MSTV Questions FCC Qualcomm TV Interference Ruling - TvTechnology

MSTV Questions FCC Qualcomm TV Interference Ruling

Last month, the FCC released an order allowing Qualcomm to use OET-69 interference methodology and setting de minimis limits for Qualcomm interference to broadcast stations. Last week, the Association for Maximum Service Television filed a Petition for Reconsideration and/or Clarification of the Qualcomm order, say
Author:
Publish date:

Last month, the FCC released an order allowing Qualcomm to use OET-69 interference methodology and setting de minimis limits for Qualcomm interference to broadcast stations. Last week, the Association for Maximum Service Television filed a Petition for Reconsideration and/or Clarification of the Qualcomm order, saying "the commission should make it clear that Qualcomm cannot take advantage of that waiver in markets where the proposed interference would cause unique, market-specific harms not contemplated by the Qualcomm order."
In these cases, MSTV argues, a lower interference threshold, perhaps zero, should be used.
As an example, MSTV described a situation where a Qualcomm transmitter in an area with a large Hispanic population, operating on a channel adjacent to the market's only Spanish language TV station, could cause interference to a much higher percentage of viewers, even if only 0.5 percent of the total population within that station's service area was predicted to receive interference.
MSTV said the Qualcomm order is ambiguous as to whether the FCC is required to consider market-specific concerns. The MSTV petition said that through informal discussions with bureau staff, "MSTV has learned that the bureau will evaluate Qualcomm's applications solely to determine whether its operations would be within the interference thresholds established by the Qualcomm order."
MSTV said this is troubling, as Qualcomm has announced it has filed applications to take advantage of interference thresholds in at least nine markets.
The Qualcomm order requires the company to publicly file a modification application and comprehensive engineering statement whenever it seeks to operate under an interference threshold waiver. MSTV expressed concern that while the order does not include an exemption for transmitters operating at less than 1 kW ERP, under Sec. 27.50(c)(5) Part 27, licenses are exempted from notifying other Part 27 licenses of operations at such power levels.
MSTV warned that Qualcomm may interpret this rule as applying to broadcast stations as well. MSTV asked the FCC to clarify the statement "the disclosure requirement applies to all of Qualcomm's operations, including those from transmitters operating under 1 kW ERP, and that all transmissions must be considered when determining compliance with the interference thresholds of the Qualcomm Order."
MSTV reviewed Qualcomm's filings in nine markets where it is requesting waivers under the interference threshold and determined that "Qualcomm has used inaccurate calculations of affected DTV stations' population baseline figures." MSTV said that Qualcomm used the population within a station's DTV noise limited contour for determining interference instead of the population baselines provided by the FCC in Appendix B of the Memorandum Opinion and Order on Reconsideration of the Sixth Report and Order, explaining, "Use of the wrong baseline inappropriately inflates the population served by affected DTV stations and thereby underestimates the interference caused to DTV stations."
For additional information how Qualcomm operations could impact specific stations using channels 54, 55 and 56, see the MSTV Petition for Reconsideration and/or Clarification of the Qualcomm Order.