1, 2011.
By Feb. 1, TV and Class A TV stations in the following locations must place their EEO public file reports in their files and post them on their websites: Arkansas, Kansas, Louisiana,Mississippi, Nebraska, New Jersey, New York and Oklahoma.
Feb. 1 is the deadline for TV stations in New Jersey and New York to electronically file their broadcast EEO midterm reports (Form 397) with the FCC.
Send questions and comments to: firstname.lastname@example.org