Broadcast Auxiliary Service, Frequency Coordination, and Database Issues

By Timothy P. Hardy

Introduction
The FCC recently enacted new rules requiring users in the Broadcast Auxiliary Service (BAS) microwave bands to formally prior coordinate their proposed systems before submitting an application for license. This paper will discuss the new prior coordination requirement as well as provide information on the state of the broadcast auxiliary service databases used for this functionboth the FCCs Universal Licensing System (ULS) as well as private industry maintained databases. Accuracy of the underlying database is key to successfully performing detailed interference analysis and coordination, and we will discuss some of the steps necessary to ensure that the BAS data is as accurate as possible. Detailed data analysis and cleansing of the information is required prior to performing analysis and coordination work. We will point out some common errors committed by users when filling out their application forms. While the ULS and FCC processors catch some of the mistakes made, many of the errors get through the system unchecked. These errors can have a serious and detrimental impact on the BAS by putting systems at significant risk of potential harmful interference.

State Of The Database

Anyone who has examined the FCC ULS database in the BAS bands (900 MHz and above) knows that there are problems with the data. It has been widely publicized that the ULS data is missing receive site data on hundreds or even thousands of records in the BAS service. There are several reasons for this omission, chief among them is the old Form 313 did not require the user to provide geographic coordinates of the receive siteit only required the street address. Comsearch has been maintaining a database on the BAS bands since 1978 and while it was sometimes difficult to fill-in the missing data, it was possible to make some informed judgments regarding the data required for detailed interference analysis functions. During the summer of 1978,

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Comsearch spent three months visiting the FCC reference room, pouring through station files to build the initial BAS database. This data was also augmented considerably by a 5"x8" card file that Mr. Steve Linn of the FCC maintained in his office of all licensed and applied for BAS stations. These card files proved to be so valuable that Steve even allowed us to copy them. Since the initial build of the database, we have been receiving copies of all BAS applications and licenses and have updated the database daily with this information. Now that ULS and the Form 601 have been used for the last few years, data accuracy has definitely improved. However, accuracy of the data in the ULS database is wholly dependent on the information supplied by the applicant. Comsearch has been analyzing the data filed and licensed since ULS was implemented and has since found several serious errors that have passed the FCCs referential checks. Some of these errors are quite significant and can have a detrimental effect on successful spectrum management. Listed below are the top ten errors that we have noticed in BAS applications filed in ULS.

Top Ten Errors

10Errors in Coordinates and Ground Elevations
The coordinates and ground elevations of the sites are one of the most critical pieces of information for determining interference with other systems. These point-to-point systems are highly directive and if the wrong coordinates are used, the antenna azimuths and therefore, antenna side lobe information will be incorrect. The ground elevation is critical since all coordinators now use very accurate digitized terrain data to assess the loss (if any) on potentially interfering paths. We have noticed numerous applications for stations where the coordinates match the coordinates on the broadcast stations license or from the FCCs CDBS database. One would think that this would be correct, however, these coordinates are in the NAD-27 datum. ULS requires all coordinates in theNAD-83 datum. The differences between the two datums can range from 50 to 100 meters. The FCC rules require accuracy of the coordinates to within 1". Datum conversion programs are available free of charge on the FCCs Web site: http://wireless.fcc.gov/uls/utilities/nadcon.html. Most of the ground elevation errors that we have noticed were caused by the incorrect entry of the elevation in feet rather than meters. In addition, several applications were filed with the towers overall height AMSL instead of the ground elevation AMSL at the base of the tower.

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9Invalid emission designators

The emission designators used by the FCC are consistent with the ITU. In 1986, the FCC changed from the old format that listed the bandwidth in kilohertz and the modulation with two letters, to an abbreviated listing of the bandwidth and three letters to describe the modulation. When the change was implemented, wholesale changes of the old emission designators were made to fit the new standardized format. Unfortunately some of the wholesale assumptions that were used proved to be wrong in describing the modulation or loading of the signal. For example, in the 7 GHz band an old emission designator for an analog video signal would be 25000F9. When this was convertedto the new format, it was changed to 25M0F9W. However, F9W designates a digital signal, so ULS will require the applicant to enter modulation and bit ratefields that are not required for analog video systems. These analog video licenses should be changed to F8W or F8F to more accurately describe the modulation and loading of the signal.

8Invalid antenna or equipment models

Many of the applications reference the wrong antenna gain and beamwidth for the model specified. This can drastically affect the EIRP and the directivity of the antenna that is used. Another major problem is entering the radio equipment model number in the antenna field instead of the equipment field or vice versa. ULS does not check antenna or equipment model numbers, or whether the gains and beamwidths match the model. It is the applicants responsibility to provide accurate information. All of this information is available from the various manufacturers and most have it available on their web sites.

7Inconsistent data on paths

A vast majority of BAS paths operate in duplex mode. For example, they go from the studio to the transmitter and have another frequency from the transmitter back to the studio. Many of the recently filed applications have inconsistent data between the two licenses on the path. The two sets of coordinates, ground elevations, antenna heights and antenna models on the path must be consistent with each other. The only exception to this would be the very rare instance where more than two antennas are used on a path.

6Inconsistent data on sites

BAS microwave stations are licensed on a frequency-by-frequency basis. BAS stations that have multiple frequencies on the same path or even on many different paths will have separate licenses(and call signs) for every separate frequency. Other ULS microwave services are licensed on a site basis. In these services, one license covers all frequencies and paths coming out of a particular station. The major advantage with this type of licensing scheme is that changes to site-specific
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information only need to be made to one license. These kinds of changes to BAS licenses could require amendments to numerous licenses. We have seen many examples or recent filings for new digital STLs where the coordinates of the studio have been updated by GPS or current mapping. However, other licenses at the same old studio coordinates have not been amended as required.

5Site data (coordinates, ground elevation) not matching ASR data

All towers greater than 200 ft. tall must be registered in the FCCs ASR database. If a transmit station is applied for with a tower height of 200 ft., ULS will require a valid ASR number and the coordinates and ground elevation must match the ASR information (within certain tolerances). However, ULS does not currently require ASR data on receive locations (this is listed on the 601 form but the program does not require it and it is not checked) so receive sites that are applied for with coordinates not matching the ASR are not caught by ULS.

4Polarizations not matching the specified antennas

Many paths have more than one frequency or have frequencies in both directions (duplex operation) where the licensed frequencies are on different polarizations. In these instances, either the antennas must be dual-polarized or there must be separate antennas for both polarizations. Most often, only two antennas are used and they must be dual-polarized.

3Modulation Caution / ATPC Question

Modern digital radios allow the user to easily change the modulation and bit rate by software in the radio or by replacing a card. Licensees are cautioned that FCC rules specify these changes need to be re-coordinated and licensed. Many applicants have been mistakenly answering Yes to the question whether the radio on the path has ATPC (automatic transmit power control). This question only applies to radios that have a specific function that allows them to operate at a nominal level below the maximum and then increase to maximum during fading on the path. If the radio being used does not have this specific function, the answer to this question should be No.-

2Aural Broadcast antenna gains and beamwidths

In the 900 MHz bands it is common practice for the antenna vendors to specify antenna gains in dBd. ULS requires the antenna gain in dBi. Additionally, antennas in this band usually have a much larger beamwidth for horizontal polarization. Applicants are cautioned that using horizontal polarization may result in the antenna not meeting FCC requirements.

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1Incorrect EIRP
This is by far the most prevalent and troubling error found in applications filed since the inception of ULS. We have found about 500 instances where the EIRP listed in the application is obviously wrong since the calculated receive signal level on the paths would be far too low to be reliable and in some instances are below threshold of the receiver. In most instances where this has been found, the radio transmit power has been entered instead of the EIRP (effective isotropic radiated power).This can lead coordinators and new applicants to under-estimate interference cases by as much as30-40 dB. This is especially troubling since we have contacted several hundred licensees to let them know that they are licensed for the wrong EIRP and less than 10% have done anything about it. This lack of attention can lead to serious interference problems that would most likely be their responsibility to clear since they are operating well outside their licensed parameters. Additionally, if the FCC compliance branch inspected the offending system, a serious forfeiture could be levied and the FCC would likely want to inspect all other licenses to see what else may be operating illegally. EIRP is calculated as follows: EIRP (dBm) = TX Pwr (dBm) + Ant Gain (dBi) wg loss (dB) BF loss (dB) Where, TX Pwr = Radio Transmit Power in dBm. Ant Gain = Antenna Gain in dBi. Wg loss = Waveguide loss in dB. BF loss = Branching and Filter loss in dB.

Prior Coordination Basics

After ensuring that the database is as accurate as possible, the next step in the process is to perform a detailed interference analysis to select the frequency, polarization, and antenna performance required for the path. The coordinator should also ensure that the proposed path meets all applicable requirements such as minimum path lengths, maximum EIRP, quiet zones, etc. Once the interference analysis phase of the project has been completed, the FCC rules require the coordinator to forward a detailed prior coordination notice to all potentially affected users. TIA bulletin TSB10-F defines the coordination area for bands below 15 GHz as a circular distance of 125miles and a keyhole distance of 248 miles. The keyhole area is defined for angles 5 of the antennas main beam. The prior coordination process is an iterative process involving both notification and response. All recipients of the prior coordination notice have 30 days (this timeframe can be shortened on a case-by-case basis) to analyze the proposal and respond with any interference problems that they may have found. If potential interference is noted, it is the initiating coordinators responsibility to resolve it. If no response is sent to the initiating coordinator within the 30-dayperiod, he may assume that no interference problems exist and proceed with FCC filing.

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Prior coordination notices (PCNs) are valid for six months from the date of the notice. PCNs can be renewed for an additional six-month period, but the renewal must be made prior to the end of the six-month cycle. FCC application must be made within six-months of the date on the last coordination notice for the path or the FCC will return the application as defective. The FCC filing must include a detailed statement certifying that coordination has been completed and also include a list of the entities that were party to the coordination. If this certification is not included, the FCC will return the application as defective.

Conclusion
The prior coordination process has worked very well in the Part 101 services for over 33 years. Contrary to what you may have heard or read elsewhere, there was no ULS or FCC database back in1971 when prior coordination was first required as the result of Docket 18970. Most coordinators at that time used mylar map overlays and plotted all paths by hand. Using either a slide rule or the first rudimentary calculators, coordinators performed their interference calculations. The private coordination firms began building databases and the data accuracy improved along with the entire prior coordination process. ULS gives the community a significant advantage over the early days of common carrier coordination. The data is not perfect, but it at least provides a starting point. It is imperative for new applicants to make certain that their data is as accurate as possible to ensure that the ongoing integrity of the database is maintained or improved. ULS software will catch a variety of errors but we have shown that it will not catch several that could have a serious detrimental effect on other applicants and licensees.

About the Author

Tim was one of three founders of Comsearch in 1977 and is currently Vice President, Engineering. He was deeply involved in formulating the prior coordination process and personally developed a nationwide database of all common carrier facilities in use at that time. He subsequently developed databases in other commercial frequency bands including, Private Operational Fixed, Cable Antenna Relay, and Broadcast Auxiliary. In addition to his work in the data area, Tim engineered and coordinated thousands of microwave paths for major telecommunications companies and numerous state and local governments. Tim has earned recognition throughout the industry as the expert and historian of microwave and satellite networks in the US. Tim is a founding member of National Spectrum Managers Association (NSMA) and is an NSMA "fellow." He is a Senior Member and past member of the Board of Directors of National Association of Radio and Telecommunications Engineers, Inc. (NARTE).

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