Update: Effective Date Set for Registration Requirement for TV Pickup Licenses

Posted on January 30, 2013 by FHH Law

Mandatory registration is one element of FCC's expansion of wireless backhaul opportunities.

If you’ve got a TV pickup license in the 6875-7125 MHz or 12700-13200 MHz bands, you’ll be needing to register your stationary receive-only sites in the Commission’s Universal Licensing System (ULS) in the near future (if you haven’t done so already). Section 74.605, the Commission’s rule requiring such registration will finally become effective April 1, 2013, according to a notice in the Federal Register.

Long in the works, the “new” requirement was actually adopted nearly 18 months ago – back in August, 2011 – as part of the Commission’s overhaul of the wireless backhaul process. That overhaul is intended to make more spectrum available for fixed wireless operations serving as the “middle mile” links that move end-user traffic between cell towers and the core network. The increased spectrum availability is to be accomplished by allowing such services to share spectrum already used by TV pickup licenses in the 6875-7125 MHz or 12700-13200 MHz bands. But effective sharing will require coordination of use of the frequencies, and mandatory registration of receive-only sites will obviously facilitate such coordination.

Of course, it’s been a good idea to register such sites for some time, as we (and our friend and reader, Dane Ericksen) were recommending nearly two years ago. The Commission has permitted ULS registration of TV pickups since 2008 as an optional aid to coordination in the band. But come April, “optional” registration will become “mandatory” registration.

The delay in making Section 74.605 effective is a bit puzzling. Since the rule constitutes an “information collection”, it had to be run through the Paperwork Reduction Act process at the Office of Management and Budget. But according to the FCC’s Federal Register notice, OMB had signed off on the rule back on March 27, 2012. Whatever the reason for the one-year hold-up in making the rule effective, though, the fact of the matter is that we now know that it will be effective on April Fool’s Day. If you’ve got a TV pickup license in the 6875-7125 MHz or 12700-13200 MHz bands and you’ve been dragging your feet as far as registration goes, now would be a good time to get that job done.

Tags: , , , , , , , , , , , , , ,

Time To Doublecheck Your BAS Data In ULS?

Posted on February 7, 2011 by Harry Cole

With FS wireless backhaul stations a strong likelihood, a veteran consulting engineer recommends review of BAS records in ULS – and we second that emotion

Last August we reported on a Commission proposal to make more spectrum available for wireless backhaul linking mobile signals back to the core network. As of yet we haven’t heard anything more on this from the Commission, but it’s a reasonable assumption – particularly given the FCC’s fixation on all things wireless – that all or most of its proposals will be adopted eventually, probably sooner rather than later. 

One central element of the proposal would open up the 6875-7125 MHz and 12.7-13.2 GHz bands for backhaul on Fixed Service (FS) stations. But heads up – those bands are currently used for Broadcast Auxiliary Services (BAS), including studio-transmitter links. If new FS stations are allowed into those bands, they would presumably be required first to prepare and submit coordination studies to demonstrate appropriate protection to incumbent licensees, including BAS stations. No problem so far.

But as our friend Dane Ericksen, a well-known and highly-respected consulting engineer, has pointed out, the FS coordination efforts will be based on information currently available in the FCC’s ULS database. And, according to Dane, that information is in many instances less than complete and accurate. He cites figures that are pretty amazing.

According to Dane:

Of all 7 GHz TV BAS fixed-link records: 15 percent of all 7 GHz TV BAS fixed-link records had missing receive-end coordinates; 37 percent had missing receive-end antenna height; and 51 percent had missing receive-end antenna make and model information; and

Of all 13 GHz TV BAS fixed-link records: 13 percent had missing receive end coordinates; 35 percent had missing receive-end antenna height; and 50 percent had missing receive-end antenna make and model information.

So if an FS applicant were to undertake coordination based on existing partial ULS data, it’s at least possible that it would succeed in obtaining authorization that could cause interference to an incumbent BAS facility.

How such a problem would get resolved is not clear at this point. But how such a problem can be avoided is incredibly clear and incredibly simple: BAS licensees can and should take a few minutes, now, to confirm that the ULS database accurately reflects the facilities they are currently utilizing. (Dane’s article provides a useful checklist of Things To Do along those lines.) If errors or omissions in the data pop up, in most instances they should be correctable through routine processes (e.g., an application to amend the entry).

By making sure that your licensed facilities are accurately reflected in the database, you will be doing yourself, other potential spectrum users, and the Commission a very useful service.

We at Fletcher Heald would be happy to help out in the process, should you request our assistance.
Tags: , , , , , , , , , , , ,

New Consolidated FCC Database System In the Works

Posted on April 12, 2009 by Paul J. Feldman

A CommLawBlog scoop: Agency brainstorming on possible "consolidated licensing system"

Word on the street (actually, word around the FCC) is that the Commission is embarking on a quest for what some might view as the bureaucratic equivalent of the Impossible Dream: an Uber-consolidated on-line licensing system to unify the balkanized collection of existing systems currently in use. This would mean “hello” to a new “Consolidated Licensing System” and “see ya” to the Universal Licensing System (ULS), OET’s Experimental Licensing System, the International Bureau’s “MyIBFS”, and the Media Bureau’s (apparently mis-named, or at least prematurely named) “Consolidated Database System” (CDBS). At this point, it’s not clear whether any other systems – such as the FCC’s tower registration operation – would also be included.

On-line filing – whether it’s used for license applications, routine reporting, or other requests or notifications – is obviously a Good Idea. It streamlines processes, permits easy on-line access to filed materials, facilitates cross-checking and searching, pushes the initial inputting burden onto the applicant (rather than the FCC’s staff), saves paper, and generally makes life better. Oh sure, there have been the occasional complaints about the user-friendliness of, say, ULS (née 1998) and CDBS (née 2000). And yes, some users have carped about how you can’t simultaneously search the various databases for information about a particular entity, or a particular location, etc.

But maybe, just maybe, the FCC has heard those cries of despair and frustration.

Recently the Commission convened the first of a series of brainstorming sessions – complete with “facilitator” and scribe – to begin the process of designing a new “Consolidated Licensing System” (CLS). Since this project (which as far as we know has not been formally announced) seems to be in the very early development stage, its contours are still a bit ill-defined, at least to us in the outside world. But having attended the initial brainstorming exercise, I can say that it looks like the Commission intends to do everything it can to Get It Right this time around: that is, the goal appears to be a full consolidated licensing database encompassing all spectrum users subject to the FCC’s authority, a system designed with maximum input from private sector users as well as the FCC's own staff.

The initial brainstorming session included representatives of Part 90 frequency coordinators – who routinely submit hundreds of applications into ULS every week – along with a boatload of FCC staffers. The latter made a considerable effort to solicit criticisms, praise and suggestions from the former. Word at the table was that similar meetings will be held in due time with other user constituency groups. Keep your ears, and your schedules, open.

So will we be seeing a spanking new and efficient CLS this year? Uhh . . . no. This is a vast, long-term project with a lot of moving parts (not to mention a cost likely measurable in the bazillions).  From the tenor of comments at the first meeting, it appears that, in the best case scenario, we might start to see some initial elements of the CLS phased-in toward the end of 2010.  Down here in the CommLawBlog.com bunker we are hopeful, but we won't be holding our breath.

As a practical matter, though, the longer the Commission takes to craft the CLS, the better off we all will probably be. With about a decade of experience with ULS and CDBS under our belts, we’re pretty much used to the various quirks of those systems, and the Commission has ironed out many more along the way. So we should be able to get by for a little longer with the status quo, particularly if the additional time is spent productively, honing the new CLS to maximize its user-friendliness as well as its bottomline bureaucratic utility.

While the Commission’s seeming reticence to go public with its plans thus far may suggest that the public is being kept away from the planners, my personal observation flatly contradicts that suggestion. Indeed, the staffers at the brainstorming session I attended were emphatic in their efforts to solicit maximum input from those of us in the private sector. The approach the Commission is taking is somewhat novel (at least for the Commission), so it makes sense for it to dip its toe in the water before jumping in all the way.

So be on the lookout for further opportunities to toss in your two cents’ worth, and be sure to have your thoughts ready when those opportunities arise. Informed and constructive suggestions from the public will be perhaps the most valuable contribution we can make to this project.
Tags: , , , , , , , ,