SBE Calls On FCC To Examine Its NADs
The earth may have moved for some, but apparently not for the FCC.
In the 1980’s, geographers around the globe began to realize that the North Pole was fictional. Not the one where Santa Claus lives, but the one that represents one end of an axis around which the Earth rotates. The one where all the longitude lines on a map should intersect, and the lines of latitude converge. It turned out this North Pole was not quite where we had put it. Meaning, from a cartographical standpoint, that geographic coordinates did not accurately reflect physical reality.
This revelation came about because, as we sent an increasing number of satellites into orbit above the Earth, they stubbornly insisted on circling around a center of mass several hundred feet away from the north-south axis conventionally relied on by geographers. Even then, we might not care, except that satellites used for GPS navigation and surveying provided latitude and longitude based on the true center of the Earth, which differed from the coordinates marked on people’s maps.
Geographers, being orderly people by nature, found the discrepancies troubling. Conceding the point to the satellites, they duly set aside the old coordinate system, North American Datum 1927 (NAD27), in favor of North American Datum 1983 (NAD83), which better reflects the actual center of the Earth’s mass. True, this caused the coordinates of landmarks across much of the country to change overnight, but that is a small price to pay for consistency,
So how ironic that the FCC, which regulates many kinds of satellites, still conducts certain business – specifically, CDBS, its broadcast licensing database – using NAD27. For comparison, the FAA converted to NAD83 19 years ago, the FCC’s wireless licensing system, 12 years ago. The need for the change is a no-brainer – the Media Bureau apparently just hasn’t gotten around to it.
Perpetuating the sense that this is the issue time left behind, a Society of Broadcast Engineers petition for rulemaking has just surfaced in the Commission’s docketing system. The petition is dated August 10, 2007 (yes, SBE has a “stamped” copy with that date), but is marked in the FCC’s records as having been received April 6, 2011. The petition has not yet been docketed or assigned a rulemaking number. And given the history of this issue, we’re not counting on further developments anytime soon. Change in this area happens only by degrees.
Yes, it's a mystery how the 2007 SBE Petition for Rulemaking surfaced recently with an April 6, 2011, date stamp. And I would say the change in this area happens only by degrees/minutes/seconds (grin).
See also the H&E Section 1.958 petition; it's on our web site, at http://h-e.com/sites/h-e.com/files/upload/1.958_petition.pdf. That petition was sent by both first class mail and by e-mail to the FCC Office of the Secretary on March 21, with courtesy copies to OET. Then on April 5 I got a call from an OET staffer indicating that they wanted to run with the H&E petition, but the Secretary's office couldn't find any record of receiving it. So on April 5 we sent another copy, this time my overnight UPS delivery, so we would have a signed receipt (and yes, it was sent to the special East Hampton Drive address to be used by overnight delivery services such as UPS and Federal Express).
But it gets better: On April 29 I received yet another call from OET, saying that the Secretary's office still couldn't find any record of the H&E petition, and could I provide a copy of the proof of delivery from UPS? We did so, and we were about to send yet another overnight copy when I received a "never mind, we found it" e-mail. So hopefully there will be an NPRM to fix the stunning formula error in Section 1.958 of the FCC Rules (the first term of the longitude cosine series has Cos(5ML) when it should be just Cos(ML), where ML is the mid-latitude of the two points having their distance calculated. Since this is the first, and primary, term in the series, it results in a huge error in the formula for the length of a degree of longitude.
Who knows, maybe the Commission will combine the 2007 SBE Petition to change the CDBS from NAD27 to NAD83 with the 2011 H&E Petition to fix Section 1.958; a two-for-one special, if you will.
And I now have a theory where the April 6, 2011, date-stamped version of 2007 SBE petition came from: The second-attempt H&E petition was received by overnight delivery at the FCC on April 6, 2011, and our petition made reference to, and provided a copy of, the 2007 SBE filing, as well as an October 29, 2009, EIBASS letter asking what ever happened to the 2007 SBE filing.