FCC Proposes Changes to Satellite/BAS Coordination Rules

The FCC has released a Notice of Proposed Rule Making (NPRM) concerning frequency coordination between fixed satellite services and the fixed microwave (FS), broadcast auxiliary (BAS) and CATV relay services (CARS) in the 7, 10 and 13 GHz bands. The new rules are being offered to promote frequency sharing between the services.

I won't spend time describing the 10.7 to 11.7 GHz band coordination process, since it doesn't involve broadcast operations; please refer to the NPRM for details. In the 6,875 to 7,075 MHz and 12,750 to 13,250 MHz BAS/CARS bands, both geostationary (GSO) and non-geostationary (NGSO) satellite orbit stations will have co-primary status with broadcast and cable operations. Coordination with fixed BAS and CARS stations will be handled using the procedures in Section 101.103(d) that were recently adopted for coordination between terrestrial microwave stations in these bands. See RF Report for October 20, 27 and November 3 for information on the coordination process.

The NPRM acknowledges, that "frequency coordination and spectrum sharing between FSS and BAS/CARS fixed and mobile operations will be challenging." The NRPM states, "Nevertheless, we believe that spectrum sharing between FSS earth stations (both GSO and NGSO) and BAS/CARS fixed and mobile operations is feasible because the number of new FSS earth stations should be relatively small." New NGSO/GSO operations in the BAS/CARS bands are limited to gateway or feeder link operations.

Coordination with BAS mobile TV Pickup (TVPU) links used for newsgathering operations will be more complicated, since the mobile transmitter can operate in the air (from helicopters or airplanes used as relay links) or on the ground and are usually licensed for operation throughout the entire band throughout the coverage area (or more) of the parent broadcast station. To further complicate coordination, the NPRM notes that many FCC database entries do not have coordinates specified for broadcast auxiliary receive sites, since this data was not requested on earlier FCC applications. It also notes, "BAS frequency coordinators often effect real-time coordination to accommodate TVPU ENG deployments as needed to cover unscheduled, fast-breaking newsworthy events, such as disasters or law enforcement activities."

FSS stations would have to initiate coordination with broadcasters and cable companies using the procedures in Sections 25.203(b) and 25.251 of the FCC Rules, which identify a coordination distance contour based on ITU Appendix 7 and certain ITU Recommendations. The NPRM, however, notes that the coordination distances under this approach are "conservatively large." It asks if, "considering the relative brevity of TVPU operations," these distances should be changed to reduce "the overall coordination burden where the potential for interference is minimal."

All potentially affected licensees and applications within the ITU Appendix 7 coordination distance contour from a proposed earth station have to notified. The FCC NPRM explains, "We note that the rules give applicants the flexibility to determine how best to identify facilities that may affect or be affected by the proposed facilities, and licensees who must be notified. Thus, in addition to thoroughly checking relevant Commission and any other licensing databases to assess both local and nationwide licensees that may have operations in the affected area, the FSS earth station applicant should also find it useful to contact local broadcast frequency coordinators, where they exist, to help identify the licensees with operations within the coordination contour of the FSS earth station, that need to be notified."

Responses to the coordination notification indicating potential interference are required to specify technical details in writing and all parties "must make every reasonable effort to eliminate all technical problems and conflicts." If no response is received in 30 days, the application is assumed to have made reasonable efforts to coordinate the frequency and may file the application. Satellite coordination rules allow extension of the coordination period to 45 days and the FCC asks if the same extension should be allowed for coordination with BAS/CARS stations.

Operators proposing new BAS/CARS mobile stations in the 7 and 13 GHz bands may coordinate with the FSS operators using either the informal coordination process in Sections 74.638 and 78.36 of the FCC Rules or the coordination procedures described in Section 101.103(d) required for fixed BAS/CARS stations. Since the FSS allocation in the 7 and 13 GHz bands is co-primary, proposed BAS/CARS operations on frequencies shared with FSS must protect all authorized FSS operations.

You may be wondering how itinerant or short term BAS/CARS operations (such as at major events or news stories) in the 7 and 13 GHz will be coordinated. The FCC NPRM says these can be coordinated the same way these operations are coordinated with other BAS/CARS stations -- using the local frequency coordinators under the procedures outlined in Sections 74.638 and 78.36 of the Rules. These short-term BAS/CARS operations are secondary to existing fixed operations and the FCC proposes maintaining this secondary status with regards to interference to FSS operations. The FCC NPRM warns FSS operators, "Because it is not possible to predict where breaking news may happen, licensees of new FSS earth stations should be aware and take into account short-term TVPU deployments, to the extent possible. This can be done by avoiding locations where operations by TVPU licensees and short-term itinerant use is expected to be high, such as in major urban areas or near certain venues, such as locations where major sporting events are held."

Although the FCC does not expect the number of FSS operations in the 7 GHz and 13 GHz bands to be large, broadcasters should be aware of the potential for interference, both to existing BAS/CARS operations and to FSS operations from planned BAS/CARS facilities. I encourage readers responsible for BAS/CARS facilities in these bands to read the Notice of Proposed Rule Making (NPRM). The NPRM was released Dec. 23. Comments are due 30 days and reply comments are due 45 days after publication in the Federal Register.