Key Provisions of WCA/NIA/CTN Key Provisions of WCA/NIA/CTN ProposalProposal

Presented by Todd D. GrayPresented by Todd D. Gray

February 18, 2002

• New Band Plan

• Technical Rules for MBS

• Technical Rules for UBS/LBS

• Transition Process

• Other Elements

Key Provisions of WCA/NIA/CTN Proposal

New Band Plan

• Contemplates 3 principal band segments:– Middle Band Segment (MBS)– Lower Band Segment (LBS)– Upper Band Segment (UBS)

• Contemplates 2 “Guardband” Segments:– Transitional Bands J and K

• Retains Current I band with changes

The Old and New BandplansThe Old and New Bandplans

A1B1A2B2A3B3A4B4C1D1C2D2C3D3C4D4E1F1E2F2E3F3E4F4G1H1G2H2G3H3G4I

A1A2A3B1 B2 B3C1C2C3 D1D2D3 J A4B4 C4D4E4 F4 G4 K E1 E2 E3 F1 F2 F3H1H2H3G1G2 IG3

WCS/PCS-like licensing

TDD or FDD upstream

Cellular-friendly technical rules

WCS/PCS-like licensing

TDD or FDD downstream

Cellular-friendly technical rules

MDS-like licensing and

technical rules

Primarily high power

downstream

2500 MHz 2566 2572 2614 2620 2686 2690

New Band Plan

New Band Plan – Mid Band Segment

• “MBS” Intended primarily for Video Services

• Big-Stick, High-Power, One-Way• 7 Channels @ 6 MHz (4th channel in each

group)• Will reside at current Channels C3-E2

(C3, D3, C4, D4, E1, F1, E2)

New Band Plan – Lower/Upper Band Segments

• “LBS/UBS” Intended for two-way digital services

• Low-Power, Cellularized, Two-Way

• Contiguous channels in each Group

• LBS: 12 channels @ 5.5 MHz

• UBS: 12 channels @ 5.5 MHz

New Band Plan – Transitional Bands

• J Band – 6 MHz drawn from A, B, C and D licensees

• K Band – 6 MHz drawn from E, F, H and G licensees

New Band Plan – I Band

• Existing ITFS response channels at 2686-2690 MHz, As now, except de-interleaved

Technical Rules for MBS• Will rely on traditional D/U interference ratios• 45 dB co-channel/0 dB adjacent channel for

analog• 32 dB co-channel where protected station is

digital• Prior approval with streamlined FCC process

for facility changes

Technical Rules for LBS/UBS

• Goals: Limit interference and maximize flexibility for technical changes

• No FCC approval required for technical changes

• Relies on power restrictions at boundaries of each licensee’s GSA and spectral masks limiting out-of-band emissions

Transition Process

• Relies on Geographic Service Areas – GSAs

• Modifies licensees’ PSAs by splitting overlap areas

• Creates exclusive areas of service for each licensee

Transition Process – Timing

• No specific deadline for transition – timing is determined by “Proponent” seeking to transition market at its expense

• Daisy Chain Effect – Proponent in Market A may have to transition nearby Markets B, and C etc.

Transition Process

• Pre-Transition Data Request• ITFS Licensee Response• Decision on whether to proceed• Transition Notice• Transition Plan• Acceptance or Counter-Proposal

Transition Process

• In event of Licensee Acceptance:– Transition Proceeds in accordance with transition Plan at

Proponent’s expense• In event of Counter-Proposal, Proponent can:

1.Accept counter-proposal and proceed 2.Invoke dispute resolution and wait for decision 3.Invoke dispute resolution and proceed based on

Counter-proposal – Mutual Risks….

Transition Process – Safe Harbors (Simplified)

#1: MBS Channel uses same transmission parameters as ITFS licensee’s current ITFS video channels

#2: Video programming has to be on ITFS licensee’s own MBS Channel(s) (no channel shifting)

#3: To accommodate multiple program tracks, Proponent may provide multiple analog MBS Channels or digitize a single MBS Channel

Transition Process – Safe Harbors (Simplified)

#4: Shared ITFS groups – share MBS/UBS/LBS channels pro rata in absence of agreement

#5: Video at multiple transmit locations has to be accommodated at those locations

#6: Disruption to ITFS operations should be minimized (7 days or fewer)

Transition Process – Safe Harbors (Simplified)

#7: Proponent can require filters on MBS transmitters to avoid interference

#8: Additional transition time will be allowed in markets that have an operating commercial video system

#9: ITFS STLs can be replaced by UBS, MBS or other suitable microwave facilities

Other Proposal Elements (1)

FCC to resolve old 1995 MX applications for new stations by auction (as required by Communications Act) after final settlement opportunity

Other Proposal Elements (2)

All remaining ITFS spectrum licensed by FCC on basis of Basic Trading Areas (BTAs) on channel group basis. In event of MX applications, resolve by auction

Other Proposal Elements (3)

Consent process for converting the MBS portion of band to low power, two-way operations where there is no remaining video need in a market

Other Proposal Elements (4)

Process for pro rata reimbursement of Proponent in a market where later commercial operators use channels transitioned at the expense of the Proponent

Other Proposal Elements (5)

FCC urged to suspend construction deadlines for individual ITFS facilities. FCC also urged to grant renewal to any ITFS station where the station provided “substantial service” during the preceding license term.

Dow, Lohnes & Albertson, PLLC

1200 NEW HAMPSHIRE AVENUE NW

WASHINGTON DC 20036

TELEPHONE 202-776-2571 tgray@dowlohnes.com

www.dowlohnes.com

Todd D. Gray