The Society of Broadcast Engineers, in comments filed June 27 with the Federal Communications Commission, opposed an agency proposal to allow Fixed Service (FS) operations into bands licensed for Broadcast Auxiliary Service (BAS), such as ENG, and Cable TV Relay Service (CARS) as well as another to segregate the band for FS, BAS and CARS services.
The SBE filed the comments in response to the commission's "Wireless Backhaul: Further Inquiry into Fixed Service Sharing of 6875-7125MHz and 12700-13200MHz Bands" proceeding.
In rejecting the proposals, the SBE said the fact that the agency issued the Public Notice "despite a full and complete record from the comments filed in the proceeding to date (which clearly identify the obstacles to effectuating FS sharing with mobile BAS and CARS operation), indicates that the Commission has already decided what the outcome of this proceeding is going to be."
The SBE filing said the process being employed in the FS-BAS-CARS matter is like "so many others in recent Commission jurisprudence" that is "conducted exactly backwards." According to the filing, the FCC has "already conceptually adopted" adding Fixed Service backhaul to the 7GHz and 13GHz bands used today for BAS and CARS with the aim of facilitating expanded broadband. "The concept appears as a fait accompli in the National Broadband Plan," the filing said.
Aside from questioning the process being used to consider the proposals, the SBE filing took aim at specifics. According to the filing, the proposal makes no allowance for protecting new BAS or CARS service areas that do not duplicate existing licensed BAS or CARS service areas from interference generated by FS operations. "That is a complete disaccommodation for any new BAS or CARS facilities and presumes that there is and should be no growth in BAS or CARS operation at 7 or 13 GHz at all," the filing said.
The filing also found fault with studies from the Wireless Bureau that don't reflect the real range of 7GHz and 13GHZ used for ENG. Section 74.24 of existing FCC rules allows ENG operation outside licensed coverage areas on a temporary basis. That provision was created to relieve commission staff from having to issue thousands of Special Temporary Authorizations as well as to accommodate the unpredictability of where news happens, the filing said.
BAS and CARS operations pursuant to the Section 74.24 would not be protected from FS links envisioned by the commission's plan, nor would the FS links be protected from those BAS and CARS operations, the filing said.
"If the Commission proposes now to limit BAS and CARS licensees to operation only within licensed service areas, and to delete Section 74.24 in order to force this incompatible sharing plan, it would have the effect of eliminating broadcasters' ability to cover news events and it would have an exceptional, negative effect on localism in broadcasting," the filing said.
The filing also rejected the idea of segregating channels used for FS and mobile services in the 7GHz and 13GHz bands. Doing so would "result in a substantial reduction in the availability of both bands for TV pickup operation going forward," the filing said.
The SBE told the commission in the filing that policy decisions shouldn't be made prior to technical spectrum planning and said "the prejudgment that is manifest in this proceeding is unsettling."