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FCC Eyes Video Uplink ATIS Rule Changes

WASHINGTON—The FCC released a Notice of Proposed Rulemaking (FCC 12-117) last week as a result of a comprehensive review of licensing and operating rules for the satellite services. Most of the proposed changes will have little impact on earth station uplink facilities used for conventional C-band and Ku-band program distribution and newsgathering, but one of them, involving uplink transmitter identification, will affect uplink operators transmitting “broadband video information.”

Section 25.281 of the FCC rules describes the “Automatic Transmitter Identification System (ATIS)” that’s required to identify uplink signals. This system uses an analog subcarrier at 7.1 MHz FM modulated with a 1,200 Hz Morse code tone signal injected into the analog FM uplink signal. In today's digital transmissions, there is no FM analog signal to carry the 7.1 MHz ATIS signal.

With the use of different today’s encoding methods and encryption, it’s difficult to identify uplink transmitters.

In the NPRM the FCC proposes modifying Section 25.281 to add two methods for placing the required identification. One would be transmission of identification information in the Network Identification Table of an MPEG transport stream. The other method would transmit an accompanying low-date-rate spread-spectrum signal with the ATIS information. For many uplink operators, adding the required ATIS information (FCC call sign, a telephone number providing immediate access to personnel capable of resolving interference or coordination problems, and a unique 10-digit serial number) to the MPEG Network Identification Table should not be difficult. Note, however, that the operator must not be able to change the 10-digit random serial number. Any ATIS equipment has to be integrated into the uplink transmitter chain in such a way that this cannot easily be defeated.

The NPRM would also modify the rule requiring station identification (Section 25.206) to correct an error which pointed to a non-existent rule section rather than Section 25.281.

The FCC requested comments on ATIS including whether more or less information should be required for digitally-modulated uplinks. One example would be to add the geographic coordinates of the uplink. The FCC also requested comment on whether all uplinks--not just those carrying broadband video information—should be required to transmit ATIS and if so, what other methods of identification should be allowed.

Uplink operators will likely require time to implement the new Section 25.281 requirements. The NPRM asks for comment on whether a grace period after the effective date of the rules would be needed to allow operators time to conform to the new ATIS requirements and, if so, how much time would be needed.

The new ATIS rules are among the many changes proposed in the NPRM. Other changes would increase the opportunities to use Form 312-EZ, the simplified Form 312 that allows expedited processing, and remove some restrictions on the ability to increase uplink power to overcome rain fade. Refer to the NPRM for information these and other proposed changes.

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.