VERY IMPORTANT PART 74 NEWS -- APRIL 14, 2003

Hi Everyone,

This is a summary of the various frequency coordination related meetings we attended at NAB. It seems like all I did from Monday thru Wednesday was attend meetings - I only got to spend a half-day on Wednesday on the "showroom floor"!

Frequency Coordination Issues:

The FCC has written a sweeping set of changes to the BAS Part 74 rules.  In many cases, the FCC has re-written the BAS rules to align our rules with the rules in Part 101 (microwave) and Part 90 (Land mobile).  While many of the changes make sense, such as allowing digital modulation in BAS bands, others may not be so beneficial to broadcasters, such as requiring formal PCN style frequency coordination for most BAS bands from 950 MHz and up. Rather than try to summarize what rule changes the FCC will be implementing, please see a wonderfully written summary of the changes by Dane Ericksen of Hammett & Edison at the link below:

http://www.sbe.org/FCCLiaison/ET%2001-75%20Sig%20article.2.pdf (96 kb)

The digital modulation parts of the new rules are already in effect and the rest of the rules are scheduled to become effective on April 16, 2003. It is in your best interests to look at these rules and become familiar with them! SBE has looked at these rules under a microscope and already filed several petitions for reconsideration. Links to these petitions, and what you can do about them, are listed later in this document.

2 GHz Transition Issues:

Over 2 ½ years ago, the FCC re-allocated the bottom 35 MHz of the 2 GHz band (Channels 1 & 2) to the Mobile Satellite Service (MSS). Included in this re-allocation is a unique 2-step transition plan that allows BAS users to move from these frequencies, as the MSS operators require the 2 GHz frequencies. NAB 2 GHz transition meeting presentations can be found at:

http://www.az-frequency.com/afcc/TechPapers/writeups.php

We also discussed the FCC's recent re-allocation of 15 MHz from MSS to Advanced Wireless Service (AWS). Of the 35 MHz allocated to MSS from BAS, the bottom 10 MHz of 2 GHz channel 1 (1990-2000 MHz) and the top 5 MHz of channel 2 (2020-2025 MHz) will be re-re-allocated to AWS and the middle 20 MHz (2000-2020 MHz) will remain with MSS. This means the BAS transition will almost certainly be done in one phase, although the FCC may surprise us with another unique plan. So be prepared to make the jump directly to digital ENG!

The (possible) Future of ENG - Digital ENG Band Plans:

In the 2 GHz manufacturers standards meeting we discussed a possible new 2 GHz band plan with 12 MHz wide channels. In the original FCC phase 2 proposals, the FCC specified a 12.142857 MHz wide channel (85 MHz / 7 channels). Manufacturers noted the difficulty in taking off the shelf frequency synthesizers and using them in such a band plan, making the manufacture of equipment more difficult, costly and extending the manufacturing lead-times.

One possible solution to this problem was redoing the Phase 2 band plan to make the channels exactly 12 MHz wide. This would allow the use of existing synthesizers to create radios compliant with the new standards.  In narrowing up the channels to exactly 12 MHz, we would use 84 of the 85 MHz allocated to BAS. This left 2 options, make one channel 13 MHz wide or take the left over 1 MHz and create 500 KHz "guard bands" on both ends of the 2 GHz BAS spectrum. Such a band plan is show in the link below:

http://www.az-frequency.com/afcc/TechPapers/2GHz-bandplans.pdf (27 kb)

You ask, what will this do for ENG other than make the manufacturers happy?  It allows for several cool things to happen. Manufacturers can make receivers send link status back to transmitters - giving the receivers the ability to "dial up" the bit rate on a great link and down on a not-so-great link. The duplex link also allows for automatic transmitter power control, which would effectively eliminate users using more power than they need, along with other features that can be added later.

Where YOU Can Help!

The following links will take you to a summary of the new FCC Part 74 rules that take effect on 4/16/03 and also various filings that SBE has filed with the FCC that may directly impact your operations.  I'm told that the FCC places a lot of weight on individual stations comments versus trade organizations comments.

Please take the time to read the following documents and make your feelings known to the FCC.  The easiest method to make your feelings known is to go to the FCC's Electronic Comment Filing page at http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi and fill in the form.  For the Frequency Coordination and Partial reconsideration petitions please use FCC proceeding number "01-75" and use "01-185" for the Terrestrial MSS petition.

It is important that your station file a comment, even if you don't agree with the SBE's position on these matters. Remember, decisions are made by those who participate and some of these proceedings will severely affect your stations BAS operations.  And this is NOT just a TV matter as it includes 950 MHz Aural STLs, so it includes RADIO too!

Reference Documents:

SBE Request for Stay of the PCN frequency coordination requirement:

http://www.sbe.org/FCCLiaison/ET%2001-75%20Stay%20Master.pdf (Caution: 2.6 Mb)

SBE Petition for Partial Reconsideration of the ET 01-75 R&O:

http://www.sbe.org/FCCLiaison/ET%2001-75%20Recon%20Master.pdf (217 kb)

SBE IB 01-185 (Terrestrial MSS) Petition for Reconsideration

http://www.sbe.org/FCCLiaison/01-185%20cvr+recon.pdf (197 kb)

Once again,  this reminder:  Now is the time that all licensees verify that all of their licenses are 100% correct, or be prepared for problems.

Please contact me at the e-mail address or phone number below if you have any questions.  As I noted above, these are issues that cannot wait for "someone else" to deal with. SBE has opened the door and we need you to help us keep it open - or we ALL will lose....

Thanks in advance,

Howard Fine, SCFCC
howard@pactv.com
(323) 962-7841

Addendum:

Karl Voss adds the following comment about an FCC Stay granted today, April 15:

"Today the FCC granted a 6 month stay of the PCN requirement. The PCN requirement now takes effect on 10-16-03. The "official" FCC document can be found at:

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-1141A1.pdf (103 kb)

Karl Voss
KPNX-TV/DT
kvoss@kpnx.com
602-261-6191

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