The Society of Broadcast Engineers (SBE) last week added its voice to opposing the new BAS reallocation rules proposed by the FCC.
The organization in a Petition for Reconsideration
of the FCC Third Report and Third Memorandum Opinion and Order
on reallocation of the 2-GHz broadcast auxiliary spectrum said, "Two different band plans will cause massive interference and significant loss of news service to the American public." This conclusion is based on a laboratory tests conducted by Microwave Radio Corporation to determine the amount of interference a digital signal operating under the new 12-MHz channel band plan would cause to a conventional FM analog video signal operating under the old 17-MHz channel band plan and vice-versa.
This situation has to be evaluated because, as the SBE filing and the NAB/MSTV Petition for Reconsideration and Clarification
(see article in this week's RF Report) point out, there are many cases where news crews from top 30 markets and those outside the top 30 markets will be covering the same story in the same location. Local frequency coordinators pointed out that stations in the Salinas-Monterey market (#121) rely on mountaintop ENG receive sites in the Coastal Range separating the Monterey Bay region from the San Francisco Bay metro area. Numerous stations in the San Jose/San Francisco/Oakland market (#5) rely on a mountaintop site only two miles away on the same mountain range. The SBE filing explains, "When the large-market stations fly their helicopters or drive their ENG vans to the coast to provide their audience information about a breaking news story or natural disaster, coordination between the large-market and small-market stations will be virtually impossible, as each Salinas/Monterey user of the legacy band plan will necessarily receive on-axis, co-channel interference from up to three users of the new band plan."
SBE points out that similar situations exist between top 30 market stations and stations in surrounding markets -- Boston and Providence; Phoenix and Tucson; and Chicago and Milwaukee. "Coordinators in all of these markets have examined their current coordination plans and voiced extreme concern over their markets' respective ability to absorb the impact of this period of disparity, which the FCC dismisses as 'temporary.' A major problem is expected in state capitals that are not in the top 30 markets but see significant ENG use (election coverage, for example) by stations outside the market. Austin, Texas (market #54) is cited as an example. Stations from Houston (market #11) and Dallas (#7) have bureaus in Austin and have backhauls (microwave or land-line) to their main studios. "Dallas stations have been known to relay live coverage of spot news from Austin all the way back to Dallas via helicopter." Tallahassee, Florida (market #111) is another example, with ENG trucks from Tampa (#13) often driving to the state capital to cover stories there. Stations from Miami (#17) and Orlando (#20) also frequently have ENG operations in Tallahassee.
SBE said that if the impact of this mixed channel plan operation imposed an additional interference penalty on the order of 10 or even 20 dB worse, "it would be conceivable to SBE that even more heroic real-time frequency coordination between users might still make things work." However, if the penalty was on the order of 40 to 50 dB worse, "there would be no hope of frequency coordinating around such a shortfall, or worsening, of the frequency coordination requirement."
The SBE filing states, "Unfortunately, the attached MRC report shows that coded orthogonal frequency division multiplex (COFDM) digital operations would be degraded by analog operations still on the old band plan by around 43 dB, and that conventional FM video analog operations would be degraded by around 47 dB by COFDM operations using the new band plan. SBE does not believe that any amount of improved frequency coordination would be able to withstand a four to five order of magnitude worsening of the frequency coordination requirement."
The MRC study included in the SBE Petition for Reconsideration
contains numerous tables, spectrum analyzer photos and graphs showing the impact of interference between the stations using different band plans and supporting the assertions by SBE and NAB/MSTV that this staged transition will not work.
SBE's conclusion in its filing nicely summarizes the situation:
"In its zeal to protect the economic interests of the new entrants to the spectrum at 1,990-2,025 MHz, the FCC has issued a decision which will force television stations serving an aggregate of 46 percent of the American public to make a Hobson's choice: either subsidize the newcomers by absorbing substantial conversion costs up-front, in hopes of reimbursement three to five years hence, or provide their audiences reduced news coverage, and therefore inferior service, so spectrum can be given away to a new technology which offers no equivalent information-disseminating service to the public. How odd that the FCC would take a step which so obviously undercuts the ability of local broadcasters to serve the public, while at the same time pursuing a public inquiry into Localism in the Media. The uniquely local program content which only local broadcasters can provide -- including live coverage of breaking news, threatening weather, natural disasters, or threats to public safety-depend for their existence on the BAS spectrum that is the subject of this rulemaking, and which SBE and others have so carefully coordinated for years, to the benefit of local audiences nationwide."
In addition to requesting reconsideration of the Third Report, the SBE asked for clarification of a conflict between the Third Report and the existing FCC Rules. SBE notes that Section 74.24(c) of the FCC rules would require the visiting TV Pickup station to protect the local TV pickup station, effectively preventing operation by visiting digital ENG trucks, "or certainly a vastly reduced number of visiting digital ENG trucks." However, the Third Report says BAS stations operating under the old band plan "must operate on a secondary basis to BAS licensees using the Phase II channel plan and must be prepared for the potential disruption associated with secondary operation, such as the interference likely to be caused by a BAS licensee operating on the Phase II channels that enters the market to cover a sporting event or breaking news story." If the visiting TV pickup station is licensed to a broadcast network entity, a cable network on a wide area basis or for the entire U.S., Section 74.24 would not apply and the visiting digital ENG truck would take priority over local, old band plan analog operations. In other cases, which rule applies isn't clear.
SBE also asked for clarification on the language saying continued operation on the old band plan is permitted "if all 2 GHz TV BAS licensees in the market will agree." In smaller markets, can a single "poor" station block conversion to the new band plan? Alternatively, can a single "rich" station choose to change to the new band plan and force other stations to follow suit?