COMSEARCH^®

Taming the Spectrum  

In this issue:

MARKET TRENDS:
Spectrum Sharing in the 1.7 and 2.1 GHz Bands

CASE CORNER:
FCC Licenses--Only As Good As the Data

REGULATORY RAP:
Microwave and Satellite News

WHAT'S NEW AT COMSEARCH

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Spectrum Sharing in the 1.7 and 2.1 GHz Bands

by Laura Fontaine

For over ten years, the FCC has been engaged in an effort to identify and make available spectrum for Emerging Technologies (ET) and Advanced Wireless Services (AWS).  This includes services commonly referred to as second generation or 2G, PCS, 3G or IMT-2000 as well as future generations of wireless systems.  The latest chapter in this epic endeavor began last November when the FCC released a Notice of Proposed Rulemaking¹ allocating spectrum and proposing licensing and service rules for AWS in the 1.7 GHz (1710-1755 MHz) and 2.1 GHz (2110-2155 MHz) bands.

Similar to the rules governing the 1.9 GHz band for PCS, there are significant spectrum sharing, relocation, and reimbursement considerations.  This time, the issues are more complex because they involve both government and non-government services that currently operate in the proposed bands.  AWS providers are being asked to relocate or share spectrum with these users.  In addition, just as before, new AWS licensees are required to reimburse incumbent operators for relocation expenses.  While this relocation/sharing process is well defined and understood for the commercial 2.1 GHz band, the same cannot be said for the government 1.7 GHz band.  In the government band, the entire relocation process is being developed by the NTIA and affected government agencies without commercial industry involvement.   Yet despite having little understanding of the process, the commercial AWS provider is the one who will ultimately bear the cost burden associated with incumbent relocation and the potential unforeseen transition delays that may impact system deployment.  

Sharing spectrum between AWS systems and incumbent fixed and mobile systems, and relocation of potentially impacted government and non-government incumbent systems will be critical to speedy deployment of new advanced wireless services.  The sharing of encumbered spectrum is not a new idea.  Spectrum sharing is born out of the need to accommodate diverse technologies with limited spectrum options.  It is typically a preferred solution because it provides benefits to both incumbents and new service providers.  In many cases, sharing spectrum will be the only viable means to deploy these new technologies.

Spectrum Sharing Feasibility
Comsearch has helped PCS and microwave operators in the 1.9 GHz band successfully deploy networks and transition systems to new spectrum by implementing a proven spectrum sharing process that addressed the concerns of both the incumbents and PCS operators.  Incumbent microwave operators were concerned with the availability of alternative spectrum, uninterrupted service, interference potential, and relocation costs.  The PCS operators wanted to get their systems to market quickly but with reasonable relocation costs.  These concerns are no different for the new AWS bands.  Because of these and other similarities between the 1.9 GHz and AWS bands, our spectrum sharing process is well suited to the 1.7 GHz and 2.1 GHz relocation efforts.

The 1.7 and 2.1 GHz bands are currently used by a number of fixed and mobile services that belong to both government and non-government users.  Figure 1 shows what types of services can be found in the specific spectrum blocks.

 
Figure 1:  Fixed and mobile services currently in 1.7 GHz and 2.1 GHz bands

Comsearch’s proprietary database includes all of the FCC’s licensed data for the 2.1 GHz band, as well as enhanced data such as antenna and equipment information.  This additional data is necessary to accurately determine spectrum sharing feasibility between AWS and fixed microwave systems. 

It is important to note that the Federal Government frequency assignments in the 1.7 GHz band are stored in the GMF, which is not available to the public.  The NTIA maintains the GMF and frequency assignments for government operations.

Spectrum Sharing Process Step 2:  Determine band clearing reimbursement obligations
The value of spectrum is often based on band clearing and reimbursement obligations.  In the case of the AWS bands, this is compounded by the varying obligations for each band.

1710-1755 MHz Band
In designating this spectrum for AWS, the FCC relied on an assessment² conducted by NTIA on the viability of making the 1710-1755 MHz band available for AWS.  The NTIA assessed fixed and mobile assignments for both military and non-military uses and determined that most federal users of the band would voluntarily relocate or modify their operations no later than December 2008.  On March 2001, NTIA issued a report³ estimating the costs of relocation to be $266-$413 million.  However, NTIA has stated that the final cost estimates may differ from prior estimates based upon receipt of additional data. 

Following the cost estimate report, NTIA defined mandatory reimbursement rules for relocation of Federal systems.  The rules establish guidelines for reimbursement costs and negotiations.

2150-2155 MHz Band
The FCC will consider relocation procedures in a separate proceeding to be initiated in the near future.

Spectrum Sharing Process Step 3:  Perform analyses and start relocation processes
An interference analysis is the basis for determining whether services can share spectrum and to what extent.  Modeling interference through the use of industry-accepted standards provides these answers.  This is precisely how the process was initiated in the 1.9 GHz PCS band.  Based on initial interference analyses, PCS systems were able to quickly deploy with minimal relocation of microwave paths.  As networks expanded, the PCS operators relocated additional microwave paths.  Today, over 80% of the 1.9 GHz microwave paths have been relocated to other bands.  This relocation model can also work in the 1.7 GHz and 2.1 GHz bands.

By conducting an initial impact analysis during the preliminary design phase, an operator can identify potential incumbent systems that need to be relocated.  Because relocating systems can take several months to a year, operators should begin evaluating relocation obligations early in the design process. As the RF design and frequency plan changes, additional analyses are necessary to identify any new links requiring relocation.  It may also be possible to find alternate solutions to avoid interference such as reduction in power or upgrading antennas.

Conclusion
Spectrum sharing will have to occur in the AWS bands to some extent until relocation of all incumbent systems has been completed.  Through a well-defined sharing process, incumbents are protected from interference and operators are able to rapidly deploy their new services with minimal costs.  However, there will be cases where sharing is not feasible leaving relocation as the only initial option.

The keys to successful spectrum sharing or relocation include the availability of data on incumbent systems, the ability to accurately analyze and predict potential interference between the proposed and incumbent systems, effective information coordination, skills at negotiation, and most importantly involvement of all stakeholders that leads to a clear understanding and acceptance of the process. To facilitate the sharing and relocation effort in the AWS bands, the Government must allow for increased industry participation in developing procedures for the transition of the 1.7 GHz band.  

When relocation becomes necessary, data and engineering analyses will help to determine the most cost effective and most equitable relocation approach to ensure that new Advanced Wireless Services can be properly and efficiently deployed.

Case Corner

FCC Licenses—Only As Good As The Data

by Tim Hardy

Have you verified the data on your licenses lately?
To ensure that microwave systems are protected from either receiving or causing harmful interference, it is imperative that the technical information on the license be as accurate as possible.  However, surprisingly enough, the FCC data on some licenses is often incomplete, inaccurate, or worse yet, the system may not even be licensed at all.  Some coordination agencies rely solely on the FCC’s ULS database for planning new systems, so if facilities are missing or in error, actual interference could still result after the coordination process.  In addition, operating without a valid FCC license is a very serious offence and can result in fines of up to $10,000 per occurrence and having the system shut down.

Comsearch helps to eliminate interference threats through complete interference monitoring services utilizing our proprietary databases that include data from over 5000 clients and from the FCC.  These databases include microwave, satellite earth station, and multiple address systems (MAS) and provide the most comprehensive snapshot of the interference environment around any given system.

We recently completed a major review of the 2.1 GHz facilities in our database and found several hundred stations that were operating without valid licenses.  Through our research, we found that not one of the station owners realized their licenses had expired.  We uncovered numerous reasons for this, the most prevalent are summarized below:

1. I thought that the FCC would notify me prior to my license expiration date, but I never received notification.
   While it is true that the FCC will send a reminder to each licensee 90 days prior to license expiration, it’s important to remember that the license period is ten years.  If the address or contact information on the license have not been kept current, then the reminder notification may get lost in the mail or sent to the wrong person within the organization.  Even if you did not receive prior notification of a license’s pending expiration, you are still responsible for ensuring its timely renewal.  Another reason for not receiving notification might be that the license involved could have expired during the last license cycle.  We found several operating stations whose licenses had expired over ten years ago.  
   

2. But I filed my renewal applications in a timely fashion.  
   Whenever we found a questionable license and received this response, inevitably we found that the renewal application was either filed untimely, or failed to include the necessary application fee.  In these instances the FCC will dismiss the application and send a dismissal letter to the applicant.  We were surprised to find so many stations still operating under this condition.  Another misconception we encountered during our research is thinking that one renewal application will somehow cover all operating stations.  Stations licensed under Part 101(Fixed Microwave) have to be renewed individually, thus each would have their own expiration dates.  If the stations were initially granted on the same day, they will have the same expiration date.  However, stations licensed under Part 74 (Auxiliary Broadcast) are all renewed at the same time with the renewal application for the broadcast station.

Historical Problems in the Database
In addition to the 2.1 GHz data cleanup project, we have been working with numerous licensees to make certain that their operating facilities are properly licensed and that the licenses accurately reflect the operating parameters.  Prior to the introduction of Universal Licensing System (ULS) in 1999, the FCC’s database of Part 101 facilities did not contain the make and model information for either antennas or radio equipment.  This information is critical for effective spectrum management so that various coordination agencies can maintain this information in their databases.  If your station was initially licensed prior to ULS, chances are this information is missing from the ULS database.

In addition to missing these critical data elements, the database from which the ULS was developed had major problems in certain areas.  The old Part 94 (Private Microwave) facilities were in relatively good shape since the applications and licenses had been entered into a database for quite some time prior to the ULS.  However, the old Part 21 (Common Carrier) facilities licensed prior to ULS are in extremely bad shape due to the fact that these applications were not entered into a database prior to the mid to late 1990’s.

The Common Carrier bureau tried to collect this data on several occasions, even asking licensees to “informally” submit detailed information on all of their licensed stations.  While a noble effort, most of the data provided by licensees was never entered into the database.  In the mid-90’s, the licensing function for Common Carrier applications was shifted from Washington, DC to Gettysburg (the same group already processed the Part 94 applications).  While this change certainly improved the Common Carrier database (since applications were now being entered into the database) so many prior applications and licenses had never been entered, leaving the database with huge holes.  When the licensing function was shifted to Gettysburg, truckloads of Common Carrier applications were sent for entry into the database.  Unfortunately, all of this information was permanently lost when a major flood struck the Gettysburg offices.  To this day, we are still finding Common Carrier facilities that filed for and were granted licenses in the mid-90’s, but have no record in the current ULS database.

The license period is ten years.  We find several hundred licenses that have paths going nowhere; paths where the other station license has been canceled by the operator.  Since the FCC licenses stations, not paths, these “orphan paths” remain in the database forever until the operator cleans them up.  These kinds of problems are identified in the license data audit.

What should I do to ensure my facilities are properly licensed?
There are several answers to this question.  At a minimum, make certain you have a current and valid copy of the FCC license for every operating station in your network.  These licenses should be examined in detail to ensure that the technical information represents the actual operating parameters.  Comsearch offers a license auditing service that will compare the licensed data to the data in our database and report any discrepancies.  We can also compare these two sets of data to your dataset if provided.

The most comprehensive method to make certain that your system is properly licensed is to conduct a detailed field audit of every station.  There are several benefits derived from this kind of audit.  First, most of the older stations’ coordinates were developed prior to GPS.  The FCC Rules require coordinate accuracy to within ± 1 second.  Using differential GPS, the field audit technician can verify the coordinates to this level of accuracy and can verify the antenna heights, sizes, equipment make and model, and frequency.  A recent field audit conducted for one of our major customers uncovered several instances where the wrong equipment and frequencies were installed and in operation.

Licensees and operators need to proactively ensure that their licenses accurately and completely cover their operating facilities.  Errors and omissions are always inevitable when dealing with databases of this size and scope, but minimizing these kinds of problems can help ensure that your system will operate free from interference for many years to come.  The cost to perform the data audit can be very small when compared to the costs associated with retuning equipment, shutting systems down, or worse yet, an FCC fine.

For more information our Comsearch’s interference monitoring services, click here.

Regulatory Rap

Microwave and Satellite News

Some Sixty Years Later…
In keeping with the Governments ongoing initiative seeking spectrum policy reform, FCC Chairman Michael Powell and NTIA’s Assistant Secretary Nancy Victory signed a Memorandum of Understanding (MOU) on January 31.  The MOU establishes procedures relating to frequency coordination and spectrum planning provisions contained in the Communications Act and represents an update to the previous MOU between the parties dating back to 1940.   DOC-230835A1.doc  DOC-230835A1.pdf  DOC-230835A2.pdf  DOC-230835A1.txt  DOC-230835A2.txt

Important Notice to Part 101 Applicants
Effective April 1, 2003, a number of changes to the FCC Part 101 Rules go into effect.  While these changes are considered an improvement to the existing rules, there is one unintended consequence.  If you have a 23 GHz microwave system that was previously prior coordinated but not yet filed with the Commission, it is important that you file prior to the April 1 deadline.  If you file after the April 1 date, a new frequency plan will be in effect and the Commission will return your application for re-coordination.

FCC Affirms UWB Technology
On February 13, 2003, the Commission adopted a Memorandum Opinion and Order reaffirming the procedures adopted last year to authorize the unlicensed operations of ultra-wideband (UWB) devices.  It is anticipated that high-end consumer products utilizing this technology will be available by next Christmas with mobile hand held devices available the following year.  While these devices operate at extremely low power levels, the fact that they operate across a wide range of occupied spectrum (3.1 – 10.6 GHz) raises some concern of potential interference.  Sensitive devices such as receive-only earth stations should be particularly concerned about the potential impact from these devices.  (Dkt No 98-153, FCC No. 03-33)  DOC-231197A1.doc  DOC-231197A2.doc  DOC-231197A3.doc  DOC-231197A1.pdf  DOC-231197A2.pdf  DOC-231197A3.pdf  DOC-231197A1.txt  DOC-231197A2.txt  DOC-231197A3.txt

FCC Budget Of $281 Million Proposed For Fiscal Year 2004
The President has submitted a budget to Congress that proposes fiscal year 2004 funding for the Federal Communications Commission of $280,798,000. DOC-230893A1.doc  DOC-230893A1.pdf  DOC-230893A1.txt

The FCC'S Advisory Committee For The 2003 World Radiocommunication Conference Approves Draft Proposals 
(DA No. 03-91) DA-03-91A1.doc  DA-03-91A1.pdf  DA-03-91A1.txt

New Broadcast Auxiliary Interface Between The Universal Licensing System (ULS) And The Consolidated Database (CDBS) Available 
(DA No. 03-161)  DA-03-161A1.doc  DA-03-161A1.pdf  DA-03-161A1.txt

Freeze On The Filing Of TV and DTV "Maximization" Applications In Channels 60-69 (DA No. 03-46)  DA-03-46A1.doc  DA-03-46A1.pdf  DA-03-46A1.txt

Amendment Of Parts 2, 73, 74, 80, 90, And 97 Of The FCC's Rules
Amended rules to implement decisions from World Radiocommunication Conferences concerning frequency bands below 28000 KHz. (Dkt No. 02-16, FCC No. 03-39) FCC-03-39A1.doc  FCC-03-39A1.pdf  FCC-03-39A1.txt

FCC Auctions:

Auction 44 - Wireless Telecommunications Bureau Grants Lower 700 MHz Band Licenses 
DA No. 03-158)  DA-03-158A1.doc  DA-03-158A4.doc  DA-03-158A5.doc  DA-03-158A6.doc  DA-03-158A1.pdf  DA-03-158A2.pdf  DA-03-158A3.pdf  DA-03-158A4.pdf  DA-03-158A5.pdf  DA-03-158A6.pdf  DA-03-158A1.txt  DA-03-158A2.txt  DA-03-158A3.txt  DA-03-158A4.txt  DA-03-158A5.txt  DA-03-158A6.txt

Auction 49 - Revised Inventory and Auction Start Date for Auction of Lower 700 MHz Band Licenses
Represents the 700 MHz licenses that were not auctioned off previously.  (DA No. 03-100) DA-03-100A1.doc  DA-03-100A2.xls  DA-03-100A1.pdf  DA-03-100A2.pdf  DA-03-100A1.txt  DA-03-100A2.txt

Auction 50 - Narrowband PCS Spectrum Auction Revised Inventory And Start Date
(DA No. 03-372)  DA-03-372A1.doc  DA-03-372A2.xls  DA-03-372A1.pdf  DA-03-372A2.pdf  DA-03-372A1.txt  DA-03-372A2.txt

Auction 52 - FCC Announces Auction of DBS Orbital Slots
On March 3, 2003 the FCC released Report No. AUC-03‑52-A (Auction No. 52) which announced the auction of licenses to use the Direct Broadcast Satellite service allocation scheduled to commence on August 6, 2003. The auction will include 4 licenses for unassigned channels at orbital locations of 175º W.L., 166º W.L., 157º W.L., and 61.5º W.L.  These licenses would be subject to the Commission’s DBS service rules, including the geographic service rules at 47 C.F.R. section 25.148(c).  Specifically, DBS licensees must provide DBS service to Alaska and Hawaii where such service is technically feasible from the authorized location (FCC No. 03-40)  FCC-03-40A1.doc  FCC-03-40A1.pdf  FCC-03-40A1.txt

Auction 53 - Auction Of Multichannel Video Distribution And Data Service Licenses Rescheduled For June 25, 2003
(DA No. 03-286) Bidders should note that the interference environment is extremely complex and the subsequent coordination requirements are significant.  DA-03-286A1.doc  DA-03-286A2.xls  DA-03-286A3.xls  DA-03-286A1.pdf  DA-03-286A2.pdf  DA-03-286A3.pdf  DA-03-286A1.txt  DA-03-286A2.txt  DA-03-286A3.txt

Spectrum Management 2003

The National Spectrum Managers Association (NSMA) invites you to participate in the associations' annual conference "Spectrum Management 2003 " at the Holiday Inn Rosslyn Hotel (click here for hotel information) in Arlington, Virginia on May 20 and 21, 2003 .

Following a highly successful conference in 2002, Spectrum Management 2003 will once again address the critical spectrum management issues that are affecting the wireless industry today and into the future. Conference attendees represent spectrum management professionals of major wireless carriers, government regulatory agencies, vendors, systems integrators and consultants. For more information visit www.nsma.org.

Hispasat 1B Added to Permitted Space Station List
On March 5, 2003, the International Bureau added Hispasat S.A.’s  Hispasat-1B satellite, see Order for File No. File No. SAT-PDR-20020208-00016, located at 30° W.L., to the Commission’s Permitted Space Station List with certain conditions.  As a result of this action, U.S. earth stations with “routine” technical parameters will be able to communicate with Hispasat-1B immediately, in certain conventional Ku-band frequencies, i.e. 11.7-12. GHz for the downlink and 14.0-14.5 GHz for the uplink.  

Reply Comments on FCC Part 25 Revisions and Streamlining Due
Reply comments for FCC IB Docket No. 00- 248 (FCC Document 02-257), “ Streamlining and Other Revisions of the Commission's Rules Governing the Licensing of, and Spectrum Usage by, Satellite Network Earth Stations and Space Stations” are due by April 8, 2003.  In this document the Commission invited comments on revising part 25 of the Commission's rules to increase the number of earth station applications that can be processed routinely or, in the alternative, to streamline the processing of earth station applications.  Among the items included in this Further Notice of Proposed Rulemaking are the antenna sidelobe and maximum power density limits for both small diameter C-band and Ku-band terminals

Comsearch meets with FCC to discuss Extended Band Coordinations
Comsearch met with the FCC last month to discuss issues involving the coordination of earth stations using the extended portions of the C and Ku bands.  The meetings with the IB and WTB involving earth stations operating in the band 6.425-6.525 GHz.  This band has been allocated to Auxiliary Broadcast and LTTS services.  The WTB was concerned that not all potential operators in the band were notified during the coordination process, specifically, those licensees with regional or nationwide licenses.  It was agreed that a listing of all the regional and nationwide licensees would be developed and provided to Comsearch so that all future coordinations would include all potentially affected licensees.  It was also agreed that the 35-day coordination response period should be observed by all. 

In separate proceeding, Comsearch met with FCC IB and OET, the NTIA, and the Navy, to discuss earth station licensing in the 13.75-14.0 GHz band.  Practical concerns about the interference analysis techniques used by both the Navy and Comsearch were discussed.  The NTIA and Navy also inquired about instituting emergency shut down procedures for earth stations that may be granted conditional clearances.  Additional technical meetings between Comsearch, the FCC, and Navy will continue to achieve a common analysis technique.  The Navy made a point that above ground shielding included in over-the-horizon loss calculations must be under the control of the licensee, i.e. a licensee maintained shield wall or building, and that sites in close proximity to the shore-line would have a difficult time receiving clearance from the NTIA/Navy.

Satellite Companies Undergo Executive Changes
In the past two weeks several of the large satellite services providers have announced changes in leadership positions. On February 24, 2003 Intelsat announced that Ramu Potarazu, President & Chief Operating Officer (COO) of Intelsat Global Service Corporation, will be promoted to President & COO, Intelsat (Bermuda), Ltd. within one month.  On February 27, 2003,  Boeing officials have selected Dave Ryan to lead Boeing Satellite Systems effective immediately. Ryan, a 13-year Boeing employee, succeeds Randy Brinkley, who has announced his intent to leave the company on June 1, 2003. As vice president and general manager of Boeing Satellite Systems, or BSS, Ryan will report to Bill Collopy, vice president and general manager of Launch and Satellite Systems, a division of St. Louis-based Boeing Integrated Defense Systems.

Also, on March 10, Gilat Satellite Networks Ltd. announced the resignations of the company's Chairman and CEO Yoel Gat and President Amiram Levinberg, both co-founders of the company effective upon the meeting of the new Board of Directors expected in April. The voluntary resignations open the way for the appointment of a new Chairman and President and CEO at the upcoming meeting of the new Board of Directors in April where it is expected that Shlomo Rodav will become Chairman of the company and Oren Most will be appointed the new President and CEO.

What's New at Comsearch!

Comsearch Enters the Government Wireless Market – GSA Schedule Application to be complete in Spring of 2003

Comsearch expects this Spring to be listed on the GSA schedule—A first step in providing our products and services to the Federal Government.

The growing demand for wireless communications systems and usable RF spectrum can be felt in virtually every market—especially within our Federal Government.  All government agencies are challenged to make the most efficient use of their spectrum to ensure complete secure communications, particularly in the current climate.

The Government represents one of the largest markets in telecommunications—being listed on the GSA Schedule allows Comsearch to provide our expertise in system design, engineering and spectrum management to these agencies and supporting departments serving and protecting our nation.

Comsearch Offers Engineer, Furnish & Install Services for Mobile, Microwave & Satellite Communications Systems . 
Click here for more information.

Comsearch Offers License Auditing Services –  
Comparative Analysis of Wireless Facility Licensed Data to Comsearch’s Accurate Proprietary Data

Comsearch Announces the Sale of iQ·link^® To A Fifth Vodafone Company – Premier Microwave Network Design Tool Continues To Be First Choice Of Leading Global Operators

Comsearch Selected as Official Frequency Coordinator For CTIA WIRELESS 2003 – RCR News Interviews Comsearch VP on Frequency Coordination Process

Comsearch Offers Free Passes to the National Association of Broadcasters (NAB) 2003 show. Click here to take advantage of the NAB 2003 FREE exhibits-only registration pass by April 2, 2003.  Comsearch booth #N1751.

Comsearch Executives Participate in Major Industry Events

Les Polisky – Sr. Principal Field Engineer – will present “Avoiding Microwave Station and TV Reception Degradation from Wind Turbine Facility Installations” at the WINDPOWER 2003 Conference & Exhibition.  Click here for more information.

Chris Hardy – Vice President, Spectrum Management Solutions – will present “Technical and Regulatory Changes in the Auxiliary Broadcast and CARS Service” at the NAB 2003 Conference.  Click here for more information. 

Mark Gibson – Senior Director, Business Development – will speak on “Wireless Planning for the Healthcare Environment” at the ASHE (American Society of Healthcare Engineers) Planning & Design Conference. For more information, click here. 

Saul Torrico – Principal Scientist – will present “Predicting the Radio Channel for Third-Generation Systems” at the 2003 World Wireless Congress.  Click here for more information.

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