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Re: SBE Regulatory Alert - Apr 23, 2018
To: CRTech <crtech@crtech.org>
Subject: Re: SBE Regulatory Alert - Apr 23, 2018
From: Sherrod Munday <smunday@ieee.org>
Date: Wed, 25 Apr 2018 14:00:14 -0400
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On Apr 25, 2018, at 11:10, Scott Foster <Scott.Foster@SalemMedia.com> wrote:
One comment I had previously seen mentioned that you could send in one registration if your receive dishes were within a certain number of feet of each other, is this true or do we need to file for each and every dish?

I’ll chime in here.  

Where I work, we have 19 satellite dishes located within ~2.5 acres.  

We formerly had a C-band transmit license for our antenna site, but a few months ago I went through the process of converting it to a downlink-only registration because we aren’t doing any transmitting from the site and I wanted to ensure that we were coordinated and protected against interference *prior* to any FCC action (which unfortunately has now been demonstrated).  Thankfully, they processed it just a day before they published the freeze in applications.

I wanted to know the answer to the same question that Scott Foster asked above, so I actually called both our FCC attorney and the FCC’s satellite office and spoke with Paul Blais (Chief, Systems Analysis Branch of the Satellite Division).  I received slightly varying answers, but I chose to go with what Mr. Blais told me (I kinda figured the guy in charge of the satellite division of the FCC knows best what he’s talking about).

In brief: if you only register a single dish, then if you ever remove or replace that dish (unless with an identical model dish and submit a minor modification to amend your registration to reflect the identical replacement), then your registration is moot (null and void) since it was for a dish that no longer exists or is in use at your location.  The registration is tied to the registered dish, not the facilities or site in general.

Paul therefore recommended that *ALL* dishes at a location be listed on the registration form. 

However: I chose to only do a frequency study and request downlink frequency coordination on the *one* smallest dish that is most vulnerable to interference (due to its smallest size (largest beamwidth) and its physical location (highest on the site and therefore more exposed to point-to-point terrestrial links)).  

Since all of our dishes are within several hundred yards of each other, any coordination for the one dish inherently protects the other dishes as well.  (The great circle plot done by Micronet (an alternative to Comsearch) covers the entire state of Tennessee, so I’m not worried about a couple hundred yards.)

If we ever replace that dish or move it, then we will have to go through a frequency study and PCN modification again to continue receiving protection at our site.

If you want to see the results of my recent application that involved a frequency study through Micronet, here’s a direct link to the FCC’s IBFS page showing the mod:

Go to the Attachments menu to see the various things that get attached for a PCN-protected application.

Couple of pointers and/or notes:

1. Get an FRN for your company/ministry/organization.  Don’t use your personal FRN.  When you complete the forms that Mark Johnson previously mentioned, use the organization’s FRN and name, *NOT* your own.  You’re not the applicant.

2. Get the specs on your dishes gathered together.  This one took a while, especially for the dishes that are still functioning but no longer manufactured where we couldn’t find the original tech spec sheets.

3. I did have one error in my forms and submission: I attempted to add the Ku band to our downlink site.  The FCC contacted me after I submitted the forms and clarified that they would issue the license *without* the Ku band included, because they don’t coordinate or care about domestic US-only Ku band usage that doesn’t involve transmission in the Ku band.  On the other hand, if we needed to use International Ku band (that extends beyond the US range of frequencies) this would be a different story.  So, unless you’re using the international Ku band or transmitting (in which case you’d already have a license anyway), leave off any Ku band downlink mention.
Sherrod Munday

Follow-Ups: Re: SBE Regulatory Alert - Apr 23, 2018
(Dave Land <dave@klvv.com>, 25 Apr 2018 18:13:43 -0000)
References: SBE Regulatory Alert - Apr 23, 2018
(Michael Barnes <barnmichael@gmail.com>, 24 Apr 2018 22:40:48 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Terry Cowan <tcowan@knlr.com>, 24 Apr 2018 23:18:55 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(dave allen <crtech-mail@reyware.us>, 24 Apr 2018 23:32:50 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Tom Bosscher <tom@bosscher.org>, 25 Apr 2018 00:15:38 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Gregg Richwine <gmsnrich@live.com>, 25 Apr 2018 03:23:29 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Mark Johnson <linkupsat@icloud.com>, 25 Apr 2018 04:24:39 -0000)
RE: SBE Regulatory Alert - Apr 23, 2018
(Scott Foster <Scott.Foster@SalemMedia.com>, 25 Apr 2018 15:10:32 -0000)
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