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Re: So about C-Band registration Form 312 and E47...
To: CRTech <crtech@crtech.org>
Subject: Re: So about C-Band registration Form 312 and E47...
From: Michael Barnes <barnmichael@gmail.com>
Date: Thu, 14 Jun 2018 22:57:04 -0700
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Here is Sherrod's post:

Sherrod Munday <smunday@ieee.org>
Apr 26
to CRTech
First of all, kudos and thanks to Mark for passing this excellent writeup to the list.  I’m sure it will be very helpful to many.

I did have a few comments, having just gone through this process (for the first time) within the last few months myself.  See my notes in-line below.

On Apr 26, 2018, at 08:56, Mark Johnson <linkupsat@icloud.com> wrote:
> Here is additional information on C-band an Form 312. This is from SES.

To clarify one thing:  All new applications *must* be submitted electronically by filling out forms directly on the FCC’s web site.  The downloadable, fillable form-ready Form 312 PDF that you can download is **outdated** (per Paul Blais of the FCC’s Satellite Division).  It’s still online only because it would take a [literal] act of Congress to modify that form and change what’s published. 

Skip the PDF and go straight to the site as referenced in the SES instructions.

> On April 19, 2018, the FCC instituted a freeze on applications for new receive-only earth stations in the conventional C-band (3700-4200 MHz) but allowed existing earth stations to be registered until July 18, 2018.  The steps for registering a receive-only earth station during this window are as follows:
> 1.    Complete FCC Form 312 Main Form and Schedule B online at the FCC’s Website. 
> ...
> (d)    When you get to the Form 312 main form screen, fill in the required information using the attached sample “Registration of a New C-band Receive-only Earth Station” as a guide.  Under Item 22, check both items “Using U.S. licensed satellites” and “Using non-US licensed satellites.” You will then also need to check “Yes” in response to Item 42a and specify “Permitted List” in response to Item 42b.
You may not want to select “Using non-US licensed satellites.”  This could trigger additional documentation requirements (or follow-up contact from the FCC) clarifying which *specific* international satellites you need to use at your location.  If you’re not using any international satellites, it would be best to only select the “Using U.S. licensed satellites” option.  (Per my contact at Micronet and FCC.)

Further point of clarification:  Unless you are transmitting from your earth station to a satellite for reflecting back to the US, then you are not using a “non-U.S.-licensed satellite to provide service in the United States” (question 42.a).  For a Receive-Only application, this question is basically moot.

> Items 30 through 33 should be answered “N/A.”  In Item 43, you should specify that you are providing coordinates in WGS84 format, as indicated in the sample.
I submitted my application using NAD83 coordinates with no problems.  Google Earth (plus information from our original construction survey and a tape measure) provided accurate NAD83 coordinates, and the FCC didn’t have any issues with my submission.

> In addition, because the FCC’s freeze decision includes a waiver of the requirement to file a coordination report, you should check yes for item 39
This seems to reference the incorrect question.  Item 39 refers to the applicant being a party to a felony and/or illegally monopolizing the airwaves (question 39 refers to #37 and #38).  Check me on this, but I think this may have been intended to refer to item 35 (Does the Applicant request any waivers or exemptions from an you the Commission’s Rules?).  Just read each question carefully and figure out (from prior information posted to this list) where you need to indicate that there is no frequency coordination report (if that’s the direction you choose to go, understanding that there would be no protection afforded if your registration is approved).

> (g)    Click on the button marked “Antenna” and fill in the required details using the sample form as a guide.  Remember to click on “Validate” to make sure your inputs are saved.  Note that the input power and total EIRP fields should be left blank since this is a receive-only earth station.
You can also put 0 (zero) into the fields for input power and EIRP.  (Again, per Paul Blais.)

> Click also on the “Antenna Gain”, “Frequency”, “Frequency Coord” and “Particulars of Operation” buttons to fill in the required information about your antenna and the receive frequencies you want protected. 
For C-band downlink, use the entire range of 3700 - 4200 MHz to protect the entire spectrum.  Do *not* just use the center frequency of any single signal that you currently take.  You want to be protected (or at least registered) to be able to use anything in the entire band in case (or “when”) your primary satellite signal has to be changed for whatever reason.

> When you click the “Frequency Coord” button, you will be asked some information about the eastern and western-most satellite orbital locations the antenna points at.  Generally, for C band  dishes receiving video or audio programming distribution, the range is 60°W – 143°W.  However, if you are receiving from a satellite further east than 60°W, please extend the coordinated arc to include the actual satellites with which you are communicating.
My contact at Micronet informed me the that the FCC tends to yellow-flag applications with Elevations set to lower than 20 degrees above the horizon.  In our case, even though we’ve picked up signals lower than that in a few specific instances, I chose to set my orbital arc coverage to the satellites that were just right above 20.0 degrees elevation for the east and the west.  This way, I have protection pretty much from horizon to horizon (as the FCC sees it).

> Under “Particulars of Operation,” the typical emission designator for digital signals is 36M0G7W.
Beware: it’s a complicated thing to figure out the correct emission designator.  Consult with your FCC lawyer or frequency coordinator to confirm, but I spent quite a while digging into figuring out which designator to use to accurately represent the services we use at our downlink.  I ended up carrying forward and re-using the prior designator of 8M20G7W because that’s representative of what we formerly used at our uplink.

Note that the combinations of letters and numbers form a matrix of options that include things like SCPC/MCPC, analog vs. digital, voice vs. data, bandwidth/data rate used, etc. so you want to get this right.  Even though your narrative (in the description text boxes) elsewhere will specify video/audio/data etc. in plain English terms, I personally have a hunch that this technical designator is the official reference if it ever gets questioned. 

Do your homework before just taking SES’s default value to ensure it’s right for your operation.

>     Multiple receive antennas at a site that are within 1 second in latitude and longitude can be filed as part of a single registration.  If all antennas are the same model, just indicate the quantity in item E29 on the Antenna page.  To add antennas of different models, click on the “Add” button at the bottom of the Antenna page.
If you do have more than one model of antenna at a site and you register them all on the same form, be sure to enumerate the frequencies used (3700-4200), polarization used (Horizontal *and* Vertical), dish gain (dBi at a certain frequency - usually found in the mfr’s tech specs), etc. for *each* dish.  You’ll end up taking longer to do the single application but when you’re done all of your dishes and their downlinks will be registered together.

It’s a lot of steps to go through, and there will be lots of “Didn’t I just do this for the other dish?” thoughts, but just remember, the government likes duplication of efforts.  At least we aren’t having to fill it out in triplicate on 5-layer carbon paper anymore.


Additional notes:

Schedule B (Technical and Operational Description) form:

* E15 (2-degree compliance):
  This question asks “...do(es) the proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a)”. 

If your dish is ancient (manufactured before 1983 -- or old stock sold after that date) or unidentifiable due to lack of documentation, you will likely not be able to register it as you cannot demonstrate compliance with 2-degree spacing.   For further information, see question #6 at https://www.fcc.gov/research-reports/guides/frequently-asked-questions-faq-processing-earth-station-applications

Furthermore, question #7 at the same URL elaborates:
"Any proposed earth station that does not operate in the conventional C-band or the conventional Ku-band or does not meet the two-degree spacing technical standards is considered to be “non-routine” and is evaluated on a case-by-case basis to determine if the earth station can operate without causing unacceptable interference in a two-degree orbital spacing environment and if grant of the application would be in the public interest.”
If your dish is not 2-degree compliant you should count on a delay in processing your application, and/or you should plan to have your application denied. 
If this is the case, you frankly need to seriously question why you shouldn’t replace your dish with a modern 2-degree compliant (Section 25.209(a)-compliant) dish.  Your signal will be better once you’re on a new dish.

* E20 (FAA Notification regarding lighting requirements on antenna structures):
In our case, because the dish antennas were sheltered/surrounded by buildings and/or geographical features that are higher than the dishes, we did not need to have any lighting on the dishes even though they were higher than the maximum allowed height for unlit antennas.  This also may be moot because the dishes were not new construction or modifications (they were all preexisting) but we figured it would be better to cite chapter and verse as to why we didn’t need to light the dishes.

Here’s the language we used in our filing; this went into a simple Word attachment that was submitted with question E20:

Although the antenna height above ground level for earth stations range from 3.8 meters to 7.2 meters, FAA notification is not required pursuant to the shielding provisions of Section 17.7(e)(1) of the Commission’s rules, 47 C.F.R. § 17.7(e)(1).

Specifically, the earth station dishes are shielded by adjacent trees and buildings of greater heights as demonstrated in the included photographs. Accordingly, FAA notification is not required per Section 17.7(e)(1).


Embedded within that Word document were a pair of photos showing the ground-level and overhead views of our site to demonstrate that the trees and buildings around the dishes are higher than the dishes themselves.


If you follow the information that’s been posted thus far and you can dig out the tech specs for your 2-degree compliant dish, you’ll be able to do the registration yourself.  That being said, you should definitely run the completed forms by your lawyer/broadcast attorney prior to actually submitting the application just to ensure that you’re doing it correctly. 

If you choose to coordinate the frequency usage to gain protection, contact the folks at either Comsearch or Micronet (the company we used, and they were extremely helpful to this first-timer) and inquire about getting a C-band downlink coordination study done for your site.  They’ll be able to guide you in the process and will provide the necessary docs for submission to the FCC along with your application.

I hope this helps!

Sherrod Munday

On Thu, Jun 14, 2018 at 7:55 PM, Cameron Beierle <manager@kacs.org> wrote:

…Which makes me wish I still had Sherrod’s post.






From: Ron Huckeby [mailto:huckebyrj@gmail.com]
Sent: Thursday, June 14, 2018 6:37 PM
To: CRTech
Subject: Re: [CRTech] So about C-Band registration Form 312 and E47...


I think Sherrod addressed the emission designator in a post last month. 

Ron Huckeby, CBRE
Broadcast Engineer
Butte, MT
406.491.4998 Voice & text


On Thu, Jun 14, 2018, 5:41 PM Cameron Beierle <manager@kacs.org> wrote:

Working my way through the registration form, and encountering questions I’ve never had to deal with before.  One is E47 Emission Designator.  The code to enter is based on the Carrier Size…..Which I have no idea about, nor where to get it.


So, anyone using the AmbOs system on your C-Band dish and/or who has already determined the Carrier Size, please shoot me an e-mail and let me know where to find the details or what the correct code is for this box on the form.


This is one question…


I’m sure there will be more! L




Cameron Beierle

General Manager

KACS-KACW-KBSG Family-Friendly Radio

Chehalis Valley Educational Foundation

SW Washington’s family radio service

2451 NE Kresky, Unit A

Chehalis, WA  98532




Follow-Ups: Re: So about C-Band registration Form 312 and E47...
(Sherrod Munday <smunday@ieee.org>, 15 Jun 2018 13:18:24 -0000)
References: So about C-Band registration Form 312 and E47...
("Cameron Beierle" <manager@kacs.org>, 14 Jun 2018 23:41:03 -0000)
Re: So about C-Band registration Form 312 and E47...
(Ron Huckeby <huckebyrj@gmail.com>, 15 Jun 2018 01:37:01 -0000)
RE: So about C-Band registration Form 312 and E47...
("Cameron Beierle" <manager@kacs.org>, 15 Jun 2018 02:55:11 -0000)
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