The Society of Broadcast Engineers (SBE) submitted Comments this week in the FCC's Public Notice DA 11-1011 titled "Wireless Backhaul: Further Inquiry into Fixed Service Sharing of the 6875-7125 MHz and 12700-13200 MHz Bands."
SBE's comments point out flaws in the Commission's present sharing proposals and in the Wireless Bureau's studies. These bands are used by broadcasters for broadcast auxiliary services (BAS) and by cable operators for cable TV relay services (CARS). Broadcaster uses include fixed links for studio-to-transmitter sites, return links from receive sites and portable, mobile and aeronautical use for electronic news gathering.
I described DA 11-1011 earlier this month in "7 and 13 GHz ENG Will Complicate Fixed Services Sharing". SBE, in its comments, says, "It is no secret that the Commission has already conceptually adopted the addition of wireless backhaul to the BAS and CARS 7 and 13 GHz bands to facilitate expanded broadband. The concept appears as a fait accompli in the National Broadband Plan."
The statement noted that the FCC's issuance of a Public Notice, in spite of comments received concerning obstacles involved in sharing the BAS spectrum, "…indicates that the Commission has already decided" the outcome of the proceeding, and stated that the only thing left was in how to justify the policy decisions that have been made.
The SBE further commented:
"Policy decisions should not be determined in advance of technical spectrum planning. The prejudgment that is manifest in this proceeding is unsettling."
The SBE notes that the Commission's present sharing proposals permit Fixed Services (FS) sharing outside the licensed service areas of current BAS and CAR stations effectively "freezes" the protected BAS and CARS mobile operation area "to a single point in time."
According to the SBE:
"Any new BAS or CARS applicants for facilities which envision service areas outside those which duplicate presently licensed BAS or CARS service areas would not be protected from FS operations which have located in the proposed new BAS or CARS facility's service area in the meantime."
The SBE document stated that this presumes that there would not be any growth in BAS or CARS operations in the 7 or 13 GHz regions. It also says the Wireless Bureau's studies are flawed, as coverage areas on licenses do not accurately indicate areas in which TV stations will use these bands, and that Section 74.24 of the FCC's Rules facilitates temporary operation outside a licensee's service area. Some BAS licenses specify nationwide operation. This works due to efforts by local market coordinators who do their work in real time.
The SBE's comments further warn that, "Sharing between FS operations and mobile and temporary fixed ENG operation at 7 and 13 GHz is simply not feasible. Forcing such sharing notwithstanding this incompatibility will result in interference to FS stations, or else it will result in an unacceptable reduction in broadcasters' ability to do real-time newsgathering."
The SBE concluded by stating, "The record in this proceeding shows that neither of the Commission's newly-proposed sharing plans is workable, and neither is in the best interest of either FS or BAS/CARS licensees of the Commission. Therefore, for the reasons discussed herein, SBE again respectfully requests that the Commission abandon the sharing proposal as unworkable."
