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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 14:23:00 -0400
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On Apr 25, 2018, at 11:38, nathaniel.steele@icloud.com wrote:
So Let me be clear on things, It will cost money to file, if you file without PCN you have no protection from interference and if you do the PCN it cost’s more money but you will get protection from interference? EVEN if the FCC decides to let mobile broadband companies use the spectrum as well? 

Correct.  If you are coordinated then you will have protection from new entrants into the marketplace (or RF space, as the case may be), even if (when) the FCC allows 5G WISPs to jump into the midband range.

Once you’re protected, you have primary [shared] use of the downlink C-band frequencies in your area.  Any other use or user that causes interference to your downlink operation will have to mitigate the interference or modify their setup to protect your interest.


On Apr 25, 2018, at 11:55, Mark Croom <markc@newmail.kinshipradio.org> wrote:
If you're filed as using the band, you're filed as using the band in a given location (even if receive-only). I tend to think PCN was a foolish requirement for downlink stations anyway, they are really more important for stations that are doing uplink. Maybe there's some compelling tech reason I don't understand, but my perception is that the PCN requirement for downlink stations was just a hoop to jump through. 

Look at it this way: If you don’t have protection to use the downlink frequencies and somebody sets up something that causes interference to your primary satellite feed that’s on the air 24x7, you are out of luck and you’ll just have to accept whatever quality of service you end up with, interference and all.

If you’re a top-10 market and your station relies on a sat feed that’s swamped by a WISP or a new 5G service provider, you’ll end up having to figure out a way to remedy the interference (at *your* expense) to continue receiving the satellite signal.

Think about this from a TV station’s perspective: If you’re a local affiliate who’s going to be carrying the Super Bowl and you lose your ability to receive the feed from CBS (2019) due to new interference, do *you* want to have to explain that technical nuance to your viewers (who just jumped off your OTA signal to watch it on satellite or cable instead) or your sales/marketing department?  Bye, bye advertising dollars!

(And hopefully not bye, bye job!)

The same holds true for any radio station carrying satellite content.  It’s better to have the government’s weight and force behind your licensed/registered rights to the RF space than fight the problem on your own.


My perception from the information I've seen so far is that the waiver of the PCN requirement doesn't reduce your protection,

Without a PCN, you have *NO* protection against interference.  That’s the point.


it just allows users to file at a reasonable cost so the Commission, the proponents of the band sharing, and those who choose to comment in the proceeding have more accurate information about who is using the band.

Yep.  You’re paying to participate in the survey.  Don’t you love how the government offers to “help” you by reducing the cost to register your downlink?

Dick Becvar put it well in his last post:  It’s better to go ahead and get the PCN study done if you can do so.  There is absolutely *no* guarantee that it will be possible after July 18, 2018.

And with this notice, good luck getting a PCN done in short order.  I’m sure that Comsearch and Micronet are going to be swamped with orders for new studies.  We had the benefit of a prior coordination done for our approximate location so there were no potential conflicts and it was a streamlined PCN notification that was sent out to all other coordinated entities in our area; it only had a brief waiting period.  A new  PCN does have a longer wait time, as Dick indicated: time is of the essence.

--
Sherrod Munday

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
(nathaniel.steele@icloud.com, 25 Apr 2018 15:38:30 -0000)
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