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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: Thu, 26 Apr 2018 13:57:02 -0400
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In-reply-to: <dc3ddb89-2d0e-f894-2583-7107271ea680@whwl.net>
References: <CAAthHBZBXWTdLRxSXhgciKCOeariGQkiSN0xgHZFbMMgCUDEoQ@mail.gmail.com> <e058b127-4f6d-941c-9de0-c4a6d04efdff@knlr.com> <332291e1-422a-08a0-9861-d6fffe8a9116@reyware.us> <835ec0ff-912d-a1e7-99a8-9b3306941381@bosscher.org> <DM5PR20MB19778FBA65414B3A6691B8E8A48F0@DM5PR20MB1977.namprd20.prod.outlook.com> <005101d3dcab$6fb668a0$4f2339e0$@icloud.com> <EEBEE694-91EC-40D3-9988-821E4F997AEF@ieee.org> <CAA8ua=wmQLZhaTrBpHn9Pj0o8mwMjw9MnPS=H7GXBevmvHu-wQ@mail.gmail.com> <96E5AAA5-0785-4F7F-A0B4-9E7FAD4E2756@ieee.org> <008c01d3dcc1$7cfc1350$76f439f0$@icloud.com> <dc3ddb89-2d0e-f894-2583-7107271ea680@whwl.net>
On Apr 26, 2018, at 13:17, Andy Larsen <andy@whwl.net> wrote:
This was exactly my thought. I like the idea of registering to let the FCC know how many users are out there and *depend* on C-band satellite to make the communications networks work. However, my gut feeling is that the FCC will go ahead with this regardless. There are many more wireless users begging for more data than there are broadcasters. So I agree...paying to say "yes, we're here" so the FCC knows how many users it's ignoring, but offering no protection, I can think of better ways to spend the money. It seems like I've just flushed $435 down the bureaucratic hole.

Recognizing that no one has a crystal ball, let me throw out a couple of questions...

If I register now and the FCC goes ahead with this stupid idea, could I then do a PCN and *add* it to the registration?

There’s no guarantee that you’ll be able to add a frequency study after the 90-day window.  They may decide to grandfather in all previously-protected sites and say “tough luck” to any latecomers (which in practice would mean that you *might* be able to subsequently get protection for a certain range of the C-band downlink, *excluding* whatever the FCC decides to carve out and donate to the big-pocket ISPs/cellular carriers).

That’s about as clear as my murky-view crystal ball shows here...

Since I'm already an existing user will I have any kind of priority to do that, or have I now lost any hope of having protection if the move is made and I don't have a coordinated downlink when that decision comes down?

As mentioned, once the 90-day window is over, all bets are off.  As you might have figured out based on the FCC’s action on April 19, they may not provide you any advance notice of a future action.  You’ll just have to read between their lines to try to guess what they’re going to do next.  

I guess the big question I'm really asking is this: As the manager of a small non-profit ministry, help me understand why this is a good use of resources.

You have a good grasp of the most important question.  Let me try to give you one perspective on it:

It all boils down to risk vs. reward.  As the manager of your station and ministry, you’ll have to assess the likelihood that the FCC might take a chunk of C-band away from satellite use and allocate it to terrestrial use (Wireless ISPs) instead, and then you need to assess the potential impact such a move might have on your broadcast operations if a WISP moves into your area and starts creating interference to your non-protected downlink.

One way to look at it is like buying insurance.  Do you have liability or fire insurance on your building?  Probably.  You hope to never need it, but the potential cost of doing business without it is so much more significant than paying the premiums that it makes sense to carry the insurance.  

This entire “scheme” (as some might call it) of doing a frequency study and submitting it to obtain interference protection is your insurance that gives you the peace of mind to sleep soundly knowing that your station would have priority if some newcomer wants to start transmitting in your area.   In reality, it’s not that much different than the FCC license you hold to transmit over the air: it affords you the right to be heard within your contour without interference.  This is just on the other side of your operations: it’s getting the content *in* the door instead of pushing it *out* to the listeners.

As Tom Bosscher previously wrote, he was able to protect his downlink when someone wanted to set up shop on a protected frequency in his area.  Without protection and priority, he would have had to accept whatever interference they might have caused.

Which position do you want to be in when it (interference and/or a WISP) comes?  

For my employer, satellite is important enough that we simply couldn’t afford to take the chance that our primary (and most reliable) means of getting content could be adversely affected without having any remediation options.  You’ll have to make that determination for your ministry; we don’t have the insight to know the value of satellite to your organization.

On the financial side of things, you might at least have the option of asking listeners to pitch in to help get you over this hurdle.  It’s a one-time fee that’s steep for a non-profit ministry, to be sure, but all it takes is a handful of listeners who care enough to chip in $20-50 each and you’ll get there soon enough.  (In our case, the cost for the frequency study wasn’t due until the final report was issued.  YMMV.). Then just add a small amount to your operating budget to renew the license/registration when it comes up for renewal, and you won’t have to worry about it again.

--
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)
Re: SBE Regulatory Alert - Apr 23, 2018
(Sherrod Munday <smunday@ieee.org>, 25 Apr 2018 17:19:23 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Pat Wahl <pwahl@wwib.com>, 25 Apr 2018 17:44:04 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Sherrod Munday <smunday@ieee.org>, 25 Apr 2018 17:58:42 -0000)
RE: SBE Regulatory Alert - Apr 23, 2018
(nathaniel.steele@icloud.com, 25 Apr 2018 18:16:18 -0000)
Re: SBE Regulatory Alert - Apr 23, 2018
(Andy Larsen <andy@whwl.net>, 26 Apr 2018 17:17:17 -0000)
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