FCC Lays Groundwork for 470-512 MHz Reallocation

While the spectrum sharing Report and Order attracted the most news coverage this week, the FCC also made some changes that should make it easier to reallocate spectrum between 470-512 MHz (TV Channels 14-20).

Last Thursday the Chief of the FCC Office of Engineering and Technology in Order DA 12-654 dismissed separate petitions filed by the National Public Safety Telecommunications Council (NPSTC) and the Association of Public Safety Communications Officers (APCO) for changes to rules for public safety use of the 470-512 MHz spectrum. In several larger markets, some TV channels in this band have been reserved for Public Safety and commercial land mobile use. The NPSTC requested that the FCC revisit its sharing rules in light of the DTV transition and APCO asked the FCC to update the list of TV stations on Channels 14-20 that land mobile applications for 470-512 MHz operations must analyze to comply with the FCC's interference requirements.

The FCC has not acted on either of these petitions. In dismissing the applications, the Order states, "As noted, the Spectrum Act requires the Commission to reallocate the spectrum in the 470-512 MHz band currently used by public safety licensees. As the Commission implements this legislation, we expect that the sharing environment between the remaining land mobile operations and television broadcasting in this band will change. Thus, we conclude that it would be premature to consider changes to the interference protection requirements at this time."

In a separate action, the FCC's Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau issued a Public Notice (DA 12-643) suspending the acceptance and processing of certain Part 22 and 90 applications for 470-512 MHz. The Wireless Bureau took this action "in order to maintain a stable spectral landscape while the Commission determines how to implement recent spectrum legislation contained in the Middle Class Tax Relief and Job Creation Act of 2012 …." The suspension only applies to applications for new or expanded use of these frequencies.

The Public Notice states, "This action will serve to stabilize the spectral environment while the Commission considers issues surrounding future use of the T-Band, solicits input from interested parties, and works to implement the directives of the Act. In the interim, and until further notice, we conclude that prudent spectrum management dictates that we should stabilize the existing spectrum landscape by suspending the acceptance and processing of T-Band licensing applications that could alter the spectrum landscape and thereby make implementing the Act more difficult or costly."

The obvious conclusion based on the Spectrum Act is that the FCC would auction the spectrum in the 470-512 MHz currently reserved for public safety and land mobile for wireless broadband. This spectrum, however, is limited to specific TV channels in a limited number of markets. The markets are the ones where the FCC is most likely to have problems repacking stations. There are places in the Northeast where there are no UHF channels currently available for broadcasting. It may make more sense, if the law allows it, for the FCC to use this reallocated 470-512 MHz spectrum for displaced full power UHF TV stations and open up more contiguous spectrum at the upper end of the current UHF TV band.

Doug Lung is one of America's foremost authorities on broadcast RF technology. He has been with NBC since 1985 and is currently vice president of broadcast technology for NBC/Telemundo stations.