SBE counters wireless association comments on proposed changes to ULS

The Society of Broadcast Engineers told the Federal Communications Commission April 18 that the objections of CTIA–The Wireless Association to an FCC rulemaking proceeding to modify the Universal Licensing System mischaracterize the SBE’s proposal and were filed in a “non-timely manner.”

At the heart of the matter is RM-11308, a commission rulemaking proceeding that grew out of an SBE proposal to allow TV pickup licensees to document the locations and heights of their ENG receive-only sites and remote pickup licensees to document the location and height of their RPU-RO sites.

The CTIA objections don’t state the true nature of the SBE’s petition, the society told the commission. Specifically, the CTIA claims the SBE petition seeks “a prior coordination notice requirement for CMRS operators with respect to ENG-RO sites,” according to the SBE filing.

Additionally, the CTIA claims the SBE petition “asks that CMRS licensees be required to notify ‘BAS licensees’” before building and operating such stations. The comments also say the SBE petition would require CMRS base stations “to delay testing and operation” until after filters are installed on ENG receivers.

The SBE filing asserted that its petition did not ask that CMRS licensees “be required to first notify a TV Pickup licensee” with an ENG-RO site near a CMRS base station. According to the filing, “in the spirit of being a good spectrum neighbor,” if tests revealed a new CMRS base station interfered with an existing ENG-RO site “licensed to an earlier-in-time TV pickup station,” the tests could be halted until the “necessary filters were added.”

The SBE told the commission that nowhere had it suggested steps would be mandatory and that “these entirely reasonable possible mitigation measures” were a suggestion.

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