STELA Update II: Effective Date, Comment Deadlines Set For Changes In Signal Prediction Methodology
As we reported the day before Thanksgiving, the Commission – acting at Congress’s direction – adopted a number of changes in its rules relating to satellite carriage of broadcast programming. Included among the FCC’s actions was a Report and Order and Further Notice of Proposed Rulemaking (R&O/FNPRM) in which the Commission addressed prediction of digital TV field strength levels at particular locations. (Such predictions are an important factor when it comes to carriage of “significantly viewed” stations by satellite carriers.) The Commission adopted a modified Longley-Rice model, but also (in the FNPRM portion of its order) solicited comments on some further changes suggested by an earlier commenter. Among other things, the Commission is curious about the commenter’s suggestions relative to [WARNING: Intense techno-speak dead ahead; deploy shields as needed]: “1) calculation of diffraction loss close to an obstacle or leading up to and following a pair of obstacles and 2) a factual or scientific basis for explaining the additional losses in the line of sight range above and beyond the free space loss and two-ray-loss.”
The R&O/FNPRM has now been published in the Federal Register (in separate chunks: the R&O may be found here, and the FNPRM may be found here). That in turn sets the effective date of the changes adopted in the R&O and the comment deadlines for the FNPRM. The effective date is January 21, 2011. Comments in response to the FNPRM are due by January 21, 2011, and reply comments by February 7, 2011.
Two observations on FCC's confusion on TV propagation prediction:
1) In the TV whitespace Docket 04-186 MO&O 2 months before the STELA NPRM, FCC said:
"No party has described an alternative model that will provide more accurate calculations of TV station contours than the Commission's current method. The current method of calculating TV station contours in Section 73.684 of the rules using the FCC curves in Section 73.699 of the rules is straight forward, well understood and has proven sufficiently accurate over time"
2) In the Docket 10-237 NOI, adopted a week after STELA FCC said
"The Commission has relied on the Longley-Rice propagation model to predict the behavior of radio waves for many interference analyses, so that coverage areas may be established for various types of transmitting equipment.44 In the 2009 Commission Broadband Workshop discussed above, Dr. Joseph Mitola III of Stevens Institute of Technology stated that the Longley-Rice model is inadequate for cognitive radios."
While I believe that continued use of R-6602 with respect to allotment of full power stations is useful to give administrative certainty to broadcast licensees when these licenses are often worth hundreds of millions of dollars, at some point FCC should come up with a consistent statement of the actual coverage of TV broadcasters and not use ad hoc model selection to placate the problem at hand.