Taming the Spectrum  

In this issue:

MARKET TRENDS:
Access to Radio Spectrum Just Became a Little Easier, But Buyer (or Lessee) Beware!

CASE CORNER:
Microwave Link Installation Helps Wind Energy Client Improve Facility Operations and Maintenance

REGULATORY RAP:
Spectrum Management News

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Access to Radio Spectrum Just Became a 
Little Easier, But Buyer (or Lessee) Beware!

by Chris Hardy, VP and General Manager

Regulation of the radio spectrum has been a hotly debated subject for nearly a century, beginning in the early 1900’s when the Government passed the Radio Act of 1927 and the 1934 Communications Act, which took control of what was previously considered as “free” airwaves.  Over the last 20 years, advocates for deregulation have convinced the Federal Communication Commission (FCC) to consider more flexible approaches to spectrum management.  The FCC’s recent rulemaking establishing a secondary market for spectrum usage rights represents another significant turn in this long running conversation.

In 2000, the FCC adopted a Policy Statement identifying goals and principles for further development of secondary markets in spectrum usage rights.  They also issued an NPRM (Docket No. 00-230) to identify steps that the FCC might take to implement their policy with respect to Wireless Radio Services and Satellite Services.  The FCC wanted to modify spectrum usage rights to allow spectrum to flow more freely among users in response to economic demand and technology advances, while being consistent with statutory mandates and public interest objectives.  The FCC was concerned that existing licensees were not fully using the spectrum allocated to them.  Thus, there may be large amounts of fallow spectrum in many areas, while at the same time demand for spectrum in other areas was constrained.

In the NPRM, the FCC proposed several ways to remove unnecessary regulatory barriers and clarify rules to more easily allow Wireless Radio Services licensees to lease their spectrum.  It asked for comment on the types of leasing arrangements that would be desired and what responsibilities should be put on the licensee, the spectrum lessee, and the FCC.  It also asked for comment on approaches that might involve transfers of control of spectrum subject to FCC approval through a streamlined process.

In 2002, the Spectrum Policy Task Force Report provided support for the secondary market initiative and spectrum leasing.  The report described high demand for spectrum-based services and devices, indicating that technological advances have significantly increased the types of service offerings and contributed to increased consumer demand.  The report discussed two complimentary approaches to expand access to spectrum.  The first relying on secondary market arrangements involving spectrum leasing with licensees holding the rights to determine who could have access to their exclusive-use spectrum.  The second approach discussed open access to licensed spectrum for non-interfering devices - in essence, an underlay of low-power unlicensed devices such as Software-defined radio or Ultra-wideband.  The strong endorsement of the Task Force helped in the implementation of the reforms outlined in the Report and Order.

The Report and Order and Further Notice of Proposed Rulemaking for “Promoting Efficient Use of Spectrum Through Elimination of Barriers to the Development of Secondary Markets” was adopted on May 15, 2003 and released on October 6, 2003.

The Report and Order goes into significant detail discussing the spectrum leasing policies and providing justifications for each.  The Order basically allows two types of spectrum leasing, “spectrum manager” leasing and “de facto transfer” leasing.  It also goes to great lengths to try to justify that the provisions are allowable under the Communications Act, particularly Section 310(d), and in light of the Intermountain Microwave standard of 1963 (see table of definitions below).

Spectrum Manager Leasing
Under the “spectrum manager” leasing option, licensees and spectrum lessees may enter into spectrum leasing agreements for any amount of spectrum, in any geographic area, for whatever term agreed, as long as it is within the scope and term of the license.  No prior FCC approval is required provided that the licensee maintains de jure and de facto control over the leased spectrum.  De facto control is based on the new definition of de facto control.  Essentially, the licensee acts as “spectrum manager” with regard to the spectrum rights it chooses to lease.

Some notable requirements for the “spectrum manager” leasing option include:

• Licensee maintains de jure and de facto control of the leased spectrum.
• New definition of De facto control requires the licensee to maintain an active, ongoing oversight role to ensure that the spectrum lessee complies with all FCC policies and rules, and the Communications Act.
• All technical and interference-related service rules applicable to the particular service or frequency band will also apply to the spectrum lessee.
• Eligibility and qualification rules and the use restrictions applicable to the licensee will be applied to the spectrum lessee.
• Licensee must provide notification to the FCC of each spectrum lease into which it has entered.
• Notification to the FCC must be provided within 14 days of lease signing, and at least 21 days in advance of spectrum lessee operations.
• Licensee notification must include information on the spectrum lessee, the specific spectrum range, geographic area of operation, and lease term.
• Lessee is required to indicate whether it holds interests in other spectrum (through licenses or leases) in the geographic area covered by the lease.

Although prior FCC approval is not required under this leasing option, the FCC retains the right to investigate and obtain additional information post-notification, and to terminate arrangements that it determines violate any notification certifications or public interest concerns  (e.g. foreign ownership or competition concerns).  The FCC plans to submit notification certifications in an informational public notice on a weekly basis and have them publicly available in the FCC ULS database.

De facto Transfer Leasing
“De facto transfer” leasing allows licensees and spectrum lessees to enter into spectrum leasing agreements that involve de facto transfer of control for any amount of spectrum, in any geographic area, and for any period of time within the scope and term of the existing license.  De facto control of the leased spectrum is transferred to the spectrum lessee for the duration of the lease, but de jure control is maintained by the licensee.  Requirements under this option differ slightly depending on whether parties enter into a “long-term” arrangement (longer than 360 days) or a “short-term” arrangement (360 days or less). 

Some notable requirements of the “long-term” de facto transfer leasing option include:

• The spectrum lessee exercises de facto control of the leased spectrum.
• The licensee retains de jure, or legal, control of the leased spectrum and may impose other terms and conditions as mutually agreed.
• The spectrum lessee assumes responsibility for interacting with the FCC with respect to the leased spectrum, including associated filings.
• The spectrum lessee is primarily responsible for ensuring that it complies with all FCC rules and the Communications Act.  However, the licensee can still be held liable for non-compliance especially if it has knowledge about the lessee’s failure to comply.
• All of the particular service rules applicable to the licensee under its authorization (both interference and non-interference related) apply to the spectrum lessee.
• Eligibility and qualification rules and the use restrictions applicable to the licensee will be applied to the spectrum lessee.
• A lease application must be filed with the FCC and prior FCC approval is required.
• Upon FCC acceptance of application, it will be placed on public notice with petitions to deny due within 14 days.
• Using a streamlined process, the FCC will, within 21 days of the public notice, either consent to the transfer or “offline” the application for further examination.

The requirements for the “short-term” de facto transfer leasing option include:

• The spectrum lessee exercises de facto control of the leased spectrum.
• The licensee retains de jure, or legal, control of the leased spectrum and may impose other terms and conditions as mutually agreed.
• The spectrum lessee assumes responsibility for interacting with the FCC with respect to the leased spectrum, including associated filings.
• The spectrum lessee is primarily responsible for ensuring that it complies with all FCC rules and the Communications Act.  However, the licensee can still be held liable for non-compliance especially if it has knowledge about the lessee’s failure to comply.
• Some additional flexibility with regard to particular service rules and policies are provided to the spectrum lessee.  Interference-related rules will apply to the lessee, but certain service rules related to use restrictions, designated entity policies, and spectrum aggregation will not be applied to short-term lessees.
• Short-term leasing arrangements that meet specified conditions will be approved within 10 days pursuant to FCC special temporary authority (STA) procedures.

Collection of Information on Spectrum Leasing
Based on the notification and application requirements, the FCC will be collecting information on spectrum lessees and leases in the ULS.  The FCC claims it will be useful for other entities seeking information on leasing and for their enforcement purposes.  They declined to provide any special database or spectrum registry however, concluding that may be best suited to private sector entities.  They defer to the Further Notice of Proposed Rulemaking to explore whether any other action is necessary to promote information access to enhance the efficiency and effectiveness of the secondary market.

The second table identifies specific services that were called out in the Report and Order as excluded from the spectrum leasing options.  However, any service not on the included list should be considered excluded also.  Of particular note, MDS / ITFS, Satellite, Cable TV Relay, MVDDS, and 700 MHz Guard Band Manager services have been excluded, but are put into the Further Notice of Proposed Rulemaking for future consideration.

Case Corner

Microwave Link Installation Helps Wind Energy 
Client Improve Facility Operations and Maintenance

by Lester E. Polisky 

The increasing complexity of commercial wind power turbines requires that they be remotely controlled and monitored in order to optimize their performance and ensure that they work in concert with the overall utility power grid.  This remote monitoring is often accomplished through the use of microwave links performing functions known as System Control and Data Acquisition (SCADA).  As part of Comsearch’s innovative RF solutions offerings to the wind energy industry,  we entered into an agreement with one of our wind energy clients to design and install a SCADA microwave link.

The role of the SCADA microwave link is extremely important for the coordination of power generated from a wind energy network.  On-demand supply from the wind energy grid must be instantly available, and it is critical that the main power grid substation know the technical parameters of the wind energy power to be supplied.  These parameters include, phase angle, frequency, power factor, voltage, and current and must be known precisely at the substation so that the wind energy can be phased into the grid without creating a misalignment thus prompting a shut down.  The switching-in of the power from the wind energy facility must be done in phases to avoid such a misalignment.  Once the wind energy power is switched on to the electrical grid, the SCADA data provides metering of the power delivered for operational and billing purposes.  While the wind energy facility is on the main grid, its output must be constantly monitored to insure there is enough power generated to produce a net positive input to the grid. Otherwise, the wind energy grid is taken off-line either at the substation or at the wind energy O&M facility.

Thus, the SCADA microwave link will connect our wind energy client’s control center and the electrical control substation facility for the electrical power grid, approximately 2.8 miles away.  The link will operate in the 5.8 GHz unlicensed band and will have the capability of transferring 10 Base-T Ethernet signals in both directions on the path.  A voice link included in the overhead of the radios will also be available for use.  The microwave system can have as many as twenty-four additional voice channels added to it through the addition of a channel bank.

Comsearch has installed these types of microwave links in the past.  The most notable of past Comsearch microwave installation projects was the emergency work performed in New York City to interconnect cell sites on wheels (COWS) for Sprint during the recovery efforts from the September 11^th terrorist attacks on the World Trade Center (see archived WirelessPulse article NYC Telecom Recovery Efforts Following the Terrorist Attacks, November 2001, Vol 1 Issue 1).

In contrast to the New York City project, the wind energy installation project required a turnkey microwave link.  The installation project is divided into five distinct tasks.  They are:

1. Preliminary design of the microwave link to the reliability objective
2. Select and purchase the hardware for the entire system

3. Installation

4. Perform compliance testing

5. Provide training for on-site technicians for operation and maintenance of the link

The first step in the preliminary design is to determine the antenna heights.  The results of this analysis indicate that the antenna at the substation is to be placed atop a 110-foot tower which was built just prior to the installation of the link.  The antenna at the wind energy facility side was installed on the roof of the operations and maintenance building on a 16-foot pole.

                                         Figure 1 Microwave Path Profile

In order to specify the equipment to be installed on the path, we had to first determine the power available at the site.  At the operations and maintenance building there was a 120-VAC-to-VDC converter for the radio equipment.  Thus, the radio at this site will be powered from an external AC-to-DC power supply.  Comsearch also selected a 120 VAC uninterruptible power supply (UPS) with at least two-hour capacity to maintain the input AC power to the AC-to-DC power supply in the event of a power outage.  At the substation there is a 48-VDC-power supply with battery backup so no UPS was required at this location.  The current draw of the radios is less than 1 Amp. 

Table 1 Design Parameters and Reliability Calculation

Comsearch not only designed and installed the microwave link but also tested the operation of it by verifying the received signal level (RSL) and running a bit-error-rate (BER) test for a digital signal transfer.  The RSL and BER measurements demonstrated that the link was operating in compliance with the design specification.

After the completion of the testing, the installation team conducted training for the personnel responsible for the operation and maintenance of the link.  The training was tailored for the installed system, but also included basics of microwave.  All of the components of the system were described in detail.  The training also included how the power supply and data interfaces were to be made to the microwave link.

As the world looks towards alternative sources for power, the use of wind energy will continue to become more prevalent.  However, access to the main power grid can only be accomplished through careful monitoring and control provided by SCADA links.  Consequently, wind energy providers must pay strict attention to the planning, design, installation, and maintenance of SCADA microwave links to assure safety and the success of wind provided energy in the future.

Regulatory Rap

Spectrum Management News

Interference Temperature
On November 28, 2003, the Commission issued an NOI and NPRM to introduce and explore the concept of “Interference Temperature” as a means of quantifying and managing interference in order to allow unlicensed operation in licensed bands.  The NPRM portion of the document identifies the upper 6 GHz and 13GHz CARS point to point microwave bands for the initial trial of this concept.  Our preliminary review of the document indicates certain flaws in the concept, especially when introducing it into the point-to-point bands.  The basic tenet of the concept assumes that there is a certain level of interference that is consistently present at a receiver that is above the noise floor of the receiver.  Once this new level is identified, other co-channel (unlicensed) devices should be able to operate as long as they stay below this level. 

Modification of Parts 2 and 15 Of The Commission's Rules For Unlicensed Devices And Equipment Approval
Proposed review and update of certain rule sections contained in Parts 2 and 15 of our rules. (Dkt No. 03-201, FCC No. 03-223)  FCC-03-223A1.pdf 

FCC Acts to Promote Efficient Use of Spectrum Through the Development of Secondary Markets
Removed unnecessary regulatory barriers to the development of secondary markets in spectrum usage rights. (Dkt No. 00-230, FCC No. 03-113)  FCC-03-113A1.pdf  FCC-03-113A2.pdf  FCC-03-113A3.pdf  FCC-03-113A4.pdf  FCC-03-113A5.pdf 

Editorial Amendment Of Part 0 Of The Commission's Rules
Section 0.121 of the Rules Amended to update the geographical coordinate locations of the Commission's protected field installations where radio spectrum monitoring operations are conducted. (DA No. 03-2899)  DA-03-2899A1.pdf 

Electronic Filing Starts For Cable Operators
(DA No. 03-2991)DA-03-2991A1.pdf 

Revisions to Broadcast Auxiliary Service Rules in Part 74 and Conforming Technical Rules for Broadcast Auxiliary Service, Cable Television Relay Service and Fixed Services in Rule Parts 74, 78 and 101
Denied a Request for Extension of Temporary Stay filed by the Society of Broadcast Engineers, Inc., to delay, by an additional six months, the effective date of coordination procedures adopted by the R&O in this proceeding. (Dkt No. 01-75, DA No. 03-3215) DA-03-3215A1.pdf 

Wireless Telecommunications Bureau Extends Freeze on High Power use of 460-470 MHz Band Offset Channels
The FCC seeks comment on American Hospital Association's proposal for migration of medical telemetry equipment to wireless medical telemetry service. (DA No. 03-3178) DA-03-3178A1.pdf 

FCC Opens 70, 80, and 90 GHz Spectrum Bands for Deployment of Broadband "Millimeter Wave" Technologies
The FCC adopted service rules for the commercial use of spectrum in the 71-76 GHz, 81-86 GHz, and 92-95 GHz bands to promote the development of an additional competitive broadband platform. (Dkt No. 02-146, FCC No. 03-248) DOC-239368A1.pdf  DOC-239368A2.pdf  DOC-239368A3.pdf  DOC-239368A4.pdf  DOC-239368A5.pdf   FCC-03-248A1.pdf  FCC-03-248A2.pdf  FCC-03-248A3.pdf  FCC-03-248A4.pdf  FCC-03-248A5.pdf 

FCC Adopts Third Generation ("3g") Rules Making 90 MHz of Spectrum Available for Broadband and Advanced Wireless Services
The FCC adopted a Report and Order to advance its efforts to provide new and existing wireless operators with additional spectrum resources.  DOC-240030A1.pdf  DOC-240030A2.pdf  DOC-240030A3.pdf  DOC-240030A4.pdf  DOC-240030A5.pdf  DOC-240030A1.txt  DOC-240030A2.txt  DOC-240030A3.txt  DOC-240030A4.txt  DOC-240030A5.txt

FCC Proposes to Fine Four Licensees a Total of $40,000 for Jointly Violating RF Radiation Limits
DOC-240190A1.pdf 

FCC and National Imagery and Mapping Agency (NIMA) Agree to Share Databases on Tower Locations
The FCC and NIMA entered into a Memorandum of Understanding (MOU) to exchange unclassified database information on tower locations on a quarterly basis. DOC-240497A1.pdf 

Amendment of Rule Parts 2, 25 and 87
Amended Parts 2, 25, and 87 to implement domestically various allocation decisions from several World Radiocommunication Conferences concerning the frequency bands between 28 MHz and 36 GHz. (Dkt No. RM-10331, 02-305, FCC No. 03-269)  FCC-03-269A1.pdf

Amendment of Section 2.106 of the Commission's Rules to Allocate Spectrum at 2 GHz for use by the Mobile-Satellite Service
Suspended for 9 days, until November 13, 2003, the expiration date for the initial two-year mandatory negotiation period for Phase 1 of the 2 GHz band relocation plan between Mobile-Satellite Service and Broadcast Auxiliary Service. Modified the rules that new 2 GHz Mobile-Satellite Service (MSS) licensees are to follow when relocating incumbent Broadcast Auxiliary Service (BAS) licensees in the 1990-2025 MHz band and Fixed Service (FS) microwave licensees in the 2180-2200 MHz band. (Dkt No. 95-18, 00-258, 01-185, FCC No. 03-280)  DA-03-3543A1.pdf  DOC-240829A1.pdf  FCC-03-280A1.pdf 

Amendment of Section 2.106 of the Commission's Rules to Allocate Spectrum at 2 GHz for use by the Mobile-Satellite Service http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-280A1.doc  

Earth Station on Board Vessels           
On November 24, 2003 the FCC released a Notice of Proposed Rulemaking (IB Docket 02-10) concerning the procedures to govern the licensing of Earth Stations on board Vessels in the 5925-6425 MHz/3700-4200 MHz Bands and 14.0-14.5 GHZ/11.7-12.2 GHz Bands.  The NPRM seeks, in part, to implement decisions reached at the International Telecommunication Union’s 2003 World Radiocommunication Conference to add a footnote to the International Table of Frequency Allocations stating that in the 5925-6425 MHz and 14.0-14.5 GHz bands ESVs may communicate with space stations in the FSS. This would allow for the operation of ESVs under the condition that interference into existing and future commercial FS and FSS systems as well as government space research and radio astronomy systems.  

Additionally, the NPRM seeks to establish a regulatory scheme that could enable foreign-licensed ESVs to operate near the United States coastline without causing harmful interference to domestic operations. 

Essentially, the NPRM seeks comments on proposals to license ESVs in a similar fashion to VSATs at Ku-band, i.e. blanket authorization.  At C-band, the proposals include a Non-Coordination Approach and a Coordination Approach.  The proposed Non-Coordination Approach would provide a short-term license for C-band ESV operations with specific conditions imposed to facilitate the identification and elimination of harmful interference in the event that an ESV causes interference to an FS system.  The proposed Coordination Approach would require, among other things, that ESV operators coordinate their operations prior to receiving a license and meet certain technical criteria designed to protect FS operators.  Under either method, ESV use would be prohibited from causing harmful interference to, claiming interference protection from, or otherwise imposing constraints on the operation or deployment of other radio services in the C-band.

Reply comments are due 30 days after Federal Register publication. 

FCC Issues New Rules for 2 GHz MSS
On November 5, 2003 the FCC adopted a Third Report and Order and Third Memorandum Opinion and Order regarding the allocation of spectrum at 2 GHz to Mobile Satellite Services (ET Docket 95-18).  The Order modifies the rules that new 2 GHz Mobile-Satellite Service licensees are to follow when relocating incumbent Broadcast Auxiliary Service (BAS) licensees in the 1990-2025 MHz band and Fixed Service (FS) microwave licensees in the 2180-2200 MHz band.  In February, the FCC decided to reallocate 30 megahertz of 2 GHz MSS spectrum to new Fixed and Mobile services as part of the Advanced Wireless Services (AWS) proceeding (ET Docket 00-258) and to allow MSS licensees to provide an Ancillary Terrestrial Component (ATC) in conjunction with their MSS networks (IB Docket 01-185, March 2003. 

Specifically, the FCC decided to:

For relocation of BAS in the 1990-2025 MHz band by new MSS entrants:  

• Require the relocation of BAS incumbents in all television markets to the final (Phase II) plan at 2025-2110 MHz.  This will eliminate the necessity of relocating BAS licensees to an interim (Phase I) channel plan as part of the previously adopted two-phase approach to relocation.

• Retain the requirement that all BAS operations in markets 1-30 must be relocated prior to the initiation of new MSS in the band.

• Amend the rules to specify that the time period for calculating a one-year mandatory BAS negotiation period for markets 1-30 and the ten-year sunset period commence upon publication of this Report and Order in the Federal Register.

• Require the relocation of all fixed BAS stations on channels 1 and 2 nationwide prior to the initiation of new MSS in the band.

• Decline to require the reimbursement of relocation expenses for BAS facilities for which initial applications were filed at the Commission after adoption of the MSS Second Report and Order.

• Modify the final (Phase II) BAS channel plan to provide for seven channels of 12 megahertz each, and a 500 kilohertz data return link (DRL) band at both ends of the seven channels.

• Permit BAS licensees to operate indefinitely on their existing 17-megahertz wide channels in the 2025-2110 MHz band on a secondary basis, if they so choose.

• Clarify that an assignment or transfer of control does not disqualify a BAS incumbent from relocation eligibility.

Also, for FS microwave relocation by MSS/ATC licensees in the 2180-2200 MHz band:

• Clarify that TIA TSB 10-F, or its successor, is an appropriate interference standard that may be used for determining interference from MSS ATC stations to incumbent FS operations in the 2 GHz band.

• Clarify that FS incumbents relocated through the negotiation process are eligible for reimbursement for relocation to leased facilities or alternative media, but decline to extend reimbursement eligibility to FS incumbents that voluntarily self-relocate.

FCC International Bureau Kicks-Off  Design of Enhancements to IBFS System
In conjunction with an open meeting held on November 21, 2003, the FCC IB announced it was commencing the design of new enhancements to the on-line satellite filing system IBFS. As a response from industry and regulatory reforms the IB will undertake  development of a new EZ Form for satellite earth stations and a Schedule S technical form for satellite space stations.  Additional enhancements required by the adoption of the satellite reform order and requested by the user community will be addressed subsequent to these actions. The IB in encouraging those members of industry whom would like to become actively involved  in this development to serve as members of the design team.  If interested contact Mary Jane Solomon on 202-418-0593 or via e-mail at MaryJane.Solomon@fcc.gov.

What's New at Comsearch!

Comsearch Broadcast License Management Services

The FCC recently enacted new rules requiring Broadcast Auxiliary Service (BAS) providers in the microwave bands to formally prior coordinate before submitting an application for license.  With this new requirement, it is more important than ever to have accurate and updated technical information in the FCC’s licensing database.

 

Over the last six months Comsearch has cleaned up it’s database in preparation for this coordination work to help ensure that the data on BAS licenses is accurate and in compliance with FCC regulations.  We offer three levels of license management services to help BAS operators manage their licenses and avoid costly filing mistakes.  Click here to learn more.

 

Comsearch Frequency Protection Clients Eligible To Receive FREE Standard Package Access To Comsearch Interactive Solutions

Online access to Comsearch’s comprehensive proprietary databases including Microwave, Earth Station, Radio Equipment and Antenna information.  Access to terrain data, engineering reports and regulatory information, and engineering design tools are also included.  Click here to learn more and to sign up.

 

Comsearch Releases Version 8.1 of iQ.link^® Microwave Network Design Software

Enhancements include automatic frequency planning module for automatic transmit power control and correlated fading. Click here. 

 

Comsearch PCNs Go Electronic

Comsearch has implemented electronic distribution of all Prior Coordination Notices (PCNs) . To ensure that you continue receiving PCNs. Click here to learn more.

 

Comsearch 2003 Web Survey Winner!

Congratulations to Chuck Zimmermann of Western Wireless , winner of Comsearch’s 2003 Web Survey Contest.  Chuck won a $250 Gift Cheque from American Express. 

 

Comsearch 2004 Trade Show Participation Schedule

• Cellular Telecommunications Industry Association (CTIA), Atlanta, GA  March 22-24,2004. More information...

• National Association of Broadcasters (NAB), Las Vegas, NV  April 17-22, 2004. Click here.

• United Telecom Council (UTC), Nashville, TN   May 16-19, 2004. Click here for more info.

 

The Comsearch offices will be closed from December 25 through January 2.  Emergency service coverage is available to our clients during this time, except for Christmas Day, New Years Eve and New Years Day, by calling 703-585-6357.

 

Comsearch extends best wishes for peace, hope and happiness

to all of our clients, partners, and colleagues this holiday season

and through the New Year.

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