LMR Users Urge FCC to Change Rules Around TV Protections in T-Band
Monday, February 14, 2022 | Comments

Several communications organizations and T-band users came out in support of a Land Mobile Communications Council (LMCC), now called the National Wireless Communications Council (NWCC), petition to the FCC to make rule changes to the T-band spectrum.

The National Association of Broadcasters (NAB) meanwhile submitted comments urging caution should the FCC choose to move forward with any changes to protections to the TV stations.

In the Middle Class Tax Relief and Job Creation Act of 2012, Congress mandated that the FCC auction the T-band spectrum by 2021. To preserve the spectrum following the passage of that act, the FCC placed a freeze on any new applications or modifications in the band.

At the end of December 2020, Congress repealed the mandate, and shortly after, the FCC began the process of lifting the freeze. Last June, the NWCC filed its petition asking the FCC to address issues involving TV station interference protections in the band.

“The petition recommends a common-sense correction to Federal Communications Commission (FCC) Rule Section 90.309 governing the protection of television stations by land mobile systems operating in the 470 – 512 MHz band (T-Band),” the NWCC said in comments supporting its petition. “The proposed change reflects the migration of television stations from analog transmission on which the rule currently is based to digital transmissions (DTV) pursuant to the so-called DTV transition.”

The NWCC noted that TV stations had been required to broadcast exclusively in digital format since 2009.

“Updating the rule as proposed would represent sound spectrum management policy,” the NWCC said. “It would maintain appropriate protection to full-power and low-power television stations from land mobile stations, but would recognize, as do the revised Part 73 rules, that DTV stations have superior interference immunity. The petition also proposes edits to the Part 90, Subpart L rules to reflect the elimination of certain radio services and the fact that no T-Band spectrum has been or will be made available in Cleveland, Ohio or Detroit, Michigan due to Canadian considerations.”

The NWCC said its member organizations represent a large number of organizations that represent T-band licensees and noted that many of these licensees are just now being able to modify their system following a nearly decade long freeze on activity in the band.

“After an almost decade-long freeze, incumbents now are permitted to modify their systems but remain subject to a rule that no longer reflects the reality of the spectral environment. The NWCC urges the FCC to adopt a notice of proposed rulemaking consistent with the petition as expeditiously as possible.”

The NWCC said that making changes to the band would allow for continued protection against interference to TV station and allow organizations to maximize use of the band.

“T-band remains a critical spectrum home for land mobile licensees in eleven of the nation’s largest cities,” the NWCC said. “It supports multiple public-safety operations in many markets, refineries and other facilities that provide essential services to the American public, as well as commercial systems on which the wide-area dispatch requirements of a broad variety of business and industrial entities are addressed. The rule changes proposed would ensure full interference protection for co-channel and adjacent channel television stations while allowing land mobile users to maximize the utility of the band in meeting their communications needs.”

The National Public Safety Telecommunications Council (NPSTC) said it fully supports the NWCC’s proposal for rule changes to the band and noted the thoroughness of the proposed rule changes in the petition.

“The commission is fortunate that the LMCC has done so much of the work required to initiate the rulemaking proceeding it has requested,” the NPSTC said. “The LMCC petition is comprehensive and includes the background leading to the request, specific recommended changes to the rules and the rationale for the recommendations provided. The petition even provides a succinct summary on the history of the T-band spectrum sharing that began in the 1970s. This summary should be helpful as well in crafting the NPRM.”

NPSTC argued that this is a strong need for TV spectrum to be shared in order to support public safety and industrial/business operations.

“Moving forward with the rules changes as the LMCC has requested will serve the public interest and can result in greater spectrum efficiency,” NPSTC said.

The Enterprise Wireless Alliance (EWA), a member of the NWCC, said that the changes to the rules were long overdue.

“It is unfortunate that this change was not implemented on the FCC’s own motion in conjunction with the Part 73 rules changes that updated the criteria for interference between digital television stations,” the EWA said in its comments. “These changes were adopted well before Congress enacted the so- called T-band mandate to reclaim and auction that spectrum. Had that been done, a modified rule would have been in place last year when the FCC finally was able to terminate its T-band application freeze for incumbents upon repeal of the T-Band mandate. Instead, until completion of what typically is a multi-year rulemaking process, T-band applicants, many of which are EWA members, must comply with a rule that protects television station contours as though they still were operating in NTSC format even though they are required to operate in ATSC format. In the interim, television stations are receiving greater than necessary protection while, conversely, affected land mobile systems are not able to derive maximum use of T-band spectrum.”

EWA noted that the issue is made worse by the fact that some TV stations LMR licensees must protect are no longer operational or have digital channels that are significantly separate from the T-band spectrum.

Fisher Wireless Services Inc. (FWSI), which operates a trunked dispatch system in the Western U.S., said that the T-band freeze was challenging on it because it prevented the company from “modifying T-band channels in its frequency plan in response to customer requirements.”

“As a long-term T-band licensee, FWSI is aware of its obligation to protect co-channel and adjacent channel television stations,” the company said in its filing. “It is prepared to do so. But, as the LMCC petition points out, the current rule requires protection of their analog contours, even though all protected television stations have been required to convert to digital format. Modifying the rules to reflect that change may permit some greater utilization of T-band spectrum by land mobile licensees without diminishing their protection requirements with the FCC’s interest in promoting intensive use of all spectrum.”

Meanwhile, the NAB filed comments urging the FCC to proceed cautiously with any changes to the rules because of how it could impact TV stations.

“The changes LMCC proposes could have the practical effect of increasing instances of harmful interference between television stations and land mobile operations in the T-band by allowing television stations and land mobile operations to operate in closer proximity to one another,” the NAB filing said. “However, as the commission is well aware, there are occasional complaints concerning interference issues between television stations and T-band land mobile operators under the existing rules, including from LMCC itself.”

The NAB said that allowing LMR and TV stations to operate closer to one another in the T-band could lead to this interference happening more often.

“Indeed, given that land mobile operations in the T-band could well be the victims of interference more often than television stations, it is unclear why LMCC believes it to be in its interest to seek the changes it proposes,” the NAB said. “Accordingly, the NAB strongly urges the commission to exercise caution in considering any changes to the existing rules governing T-band operations, and to adopt any changes only following the development of a fulsome technical record that confirms such changes will not materially increase the likelihood of harmful interference.”

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On 2/16/22, Jim Hopper said:
I am the license of many Tband channels in the Dallas area. We use channel 16 of the TV spectrum. For years TBand and UHF TV co-existed in harmony and only a few times a year did we get any interference. We now have a new TV station in Bryan TX which is 150 miles from Dallas. If you do an interference calculation with anyone s software you will come up with no interference. Yey we receive high levels of signal -70db quite often from this station. Not even a mobile unit can be used during the interference times which is 2 or 3 times a week on average. My wish is that the FCC would get the TV group and Radio group together and solve our problem. It is obvious to me that a 100watt TBand radio station in Dallas at 266 meters AAT with a 2.5khz deviation probably wouldn t cause a TV in Bryan TX much problem. But when you take a 500 meter AAT tower in Bryan TX with a 6mhz bandwidth and fill it with a 685kw transmitter we might get some interference. And the FCC says they should check in to the fact that my micro station might interfere with Bryan KBTX.
FCC please fix my problem


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