Last May, the FCC introduced a new radio service with the descriptive title “The 3650—3700 MHz Radio Service.” The FCC’s intent is to, “…create a spectrum environment that will encourage multiple entrants and stimulate the expansion of broadband service to rural and under served areas…,” as they said in their order establishing the service. New spectrum and new radio services are generally a good thing, but this new one is a little complicated.
The FCC had originally considered offering this service as unlicensed, but the existence of incumbent earth station and Federal radar systems elicited concern about the ability to coexist without pro-active coordination. Thus, the FCC decided instead to adopt a non-exclusive licensing scheme for the band. Accordingly, there are four steps involved in obtaining authority to operate:
As depicted in the above figure, the FCC has established protected zones around the in-band incumbent stations. For the grandfathered earth stations, the protected zone is 150 km. Licensees may locate base stations within these protected zones only after obtaining an agreement from the earth station licensee through frequency coordination negotiations. For the three grandfathered Federal radiolocation stations, the protected zone is 80 km, and locating base stations within these zones requires approval of NTIA via coordination through the FCC. This latter process happens automatically through the ULS.
On the issue of interference to adjacent C-band earth stations the Satellite Industry Association and others have raised concerns about out-of-band emissions and LNB saturation. The FCC believes that the new rules are generally sufficient to protect the adjacent band earth stations and thus refused to make modifications on reconsideration. However, calculations show that should conditions align in a worst-case manner, separation distances of 1 km or more may be required. The FCC left open the possibility of requiring lower out-of-band emissions for 3650—3700 MHz transmitters shown to be the cause of interference into C-band earth stations. Additional filtering may have to be added to earth station LNBs to mitigate the oversaturation issue. It should be noted that if the distance is small enough, interference into adjacent band earth station receivers may be difficult or impossible to resolve despite added filtering.
While FCC Rules currently do not require the new broadband operator to formally consider adjacent C-band systems prior to deployment, we would strongly encourage potential licensees to do so. Consider that it is generally not good business practice to “take down” the local cable system or the mayor’s backyard dish while attempting to offer new services in a community. It is a fairly easy process to verify the locations of existing earth stations and determine the proximity to your planned facilities. Depending upon the interference geometry and the operating characteristics of both systems, there may be several inexpensive options available to reduce the potential for interference. Better to identify potential problems and resolve them early in the process and prior to a significant capital outlay on infrastructure.
Note the requirement #3 above to use FCC-certified equipment. Another FCC concern is how users co-exist with each other. Thus, the Commission instituted a requirement that equipment operating in the band must incorporate a “contention-based protocol” to minimize interference. Contention-based protocols are helpful at avoiding interference among the multiple users that seek to use the band simultaneously. Under the FCC’s rules, contention-based protocols are broadly categorized as either “unrestricted” or “restricted,” defined as follows:
Through the equipment certification process, the FCC determines whether equipment meets the requirements established for contention-based protocols. The FCC also limits the band for those intending to deploy restricted or unrestricted equipment as follows:
by David Meyer
Senior Manager, Frequency Protection Services, Comsearch
Defending Your Spectrum
Frequency Protection Services
An FCC license entitles the licensee to certain spectrum rights. Generally, one of those rights is the freedom to operate without experiencing harmful interference. However, having a license does not guarantee that your system will operate interference free. To help ensure that actual conflicts do not occur, it is the licensee’s responsibility to protect and defend their licensed spectrum rights. For over 30 years, Comsearch has provided a protection service to help licensees defend their spectrum. We’ve described below a few of the real-world aspects and benefits of a frequency protection service.
But first, a little background…
A licensee operating under FCC Part 101 coordination rules must assess whether new, proposed systems operating nearby and sharing the same spectrum will cause harmful interference to their existing system. As new systems are proposed, the prospective licensee must send out a prior coordination notice (PCN) to inform existing licensees of their impending operation. This provides existing licensees with a limited opportunity to protect themselves. However, analyzing this PCN can be a time-consuming and complex process. A Frequency Protection Service helps licensees address their responsibilities outlined in FCC rule 101.103 to protect themselves from harmful interference. Without this important line of defense, licensed and proposed systems are open to all manner of interference problems. Even if a licensee is not experiencing interference today, they may be tomorrow.
Here are a few of the interference protection issues we have seen over the years:
Case 1:
Comsearch received a PCN with numerous paths and frequencies involved. A review of the information and technical analysis revealed several interference cases in excess of 20 dB with a protection client's system. We reported the cases to the coordinator and noted them in our internal tracking system. The coordinator responded with a request for a copy of the licensed information since they did not have the information in their database. We forwarded the information to the coordinator, and the coordinator changed frequencies to avoid conflicting with the protected paths.
Without frequency protection, the existing system would have been significantly degraded by the new system. The existing paths would have lost over 80% of their fade margin and been severely restricted in operation. The licensed owner would have had the additional expense of measuring to identify the problem, researching all issues involved, and working with the new operator to solve the issues. Depending on the exact fade conditions, the problem may have taken weeks or months to become predictable enough to detect the interfering source.
Case 2:
We received a PCN detailing a single path and frequency pair. A review of the data revealed two interference cases of 30 and 35 dB above the prescribed interference objectives. One case was into the protection client's path, and the other was into the coordinated path. We reported cases to the coordinator and noted them in our tracking system. The coordinator responded with a copy of the license information from the FCC's ULS stating the license for our client’s path had expired and they were not obligated to consider it in their analysis. Comsearch followed up with our client, confirmed that the path had been renewed through the appropriate process and was operating as licensed. Our client contacted the FCC, corrected the invalid expiration date, and the coordinator was again notified that the reported cases were valid and must be resolved. The coordinator modified the system to avoid the protected path.
Without frequency protection and due to the severity and distance involved, the existing system would have lost their transmission signal as soon as the new path was put into operation. What amounted to a data error on the part of the FCC could have resulted in the licensed path being interfered with, and resolution could have been time-consuming and expensive.
Case 3:
We received a PCN for a new system. Noted in the letter, was the statement, "This interference study was conducted using the FCC database. It does not include any additional microwave links that are protected by the frequency coordination process." Comsearch analyzed the technical information provided. Based on the band (23 GHz), and location (Northeast Texas), we found that there were no protection clients with potential problems.
Fortunately, in this instance there were no problems found. However, this points to a potential danger in the coordination process that is becoming an increasing concern. With some coordinators using only the FCC data, any company who has coordinated a path, but not yet filed for it is invisible in their analysis. This is because the FCC databases do not contain any information on coordinated paths. All newly engineered systems must be considered in every technical analysis. Failure to protect a coordinated path could result in the path experiencing (or causing) interference due to a conflicting system coordinated on top of it. If the conflicting path has a more recent application and grant date than the path that was actually coordinated first, this will further complicate the issue. The solution is to have every path protected and fully analyzed for any activity in the area as soon as it is coordinated.
Case 4:
Comsearch received a call from a protection client experiencing a problem on their existing microwave path. An interference review of the path by the protection department showed that all licensed, applied, and coordinated systems met the prescribed objectives. A further review of activity in the area around our client’s path showed a recent coordination and filing for a system on the same frequencies as our client’s, but the objectives were met based on the antenna cross-polarization. By contacting the new system’s owner, we were able to determine that due to an installation error, the antenna was mounted incorrectly, and the path actual was operating on the same polarization as our client. The installation was corrected and both systems were able to operate without problems.
This problem was solved through the use of our data resources and engineering expertise. The coordination and protection process helped identify and resolve the issue quickly for all parties.
Case 5:
We received a PCN and reported a 15 dB case into our client’s protected path, with a similar reciprocal case into the proposed path. The coordinator replied with a terrain loss study showing the interfering path to be blocked. Further analysis revealed that the interfering and proposed paths were along the same azimuth and if the terrain loss study were correct, the proposed path would also be blocked. A detailed map review showed the proposed path to be coordinated incorrectly, using a ground elevation 10 meters too low. The coordinator re-coordinated the path with the correct ground elevation and changed frequencies to correct the issue.
This case reveals how important it is to have all the tools and resources readily available to fully review a proposed coordination and clearance. Even coordinators with the best intentions can create problems if they do no have the most accurate, current information and solid technical databases and support for clearing frequencies.
Case 6:
Comsearch reported cases on a PCN proposing a system to be located within the main beam of both affected antennas. The case was rather far away at a distance of 140 miles, but our analysis was based on distance recommendations prescribed by the National Spectrum Managers Association (NSMA). The coordinator replied that they stopped their analysis at 125 miles and did not have this case on their reports. They thought it would be cleared due to the distance between the paths. We noted that we were following NSMA procedures and that the interfering path calculations had already taken into account the distance and any terrain impacts. The coordinator re-coordinated to eliminate the problem.
This type of issue comes up on a regular basis where a coordinator does not follow or wants to alter industry objectives or requirements. We require all coordinators to follow the recommendations prescribed by the FCC, industry, and good engineering practice.
Case 7:
We received a PCN for a Temporary Earth Station proposing to operate intermittently for a six-month period on various frequencies. We reported co-channel cases into a protected client’s receiver. The coordinator forwarded terrain loss calculations showing blockage to clear the cases. A review of the terrain between the two sites showed the path to be line-of-site with no blockage. A request for additional information was returned to the coordinator. They replied with information that they were considering blockage from trees and provided a satellite image for documentation. It was determined that the trees included in the calculations were too sparse and would not provide the blockage requested. The coordinator changed the frequencies initially requested to clear the cases by frequency separation.
Comsearch reviewed hundreds of temporary Earth Station in 2007. These coordinations are especially difficult because they involve quick response times and may include several channels of operation. We have a specific process in place to ensure these coordinations are answered and fully resolved on a timely basis. Since many of these PCNs are for single day or recurring weekend events (often for just a few hours), detecting and identifying actual interference issues from these operations would be difficult. It is vital that any potential interference issues are found and resolved prior to any operation of the sites. Failing to have a system in place to study these PCNs leaves a licensee open to outages and system degradation if cases are missed.
Conclusion
The seven cases described above are just a sampling of the issues addressed daily by our Frequency Projection Services staff. They show that having an FCC license by itself is not adequate to eliminate the potential for damaging and costly interference problems. Existing licensees and potential licensees need to maintain vigilance on their proposed and licensed systems to ensure new systems do not cause the potential for harmful interference. This can be a daunting and overwhelming task without the proper tools and expertise. A Frequency Protection Service helps licensees by taking on this responsibility and defending your spectrum.

MICROWAVE
700 MHz Spectrum Auction – This
spectrum is part of the 698—806 MHz band (“700 MHz Band”) previously occupied
by television broadcasters. It is being made available for new nationwide/local
commercial and public safety services as a result of the DTV transition. As of
February 5, 2008, Auction #73 had entered round number 30 with total bids in
excess of $18.5 Billion. Additional information and Links to the current
bidding progress can be found at Summary
Auction 73
2006 Quadrennial Regulatory Review – The Commission concluded quadrennial review of the broadcast ownership rules. (Dkt No 99-360, 00-244, 01-235, FCC No. 07-216) FCC-07-216A1.pdf FCC-07-216A2.pdf FCC-07-216A3.pdf FCC-07-216A4.pdf FCC-07-216A5.pdf FCC-07-216A6.pdf
Leased Commercial Access - The FCC
adopted a Report and Order to allow a broader and more diverse range of programming from their cable operators. (Dkt No 07-42, FCC No. 07-208)
FCC-07-208A1.pdf FCC-07-208A2.pdf FCC-07-208A3.pdf FCC-07-208A4.pdf FCC-07-208A5.pdf FCC-07-208A6.pdf
Amendment of Part 0 of The FCC Rules - FCC
rules amended to delegate authority to the Public Safety and Homeland Security
Bureau to administer part 4 of the Commission's rules, which pertain to
disruptions to communications. (FCC No. 08-27) FCC-08-27A1.pdf
Amendment of Parts 0, 1, 2, 61, 64, 73, and 80 of The FCC Rules - FCC rules changed to update the name and address that regulatees, applicants and licensees use to submit,
or file, certain applications and payments to the Commission. (DA No. 08-122) DA-08-122A1.pdf
Measurements of Additional Prototype TV
White Space Devices - The
Commission announces the second phase of laboratory bench testing on the
performance of prototype television white space devices. (ET Docket No 04-186, DA No 08-118) DA-08-118A1.pdf DA-08-118A2.pdf
Video Programming Diversity -
DOC-279038A1.pdf DOC-279038A2.pdf DOC-279038A3.pdf DOC-279038A4.pdf DOC-279038A5.pdf DOC-279038A6.pdf
Diversification Of Broadcast Ownership - FCC
Rules adopted to expand opportunities for participation in the broadcasting
industry by new entrants and small businesses, including minority- and
women-owned businesses, to own broadcast outlets. (Dkt No 07-294) DOC-279035A1.pdf DOC-279035A2.pdf DOC-279035A3.pdf DOC-279035A4.pdf DOC-279035A5.pdf DOC-279035A6.pdf
Localism Proposals Adopted – FCC Rules
adopted to help ensure that broadcast stations offer programming responsive to
the needs and interests of the communities that they are licensed to
serve. DOC-279043A1.pdf DOC-279043A2.pdf DOC-279043A3.pdf DOC-279043A4.pdf DOC-279043A5.pdf DOC-279043A6.pdf
Newspaper/Broadcast Cross-Ownership Rule
Changes - The FCC amended the 32-year-old absolute ban on newspaper/broadcast
cross-ownership by crafting an approach that would presumptively allow a
newspaper to own one TV station or one radio station in the 20 largest markets,
subject to strict criteria and limitations. DOC-278932A1.pdf DOC-278932A2.pdf DOC-278932A3.pdf DOC-278932A4.pdf DOC-278932A5.pdf DOC-278932A6.pdf
Digital Audio Radio Satellite Service in the
2310—2360 MHz Frequency Band - The FCC seeks additional comment on the
appropriate rules and policies for licensing satellite digital audio radio
service (SDARS) terrestrial repeaters in the 2320—2345 MHz frequency band. (Dkt No 95-91, 07-293, FCC No. 07-215) FCC-07-215A1.pdf
Low Power Radio Service Created –
The
FCC Adopted Rules to Promote the Growth of the Low Power FM Radio Service. (Dkt No 99-25, FCC No. 07-204) FCC-07-204A1.pdf FCC-07-204A2.pdf FCC-07-204A3.pdf FCC-07-204A4.pdf FCC-07-204A5.pdf FCC-07-204A6.pdf
Wireless E911 Location Accuracy
Requirements - FCC clarifies that wireless carriers must meet the Enhanced 911
Phase II location accuracy requirements at the Public Safety Answering Point service-area level. (Dkt
No 94-102, 05-196, 07-114, FCC No. 07-166) FCC-07-166A1.pdf FCC-07-166A2.pdf FCC-07-166A3.pdf FCC-07-166A4.pdf FCC-07-166A5.pdf FCC-07-166A6.pdf
Rural Health Care Support Mechanism – FCC
launches initiative to increase access to health care in Rural America through
Broadband Tele-health Services. (Dkt No 02-60, FCC No. 07-198) DOC-278260A1.pdf DOC-278260A2.pdf FCC-07-198A1.pdf FCC-07-198A2.pdf FCC-07-198A3.pdf FCC-07-198A4.pdf FCC-07-198A5.pdf FCC-07-198A6.pdf
SATELLITE
Satellite Industry Safeguards C-Band Frequency Spectrum Use At WRC-07
The global satellite industry emerged from successful negotiations to protect the users of its C-band spectrum from terrestrial interference with its “no change” campaign. The satellite industry at WRC-07 has ensured its uninterrupted, interference-free use of C-band for the future. This confirmed the broad and deep support for keeping the status quo for satellite services by calling for no change to the current use of the of the C-band. The campaign by the Satellite Industry urged the WRC not to identify international mobile telecommunications (IMT) systems in the C-band.
In addition to ensuring their uninterrupted use of the C-band, WRC-07 also gave satellite operators assurances that any future IMT (International Mobile Telecommunications) networks will provide them with full protection from interference. The endorsement of the satellite industry's use of this highly valuable spectrum in the band 3.4—4.2 GHz will ensure that operators will also have adequate bandwidth to roll out future service, especially in those regions where they are most in demand. The WRC has decided against the global identification for IMT, including Wimax, in any part of the satellite C band (3.4—4.2 GHz). The WRC further restricted IMT, including Wimax, by imposing stringent requirements for the protection of existing and future satellite services in the band, including transborder protection.
Reconsideration on FCC Policies and Service Rules for the Broadcasting-Satellite Service at the 17.3—17.7 GHz/24.75—25.25 GHz
The Establishment of Policies and Service Rules for the Broadcasting-Satellite Service at the 17.3—17.7 GHz Frequency Band and at the 17.7—17.8 GHz Frequency Band Internationally, and at the 24.75—25.25 GHz Frequency Band for Fixed Satellite Services Providing Feeder Links to the Broadcasting-Satellite Service and for the Satellite Services Operating Bi-directionally in the 17.3—17.8 GHz Frequency Band.
In this Reconsideration Order, the FCC hopes to provide additional flexibility to 17/24 GHz BSS space station operators by allowing them to operate their space stations, upon request, at locations other than those specified in Appendix F. They will assign space stations to orbital locations that are offset from the Appendix F locations by up to one degree, without requiring them to reduce power or accept additional interference, if there are no licensed or prior-filed applications for 17/24 GHz BSS space stations less than four degrees away from the proposed offset space station. FCC-07-174A1.doc
FCC Spectrum and Service Rules for Ancillary Terrestrial Components in the 1.6/2.4 GHz Big LEO Bands — FCC review of the Spectrum Sharing Plan among Non-Geostationary Satellite Orbit Mobile Satellite Service Systems in the 1.6/2.4 GHz Bands
In the Second Order on Reconsideration, Second Report and Order, and Notice of Proposed Rulemaking, the Commission’s decision in the Big LEO Spectrum Sharing Order to establish a band plan that improves spectrum efficiency and facilitates sharing between code division multiple access (CDMA) and time division multiple access (TDMA) Mobile Satellite Service (MSS) systems in the 1610—1626.5 MHz band (the L-band). The Commission’s decision in the Big LEO Spectrum Sharing Order to establish a band plan that improves spectrum efficiency and facilitates sharing between code division multiple access (CDMA) and time division multiple access (TDMA) Mobile Satellite Service (MSS) systems in the 1610—1626.5 MHz band (the L-band).
The Big LEO L-band band plan that was established provides an equitable distribution of the spectrum between the CDMA satellite system operated by Globalstar, Inc. (Globalstar), and the TDMA satellite system operated by Iridium Satellite LLC (Iridium). Specifically, CDMA and TDMA MSS systems will each have the exclusive MSS use of 7.775 megahertz of L-band Big LEO spectrum. In addition, in order to account for certain technical issues raised by the design characteristics of existing MSS systems, the FCC will require CDMA and TDMA MSS systems to share 0.95 megahertz of L-band spectrum. As a result of the decision, Globalstar’s CDMA system and Iridium’s TDMA system will have equal amounts of L-band Big LEO spectrum for their exclusive MSS use. In addition, in response to a petition filed by Globalstar, the FCC initiated a new Notice of Proposed Rulemaking (Notice) to consider spectrum authorizations and technical rules for ancillary terrestrial components (ATC) in the Big LEO bands. They seek comment on whether there should be an increase the amount of spectrum in which CDMA Big LEO MSS systems are authorized to operate ATC. FCC-07-194A1.doc
The FCC grants applications filed by Intelsat Holdings, Ltd. and Serafina Holdings Limited for authority to transfer control of Intelsat and six subsidiaries of Intelsat
On August 10 and 15, 2007, Intelsat and Serafina filed fourteen applications pursuant to sections 214 and 310(d) of the Act. The Consolidated Application and the fourteen Applications, as updated by the October 24, 2007 Letter and November 1, 2007 Letter, seek approval to transfer control of Intelsat to Serafina. The Applications pertain to space station licenses, earth station authorizations, wireless licenses, an experimental authorization, and international section 214 authority. DA-07-3972A1.doc

Comsearch Offers Microwave Backhaul Engineering Services
Comsearch introduces a suite of microwave backhaul engineering services, including network design, capacity planning, and reliability analysis. Comsearch has over three decades of experience working with backhaul networks. Whatever the transmission mode, look to Comsearch for network engineers and regulatory experts to manage and optimize your backhaul requirements. Contact us for more information about our backhaul engineering services.
Comsearch Offers 700 MHz AuctionPlanner to Identify TV Stations
and Challenges of Build-out Requirements
Comsearch provides accurate data in an easy-to-use format, equipping spectrum bidders with a clear picture of the current operating TV stations and providing an initial view into the potential challenges of meeting FCC build-out requirements. The 700 MHz licensees will rely on the timely transition of Analog and Digital TV stations to their final digital TV channel allotments. AuctionPlanner provides the information necessary to monitor the successful transition of the TV stations to their new allotment and monitor LPTV and translator stations in the lower 700 MHz portion of the band that can continue to operate on a secondary basis beyond the transition deadline. Click here for more information or to request a sample report.
Comsearch Selected, for the 11th year, as the CTIA WIRELESS 2008
Official Spectrum Manager
Comsearch is chosen as official spectrum manager at CTIA WIRELESS 2008 for the eleventh consecutive year, ensuring that there will be no interference issues between radio frequencies used by exhibitor demonstrations and other licensed wireless operations in the area. For more details about the show, click here.
Comsearch Interference Protection for C-Band Earth Stations
Interference Alert for C-Band Antennas Operating Near 3650—3700 MHz Wireless Broadband Services
The FCC has started licensing the Wireless Broadband Services (WBS) operating in the 3650—3700 MHz Band. Since November 15, 2007, 165 licenses have been granted for nationwide service. This new service is designed to be used for WiFi, WiMax, and other services with a base station and numerous low power mobile and stationary remote units. The operation is Co-Channel with the limited number of Extended C-Band earth stations and Adjacent Channel for the thousands of other C-Band receivers. The Co-Channel operators have been granted grandfathered status and any WBS must provide technical data and reach agreement to operate within 150 km of the grandfathered sites. All other C-Band Receivers are Adjacent Channel and despite objections from the satellite industry, the WBS must only meet the out of band emission requirements of Part 90 and are not required to coordinate with or notify the C-Band licensees.
Based on Comsearch’s technical review, we have found that there could be serious interference problems with WBS systems located near existing C-Band antennas. Comsearch has implemented a new monitoring system to protect our clients and verify the impact of the WBS applications as they are filed. Important actions for C-Band operators are to ensure that their earth stations have a valid FCC license, that the technical parameters including interference objectives are current, and that they are covered by Comsearch’s Protection Service.
For more information on Comsearch’s FCC Licensing and Protection Services contact us at 800-318-1234 or email customerservice@comsearch.com.
Comsearch Offers Telecom Carrier Reports to Identify Licensees
and Market Coverage
Comsearch offers a report that will assist companies in sorting through the often complex disaggregation, partitioning, leasing and other factors that identify a licensee in a market as well as the population and geographic areas covered. The report is offered for AWS, PCS, Cellular, WCS, BRS and LMDS bands. Click here for more information or to request a sample report.
CommScope Completes $2.65 Billion Acquisition of Andrew
Effective December 27, 2007, CommScope, Inc. (NYSE: CTV), announced it's acquisition of Andrew Corporation; “CommScope-Andrew: Better Together.” As an effect of this merger Comsearch is now part of CommScope, a leader in infrastructure solutions for communication networks, structured cabling systems for business enterprise applications, manufacturer of coaxial cable for broadband cable television networks, and one of the leading North American providers of environmentally secure cabinets for DSL and FTTN applications. As part of CommScope, Comsearch retains its brand name and is able to provide the services and solutions that we have always offered you. Click
here for more information.
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