Published:  TV Technology Magazine

Issue:  January 5, 1998





Broadcaster Face Additional Spectrum Loss

by Joe Fedele



WASHINGTON, D.C.--Have you seen what the FCC is trying to do with our 455 MHz band?," 

grumbled Marty Faubell, vice president of engineering for the Hearst-Argyle Broadcast Group. 

He's responsible for the technical operations of the third largest non-network-owned television 

station group, representing some 15 affiliates nationwide.

        Faubell was referring to yet another slap to the news gathering and remote broadcast 

capabilities of both TV and radio broadcasters. It seems the FCC is now proposing changes in the 

Remote Pick-Up (RPU) band that could result in additional overcrowding and interference to 

broadcasters.

        The Notice of Proposed Rule Making (NPRM), released on October 14th, would allocate the 

455-456 MHz and 459-460 MHz bands to the Mobile Satellite Service (MSS) on a co-primary 

basis for earth-to-space telemetry on their non-geostationary satellite systems.  The 455 to 456 

MHz portion is now the upper half of the RPU band that is used by TV broadcasters for 

communications, IFB and remote cueing.  Radio stations use the RPU as well to transmit live 

events from the field.  The 459 to 460 MHz portion is currently being used by public land mobile 

operators in non-broadcast applications.

        The FCC docket, number 97-214, would force broadcasters to share the 455-456 portion of 

the RPU band with Low Earth Orbit satellite system operators, also known as the "Little LEOs." 

These satellite systems will use small, inexpensive transceivers to communicate with satellites 

operating at altitudes much lower than those in geostationary orbits. LEO systems plan to employ 

a constellation of satellites, whose potential applications include emergency location services, 

environmental data collection, vehicle tracking, and time-sensitive business and personal data 

communications, anywhere in the world.

        Broadcasters see this new FCC proposal as yet another serious setback for their remote 

capabilities, as many remain angered by the loss of nearly half of the 2 GHz BAS microwave band 

that occurred as a result of the Budget Bill of 1997 (see the September 11 issue of TV 

Technology). 

        Bill Cordell, a registered Professional Engineer and the Frequency Coordinator for spectrum 

below 1 GHz in Houston, is very discouraged by the FCC proposal.  "Even with directional 

antennas, low power, and special sensing equipment and special modulation schemes," he said, 

"broadcasters cannot afford any interference from any other sources. In Houston, errant paging 

transmitters and two-way systems cause us enough interference problems, not to mention the 

bad over-crowding within the RPU band in all metropolitan areas." 

        "How do you resolve interference issues," " noted Faubell, "when you have satellites in 

constant motion. They [the FCC] know that broadcasters have over 25,000 licenses [for use of the 

band] and we use them all the time, every day. It appears that the FCC is not interested in a 

resolution of this matter."

        In fact, the Commission’s proposal is based on international agreements made at the 1995 

World Administrative Radio Conference (WARC-95) where the United States proposed that 

several bands below 1 Ghz, including 455-456, be allocated internationally to MSS.

        The FCC states in the aforementioned NPRM that its primary objectives is to "facilitate the 

provision of efficient, innovative, and cost-effective satellite communications services in the United 

States... [by] promoting fair and vigorous competition in the satellite communications market 

through application of an 'Open Skies' policy that encourages market entry by qualified applicants 

and affords satellite operators maximum flexibility to tailor their offerings to meet customer 

requirements.”

        This Notice is actually a continuation of previous attempts by the Commission, which began 

in 1991, to allocate spectrum for Little LEO operations.  In this proceeding the FCC hopes to 

"develop a complete record on whether to allocate spectrum for Little LEO operations in the 455-

456 MHz and 459-460 MHz bands.”

        Dane Ericksen, a consulting engineer for Hammet & Edison, and chairman of the Society of 

Broadcast Engineers (SBE) FCC Liaison Committee is one of many broadcasters fighting the 

proposal.  "The SBE FCC Liaison Committee has now completed a second draft of detailed 

comments to this matter.  These comments will clearly express to the FCC the very grave 

concerns of the broadcast engineering community concerning any potential damage to the 455-

456 MHz RPU band." The FCC comment deadline was December 1st.

        Like many, Ericksen is agitated with the Commission's proposal and remains firm in his 

conviction that broadcasters must fight back. "The SBE is on top of this matter," he said, noting 

that "broadcasters should not think we have been asleep at the switch," on spectrum allocation 

issues.

        Cordell points out that "the Commission needs to reassess the overall frequency allotments 

and seek a more efficient frequency usage (possibly by re-farming). Specific frequencies need to 

be set aside for RPU services and those frequencies should be considered sacred." 

        "If the Commission wants to charge (bid, auction, etc.) for other special telecommunications 

services, then do so, but do not simply overlay users atop existing users to “double up” in the use 

of frequencies," 

Cordell continued. "There are many other services and frequencies where these services can be 

located."

        Yet, attempts to alter FCC plans may be in vain as the Commission appears convinced that 

sharing the spectrum is a viable means of giving the fledgling LEO communications industry the 

resources it needs to capture a worldwide market.

        The commission stated in its docket that "sharing analyses and spectrum utilization studies 

indicate that these bands [455-456] may have potential capacity for sharing with Little LEO uplinks 

without creating an unacceptable impact on incumbent operations."

        

It continues, "since many auxiliary broadcast remote pickup channels in the 455-456 MHz band 

tend to be used only intermittently and Little LEO transmissions are currently limited to a short 

duration of only 450 milliseconds in the 148-149.9 MHz band, Little LEO systems may be able to 

search the spectrum for unused channels and accomplish their communications without hindering 

incumbent use."

        But no mention was made in the docket of the continuous operational use of the band by 

radio stations broadcasting live events from the field.  And, although the RPU band is the only 

spectrum available to radio stations for such operations, the Commission appears confident that 

LEO communications systems will not pose a problem to broadcasters.

        "Little LEO channel assignment and low power techniques combined with brief message 

duration and geographic separation may be able to protect broadcast auxiliary use," the Notice 

reads. "We note, however, that the signal integrity of broadcast programming material must be 

maintained and that Little LEO operations will not be permitted to cause harmful interference to 

such auxiliary broadcast signals."  

        The Notice also does not specify how such interference would be prevented or what 

recourse, if any, broadcasters would have in dealing with any such instances.

        Since 1995 studies performed by the WRC-95 Informal Working Group (IWG) have analyzed 

the possibility of spectrum sharing.  An IWG study claims that "theoretical assumptions such as 

low traffic-level mobile incumbent usage and that certain engineering techniques, such as the 

Dynamic Channel Activity Assignment System, which have been successfully used to permit Little 

LEO sharing in the 148-149.9 MHz band, may readily be applied to the instant (RPU) bands.

        Companies such as Motorola have countered that RPU bands are "more heavily used by 

incumbent commercial operations than the 148-149.9 MHz band [which] is used by incumbent 

Government operations. Therefore, the issues of spectrum sharing between Little LEO operations 

and incumbent operations in the 455-456 MHz and 459-460 MHz bands are [more] complex."

        Attempts to reach other LEO service providers for comment were unsuccessful. The 

commission sees the development of LEO operations as a major step forward in the evolution of 

global communications services.  The NPRM noted that "studies by Little LEO proponents 

estimate a 'capturable' Little LEO market in North America in excess of 40 million users by the 

year 2000.Ó

        Disappointed, Faubell concluded that, "our spectrum is being encroached on again and I 

think we are all in for another beating.”