In the Matter of An Inquiry Relative
to the Future Use of the Frequency Band 806-960 MHz; and Amendment of Parts 2,
18, 21, 73, 74, 89, 91 and 93 of the Rules Relative to Operations in the Land
Mobile Service Between 806 and 960 MHz
Docket No. 18262
FCC 70-519
19 Rad. Reg. 2d 1663
May 21, 1970, Released
Adopted May 20, 1970
JUDGES:
By the Commission: (Commissioners Robert E. Lee and H. Rex Lee
dissenting and issuing statements; Commissioner
Johnson concurring and issuing a statement.)
OPINION:
FIRST REPORT AND ORDER AND SECOND
NOTICE OF INQUIRY
By the
Commission: (Commissioners Robert E. Lee and H. Rex Lee dissenting and issuing
statements; Commissioner Johnson concurring and issuing a statement.)
1. In a
Notice of Inquiry and Notice of Proposed Rule Making adopted on July 17, 1968, (33
FR 10807) the Commission invited comments on the above captioned matter,
setting December 2, 1968, and January 31, 1969, as the dates by which comments
and reply comments, respectively, were to be filed. Subsequently, on November
20, 1968, in response to formal requests therefore, the Commission ordered
those dates extended to February 3 and March 31, 1969. The last date for reply
comments was subsequently extended to April 30, 1969.
2. Also on
July 17, 1968, the Commission initiated a proceeding in Docket No. 18261
looking toward sharing of the lower seven UHF-TV channels (14-20) by the land
mobile service on a selected geographical basis. The dates for comments and
reply comments, as well as the subsequent extension of those dates, coincided
with the dates specified for this proceeding (Docket No. 18262). As a
consequence, comments considered herein are in four categories: (1) comments
filed in response to Docket No. 18262 alone; (2) comments filed in response
jointly to Dockets No. 18261 and 18262; (3) reply comments in Docket No. 18262
alone; and (4) reply comments filed jointly in Dockets No. 18261 and 18262.
Additionally, on January 22 and 23, 1970, interested parties made oral
presentations before the Commission en banc. A list of all those who filed
statements and/or made an oral presentation relative to this docket is
contained in Appendix A. A summary of comments and reply comments will be found
in Appendix B.
3. After
weighing the many comments and reply comments filed in this proceeding, and
taking into account other relevant information, the Commission is persuaded
that it would be in the public interest to press forward with the basic
concepts set out in its initial Notice, while at the same time recognizing that
it is desirable to modify certain of the related details. These basic concepts
include a reduction in the frequency limits applicable to industrial,
scientific and medical (ISM) equipment at 915 MHz, reduction by half of the
942-952 MHz band allocated for aural broadcast studio transmitter links (STL), n1 an allocation of 40 additional megahertz of spectrum
space for "private" land mobile systems, and an allocation of an
additional 75 MHz for common carrier domestic public high-capacity mobile
systems.
n1 Additional spectrum space for aural broadcast studio
transmitter links in the band 2150-2160 MHz to be the subject of a separate
Rule Making proceeding.
4. Among other
things, it was proposed in the Notice to reallocate UHF-TV channels 70-83
(806-890 MHz) to the private and common carrier land mobile services for use in
the 25 largest urban areas on a co-equal basis with translators in the
broadcasting service. This proposal was generally opposed by
broadcasting-oriented interests but supported by land mobile user associations,
common carriers, land mobile equipment manufacturers and the Small Business
Administration.
5. The
broadcasting industry, represented principally by the comments of the
Association of Maximum Service Telecasters (AMST), takes the position that the
growth rate of land mobile radio will tend to decline in future years and that
the reallocation of television spectrum for this purpose is not justified. The
broadcasters contend that isolated situations of land mobile congestion are
caused by wasteful management practices resulting in an inequitable
distribution of users on presently available channels. The solution, they
argue, lies not in the allocation of additional spectrum, which would serve
only to perpetuate present inefficiencies, but in the implementation of a
policy of equal-channel occupancy through the use of regional management
offices. In this regard it should be noted that the Commission has initiated a
program looking toward the establishment of a regional management center.
However, being a new, untried approach there can be no assurance of early
relief to congestion in the land mobile service. As an additional measure, AMST
recommended that the more urgent needs of police and other emergency services
be met by designating the 150 MHz land mobile band exclusively for such
services and requiring lower priority business and industrial users in this
band to convert to the 450 MHz band. They also suggest that the needs of lower
priority users be met by use of an expanded common carrier dispatch system
which could be developed within the 26 MHz released by the Government in the
vicinity of 900 MHz.
6. We are
not persuaded by the broadcasters' arguments that the land mobile service does
not require the spectrum relief proposed in this proceeding. We have on many
occasions expressed a growing concern that the land mobile service is faced
with a severe shortage of frequencies in large urban areas. We are persuaded,
in view of the entire record before us, that substantial additional spectrum
space must be made available to the land mobile services to meet existing, and
more importantly, future needs.
7. If
additional spectrum space cannot be made available to the land mobile service,
the Commission would appear to be faced with a limited number of alternatives -
each of which is undesirable. It could continue licensing new users on existing
channels, leading to a chaotic situation in many areas. It could limit
eligibility and reduce licensing of new users to equal the user drop-out rate.
It could cease the licensing of new users in congested areas awaiting the
implementation of sophisticated higher-capacity communication systems not yet
on the market. The first two alternatives are clearly not in the public
interest in light of the continually growing public demand for more and
improved land mobile service. With respect to the third alternative, we will
encourage and expect the design of new and highly efficient communication
systems in the exploitation of spectrum space newly allocated herein to the
land mobile service. However, the enforced implementation of such systems in
bands now allocated to the land mobile service would entail huge expense and
inconvenience to the land mobile community and to the public and, even then,
the degree of relief possible would be, at best, uncertain.
8. With
regard to AMST's recommendation that "high priority" users be
concentrated in the 150 MHz band, the costs alone of converting thousands of
public safety and other radio systems to different frequency bands precludes
any serious consideration of such a move. It would mean, in many cases,
complete abandonment of existing systems in one band and the purchase of new
equipment in the band to which operations were shifted. Moreover, the action
would do little or nothing to relieve the overall congestion in the service and
would ignore the peculiar advantages that each range of frequencies offers in
meeting different coverage requirements.
9. It is,
of course, impossible to predict precisely how much additional spectrum space
will be required by 1980 to meet the needs of the land mobile service. However,
we continue to hold the view that communications requirements now being met in
the private land mobile service can reasonably be expected to at least double
within that time frame, regardless of the exact number of transmitters in use
today or to be in use in 1980. The additional spectrum space made available in this
proceeding and in Docket 18261 should meet substantially the long term needs of
the land mobile radio services, especially if new developments and advanced
techniques are employed in the use of the space allocated herein for private
land mobile systems and, of course, in the development of the high capacity
common carrier land mobile system provided for. In our view, it is essential in
the public interest that every encouragement be given to the development of new
techniques in the efficient use of bands allocated for "private" land
mobile systems and to the development of a high-capacity common carrier mobile
system. We believe, therefore, that the originally proposed allocation of 40
MHz to "private" systems and 75 MHz to common carrier systems
represents a reasonable accommodation for the two sectors of the land mobile
service in the frequency range 806-960 MHz.
10. Land
mobile interests filing comments in this proceeding generally supported the
Commission's proposals but expressed concern over the probability that the
development of the land mobile service in the band 806-890 MHz (channels 70-83)
would be inhibited if the land mobile service were required to protect
translators or were confined to large urban areas. In lieu of the Commission's
proposal, therefore, they recommended a nation-wide reallocation of this band
to the land mobile service on a primary basis and to translators on a secondary
basis.
11. The
Commission's original proposal was based on the assumption that translators
inherently provide a rural service while land mobile is basically urban. It was
proposed, therefore, that translators have exclusive rights to channels 70-83
outside the top 25 urban areas, with land mobile and translators sharing on a
coequal basis within these areas. The claims of the land mobile users, both
private and common carrier, that their needs extend well beyond urban
boundaries, together with the fact that several translators are already
operating in urban areas, questions the validity of our basic assumption.
12. The
protection of translators involves consideration of the same sources of
interference that affect a full-fledged television station, e.g., co-channel,
adjacent channel and "taboo" channel interference. A January 1968
study by Working Group 3 of the Commission's Land Mobile Frequency Relief
Committee found that six different TV channels between 70 and 83 were assigned
to translators located between 50 and 100 miles of the center of New York City.
It was recommended by that Working Group that translators be relegated to
secondary status. Lacking a detailed engineering study we can only estimate
what the effect of protecting these translators would be on the future use of
this band for land mobile operation in the New York City area. However, even co-channel
protection could reduce the spectrum available for land mobile use in the area
by as much as 36 MHz. If adjacent channels are protected also, land mobile use
would be further inhibited. Consideration of other taboo separations plus other
translators licensed since the 1968 study could very well preclude any
meaningful relief for the land mobile service in this important area. On the
other side of the coin, under the co-equal sharing proposal by the Commission,
once new land mobile systems developed on such channels as might be available,
additional translators in the area could be precluded. Since the translator
situation existing near New York City is not unlike that of most major cities,
there is little reason to believe now that the original co-equal sharing
proposal holds much potential for aiding the land mobile service in those areas
where relief is becoming increasingly necessary.
13. Since
we are not inclined to dismiss our primary objective in this proceeding, it is
necessary to seek other arrangements for the accommodation of the land mobile
service. In light of the above discussed sharing problems, either the land
mobile service or translators must be accommodated elsewhere. Further studies
indicate that the most reasonable solution, and the one adopted herein, is to
shift translators from channels 70-83 to channels 69 and below so as to permit
the use of channels 70-83 by the land mobile systems expected to be developed.
As set forth in Appendix C, and footnote NG63 in particular, provisions are
made for the continued use of channels 70-83 by translators under the
conditions specified. As a practical matter, because of the several years
expected to be required for the development of 900 MHz land mobile equipment
and because operational systems are expected to evolve first in major urban
areas, it is reasonable to expect that, for years, there will be no impact at
all on the vast majority of translators on channels 70-83 located in rural
areas. Also, since it is improbably that there will be extensive land mobile
use of the band 806-890 MHz for the next several years in the major urban
areas, present licensees of translators now using channels 70-83 in or near
such areas can be assured of a reasonable period during which plans can be made
to shift to a lower channel. The necessary amendments to Part 2 of the Rules
are adopted herein (Appendix C) and, concurrently, a Notice of Proposed Rule
Making is adopted proposing amendments to Part 74, Subpart G of the Rules so as
to provide for TV translator use of TV channels 14-69 and, under certain
conditions, require the shifting of translators from TV channels 70-83. It
should be noted that no action will be taken regarding the UHF TV assignments
in Puerto Rico on channels 70 and above, pending further consideration by the
Commission. (See footnote NG63, Appendix C.)
14. The
concept of using translators on channels 69 and below is not new, as it was
proposed in a 1966 filing by AMST in Docket No. 14229. The AMST filing contains
an engineering statement by Howard T. Head of A.D. Ring Associates which shows
that a substantial potential exists for assigning translators on such channels
with no ill effect on the primary use of the channels for TV broadcasting. As a
further measure of this potential it should be noted that there are over 1600
translators presently operating on the 12 VHF-TV channels 2-13. This figure is
more than double the number now operating on the 14 UHF-TV channels 70-83.
15. The
National Association of Educational Broadcasters (NAEB) and other educational
interests argued that the Commission should provide substantial additional
reservations for educational broadcasting. However, there were no arguments
presented which were different from those considered in detail and rejected by the
Commission in its Fourt Report and Order in Docket No. 14229. In that
proceeding, it was decided that an equitable number of channels had been
reserved for educational use in the present assignment table employing both VHF
channels and UHF channels 14-69. Although one should refer to that Fourth
Report and Order for full details, the rationale for the Commission's decision
can be summarized as follows:
(a) non-reserved channels may be assigned to educational as
well as commercial entities;
(b) commercial stations are under an obligation to present a
reasonable number of cultural and educational programs;
(c) local educational entities can and should cooperate in
the use of channels reserved for educational purposes, rather than attempting to
limit their use to special interest groups or institutions;
(d) thirty-one Instructional Television Fixed Service (ITFS)
channels between 2500 and 2690 MHz have been designed for in-school
instructional use, including multi-channel program needs of formal educational
systems; and
(e) expanding use of cable TV systems (recently given
authority to originate programs) holds the potential for meeting a substantial
portion of the public need for a wide variety of cultural and educational programming,
both in the home and the school.
16. In
rejecting the claims of educators for additional reservations in Docket No.
14229, the Commission proposed setting aside channels 70-83 for low power
commercial of educational stations in smaller communities not requiring or able
to support full power facilities. In a later Notice, it was proposed that in
some situations these channels might be used for additional high power
educational stations in some of the largest cities where there may conceivably be
a need for more educational stations than the present table allows. No actions
have been taken on either of the proposals. However, in the light of our
earlier decision in Docket No. 14229 with respect to additional educational
reservations, our decision to reallocate the 806-890 MHz band to land mobile
service, and the decision announced in paragraph 13 above, looking to the
shifting of translators from channels 70-83, we intend to issue a separate
Order in Docket No. 14229 withdrawing further consideration of any proposals
relating to channels 70-83 therein. Nevertheless, in terminating Docket No.
14229, we recognize that the public interest considerations for low power
educational and community television stations have not been entirely resolved.
Such uses are presently the subject of a Government-wide study seeking ways in
which communications may be applied to education in the relief of urban
problems. This effort is one in which the Commission is vitally interested and
intimately involved. Consequently, the combination of community educational and
instructional needs of the nation should not be prejudiced by the result of
this proceeding. Thus, we believe that the cooperative educational arrangements
which we discussed and encouraged in Docket No. 14229 can and should be
preserved as a regulatory and planning objective. Even though our action in
this proceeding forecloses the possibility of additional educational
reservations in the 70-83 UHF band, we are convinced that at least some of the
nation's critical needs for instructional and educational media facilities can
be met in the 2500-2690 MHz frequency band. We reiterate our belief that ITFS
is a valuable and important supplement to educational broadcasting service. In
view of our decision here, these instructional services deserve maximum
encouragement. Accordingly, we shall promptly issue a separate Further Notice
of Proposed Rulemaking in Docket No. 14744 taking positive action to that end.
17. In the
Notice we asked the question: "To what degree would UHF-TV receiver
manufacturers need to change the image rejection capabilities of their product
to cope with image problems arising from heavy land mobile usage in the range
806-947 MHz?" As pointed out in the engineering statement by A. D. Ring
Associates submitted as part of the AMST filing herein, image interference from
land mobile operations on channels 70-83 could affect TV reception on channels
55 through 60. Set manufacturers did not address themselves to this issue.
However, we shall encourage manufacturers to improve the image frequency
rejection performance of their television receivers. Information available
today indicates the image rejection capability of recent-vintage UHF-TV
receivers to range between about 35 and 40 dB. We believe that available
technology can be used to provide at least 60 dB of image rejection throughout
the UHF-TV band and we shall plan accordingly.
18. It was
proposed initially to position the 26 MHz allocated to the Government between
890 and 942 MHz so as to provide some harmonic overlap with the Government
radiolocation band at 420-450 MHz to accommodate certain devices and techniques
which rely upon harmonic relationship to function properly, and to provide a
means of minimizing interference to non-Government systems from harmonic
radiation of high-powered radars in the frequency band 420-450 MHz. The
proposed allocation of the band 893-919 MHz carried with it a consequential
proposal to reduce the ISM limits from 915 +/- 25 MHz to 915 +/- 4 MHz, a
proposal which was opposed strongly by ISM interests, generally on the grounds
that such a reduction would necessitate a prohibitive increase in the cost of
their product and negate several years of developmental work in the wider
bandwidth. The Commission and the Office of Telecommunications Management (OTM)
concluded that the benefits of harmonic relationship were outweighed by the
difficulties that would be imposed upon ISM and that the earlier proposal with
respect to the 26 MHz of spectrum space to be retained for the Government
radiolocation service within the band 890-942 MHz should be modified.
Accordingly, the Government allocation in this range will now be 902-928 MHz,
centered on the existing ISM frequency at 915 MHz and will coincide with the
new limits for ISM, i. e., 915 +/- 13 MHz. Manufacturers of microwave heating
devices strongly opposed any reduction in ISM limits although Electronic
Industries Association (EIA) and others agreed to cooperate with the Commission
in studying possible future ISM spectrum reductions. Voss Tinga Associates
offered a compromise bandwidth of +/- 10 MHz in lieu of the +/- 4 MHz proposed,
but later rescinded that offer in view of adverse comments by G. E. and others.
At present, the principal use of 915 MHz by ISM devices is in microwave ovens
and our records indicate that G. E. is the only U.S. manufacturer using the
frequency for that purpose. A number of other manufacturers use the ISM
frequency at 2450 MHz for their ovens.
19. In
support of its position against a reduction in the ISM frequency limits at 915
MHz, G. E. submitted the results of tests involving two types of magnetrons
commonly used in its ovens. The combined, overall excursion of emissions from
all tubes tested was 37 MHz centered at 917 MHz. This spread consisted of
frequency pulling due to load variations in the ovens, production tolerances,
frequency changes as the magnetrons aged and measurement error. G.E. expressed
the view that additional "guardband" should be provided to take
account of unforeseen frequency changes and concluded that the frequency limits
of 915 +/- 25 MHz should be retained to avoid a major setback in their program
to reduce costs to the consumer on their 915 MHz devices. Further, they
expressed concern over the possibility of serious interference from "tens
of thousands" of domestic microwave ovens now in use if the Commission
went forward with its +/- 4 MHz proposal for ISM. Similar views were expressed
by manufacturers of industrial equipment, although a much smaller number of
existing devices is involved. According to Voss Tinga Associates, some 20 large
industrial microwave generators are now in use in the U.S. and Canada, but
there are plans for considerable expansion of 915 MHz industrial operations in
Canada.
20. The
Commission's records indicate that G. E. is the only manufacturer having
type-approved ovens operating at 915 MHz. Measurement for type approval at the
Commission's laboratory on a small number of G. E. ovens, which includes the
effect of normal load variation, showed that all emissions in excess of the
legal out-of-band limit (i. e., 25 [square root] RF power/500 uv/m at 1000')
fall within the band 909-922 MHz. However, our present plan to require that ISM
devices comply with the new limits 915 +/- 13 MHz has been discussed informally
with G. E. representatives. Statistics developed by them, taking into account
the effects of magnetron aging, frequency drift, wide variations in loading and
a much wider sampling than was possible at our laboratory, raise questions as to
the degree to which certain of their devices can, in fact, comply with the new
limits. They argue that it would be prohibitively expensive to require them to
comply any time within the near future. Nonetheless, we can no longer afford
the luxury of what appears to be excessive bandwidths for non-communication
devices in this valuable portion of the radio spectrum and must continue to
press for +/- 13 MHz as our goal. Fortunately, at least in the case of the G.
E. ovens, there appears to be a good chance for co-existence between land
mobile systems that are expected to develop within adjacent frequency bands and
individual ovens whose radiation might exceed the frequency limits some small
percentage of the time. We wish to continue to examine this matter and solicit
comments, under the Inquiry aspects of this proceeding, with respect to: 1) the
impact of +/- 13 MHz limits on ISM devices generally; and 2) how and if
co-existence might be achieved in the case of devices not capable of complying.
21. In
paragraph 9 above it was stated that 40 MHz would be set aside for private land
mobile systems and 75 MHz would be earmarked for common carrier systems. In
reaching that decision the Commission found the need for such allocations more
compelling than the arguments of: 1) ARINC/ATA for the allocation of 22 MHz of
the band between 806 and 947 MHz to the aeronautical mobile (R) service; and 2)
the proponents for the retention of the frequency band 942-947 MHz by the
broadcasting auxiliary service.
22. In
comments filed jointly by Aeronautical Radio, Inc. and Air Transport
Association (ARINC/ATA), they estimated that by 1985, a total of 428 channels
will be required by the aeronautical mobile (R) service and that 22 MHz of
spectrum space (approximately 50 kHz per channel) will be needed to meet that
stated requirement. In arriving at that total, ARINC/ATA estimate that 139
channels will be required for operational control purposes by air transport
carriers (as compared to today's 64 channels); that 209 channels will be
required for new "inflight passenger services" (such as business and
personal messages); that 24 channels will be required for "ground handling
services"; and that 56 channels, representing approximately 40% as much as
for air carriers, will be required for operational control purposes by general
aviation. However, the total of 428 channels upon which the request for 22 MHz
of additional spectrum space is based fails to make mention of the existing 64
operational control frequencies for air carriers in the frequency band
117.975-136 MHz, or the frequencies available today in the same band for
general aviation. Frequencies in the band 117.975-136 MHz are used today for
6A3 voice communications with 50 kHz between assignable frequencies. In
practice, however, frequencies are generally assigned on the basis of 100 kHz
separation between adjacent users. The state-of-the-art would permit at least a
two-fold, and possibly a four-fold increase over present assignment practices
in this band, which would more than meet the stated need for operational
control frequencies.
23.
Additionally, it should be noted that the Preliminary Views of the USA relative
to the World Administrative Radio Conference scheduled for 1971, contemplate
the use of space techniques within the frequency band 1535-1660 MHz to meet
many of the future needs of the aeronautical mobile (R) service. The
"inflight passenger services" requiring 209 channels by ARINC/ATA
estimates have no place in the aeronautical mobile (R) service since such
operations are prohibited by the international Radio Regulations in frequency
bands allocated to the aeronautical mobile (R) service. Such operations would
be more appropriate to the air-ground portion of the high-capacity common
carrier public correspondence system envisaged in this proceeding. The
"ground handling services" and their stated requirement for 24
channels also have no place in the aeronautical mobile (R) service since, in
fact, they are no more than a land mobile service of the type now accommodated
in the air terminal segment of the industrial radio service. In summary, we
find the ARINC/ATA proposal lacking in merit and do not propose to make
provision for it herein.
24. Many
broadcasters voiced opposition to the reallocation of the lower half of the
942-952 MHz STL band to the land mobile service. The main objection stated was
that the reduced spectrum could not accommodate the expected future increase in
demand for STL service, especially within the larger cities. Los Angeles was
singled out in several comments as an example of present congestion in the
band. It was contended that all or most of the 19 available channels were
already assigned in Los Angeles and that, because of nearly coincident
transmission paths, multiple use of individual channels was impossible.
Although not proposed by the Commission in its initial Notice, channel
splitting was declared by some to be technically infeasible because of the wide
bandwidth and low noise requirements of stereo and SCA broadcast transmission.
25.
Comments submitted by A. Earl Cullum, Jr., and Associates include a table
showing the number of present and potential STL assignments in 42 cities, large
and small. Information on present assignments was derived from the Commission's
1968 Broadcast Auxiliary assignment list. "Potential" users included
all allotted FM and TV channels, regardless of whether or not there were
station assignments on the channels, plus existing and applied for AM
assignments. From this study it was concluded that the band 942-952 MHz
"will be inadequate to provide for the needs of the broadcast licensees,
especially in the larger cities." Cullum listed Los Angeles as having 26
STL assignments and, since there are only 19 channels in the 942-952 MHz band,
concluded that zero channels are available for future STL operation. According
to Cullum, that city has 72 potential STL users.
26.
However, there appears to be no real basis for Cullum's conclusion that the larger
cities are especially in need of STL channels. His data show that in eight of
the top ten cities (N. Y. and Chicago were not included in the study), four
have no STL assignments, two have but one assignment, one has seven
assignments, and one (Los Angeles) has 26. A review of all the cities studied
indicates that the need for STL service does not depend upon population, but
appears to be more a function of terrain, the individual broadcaster's
preference and possibly the availability of local wireline facilities. Further,
in computing the number of assignments, Cullum appears to have misunderstood
our recording procedures. Current records within the Commission account for
only 16 STL channels assigned in Los Angeles, in contrast to Cullum's figure of
26. This difference is no doubt due to the manner in which STL frequency
assignments are recorded in the list from which Cullum obtained his data. Dual
signal STL transmissions - such as required for FM/FM, AM/FM or FM/SCA - are
listed as two separate frequency assignments equally spaced within a single 500
kHz channel. Apparently each of these was counted as a full channel assignment.
The following is a comparison of the Cullum figures with the current number of
assignments in eight major cities, according to our records and method of
approach:
|
City |
Number of Channels Assigned |
|
|
Cullum |
FCC |
|
|
Los
Angeles |
26 |
16 |
|
Detroit |
0 |
0 |
|
San
Francisco |
7 |
5 |
|
Boston |
2 |
1 |
|
Pittsburgh |
0 |
0 |
|
Cleveland |
1 |
1 |
|
St. Louis |
0 |
0 |
|
Baltimore |
0 |
0 |
27. Clearly
one could not conclude that present usage of this band is such as to preclude
the proposed reduction in the STL band. Further, there is little reason to assume
that the demand will ever approach the number of potentials suggested by Cullum
since most of those potential users appear to be operating satisfactorily
without the use of STLs. Los Angeles does appear to present a problem, however.
If the lower half of the band is to be cleared of STL stations, seven Los
Angeles stations now assigned frequencies in the lower half will require
re-accommodation in the upper half. In the upper half, only one channel is not
already in use in Los Angeles, so that there would be some doubling-up
necessary if all are to be accommodated. Whether such doubling-up is feasible
is dependent to some degree upon the validity of the earlier argument that
because of nearly coincident transmission paths, channel re-use in the area is
impossible. There is an alternative, however. If the remaining STL channels in
the upper half are reduced in width, or if specific channelling is done away
with entirely, the long term situation in Los Angeles might be improved
considerably. This matter, as well as a means of providing relief in local
areas where congestion might arise among STL users, will be examined closely in
the proceeding referred to in footnote 1, page 2.
28. In the
initial Notice we asked certain specific questions directed to the further
sub-allocation of the new land mobile bands and the ultimate design of mobile
systems in this part of the spectrum. Comments from private land mobile
interests generally favored making no sub-allocation either between or within
the private and common carrier services. In most instances they expressed the
belief that common carrier high capacity mobile telephone or dispatch service
would be unresponsive to the majority of land mobile needs, and that larger
portions of the overall land mobile allocation should eventually be designated
for private systems. Common carriers generally agreed with the proposed
division, although the NARS urged that approximately one-half of the common
carrier allocations be designated for use by non-telephone company common
carriers for the provision of mobile dispatch service. According to NARS and
Motorola, AT & T and other telephone companies should not be allowed to
provide dispatch communications. In their view such an offering would be an
encroachment on the basic competitive services furnished by the miscellaneous
or radio common carriers, and could constitute a violation of the 1956 Consent
Decree. AT&T, however, claims that there are no legal or competitive
reasons why the telephone companies should not provide mobile dispatch service
and, in fact, that such service is already being provided on a limited basis in
some cities. AT&T also states that its contemplated high capacity system
would be capable of providing dispatch service, although further studies are
required to clearly define the potential market and system configuration and to
determine how dispatch service would fit into the overall mobile system.
AT&T urged that any further sub-allocation of the common carrier bands be
deferred until the Commission has had an opportunity to examine the results of
its (AT&T's) proposed 18-month phase I systems design and market study
which would address itself in more detail to the questions raised in the
Notice.
29. Based
on preliminary studies, AT&T contemplates an ultimate high capacity mobile
system capable of accommodating land vehicles, aircraft and, to a limited
extent, maritime vessels. It envisions a land mobile system operating on a
cellular basis, so that a city or other coverage area would be divided into many
cells, each of which would employ a portion of the total available channels.
However, again it emphasizes that additional systems studies are required under
its phase I program. Private users indicated many potential uses of frequencies
in this part of the spectrum including short range vehicular or portable
communications, car locators, mobile data transmission, etc. Some of the
suggested uses fall into the category of fixed operations, and several comments
suggested that certain fixed operation be specifically permitted in the band.
30. On the
technical side, our suggestion that single sideband or multiplexing techniques
may provide considerable advantage in common carrier and private common-user
systems was generally rejected in the comments from land mobile equipment
manufacturers and the EIA. AT&T did not rule it out entirely for a common
carrier system. The telephone company did say, however, that FM appears to
offer substantial advantages over other forms of modulation because of the
ability to repeat assignments at shorter separations as a result of FM capture.
Possible channel width figures ranged anywhere from about 25 to 50 kHz.
31. It is
obvious from the comments that much additional study and development are needed
before answers can be found to all the technical and operational questions
relevant to the optimum use of this spectrum space by the land mobile service.
Nonetheless, in the interest of providing guidance as to the direction in which
the development of this band is to proceed, some initial decisions are
necessary. Therefore, despite the originally proposed distribution of the
overall band between private and common carrier users, we are allocating
herewith the frequency band 806-881 MHz to the common carrier mobile service
and the bands 881-902 and 928-947 MHz to the private land mobile service.
Further, as noted earlier, we intend to shift translator stations from channels
70-83 and to re-accommodate them on channels 69 and below. In addition to the
translator stations, there are two educational television assignments within
the upper 14 UHF channels. These are Glen Ridge, N.J. (Channel 77) and Bowling
Green, Ohio (Channel 70). The disposition of these assignments continues under
study but in the meantime, we shall make note of the problem by a footnote to
the Table of Frequency Allocations (see NG65). The necessary changes to Part 2
of the Rules are set forth in an Appendix hereto, which includes interim
arrangements for translators in footnote NG63. This decision is based largely on
judgment factors rather than on hard-and-fast conclusive evidence. Contributing
to this decision are the following considerations:
(a) there is uncertainty with respect to the ability of some
ISM devices now in production to confine their radiation within the new ISM
limits, i.e., 915 +/- 13 MHz;
(b) from the record in this proceeding, one could reasonably
assume that common carrier systems will develop in this band prior to private
systems, however, subsequent discussions indicate the converse might be true;
(c) AT&T has indicated tentative plans to develop a
lowpowered system which - for a given level of ISM radiation - resumably would
be more susceptible to interference than would a system based on higher powers;
(d) traditionally, common carrier system users have required
a grade of service which is more interference-free than is considered necessary
for satisfactory communications by regular users of private land mobile
systems;
(e) a high-capacity, common carrier system under the control
of a single operating entity in a given area can be expected to use its total
available spectrum space in a relatively uniform fashion throughout the peak
portion of its business day; whereas
(f) regardless of whether common carrier or private systems
develop first in this band; the peak hours of use and the requirements for
immediacy of access to a frequency among the several private users are quite
diverse;
(g) the peak hours of private land mobile systems - other
than perhaps police, fire and taxicab - coincide with the local business day,
e.g., 8:00 a.m. to 5:00 p.m. according to our monitoring records, whereas
common carrier use is not so directly related;
(h) the peak hours of use of the microwave ovens (ISM
devices) referred to in (a) above tend to occur between about 5:00 and 7:00
p.m., and each such device is in operation for a relatively short period; and
(i) low priority private systems, whose peak requirements
occur prior to 5:00 p.m. local time, could be accommodated in spectrum space
immediately adjacent to 902-928 MHz where ISM radiations, no matter how slight,
would be most likely to constitute a source of potential harmful interference
to the land mobile service.
On the
above bases, we have concluded that the common carrier allocation should be
removed as far as possible from 915 MHz and have allocated the band 806-881 MHz
to meet that point.
32. In this
connection, to ensure that newly developed ISM devices comply with the new
limits, Parts 2 and 18 are amended as set forth in appendices hereto,
specifying the new limits for all such devices for which type approval or
original certification is sought, after a relatively early date yet to be
determined. Under the Inquiry portion of this proceeding we will explore also
the need for a cut-off date by which time all ISM devices must comply with the
new limits and what that date might be.
33. We do
not agree with NARS and Motorola that it would be inappropriate for wireline
carriers to provide a dispatch service and while we are not specifying in the
rules at this time what types of systems should be developed, we will expect
proposed systems to comply with the general guidelines outlined in the Notice.
Common carrier systems should be developed for both public and dispatch
requirements and private mobile systems, voice or data, including common-user
systems, should be of the most efficient design practicable. Development of the
common carrier band will be limited to wireline telephone companies, inasmuch
as radio common carriers will be given accommodation in the frequency bands
being treated in Docket No. 18261. Fixed operations in the bands in question
will be discouraged where they would otherwise detract from the potential use
of the bands for mobile services.
34. A
number of comments, pro and con, were directed to the matter of allocating
portions of the bands under discussion to the broadcasting-satellite service
for television broadcasting. This proceeding, however, is not an appropriate
forum for a decision with respect to such an allocation. The Commission's
Inquiry in Docket No. 18294 (in preparation for a 1971 Space Conference)
tentatively proposed the addition of a footnote to the international Table of
Frequency Allocations as follows:
324B The broadcasting-satellite service also may be
authorized in the band 614-890 MHz for television broadcasting, subject to
agreement among Administrations concerned.
That, too,
evoked mixed reactions from those responding in Docket No. 18294. If the
Commission continues to espouse that tentative proposal and the Space
Conference subsequently adopts that proposal, the modification of the
international Table would not enter into force until perhaps January 1, 1973.
Any subsequent decision with respect to amending the national Table to reflect
that international change would be the subject of separate rule making and a
public interest determination.
35. In summary,
actions taken herein, or in separate dockets initiated as a result of this
proceeding, include the following:
(a) the band 806-947 is reallocated as shown in Appendix C;
(b) Part 18 is modified to reflect the new frequency limits
for ISM as shown in Appendix D;
(c) our Inquiry in this proceeding is continued with respect
to the types of systems to be developed for private and common carrier use of
their newly allocated bands;
(d) our Inquiry in this proceeding is continued also with
respect to certain unresolved issues involving ISM;
(e) rule-making has been initiated this date in a new
proceeding (Docket No. 18861) to amend Part 74 looking toward the shifting of
translators from channels 70-83 and the re-accommodation of those and future translators
on channels 69 and below;
(f) as a consequence of the basic reallocation action in (a)
above, various footnotes in the Table of Frequency Allocations, relating to the
band in question are modified herewith. This, in turn, will require consequential
changes in various Parts of the Rules; and
(g) for purposes of clearing the record, an Order will be
issued in Docket No. 14229 in the near future withdrawing further consideration
of UHF - TV television broad-casting proposals for channels 70-83, therein.
36.
Authority for the actions taken herein is contained in Sections 4(i) and 303 of
the Communications Act of 1934, as amended. Accordingly, it is ordered, that
effective July 10, 1970, Parts 2 and 18 of the Commission's Rules are amended
as set forth in the Appendices hereto. [Appendices C and D omitted. See
PP52:106, 68:13, 68:141, in the Current Service Volumes.]
37. The
Commission is hopeful that AT&T, as well as others, will undertake a
comprehensive study of market potentials, optimum system configurations and
equipment design looking toward the development and implementation of an
effective, high capacity common carrier service in the band 806-881 MHz.
Parties intending to undertake such studies are requested to so indicate to the
Commission within 180 days of the release of this action, including therein
their estimates as to when such studies will be completed.
38.
Interested parties are encouraged also to submit proposals within 180 days,
with respect to the manner in which the frequency bands 881-902 and 928-947 MHz
can be most effectively used in meeting the needs of the private land mobile
users. We are looking particularly for innovative techniques applicable to
bands thus far uncluttered by land mobile systems.
39. It must
be recognized that implementation of the land mobile program in the border
areas will require appropriate coordination and agreement with neighboring
countries, in light of our obligations under the international Radio
Regulations and our bilateral agreements with respect to the UHF television
band.
CONCUR:
CONCURRING STATEMENT OF COMMISSIONER
NICHOLAS JOHNSON
I concur in
our action taken today in Docket 18262. In my concurring opinion to Docket 18261,
I detailed my feeling about this action: I would have preferred some
consideration of alternative solutions presented by the staff; I think that
some long-range planning was needed to determine if more beneficial uses could
have been made of this spectrum region. For example, the upper 14 UHF channels
have been thought by most people to offer the best region for direct
satellite-to-home broadcasting. I know that such a plan has much opposition -
both technically and politically. I presently have no particular reason to
favor such a plan. But I would have thought it profitable to have considered
what effect this decision will have on the future of satellite-to-home
possibilities. Nevertheless, I have concurred in this action, because I believe
from the limited information before me that it will be this region of the
spectrum which will offer the most practical and most efficient long-range
solution to the land mobile crisis.
DISSENTBY:
ROBERT E. LEE; H. REX LEE
DISSENT:
DISSENTING STATEMENT OF COMMISSIONER
ROBERT E. LEE
[For
dissenting statement see Docket No. 18261, page 1614, supra.]
DISSENTING STATEMENT OF COMMISSIONER
H. REX LEE
In the Matter of Docket Nos. 18261
and 18262
I dissent to
both Docket 18261 and 18262. I do so very reluctantly because I am aware of the
acute need for additional spectrum space for the land mobile users. However, I
do not believe the actions taken will do more than provide a very temporary
measure of relief to land mobile interests. These decisions are no more than
feeble efforts; and certainly do not arise to the merited distinction of being
called "solutions." For so little, the Commission's decisions also
impose harm on users of an important segment of the lower UHF-TV channels and
to the educational needs of the nation.
The First
Report and Order in Docket 18261 initially affords only temporary relief
through sharing of one or two of the lower UHF-TV channels in the ten largest
urban areas. In the recent oral argument before the Commission, both the land
mobile spokesmen and broadcasters repeatedly claimed that sharing would not
work. Their doubts are further deepened by the Commission's unwillingness to
attach any time limit to sharing privileges in the broadcast spectrum. The
Report merely states that "at the end of five years, and of course during
this period, we will evaluate the sharing proposition, as such, and make
further judgments. . . ."
Thus, two
important spectrum users are left sharing not only channels but doubts and
uncertainty. On the one hand, the land mobile users may be optimistic in
believing they can remain in this space, expand, and eventually gain exclusive
use of the lower seven UHF-TV channels. Yet the fact remains: the Commission
may force land mobile to vacate this band in a few years. On the other hand,
doubt and uncertainty plague the broadcasters who have spent millions of
dollars (with the encouragement of the Commission) and are presently continuing
their struggle to attain and maintain viable broad-casting services. They, too,
are left in the untenable position of not knowing whether it is safe to pour
more money into their operations when the Commission may "someday"
force them out of frequencies previously reserved to their use.
This
uncertainty could easily have been avoided had the Commission simply imposed an
early time limit on sharing and insisted on land mobile's early operation in
the upper part of the UHF band. This would have put land mobile users and
especially equipment manufacturers on notice that the Commission was serious
about the need for them to develop the necessary equipment and to move promptly
into the 900 MHz range for their permanent solution.
This lack
of seriousness leaves open the very real possibility that soon after the
Commission works out its licensing plan for the sharing arrangements, land
mobile users will be back seeking further relief from "new
congestion" problems on the ground that manufacturers still haven't
provided the equipment necessary for operation in the higher band. When this
happens, the Commission will once again find itself in a dilemma - unprepared
to undertake an efficient spectrum management program due to the lack of
adequate financing from Congress, and unwilling to force manufacturers and
users into the upper UHF band above 900 MHz.
The
Commission's decisions hold especially disastrous implications for educational
objectives. The First Report and Order in Docket 18262 completely removes
UHF-TV Channels 70-83 from the reach of educational broadcasting. I have no
quarrel with this action, because I strongly believe land mobile users
demonstrated the need for additional spectrum space and that this area of the
spectrum should be promptly developed in their service. Unfortunately, this
action requires the termination of Docket 14229, wherein the Commission
proposed making this range of frequencies available for lowpower community and
educational television stations.
However,
the elimination of this use did not mean the Commission was justified in
effectively denying educational users access to other spectrum resources,
especially when they are available. The Commission should, at least, have given
some assurance that educational and instructional frequency needs could be served
through an exclusive reservation of the 2500-2690 MHz band where instructional
television fixed services are now accorded sharing privileges with the
operational fixed and international control users.
Instead, the
Commission merely stated that it is "convinced that at least some of the
nation's critical needs for instructional and educational media facilities can
be met in the 2500-2690 MHz frequency band," because "ITFS is a
valuable and important supplement to educational broadcasting service."
If the
Commission, as it says, is so sure that "these instructional services
deserve maximum encouragement," I am at a loss to understand why it did
not at least put a temporary freeze on operational fixed and international
control use applications pending the final outcome of a separate Further Notice
of Proposed Rulemaking. Instead, the only commitment is to "promptly"
issue such a Notice in the ITFS Docket No. 14744.
It is my
fervent hope that the Commission will move swiftly to allocate the 2500-2690
MHz band exclusively for educational and instructional purposes. Even though
ITFS is a non-broadcast, point-to-point service, that allocation is practically
the only spectrum space left for educational users, especially in the large
urban areas where the need for multi-channel instructional facilities is the
greatest.
The
Commission must reiterate its special responsibility to educational users, to
protect their right to access to spectrum space - even over long periods of
time when the spectrum reservation may not be completely utilized. This is not
a new responsibility. In the 1952 Sixth Report and Order covering television
allocations, the Commission defended its reservation of channels for
non-commercial educational stations by recognizing that "it is of the
utmost importance to this nation that a reasonable opportunity be afforded
educational institutions to use television as a noncommercial education medium,
and that at the same time it will generally take the educational community
longer to prepare for the operation of its own television stations than it
would for some commercial broadcasters." (1 RR 614)
Nothing in
the intervening years has occurred to change this assessment. It now applies as
well to ITFS, and should not be forgotten after eighteen years when federal,
state, and local agencies find that budgetary strictures hinder their ability
to authorize funds for educational technologies. Now, more than ever, the
Commission's past policy should stand to prove there is no justification for
giving away education's future in public airwaves merely as a palliative to
relieve some present pressure of commercial and industrial users.
APPENDIX:
APPENDIX A
COMMENTS
A. Earl
Cullum, Jr. and Associates
Aeronautical
Radio, Inc. (ARINC)
Albany
Medical College of Union University
*
All-Channel Television Society (ACTS)
* American
Broadcasting Companies, Inc. (ABC)
American
Automobile Association, Inc. (AAA)
American
Telephone and Telegraph Company (AT&T)
American
Trucking Associations, Inc. (ATA)
Association
of Home Appliance Manufacturers (AHAM)
*
Association of Maximum Service Telecasters, Inc. (AMST)
Birch Bay
Broadcasting, Inc.
California
Public-Safety Radio Association, Inc. (CPRA)
California State
Communications Advisory Board
Camel
Company
Central
Committee on Communication Facilities of the American Petroleum Institute (API)
City of
Dallas, Texas
Columbia
Broadcasting System, Inc. (CBS)
Communications
Satellite Corporation (Comsat)
* Corporation
for Public Broadcasting
* D.H.
Overmyer Telecasting Company, Inc.
Dyma
Engineering
* Eagle
Broadcasting Company
Eastside
Broadcasting Company
Forest
Industries Radio Communications (FIRC)
Forestry,
Conservation Communications Association (FCCA)
General
Electric Company
* Georgia
State Board of Education
GT&E
Service Corporation
* Indian
River Television, Inc.
Institute
of Electrical and Electronic Engineers, Industrial Electronics and Control
Instrumentation Group
International
Association of Fire Chiefs (IAFC)
International
Microwave Power Institute (IMPI)
International
Municipal Signal Association (IMSA)
Joaquin
Sierra Educational Television Association
* John J.
Tibiletti
Joint
Comments on behalf of 13 licensees
* Joint
Council on Educational Telecommunications (JCET)
KREP
Broadcasting Station
Land Mobile
Communications Council
Land Mobile
Communication Section of the Industrial Electronics Division of the Electronic
Industries Association (LM/EIA)
McLendon
Corporation
* Mercury
Media, Inc.
Monterey
County California Office of Education
Moseley
Associates, Inc.
Motorola,
Inc.
* National
Association of Broadcasters (NAB)
National
Association of Business and Educational Radio, Inc. (NABER)
* National
Association of Educational Broadcasters (NAEB)
National
Association of FM Broadcasters (NAFMB)
National
Association of Manufacturers (NAM)
National
Association of Radiotelephone Systems (NARS)
* National
Broadcasting Company, Inc. (NBC)
National
Committee for Utilities Radio (NCUR)
*
Nationwide Communications, Inc.
* North
Alabama Broadcasters, Inc.
Pacific FM,
Inc.
Peninsula
Broadcasting Corporation
*
Philadelphia Mobile Telephone Company
* Philip Y.
Hahn, Jr.
Raytheon
Company
Reeve
Electronics, Inc.
Richard F.
Lewis, Jr., Inc. of Winchester (WRFL)
Rochester
Area Educational Television Association, Inc. (RAETA)
Satellite
Telecommunications Subdivision of the Industrial Electronics Division of the
Electronic Industries Association
Scranton
Times
Skyphone
Division, Times Facsimile Corporation, A Division of Litton Industries
* Small
Business Administration
Special
Industrial Radio Service Association, Inc. (SIRSA)
Spokane
Radio, Inc.
Station
KQED
* Steel
City Broadcasting Company
Sylvania
Electric Products, Inc.
Tri-City
Broadcasting Company, Inc.
United
States Independent Telephone Association (USITA)
Varian
Associates
Voss-Tinga
Associates
* WBJA-TV,
Inc.
WDVR, Inc.
* Westport
Television, Inc.
WFLY-FM
WJZZ-FM
WMBO, Inc.
* Joint Filing 18261 and 18262
REPLY COMMENTS
Aeronautical
Radio, Inc. (ARINC)
*
All-Channel Television Society (ACTS)
* American
Broadcasting Company
American
Telephone and Telegraph Company (AT&T)
*
Association of Maximum Service Telecasters, Inc.
* Central
Committee on Communications of the American Petroleum Institute
* City of
Dallas, Texas
City of
Milwaukee, Department of Police, Communications Bureau
General
Electric Company
* Georgia
State Board of Education
International
Association of Fire Chiefs (IAFC)
International
Municipal Signal Association (IMSA)
Land Mobile
Communications Council (LMCC)
Land Mobile
Communications Section
Motorola,
Inc.
* National
Association of Broadcasters
* National
Association of Educational Broadcasters
* National
Association of Radiotelephone Systems
National Committee
for Utilities Radio (NCUR)
Special
Industrial Radio Service Association, Inc. (SIRSA)
* Taft
Broadcasting Company
* Zenith
Radio Corporation
* Joint filing 18261 and 18262
ORAL ARGUMENTS
Association
of Maximum Service Telecasters, Inc.
Jack
Wayman, Esquire
Forward
Television Inc.
WKY
Television System, Inc., and RKO General, Inc.
Summit
Broadcasting Company Inc.
U. S.
Communications Corporation
All-Channel
Television Society
Joint
Council on Educational Television Communications and National Association of
Educational Broadcasters
American
Telephone and Telegraph Company
National
Association of Radiotelephone System
Communications
Industries, Inc.
Mobile
Telephone Co., Inc.
Aeronautical
Radio, Inc.
General
Electric Company
General TV Translator
Association
Land Mobile
Communications Council
Department
of Justice
National
Institute of Law Enforcement Justice
International
Association of Chiefs of Police
Associated
Public Safety Communications Officers
City of
Dallas, Texas
International
Bridge, Tunnel and Turnpike Association, Inc.
International
Muncipal Signal Association
National
Association of Business and Educational Radio, Inc.
American
Automobile and Trucking Association
American
Newspaper Publishers' Association and the Associated Press
Association
of American Railroads
National
Association of Broadcasters
Central
Committee on Communication Facilities of the American Petroleum Institute
Forest
Industries Radio Communications
Special
Industrial Radio Service Association, Inc.
Utilities
Telecommunications Council
Mobile
Radio Department, General Electric
Motorola,
Inc.
Stanford
Research Institute
APPENDIX B
PARTIES FILING SEPARATE COMMENTS IN
DOCKET 18262
A. Earl
Cullum, Jr., and Associates
Oppose
reduction of aural STL band from 942-952 MHz to 947-952 MHz, based on
predictions of future broadcasting needs. Study of 42 large and small cities
shows an average of less than 2 existing STL assignments (1968 FCC Assignments
List) per city (many have none), due mainly to broadcasters' ignorance of the
availability of these channels. But, further studies show a much higher number
of "potential users" in the same cities. This assumes one potential
STL user for each AM, FM, and TV channel now in use, plus each AM channel
applied for, plus each allotted but unused FM and TV channel. For example, St.
Louis which has no STLs now, will need 32 channels for this purpose in the
future. San Francisco will need 50 channels although it now uses only 3. Based
on this study, even the present 19 channels (500 kHz wide) will be inadequate -
much less half this number.
Aeronautical
Radio, Incorporated (ARINC)
Predicts
from FAA growth figures that aeronautical services will need total of 428
channels or 22 MHz by 1985 to meet requirements to year 2000: 348 channels for
air carriers (139 for operational control and 209 for in-flight passenger
service), 56 for general aviation, and 24 for ground operations. It requests
FCC (1) issue NPRM to carve out 22 MHz between 806 and 960 MHz for aeronautical
mobile (R) service; (2) initiate U.S position to make this a world-wide
allocation; (3) withhold any final action in this proceeding until all issues
involving 806-960 MHz band have been resolved.
Albany
Medical College of Union University
Licensee of
WAMC, FM educational station, Albany, N. Y. opposes STL reduction. Land mobile
will cause harmful interference to 943.5 MHz STL assignment because of FM
capture effect. Another required frequency change (this non-commercial FM
station was previously moved from 941 MHz) would be unreasonable.
American
Automobile Association, Inc. (AAA)
Agrees with
FCC proposals and endorses LMCC's comments, adding that (1) the 806-960 MHz
frequencies will permit continued growth of land mobile service beyond the
immediate relief envisaged in Docket 18261; (2) at least 10 years is needed to
develop land mobile equipment at 900 MHz; (3) the greatest demand at this order
of frequency will come from large users who can afford repeaters needed to
extend coverage areas.
American
Telephone and Telegraph Company (AT&T)
Agrees with
proposed common carrier allocation, but says further study is needed to answer
specific questions asked in the Notice. States that proposed 75 MHz should meet
common carrier needs for next 20 or so years and ultimately accommodate up to
100,000 mobiles in any area. Opposes any sub-allocation at this time, between
wireline and non-wireline carriers or between air, land or maritime mobile
services. When assurance is given that allocation is imminent, it will launch a
two-phase study and development program looking toward an operational land
mobile system in 5 to 7 years, air-ground system in 6 to 8 years.
Eighteen-month
Phase I will study market potentials, system configuration, and equipment
design and answer in detail many of the questions raised in the Notice.
Specific recommendations will then be made regarding spectrum suballocation. If
Phase I is successful and the FCC concurs with the findings, Phase II will
commence with the final design, construction, and field testing of
production-type equipment and system lay-out. Program contemplates operational
high capacity systems in major cities by 1980.
Says
separate allocations will likely be needed for air-ground and land mobile
systems. Estimates the former will need about 20 MHz; the rest would be used
for land mobile system capable also of accommodating maritime vehicles (public
correspondence only) in inland and nearby coastal waters. Maritime safety
services would continue on existing channels.
Probable
land mobile services include personal telephone, one-way signaling,
teleprinters, and dispatch. Latter requires special market and operational
study under PhaseI; however, initial thoughts indicate certain types of
dispatch will require dedicated frequencies, especially those involving short,
rapid calls, limited area coverage, occasional group calling and slightly less
quality at reduced rates.
Land mobile
system will be based on existing trunking techniques and employ zone or "cellular"
assignment plan. Total spectrum block will be divided into smaller groups of
channels assigned to separate geographical cells. The result is an expandable
grid pattern with frequency reassignment at predetermined intervals. Adjacent
channel and intermodulation requirements will be minimized, resulting in
cheaper equipment.
System
parameters, including modulation type, are yet to be determined. FM promises up
to four-fold utilization advantage over AM due to closer repeat distances.
Multiplex is also possible. Channel-width possibilities vary from 25 to 40 kHz.
Wire facilities will be used wherever possible for control functions to relieve
load on spectrum.
High
capacity system will not supplant existing allocations for many years, if ever.
35 and 150 MHz will be needed for areas of sparse population or difficult
terrain. 450 MHz IMTS, to be implemented this year, may be phased out gradually
in large cities but will continue for many years in smaller communities where
high capacity system is too costly. Nationwide air-ground service being
developed at 450 MHz will gradually be replaced by high capacity system at the
major air hubs.
Possible
frequency sharing with other radio services on geographic basis would be
limited to thinly settled areas and only in strict conformity with final
cellular assignment scheme. TV translators might share geographically but on a
secondary basis, as suggested in report of Working Group 3 of Land Mobile
Frequency Relief Committee. More study is planned under Phase I to thoroughly
consider the merits of sharing.
Serious
interference potential exists from ISM and high-power government radars.
Further studies and tests are needed; however, initial questions concern (1)
enforcing reduced band-width of existing ISM devices, the numbers and locations
of which are largely unknown; (2) ability of mobile service to tolerate
prescribed out-of-band ISM radiation (10 uV/m at 1 mile); and (3) border
interference from Canadian and Mexican ISM operating +/- 25 kHz. Radar presents
problems of receiver desensitization (not frequency dependent) at distances
less than 3 to 7 miles and second harmonic interference (unfiltered
transmitter) up to 55 miles. This assumes typical land mobile receivers and 1
MW radar using a directive antenna and having a 2nd harmonic 30 dB below the
fundamental. Tests must determine actual magnitude of these potential sources
of interference.
American
Trucking Associations, Inc. (ATA)
Identical
to AAA filing.
Association
of Home Appliance Manufacturers (AHAM)
Opposes
reduction of ISM band. It is needed in present bandwidth for microwave ovens
and industrial heating applications. According to industry experts, reduced
bandwidth would prevent economical microwave generation and amplification under
present technology. There are presently some 20,000 microwave ovens in home use
that are not economically adaptable to narrow-band requirements. Emission
levels range up to 10,000 uV/m at 1000 feet. Proposed change could inhibit
future sales prospects of 500,000 units per year when unit prices are reduced
below $ 300.00. Units presently cost upward of $ 650.00.
Birch Bay
Broadcasting, Inc.
Licensee FM
station KERI, Bellingham, Washington, uses STL 942.90 and 943.15 MHz. This
facility, costing about $ 25K, is the only practical means of linking studio
with mountain-top transmitter; land lines have poor fidelity and reliability
due to adverse mountain weather.
STL use
across the country is heaviest in large cities. Los Angeles STLs, now using all
available channels, would have to crowd into half this space under proposal.
Similar conditions exist in most major cities.
Proposal
implies split channelling STLs which would either reduce quality of service or
eliminate operation of one or more subcarriers. Either narrow banding or
frequency changes would impose severe economic hardship on existing users,
especially independent broadcasters.
Canadian
coordination would present serious obstacles to future land mobile use along
border cities such as Seattle, Detroit, Cleveland and Buffalo.
Benefits to
be gained from land mobile use of 5 MHz of STL spectrum is minor compared to
potential use of lower seven and upper 14 UHF TV channels. Such benefits are
completely outweighed by far-ranging detriment to FM service.
California
Public-Safety Radio Association, Inc. (CPRA)
Views
proposed reallocation 806-890 MHz as long range relief, not as immediate
solution to land mobile congestion. Considerable research and testing are needed
prior to mobile service becoming operational at 900 MHz. This band has good
possibilities for data transmission services such as teleprinters, etc. Broad
band system could be very useful to local governmental entities, and should be
considered. Do not finalize any proposals yet, but expand inquiry to gather
more information and to allow interested parties further chance to comment.
California
State Communications Advisory Board
Concurs in proposals
to leave 952-960 MHz as is and to reallocate 806-846 MHz to land mobile
service. Operational fixed in 952-960 MHz is important to state functions.
Reallocation of upper UHF TV channels, though needed for future expansion,
should not be viewed as immediate relief for land mobile congestion. Instead of
sub-allocating this spectrum, it should be made available on developmental
basis to all land mobile services. Developmental provisions should include F2
emission for transmitting hydrological and meteorological data from remote
areas not served by telephone lines. Existing shared government telemetering
frequencies 169.425 and 171.925 MHz are becoming saturated in many areas. Since
land mobile interference to translators will be minimal, reallocation 806-846
MHz should be nationwide instead of limited to metropolitan areas. This would
meet the need for additional telemetering frequencies at remote points.
The Camel
Company
Licensee of
KAML and KEEZ Texas FM stations, opposes STL spectrum reduction on basis it
will cause loss of FM fidelity.
Central
Committee on Communication Facilities of the American Petroleum Institute
Generally
supports proposals as necessary step for future land mobile growth.
Specifically endorses reduction of ISM spectrum to 915 +/- 4 MHz and the
proposed division between private and common carrier land mobile services.
However, believes land mobile use of translator frequencies 806-846 MHz should
not be limited to top 25 cities, but should be permitted on nationwide, coordinated
basis.
Opposes
dedication of separate common carrier frequencies for "private line"
service, on grounds that it would dilute the telephone companies' ability to
provide mobile telephone services to the general public.
Columbia
Broadcasting System, Inc.
Does not
oppose proposals except with regard to reduction of STL band 942-952 MHz.
Present 274 STL assignments (as opposed to 200 mentioned in Notice) represents
four-fold increase in past seven years. Broadcasters' need stems from
accelerating demand for stereo FM and the inability of common carriers to
provide necessary balanced pair of 15 kHz audio circuits for this purpose.
Also, better and cheaper STL equipment is becoming widely available. 21 STL
assignments in Los Angeles saturate available frequencies and would be
extremely crowded if forced into half the present space. Such action would also
preclude or reduce other beneficial and growing uses of these frequencies such
as wireless microphones and camera control transmitters.
City of
Dallas, Texas
Supports
proposals but views them as long range relief of little immediate benefit to
the land mobile services. Suggests frequency committee to coordinate land
mobile and TV translator operations. In meantime, until implementation of land
mobile services in this range, idle frequencies should be made available for
point-to-point operations, such as extensive Dallas computer data network now
in planning.
Communications
Satellite Corporation (Comsat)
Requests
satellite-to-earth sharing with land mobile in 806-893 MHz on basis that LM
receivers operate at much higher signal level than that delivered by small-user
satellites (same proposal made in comments to 3rd Notice of Inquiry, Docket
18294). Detailed sharing criteria can be worked out when LM parameters in this
band are better known. Appears that direct-to-home broadcasting could not share
LM spectrum, but will need major allocation below 806 MHz as recommended in
comments in Docket 18294.
DYMA
Engineering
Opposes
reduction of STL band, especially in the West, because broadcasting is more in
public interest than LM and the proposed action would restrict further
equipment improvements for STL use and for the remote control of broadcast
transmitters.
Eastside
Broadcasting Company
Opposes STL
reduction for same reasons voiced by Birch Bay Broadcasting, Inc., above.
Forest
Industries Radio Communications (FIRC)
Supports
proposals but not as a substitute for lower UHF spectrum. Especially favors
high capacity common carrier development. Lower frequencies are preferred for
wide-area private mobile systems. Endorses LMCC comments, below.
Forestry
Conservation Communications Association (FCCA)
Agrees with
proposals as means of providing future short-distance LM service. No relief for
large area services. Mentions need for more telemetering channels for
hydrological and meteorological data (point-to-point). Believes LM allocation
should be nation-wide and not just in 25 top cities. Translators should be
reduced to secondary status.
General
Electric Company (GE)
Opposes
reduction of ISM band and opposes any firm allocations now that would restrict
our position at space WARC in considering spectrum for space broadcasting (See comments
in Docket 18294). Also recommends close observance of TV taboos should land
mobile be allowed to share translator frequencies.
Reasons for
opposing ISM reduction: (1) 915 MHz is superior in cost and performance to
other ISM bands for heating and cooking; (2) large number of present units are
incapable of conversion (about 1/3 of present 15,000 microwave ovens use this
band, 10,000 more scheduled for production this year); (3) excellent market
potential would be jeopardized. Present $ 20 million market will grow to $ 125
million as units are reduced from $ 650 to $ 250; (4) 20 years' development of
economical magnetron would be wasted since it cannot operate in the proposed
narrow band. Cheapest narrow-band generator would require 5-10 years more development
and even then would cost twice as much as present magnetron; (5) 915 MHz
manufacturers could not compete with those producing 2400-2500 MHz equipment.
Sharing of ISM band with communication services is not feasible due to the high
measured radiation of devices presently in use (up to 10,000 uV/m at 1,000
feet).
GT&E
Service Corporation
Agrees with
proposed allocation. Recommends speedy final action so that equipment
development can proceed. Supports division of spectrum between common carrier
and private services, as proposed. However, believes any leased private line
service should be provided on private frequencies. Subsidiary common carrier
services such as rural radio-one-way signaling, and data transmission
(teleprinters) should be permitted to operate in this band but secondary to
high-capacity mobile service. The need for dispatch operation will be largely
supplanted by teleprinters, and should be permitted but not mandatory in common
carrier system. Air-ground service will need separate frequencies. Except as
mentioned above, shared use of common carrier frequencies by other services
outside the cities is not feasible.
The
Institute of Electrical and Electronics Engineers, Industrial Electronics and
Control Instrumentation Group, High Frequency Heating Subcommittee
Opposes
reduction of ISM band to +/- 4 MHz. To do so would sacrifice substantial
investment in development of saleable heaters, which has proceeded on the faith
that 915 MHz frequencies would continue to be available. Large number of
present industrial and home equipments would be made obsolete because
modification is not practical.
The
International Association of Fire Chiefs (IAFC)
Fully
supports the proposals as a necessary step to meet future LM needs, but
believes limiting land mobile use of translator channels to top 25 urban areas
is unnecessary restriction.
International
Microwave Power Institute (in Canada)
Oppose
reduction of ISM band on grounds it is technically but not economically
feasible to maintain +/- 4 MHz in industrial applications. Present tolerances
in order of +/- 1% at 915 MHz require +/- 2% under operating conditions.
Proposed rules would effectively eliminate 915 MHz for industrial heating
purposes presently divided equally between this band and 2450 MHz.
International
Municipal Signal Association (IMSA)
Identical
to IAFC, above.
Joaquin
Sierra Educational Television Association
Opposes LM
sharing of translator frequencies because of possible interference to present
translators being used to extend San Francisco education TV coverage to schools
in San Joaquin Valley.
Joint
Comments on Behalf of 13 Broadcasters
Specifically
opposes reduction of STL band. Generally opposes reallocation of 115 MHz or any
additional spectrum for LM use without further study into future needs of that
service. Questions common carrier need for 75 MHz in lieu of, say 70 MHz
(846-893 MHz and 919-942 MHz) which would leave STL band intact. Reducing STL
band would result in either half present channels at present channel-width or
the same number of channels at half present channel-width. Either way would be
a hardship for existing STLs. At any rate, enough time must be allowed present
STL users to amortize existing equipment.
KREP
Broadcasting
station, Santa Clara, California, claims it would suffer financial hardship if
STL band is reduced. It has filed an application to use one of the channels
that would be deleted.
Land Mobile
Communications Council (LMCC)
Representing
all land mobile radio users in matters of frequency allocation, recommends
Report and Order to allocate 806-893 MHz and 919-947 MHz to land mobile on
national basis. Translators should be secondary to LM, as per Land Mobile
Frequency Relief Committee, WG-3 report. Views this allocation as long range
resource and not a replacement for lower frequencies needed for large area LM
systems. Only the very large user and common carriers would be able to afford
multiple base stations or repeaters necessary at this order of frequency for
extended area coverage. At least 5-10 years development will be needed for
practical land mobile equipment in this range. Potential LM uses include high
capacity common carrier, private in-plant and local area, private
air-to-ground, locomotive and crane remote control, and car locator.
Land Mobile
Communications Section of the Industrial Electronics Division of the Electronic
Industries Association (LM/EIA)
Recommends
expeditious reallocation of proposed 115 MHz to land mobile in general.
Sub-allocation between common carrier and private or between various private
services should await intensive industry developmental program to explore best
use of these channels. RCCs must not be overlooked in final allocation. An
additional 10 MHz are needed for high reliability, point-to-point fixed
services such as data transmission, teleprinters, intruder alarms, and
slow-scan TV, and to accommodate 450 MHz fixed stations ousted in Docket 13847.
Land mobile must be given priority on translator channels if it is to receive
treatment in future interference conflicts. Limiting LM to urban areas does not
account for potential needs beyond the city, e.g., state-wide communications
systems, wide area hydrological and meteorological data transmission, pollution
control, etc.
Land mobile
use of 900 MHz is severely limited in coverage compared to lower bands. 95% of
present land mobile users need greater range than 5 to 15 miles possible at 900
MHz. This plus greater system costs and development time make 900 MHz
inherently impractical for majority of present land mobile users. However,
advantages in noise, building penetration and antenna size, indicate a
potential for short range, high density services such as police portables
(relayed by mobile-mounted repeaters), one-way signaling (when higher powers
are available), in-plant communications and remote control (noisy
environments), and proximity vehicle locator systems (city blockwide coverage),
in addition to point-to-point services already mentioned.
Above
conclusions and recommendations are supported by data presented in the first 3
of 5 Exhibits attached to EIA's comments. Exhibit 4 derives a practical
channel-width of 60 kHz at 900 MHz using standard + 5 kHz deviation and mobile
and base station stabilities of .0005% and .00025%, respectively. The final
exhibit analyzes the FCC's Technical Division report, "Frequency Division
Multiplex Communications for the Land Mobile Service", and insists that
multiplexing of any kind is impractical in land mobile service - except possibly
for common carrier - with little or no gain in spectrum utilization.
McLendon
Corporation
Licensee of
FM stations in Los Angeles and San Francisco opposes deletion of STL band
942-947 MHz. Present STL band completely saturated in top 10 urban areas.
Improving the crowding is difficult because STLs operate along very nearly
identical paths in most cities. The common use of antenna farms makes channel
reassignment at short separations impractical. Channel splitting would
eliminate important use of STL channels for stereo and SCA services. It is more
in the public interest to continue using this 5 MHz for present broadcast
services than to reallocate it for future private interests.
The
Monterey County California Office of Education
Opposes
reallocation of translator channels to land mobile because of possible
interference to school translator system in Monterey, San Benito, and San Luis
Obispo Counties, from vehicles in the agricultural belt and from trucks along
US 101 between San Francisco and Los Angeles. Ninety of 125 schools in Monterey
County are equipped for educational television. The overall system serves some
70,000 students.
Moseley
Associates, Inc.
Opposes STL
band reduction on grounds that all channels are needed as allocated. STL provides
more reliable, higher quality audio program circuits than wirelines. All except
three STL channels are in use in the Los Angeles area. Co-location of broadcast
facilities in Mt. Wilson area precludes increasing channel use through
directive antennas. Los Angeles is not unique. FCC should not create one
frequency shortage to solve another.
Comparison
of STL utilization efficiency with a high-capacity common carrier system, which
AT&T claims can accommodate 8,000 customers in 50 kHz of spectrum, shows
that at least a comparable number of "customers" are served by the
broadcast station which relies heavily on use of STL. Following this reasoning,
STL broadcast utilization in Los Angeles area is two orders of magnitude
greater than AT&T figures of efficient land mobile utilization.
Reducing
the band to 5 MHz would greatly limit future assignments in any area because of
the effects of harmonic radiation from other broadcast stations near STL
receiving site, which preclude the use of some STL channels.
Motorola,
Inc.
Recommends
reallocation of 806-893 and 919-947 MHz to land mobile in general, and adoption
of 5-7 year ad hoc developmental program open to private users and common
carriers alike, to explore 900 MHz systems and survey market potentials leading
to specific suballocations at a later date. For planning purposes, FCC should
assume 50/50 split between private and common carrier services.
Developmental
grants should emphasize new uses in private sector in lieu of conventional
voice service, largely impractical at 900 MHz due to range limitations. New
uses include low power, portable, in-plant, cellular, and a multitude of
non-voice services such as teleprinter, car locators, data, etc. These uses
would not lessen the need for additional spectrum in the area of 470 MHz for
conventional land mobile services.
Common
carrier authorizations should be limited in scope to telephone exchange mobile
services, and should not be used to extend the telephone monopoly into the
areas of private and dispatch services. Private services differ substantially
from traditional WCC services in terms of message length, permissible channel
loading, type of subscriber, and the need for interconnection with wireline
network. Also, customized private installations do not lend themselves to the
uniform rates schedule employed by WCCs. RCCs would be in a position to provide
any needed private line or dispatch services for hire, although system costs at
900 MHz may be a problem. As a general matter, private systems should be in the
hands of private users.
New
point-to-point voice and data services and expansion of already congested fixed
services will require an additional allocation of about 5 MHz for operational
fixed uses in the vicinity of 950 MHz.
Any consideration
of space broadcasting in this proceeding should be dismissed since neither the
eventual public need for such service, nationally and internationally, nor the
optimum spectrum ranges have been established.
Air-ground
should not be considered until land system is found viable. Because of
different requirements, air-ground will need separate allocation, and 900 MHz
may not be optimum. Shared use of common carrier land mobile frequencies in the
Rural Radio Service may be practicable.
Multiplexing
in private services is not feasible in terms of cost and performance and offers
little gain in spectrum economy. For 10 channel systems, FM/FM and FM/SSB
represent theoretical spectrum savings of 1% and 22% respectively over
conventional systems. These savings diminish as the number of channels per
system increases. Also, comparable noise performance in such systems would
require up to 1000 times as much power as conventional transmitters and be
considerably more expensive. SSB/SSB, though offering as much as 39% increase
in spectrum efficiency, is not feasible for private mobile service because of
the extreme frequency stability required, 0.015 ppm, and the effect of standing
wave flutter on 900 MHz reception in a moving vehicle.
National
Association of Business and Educational Radio, Inc. (NABER)
Sees no
land mobile relief at 900 MHz for 10 years because of extensive development
required and even then the band may not be suitable for most conventional
systems because range is limited to 5-10 miles. It is no substitute for lower
LM bands or for reallocation of 470-512 MHz. Recommends continuation of present
inquiry proceeding and a general allocation to MOBILE service without
segmenting between air and land or private and common carrier. Premature sub-allocation
could restrict development of new services and promote spectrum inefficiencies.
Such action should be delayed pending the outcome of a general development and
resting program open to all land mobile users to explore the best uses of 900
MHz. Some future possibilities include expanded fixed, short range, and
non-voice services such as car locators, alarms, and controls.
National
Association of FM Broadcasters (NAFMB)
Opposes
reduction of STL band on grounds it would cause serious congestion on remaining
channels or, if channels are split, would degrade the quality of aural
broadcasting service, especially for stereo and other forms of multiplexing.
Wirelines are not a suitable alternative.
National
Association of Manufacturers (NAM)
Recommends
holding 18262 in abeyance pending early action in 18261. Soon thereafter, adopt
proposed reallocation to land mobile in general to encourage system and
hardware development; specific sub-allocations should wait until more is known
about future requirements. This docket has promise of meeting land mobile needs
in the period 1980-2000. NAM is already thinking in terms of new uses that will
require additional spectrum, such as low power remote television, vehicle
location, multiplexing, and computer data transmission in mobile system.
Domestic public mobile land, air and maritime services will be needed in
future, as well as "private-line" dispatch service. The latter may be
especially attractive to smaller users who cannot afford to install and operate
their own systems. NAM makes no recommendation as to RCC/WCC mix.
National
Association of Radiotelephone Systems (NARS)
Agrees with
proposed 75 MHz for common carriers. Expresses dismay that FCC would question
whether RCCs should share in this allocation. RCCs have been treated equally
with WCCs in all proceedings past, and the records show even greater
utilization per channel by RCCs than by WCCs. Recommends bands 919-928.5,
855.5-865.0, 883.5-893.0, and 846-855.5 MHz be allocated for exclusive RCC use.
These bands total 37.5 MHz, or half of the spectrum proposed for common
carriers. The following explain why and how RCCs should participate in this
allocation.
RCCs,
because of their private competitive mode of operation, appeal to a "wide
base of subscribers". This makes them well suited and qualified to provide
a 'leased private line land mobile service' mentioned in the Notice. A certain
portion of this spectrum should be reserved for such service. RCCs are already
in direct competition with cooperatively owned repeater stations, and have
requested an investigation into the legality and equity of such "pseudo
common carriers". RCCs can provide the personal type of service most
desired by businessmen and without complexities of wireline interconnection. This
would help bring under tighter regulation the present uncontrolled
proliferation of private transmitters. Because RCCs have direct, personal
control over their facilities, they can insure that "leased lines"
are not wastefully employed, which WCCs cannot. Also, consideration of private
type service by WCCs may be in violation of 1956 Consent Decree.
RCCs also
lock to provide other diverse services such as air-ground, and several forms of
data transmission to and from vehicles.
National Committee
for Utilities Radio (NCUR)
Concurs
with proposed reallocation as long range relief for land mobile. If more
immediate relief for private services materialize in Docket 18261, NCUR does
not oppose 75/40 subdivision between common carrier and private service,
although even this will not meet all 1980 requirements of private services. If,
however, 18261 does not produce effective relief, NCUR recommends an indefinite
delay in any sub-allocation of spectrum in this Docket, until all needs are
thoroughly analyzed. Opposes "urbanized area" restriction on land
mobile use of translator channels, as well as proposed "co-equal"
status of translators. Believes land mobile services, especially power
utilities, etc., will require extended operation beyond city boundaries and
should not be required to protect translators. This agrees with finding of LM
Relief Committee WG3 and with LMCC filing in this Docket.
Proposes
that the portion of the STL band remaining after proposed reduction (947-952
MHz) be opened for operational fixed users. Present 952-960 MHz band houses
1300 operational fixed stations while 947-952 MHz supports only 200 STLs.
Future operational fixed needs will increase rapidly and can share this additional
5 MHz through the use of directional antennas, etc.
NCUR
opposes any provision for space broadcasting in this docket. Such provision
would be exclusive of terrestrial services, and should, if found in the public
interest, come from relinquished UHF - TV spectrum between channels 21 and 69,
inclusive. NCUR opposes separate channels for leased private-line land mobile
service as premature. Market for such service is yet unknown. Utilities require
control of their own system and would not likely subscribe to common carrier
service.
Pacific FM,
Incorporated
Opposes
reduction of STL band from 942-952 to 947-952 MHz, stating such action would be
"injurious to the development of quality FM service, and contrary to the
public interest." STL assignments, most of which have occurred over past
eight years, are increasing exponentially. STLs provide greater reliability and
fidelity than wirelines, though more expensive initially. More FM stations can
now afford STLs than ever before. Commission's proposal would create crisis for
FM broadcasters similar to what exists for land mobile. Shortage of STL
channels already exists in Los Angeles where, as in most areas, common
transmission paths prevent channel reassignment through the use of directive
antennas.
STLs serve
the general public while land mobile caters to private interest. STLs are more
efficient than proposed high capacity common carrier systems, which ATT claims
can accommodate a potential 8000 customers per 50 kHz channels. STLs often
serve, through the FM broadcasting station, many times this number of
"customers". Consideration of public interest and the current trends
in STL usage, indicates the need for even more spectrum than the 10 MHz
presently allocated.
Peninsula
Broadcasting Corporation
Opposes STL
band reduction. STLs are superior to wirelines in audio quality, reliability
and costs. Counting all the people served, STLs use spectrum more efficiently
than other services. They are used extensively in major cities and will rapidly
increase in popularity because (1) wirelines do not always provide a grade of
service capable of meeting FCC broadcasting technical standards; (2) trend is
developing to separate existing co-located studios and transmitters as stations
become more involved in community activities and develop finances for capital
improvements; (3) cost of STL equipment is decreasing as more units are sold;
(4) there is increasing pressure to move AM transmitters away from expanding
residential areas to more isolated locations.
Long
distance relay systems will also develop in this band with the emergence of FM
networks. Experience in the past year with the first such network shows common
carrier relaying substantially reduces signal quality.
Raytheon
Company
Opposes
reduction of ISM band. Comments are summarized in General Electric's reply
comments.
Reeve
Electronics
Opposes
reduction of ISM band because (1) 915 and 2450 MHz are the only "true
microwave frequencies available for industrial heating"; (2) reducing
bandwidth to +/- 4 MHz would significantly if not prohibitively increase cost
of equipment manufacture; (3) extensive and costly developments in this band
have relied on FCC retaining the present allocation; (4) greater public
benefits flow from the use of the ISM band for industrial heating than from a
proportional segment of UHF - TV band which could be reallocated instead.
Richard F.
Lewis, Jr., Inc. (WRFL)
Opposes STL
reduction. Satisfactory, economical wireline service is not available in many broadcasting
areas. It would be unreasonable to delete STL frequencies at a time when
maximum FM growth is expected. Present channels are already heavily assigned in
several large cities. It may even be necessary to enlarge STL allocation to
accommodate future needs. The proposal would merely shift the problem from land
mobile to broadcasting. Cost of equipment change or replacement ($ 5-$ 10000)
could be disastrous to shoestring FM stations. Broadcasters serve larger
segment of the public than common carrier mobile services ever could. To
conserve spectrum, consideration might he given to "leaky wave-guide"
concept for land mobile use.
Rochester
Area Educational Television Association, Inc. (RAETA)
Encloses
its filing in Docket 18262 wherein it asks that UHF channel 61 (or as an
alternative, channel 71) be reserved for full power educational television in
the Rochester, N.Y. area. It requests a decision be made on this matter at such
time as action is taken in Docket 18262. [RAETA's comments in Docket 18262 are
intended to justify the allocation of an additional UHF channel for educational
use in the "inner city" Rochester area, and do not address specific
issues in this proceeding. This is strictly a broadcast matter and, in the
interest of brevity, a summary of their comments in Docket 18262 is not given
here].
Satellite
Telecommunications Subdivision of the Industrial Electronics Division of the
Electronics Industries Association (EIA-Sat)
Recommends
no final action be taken in this proceeding until requirements of space
broadcasting are better defined. Recommends initiation of new docket proceeding
to study space broadcasting and to prepare U.S. position for WARC on this
specific matter.
Though
EIA-Sat has not formally considered the subject of space broadcasting, a
consensus among members indicates that such is now technically feasible in the
following grades of service: (1) weak signals for community reception; (2)
moderate signals for direct home reception in rural areas and other low noise
environments; and (3) high quality signals for direct reception by general
public using special low noise modulation techniques. The latter grade of
service will be available with existing techniques in a few years. However, the
political-social-legal-economic problems need further study, although the
spectrum covered in this docket appears both optimum from technical standpoint
and preferred because of current TV receivers in use. Reference is made to
NASA-sponsored "1967 Woods Hole Summer Study" of the National Academy
of Sciences, National Research Council, which recommends the provision of clear
channels for space broadcast, preferably in the upper part of the UHF band.
The
Scranton Times
Opposes STL
reduction. Claims it makes substantial use of an STL frequency which would no
longer be available if the Commission's proposal is adopted. Commission's
proposal is classic example of "robbing Peter to pay Paul."
Especially agrees with views expressed by Mosely Associates, Inc., in this
docket. (see summary above)
Skyphone
Division, Times Facsimile Corporation
A division
of Litton Industries manufactures and sells airborne equipment (Skyphone) for
public airground radio telephone system in 450-460 MHz band. Supports proposed allocation
of 75 MHz to common carriers and recommends 20 MHz of this be set aside for 300
channel Public Air-Ground Radiotelephone Service. Seven to ten years will be
needed by common carriers to design, construct and implement operational
systems to extend regular, high capacity telephone service to aircraft.
Rapid
growth is expected in both commercial and private aircraft by 1980. Corporate
aircraft represent large segment of future need for air-ground telephone
services. By 1972 there will be as many as 4,500 business jets in use in the
United States.
Recommended
air-ground system parameters set forth in RTCA Document DO-125 are: tone
signaling for initial call-up; capability for either full duplex or two channel
simplex to permit a wide range of sophistication in airborne equipments;
multiple telephone installations in the same aircraft; approximately 270 duplex
channels required; user purchases airborne equipment; for economic reasons
frequencies below 1,000 MHz should be used.
Conclusive
evidence supports technical feasibility of air-ground operation on these
frequencies: RTCA SC - 78 report, 1957, states techniques could be developed
for operation on almost any band below 1,000 MHz; Motorola comments in Docket
11997 and 16073 give results of tests and study which indicate equipment in the
960 MHz region performs well in air-ground services. Skyphone studies conducted
in 1968 substantiate technical feasibility of such service. Airborne equipment
will be just as simple to use as office telephones.
There must
be a smooth 7 to 10 year transition from 460 MHz system to high capacity system
without loss of service.
A definite
need for air-ground exists. It is not just a "rich man's toy" or
"fad." Skyphones have tripled in sales since recent release of FCC
Memorandum Opinion and Order in Docket 16073, regularizing 460 MHz air-ground
service.
For all
above considerations, Commission should set a "course of action
encompassing the uninterrupted continuation of the present Public Air-Ground
Radiotelephone Service and leading to the implementation of expanded service
within a 7 to 10 year period."
Special
Industrial Radio Service Association (SIRSA)
Urges the
Commission to implement the proposed reallocation immediately (with certain
exceptions below). However, these bands should be viewed as long range resource
of limited value and no substitute for spectrum proposed in Docket 18261. Five
to ten years development time needed to evolve present fixed equipment into
something suitable and economical for land mobile use.
900 MHz
land mobile equipment will be limited to small service areas. Many special
industrial licensees such as large construction firms, agriculture and mining operations
require greater coverage than technically feasible at 900 MHz without using
more costly multiple base stations or relays.
Allocation
of the bands proposed in this docket must be cleared of translator stations if
effective land mobile development is to be encouraged. Commission's proposal to
artificially limit land mobile operations to top 25 urban areas does not
account for similar needs in surrounding suburban areas or in special rural
areas where mining and/or agricultural activities are unusually heavy. The
Commission's own LMFRC, WG3 report concludes that translators should be
secondary to land mobile operation on these channels.
Portion of
the common carrier 75 MHz should be held in abeyance until the feasibility of
leased private line and wide-band common carrier services have been fully
proven. Even if Commission decides to implement those new services, SIRSA
doubts the need exists in the common carrier field for 75 MHz. Little relief to
special industrial service can be expected through common carrier system. The
concept of "leased private line" contemplates occasional users such
as subscribers to existing community repeaters and does not conform to most of
the needs of special industrial licensees who require continuous dispatch
service during peak hours. Its value to such licensees is speculative unless it
includes multi-access capabilities without the delay of dialing through an
interchange.
Spokane
Radio, Inc.
Opposes STL
reduction. STLs are essential to "full-service broadcasting." While
FCC recognizes that land mobile relief is needed only in major metropolitan
areas, it seeks to meet that need by pre-empting half the broadcasters' STL
spectrum on a national basis. This is obviously unjust.
Recent
increase in the use of one-way signaling services has diminished the need for
land mobile voice communications. Also, the Commission should carefully
consider the report of JTAC which recommends abandonment of the block
allocation system to help relieve land mobile congestion in the cities. All
alternatives must be evaluated before reallocating any valuable STL spectrum.
Sharing of
channels by several STL facilities in the same general area is not feasible,
although the Commission provides no alternative frequencies for the stations that
would be displaced by the proposed reallocation. The effect would be even more
interference than is likely to occur as a result of Docket 17683 which
authorizes low power auxiliary stations in this same band.
The
Commission ignores the possibility of satisfying land mobile needs in the
"undisturbed bands 890-893 and 919-942 MHz, which are tentatively
allocated for non-Government users", or the Government band 893-919 MHz.
Station
KQED
Educational
TV, opposes sharing of translator channels by land mobile users. Claims undue
interference would be caused to the 28 locally owned translators supplying KQED
signals to school systems and residents in the three hundred mile stretch
between San Francisco and Los Angeles. Interference would come from a large
volume of private and commercial vehicles and would be intensified by the
mountainous highway system in the area. It does not seem practical to attempt
to confine such a large number and diversity of radio equipped vehicles to
specific areas.
There are no
practical alternatives for the service provided by these translators. The
communities are too small for commercial television stations and too dispersed
for cable stations. The schools have invested considerable money in televised
instruction and have come to rely quite heavily on it.
Sylvania
Electric Products Inc.
Opposes
reduction of ISM band to 915 +/- 4 MHz because such action could "greatly
impede the future development of more effective alarm [intruder alarm]
devices." Reference is made to its comments in Docket 13863 requesting all
ISM bands be made available for intruder alarm devices. The public need for
such devices is "overwhelming" and "will become more acute in
years to come."
Tri-City
Broadcasting Company, Inc.
Opposes
reduction of STL band. Such action would impose undue expense and congestion on
existing licensees and reduce the effectiveness of new broadcast uses of this
band, some of which are proposed in other FCC rule making. These include telemetering
and remote control on SCA subcarriers. Telephone lines are not technically
suitable for quality aural transmission. The proposal is especially unfair in
view of the present FCC requirement that the lowest STL channels be assigned
first in any area. Thus the Commission would delete the portion of this band
which is, by its own rules, most heavily used.
As a
general matter, Tri-City also opposes reallocation of translator channels for
land mobile use, on the grounds it would jeopardize future TV development.
"It is not inconceivable that, at some future date, space must be found
for all of the present VHF Television stations in the UHF Band."
United
States Independent Telephone Association (USITA)
Supports
FCC proposal as a necessary step to permit the development of a broadband
common carrier system.
Varian
Associates
Manufacturer
of magnetrons and klystrons for ISM use, opposes reduction of ISM band to 915
+/- 2 MHz [proposal is actually +/- 4 MHz]. Reasons given are (1) center
frequencies of 915 MHz magnetrons fresh off production line vary from 913 to
927, i.e., 14 MHz; (2) for VSWR of 2.5:1 (design value), frequency pull can be
7.1 MHz, or even greater for VSWR values greater than 2.5:1 with
proportionately reduced power. The result of the proposal would be greatly
increased cost and complexity of ISM equipment.
Voss-Tinga
Associates (Canada)
Opposes
reduction of 915 MHz ISM band to +/- 4MHz. There are plans for extensive use of
this frequency in British Columbia and it is already in use for industrial and
consumer heating applications. The proposal would eliminate many of these
applications and "cause a set-back to technological developments in basic
commodity industries." Over 30 industrial generators are in use in the
U.S. and Canada. Many of these would have to be recalled from operating plants.
WDVR, Inc.
Opposes STL
reduction based on the loss of FM broadcasting service that would result. More
and more broadcasters are employing STLs for FM, FM stereo, SCA, and remote
control functions of transmitting equipment. The Commission set aside this band
with the knowledge that it would be some time before it is fully used by the
growing FM service. The functions served by this band as it is presently
allocated are more valuable to the public than the services offered by land
mobile users. If any additional spectrum is in fact needed for public safety
services, less used, less valuable frequencies should be allocated in place of
the STL band. The very portion of this band which the FCC proposes to delete is
most heavily employed by FM broadcasters.
It should
also be pointed out that all STL channels are not usable in any area. For
example, an STL channel must be selected so that it is removed by at least
1.5-2 MHz from the 10th harmonic of any nearby FM transmitter. Channel
splitting would impair the quality of stereocasting. Furthermore, there is
absolutely no need to deprive aural broadcasters everywhere of the use of these
frequencies when land mobile need is stated to be a problem only in the largest
cities.
WFLY-FM
Opposes
reduction of the STL band. At present, the STL frequency is already seriously
congested. Such a reduction would not only place a burden on present users of
STL, but will create additional problems for future FM stations.
WJZZ-FM
Opposes
reduction of STL band. STLs must be used to meet system specifications,
especially for FM stereo operation, and to overcome technical deficiencies of
telephone cables. FCC Rules, � 74.5013(a), require assignment of lower
STL frequencies first, in any area. If any part of the band is to be deleted it
should be in the upper portion, but any reduction will limit the ability of
broadcasters to improve their service to the public.
WMBO-AM
& FM
Opposes
reduction of STL band as effecting new and costly equipment changes on FM
licensees. Request "that the Commission display the same concern for FM
development it shows for the UHF evolvement."
PARTIES FILING JOINT COMMENTS IN
DOCKETS 18261 and 18262
American
Broadcasting Companies, Inc. (ABC)
ABC
reserves comment on proposals until it has seen technical arguments from other
parties. More may be said in reply comments.
All Channel
Television Society (ACTS)
ACTS
generally opposes any sharing of UHF - TV channels with land mobile service.
The Commission's proposals do not give adequate attention to the growth and
effectiveness of UHF television and disruption to that service that would
result from channel sharing with land mobile interests. Nor does the Commission
properly consider the inefficiencies and poor management that has led to
present alleged land mobile congestion, or the possible alternatives that could
bring immediate and long term relief to this situation.
Although
the Commission bases much of its proposal on the assumption that UHF - TV
channels are not being used efficiently, this thought is contradicted by the
Commission's own records.
Not
counting translator stations, the number of UHF - TV stations in use has grown
from 86 in 1963 to 260 at the end of 1968, representing a total increase of
400% in five years. Most of this growth has occurred since 1964 following
enactment of the All Channel Receiver Law, which the Commission itself stated
would not become fully effective for seven years.
On channels
14 through 20, the channels affected by Docket 18261, there are now 68
operating stations and 60 more proposed or under construction. Thirteen
operating stations and 9 construction permits are located in the 25 major urbanized
areas. The Commission is dealing with what will soon become a
"saturated" UHF table of allocations.
In Docket
18262, the Commission does not adequately account for the public need for UHF translator
as shown by rapid growth in recent years. The number of translator
authorizations grew from 575 in January 1967 to 760 in
January
1968 - an increase of 32%. This number increased to 789 during the past 11
months in 1968. Fifty-eight additional translator applications are still
pending.
The growth
of translator service is due to the growing number of primary UHF - TV
licensees and their improved financial status. Also, there has been a
considerable decrease in translator cost and an increase in quality. Now that
the major barriers to the use of translators are being dissolved, the
Commission proposes adverse regulations. Translators provide the only service
to millions of rural Americans, who would otherwise have to pay for television
service enjoyed free by the rest of the country.
All
together, counting pending applications, construction permits, and licenses,
1500 UHF assignments are or will be operational on channels 14 through 83 in
the near future. In general, the proposals would hinder the further development
and growth of UHF - TV and with it the type of diverse programming which the
Commission has sought after in past proceedings. It also diminishes the
potential return to the public from the 7.8 billion dollars invested in all
channel television sets.
These
proposals would damage the UHF - TV industry through interference to existing
licensees and prevention of further growth. The Commission's proposals in
Docket 18261 contradict its own records and policies. Some 37 UHF - TV stations
are already employing one megawatt or more in zones I and II. These and other
stations are likely to want to increase power to the maximum 5 megawatts for
several reasons: (1) it improves the coverage and puts the stations in more
competitive position; (2) the Commission has consistently encouraged maximum
power operation; and (3) UHF licensees are becoming financially able to make
such improvements.
Even if the
best engineering is applied to land mobile operations, there is no guarantee of
interference-free service for either land mobile or TV. Moreover, it is not
likely that land mobile licensees will be financially or technically equipped
or so inclined to abide by whatever sophisticated techniques the Commission
prescribes.
If there is
any question that land mobile use will degrade UHF - TV service, action in
these proposals must be deferred until the questions are resolved and
corrective measures are applied.
Whatever
congestion exists in the land mobile service is due to poor spectrum management
and not to a lack of frequencies. Block allocation has resulted in unused LM
frequencies in "congested" areas. Instead of modifying the block
allocation on an ad hoc basis as in the past, the Commission should implement a
comprehensive plan of interservice sharing. At the same time, it should apply
priorities to limit the eligibility of new licensees and to ensure the future
satisfaction of necessary public safety services. These steps, together with
new technology such as multiplexing, signaling, non-voice communications, etc.
would provide immediate and long term relief to land mobile congestion.
Instead, the Commission refuses to admit its administrative failures and
insists on "grabbing-off" UHF - TV channels to perpetuate the current
wasteful practices.
In
concluding that sharing of UHF - TV spectrum is the only immediate source of
relief for the land mobile community, the Commission ignores evidence as early
as 1956 which indicates existing equipment can easily and quickly be converted
to 900 MHz frequencies. The Land Mobile Frequency Relief Committee WG 3
concludes that 900 MHz land mobile equipment will be costly and require much
developmental work, but it fails to compare these costs with the expense of
engineering and supervising systems that would share UHF - TV spectrum. The
arguments of manufacturers against the immediate use of 900 MHz, as reflected
in the findings of the LMAC, stem more from considerations of existing
inventories and sales than from public needs.
Association
of Maximum Service Telecasters (MST)
This is a
voluminous set of comments and exhibits, over 600 pages in all, designed to
show basically (1) there is no shortage of frequencies in land mobile service
as a whole and therefore no need to tap UHF - TV spectrum; (2) communication
congestion is due to antiquated management practices which, if reformed now,
can bring immediate and long term relief; and (3) that in addition to above
considerations, the Commission's proposals are technically deficient and would
cause serious interference to UHF television and impair its future growth. By
way of proof of these conclusions, the MST filing contains 7 exhibits, totaling
about 500 pages, which are described briefly below:
Exhibit A -
37 pages of "Authoritative Statements on Land Mobile," from reports,
speeches, FCC opinion, testimony, etc., defining the nature of land mobile
congestion and suggesting solutions. Included are quotations from JTAC, DTM,
IRAC, George Haydon of ESSA, General Eddy of JCS, President's Task Force, Lew
North, Commissioners Johnson, Lee, and Hyde, Bernard Strassburg, Bob Johnson of
G. E., "Communications" Magazine, Wall Street Journal, Glenn Peterson
of G. E., Charles Lathey of DTM, Louis Mazo of Justice Department. Taken
together, these quotations are intended to support MST's conclusion that land
mobile congestion is caused not by a lack of channels but by poor spectrum
management practices in dealing with land mobile in general.
Exhibit B -
133 page report plus 100 pages of charts, graphs, etc., entitled "Growth
in Land Mobile Services from 1950-1968 and Projections to 1980" by MST and
Kelly Scientific Corporation. The report considers deficiencies in present
methods of predicting land mobile growth and suggest an "improved" method
which shows that land mobile will not reach actual congestion on existing
frequencies prior to 1994, even without substantial managerial and
technological innovations.
Exhibit C -
"Causes of Congestion in the Land Mobile Radio Services," Exhibit D -
"Recommended Action to Solve Congestion Problems and Exhibit E -
"Practicability of Land Mobile Operations above 900 MHz." These three
reports by Kelly Scientific Corporation (about 160 single spaced pages) profess
to show that land mobile congestion (1) is a symptom of backward policies in
allocation and assignment; (2) can be cured only by sweeping administrative
reforms and better systems engineering; and (3) can be relieved by immediate
use of frequencies above 900 MHz, but only as a stop-gap solution until
comprehensive management reforms are implemented.
Exhibit F -
A 14 page collection of "FCC and Congressional Statements in Support of
Utilization of all 70 UHF Television Channels for Free Broadcast Purposes:
intends to show that 18261 and 18262 proposals are inconsistent with long
standing FCC and Congressional policy of protecting and encouraging development
of a 70 channel UHF - TV system.
Exhibit G -
"Engineering Report Concerning the Reallocation of UHF Television
Broadcast Channels to the Land Mobile Service," prepared by A. D. Ring and
Associates for MST. These 48 single-spaced pages plus almost 100 pages of
charts, graphs, and tables are preceded by a summary stating in essence that
the Commission's proposals would seriously disrupt developing UHF - TV service,
were hastily conceived without proper testing, evaluation, etc. and include
numerous technical defects and problems of inplementation rendering them wholly
impractical.
General Summary
The land mobile
situation was studied for MST by the Kelly Scientific Corporation, Exhibits B,
C, D, and E above, with the general conclusion that land mobile congestion is a
result of poor management practices and not a shortage of frequencies, and can
be cured without the use of UHF - TV spectrum by fundamental reforms in the
Commission's allocation and assignment policies. These same conclusions are
substantiated by reports of the President's Task Force and JTAC, and will
probably be further supported by SRI. All of these authoritative documents
should be thoroughly analyzed before proceeding with Dockets 18261 and 18262.
A central
issue in these proceedings is the projected 1980 needs of land mobile services,
estimates of which the Commission seems to accept from the LMAC without
question and by which it concludes present frequencies, including 450 MHz
splits, will be exhausted in 2-3 years, and that double of triple the present
42 MHz must be found elsewhere.
The
Kelly/MST analysis of land mobile growth statistics (Exhibit B) shows it is not
the growth rate that is "swallowing" available spectrum, and that
there is no shortage of spectrum in the land mobile services as a whole. The
wide difference in this finding and that of LMAC is due to the more valid techniques
used by MST/Kelly and the failure of LMAC to account for errors in FCC records;
10% duplication, 6% expired assignments, and 34% exaggeration in number of
transmitters employed. Even assuming the Commission's records are accurate, the
calculation technique used by MST/Kelly, predicts there will be 2 million fewer
transmitters in 1980 than the 7.3 million figure accepted by the Commission. If
the records are adjusted for errors, it is shown that 1.6 million transmitters
were actually in use in June, 1968, although FCC annual report shows 2.9
million. Using this adjusted figure, MST/Kelly predicts there will be only 2.9
million transmitters in use in 1980. This is partially because land mobile
service has reached maturity and the number of transmitters will increase at a
decreasing rate over future years. This slowdown is not caused by a shortage of
frequencies as LMAC would have us believe. A saturated condition of 60 mobiles
per channel will not exist even in the most heavily populated areas for many years,
and even longer if better management and technical approaches are implemented.
As shown
above, there is no shortage of land mobile frequencies. There are however
instances of communication congestion in the larger cities caused by the
continuation of outmoded frequency assignment and allocation practices. This is
the conclusion reached by Kelly after 7 months of study including a survey of
2700 licensees in the Business, Taxicab, Special Industrial and Police Radio
Services.
The present
block allocation philosophy is an inefficient means of administering land
mobile radio spectrum. It discourages cooperation between land mobile users and
has resulted in "gross under-utilization." The Commission has
permitted proliferation of small inefficient users without considering actual
needs or applying appropriate priorities or technical parameters. Data on when,
where, and to what extent frequencies are being used are non-existent. Without
these facts the Commission has been pressured into accepting inflated statements
of "need" from competing land mobile users.
There must
be a general sifting of land mobile users to separate the higher priority or
necessary services from those that provide merely convenience. The present
allocation is inequitable in regard to the higher priority, public safety
services. Sixty per cent of all land mobile channels and 76% of all
transmitters are commercial. Even within public safety group itself, certain
priorities should be applied to assure availability of channels for police,
fire and other emergency services. Police service represents only 15% of all
land mobile channels and only 9% of the licensed transmitters.
Chaos in
the business service is due to the lax eligibility and technical requirements
and no coordination in the use of frequencies. This "unregulated"
service accounts for 21% of the land mobile frequencies. Additional spectrum
would not improve this situation but would only enlarge the problem and make it
more difficult or impossible to remedy.
It has been
shown that to give additional frequencies to land mobile at this time would
foreclose any opportunity of management reform. Current licensing practices may
have been beneficial 2 decades ago but are hardly appropriate now. Patchwork
adjustment is not the proper approach to reform. Congress must recognize the
need for fundamental changes in spectrum management practices and supply the
necessary funds. If these practices are revised, current land mobile spectrum
could support at least twice the present population. Equipment manufacturers
care only about selling equipment, not about better system engineering or
spectrum savings. The FCC is saddled with insufficient funds and staff to
effectively lead the land mobile industry. The following are recommended as steps
which will solve the land mobile problem without touching TV spectrum:
Establishing
area management and spectrum planning capability in cooperation with local
administrations. This will require extensive monitoring and accurate record keeping
to evaluate channel loading and user needs. It will mean selecting frequencies
to equalize channel loading, and limiting system coverage to just what is
necessary on an individual requirement basis. Service coordinating committees
are far from adequate for this task;
Halt the
proliferation of small user systems. Criteria must be established to determine
which users require private systems and which can be accommodated by common
carriers. Assignments to private users must be based on a system of priorities
which would always ensure frequencies for services necessary to public safety
and well being. A vast majority of commercial users could be satisfied more
efficiently, equitably and economically through common carriers. However, any
wireline common carrier use of the 26 MHz returned from the DTM must be of the
dispatch type provided by RCCs. A gold-plated telephone extension service for
cars and airplanes is not responsive to land mobile needs;
Concentrate
police operations in the 150 MHz band and move lower priority commercial users
to 450 MHz region or the 900 MHz band returned from DTM. This would provide
adequate police spectrum in the region considered most desirable for that use.
It would also encourage closer cooperation between local authorities in
establishing integrated police communications systems.
Portion of
the Kelly studies for MST includes an engineering showing (Exhibit E) that land
mobile operation at 900 MHz is immediately practical. Having carefully analyzed
propagation, equipment capabilities, and costs, Kelly concludes (1) the
differences between 900 MHz and 450 MHz are negligible in areas of dense
population; and (2) 450 MHz equipment can be immediately and simply modified
for 900 MHz at no more than 20% increase in cost.
Howard Head
of A. D. Ring and Associates reported on the technical implication of the
Commission's proposals (Exhibit G). The report concludes that co-channel,
adjacent channel and taboo channel interference will be serious problems in top
25 urban areas, and that the following engineering points have not been given
adequate thought in the Commission's proposals:
In Docket
18261, the Commission assumes IMW maximum ERP for TV while 22% of all UHF - TV
stations currently use more than this. The result will be protection to smaller
than actual service areas - for example, 43 mile Grade B is proposed for
Channel 17 assignment in Philadelphia, as opposed to the 69.5 mile actual Grade
B contour for that station. Certain portions of urbanized areas are closer to
Grade B contours than the separations shown in the proposals. Minimum
separation distances calculated by the Commission often fall at a point within
an urbanized area which actually extends many miles closer to the TV station
being protected, or even within its Grade B contour. The F(50, 50) curves used
to calculate Grade B contours generally produce smaller contours than the
presently accepted methods. The combined effect of multiple mobile transmitters
is not accounted for, and will increase the potential for TV interference. For
example, 20 land mobile transmitters with a duty cycle of 20% will require 18
miles additional separation (Exhibit G pages 23-27). Intermodulation and IF
taboo interference can be a problem in areas of high field strengths in
vicinity of mobile units. The proposals make no provision for moving TV
transmitters to better sites, but essentially "freezes" them at
present locations. Specifying maximum antenna heights for mobile units is impractical
because of terrain variations and the tendency of users to seek higher ground
if necessary.
Adoption of
these proposals in 18262 would cause interference to many of the existing 733
translators and deprive areas not now receiving free off-the-air television. It
would also preclude any regular TV assignments on channels 70-83 in top 25
cities where present assignments are saturated. Commission's plan for co-equal
sharing applies only to private users; common carriers appear to be exempt.
Air-to-ground service would cause wide spread interference to channels below 70
as well as 70-83. (Exhibit G pages 42-43).
Principal
causes of interference are co-channel and image (Exhibit G pages 44-46).
Interference along Canadian and Mexican borders could also be a serious
problem. (Exhibit G pages 46-47, Tables XIII-XIV). These potential problems
show the need for comprehensive field testing and experimentation before any
sharing of UHF - TV spectrum can be implemented.
The
Commission assumes land mobile users can employ engineering techniques to
minimize TV interference. Kelly reports (Exhibit C) that industrial users are
neither equipped nor inclined to employ system engineering. This is evidenced
by the high number of violations in those services. The resulting interference
would inundate the Commission's enforcement facilities.
Docket
18262 is not an appropriate vehicle to consider the complex issues raised by
direct satellite broadcasting. MST's comments in Docket 18294 discuss some of
the problems. As a general matter, however, singling out UHF - TV spectrum for
satellite broadcasting is wholly inconsistent with long standing FCC policy to
foster growth of terrestrial broadcasting.
Corporation
for Public Broadcasting (CPB)
CPB created
by the Public Broadcasting Act of 1967 to foster the greater development of
educational television, opposes any action which would impair the growth or
effective operation of local community outlets comprising the nation's
educational broadcast system. To do other than protect as first priority the
integrity of non-commercial broadcasting would be contrary to well established
national policy.
It is the
Commission's duty to preserve the existing UHF allocations for educational
television. The Commission essentially restricted educational television to the
UHF spectrum in its Sixth Report and Order when it limited educational use of
VHF channels to areas having more than three UHF assignments. Of 633
educational TV reservations 117 are VHF and 516 are UHF. VHF assignments are
almost exhausted with 78 operating stations, 4 CPs, and 12 pending
applications. Thus educational television must look to UHF channels to meet the
challenge of a truly national educational TV system.
The
importance of educational television and the necessity of maintaining and
protecting an 82 channel allocation are emphasized many times in Commission
documents. This need was also emphasized in the All Channel Receiver
Legislation enacted by Congress in 1962. Assurances by Congress and the
Commission have made the national objectives so clear as to declare educational
television spectrum off limits to encroachment by other services.
However.
CPB does not object to a plan to utilize this spectrum more efficiently, if (1)
clear and convincing evidence is given that at least as much protection will be
afforded broadcast stations as now required by FCC rules; and (2) that such
protection be afforded all educational TV assignment now and in the future,
assuming a "saturated" Table of Assignments for channels 14-83. Under
the present proposals there are serious questions about interference that must
be resolved before any sharing is considered feasible.
Now, as the
nation stands on the threshold of adequate financial resources necessary to
develop educational television, the Commission must dismiss any proposals that
would tend to hinder such development.
D. H.
Overmyer Telecasting Company, Inc.
D. H.
Overmyer Telecasting Company, Inc., licensee of UHF station WDHO TV, Channel
24, Toledo, Ohio submits that neither proposal is based on real need. It
appears that the proposals represent a predetermination by the Commission that
UHF - TV reallocation is the only available means to solve frequency congestion
in the land mobile services. There are various other alternatives. In Docket
18261 the Commission has accepted on blind faith the claims of land mobile
interest that 900 MHz frequencies are unsuitable for their needs, when in fact
such frequencies may be far superior. The Commission has not studied the question
of why the present problem could not be better solved through a more efficient
utilization and management of existing land mobile frequencies. Until such
questions are answered, any action of the type proposed herein would be
premature.
The Commission
has not judged the harmful effects which its channel sharing proposal, Docket
18261, will have upon existing UHF - TV service. Based on Commissioner Lee's
dissent and Commissioner Cox's concurring statement alone, the Commission's
proposal should be rejected.
Finally, if
the proposals are adopted, the Commission will have abandoned its long-standing
commitment to foster UHF television. Just six years ago Congress enacted the
all-channel receiver bill relying upon the Commission's own representation that
70 UHF - TV channels were indispensable. Since that time, the Commission has
consistently reiterated its belief that all 70 UHF channels are absolutely
essential for an efficient and competitive national TV system. At a time when
UHF television is finally able to support itself, the Commission proposes to
deprive it of valuable spectrum space in favor of an alleged land mobile need.
The action constitutes not only a complete about-face from existing precedent,
but also a grave disservice to many communities throughout the United States.
Eagle
Broadcasting Company
(Same as
D.H. Overmyer Telecasting Company, Inc.)
Georgia
State Board of Education
The Georgia
State Board of Education, licensee of two UHF and six VHF educational television
stations, adopts and supports the comments filed by the National Association of
Educational Broadcasters.
Indian
River Television, Inc.
(Same as
D.H. Overmyer Telecasting Company, Inc.)
Joint
Council on Educational Communications (JCET)
Docket
18261 is lesser of the two evils. If the Commission firmly decides land mobile
needs justify use of additional spectrum and that no alternative relief is
available, then use of UHF channels must proceed slowing and be in complete
compliance with the rules set forth to protect public television. Because of
the large number of potential users involved, enforcement will be a problem.
Special situations may call for special measures for interference protection,
even more restrictive of land mobile use than provided under the proposal.
Protection beyond Grade B contour must be afforded educational signals on
channels 14-20 which are relayed "off-air" to other broadcast
stations or to ITFS systems.
Docket
18262 should not be adopted. In 1966 (Docket 14229) the Commission set aside
channels 70-83 as a pool of flexibility channels for future television needs.
Needs of public television are even stronger now, especially in larger urban
areas where the Commission's proposal would be felt the most. Diverse educational
needs will require as many as 4 non-commercial channels in major cities. The
Commission has a proposal outstanding to use the upper UHF channels for
low-power community educational stations which should not be abandoned. Rand
studies for the President's Task Force indicate the need for several such
stations in city ghetto areas. New techniques such as "stratovision",
"polycasting", and satellite broadcasting would be compelled to use
these flexibility channels. In the latter case, comments in Docket 18294 by
Comsat, RCA, and GE point to these channels as being optimum for space
broadcasting. Frequencies 919-942 MHz would provide adequate spectrum for space
broadcasting and still leave channels 70-83 for expanding terrestrial systems.
Mercury
Media, Inc.
(Same as D.
H. Overmyer Telecasting Company, Inc.)
National
Association of Broadcasters (NAB)
NAB terms
action proposed by the Commission as drastic and extremely premature, though
some reallocation of upper portion of UHF - TV spectrum may be necessary in the
future. Primary basis for proposals, i.e., predicted land mobile growth to year
1980, is grossly overstated. MST shows that ACLMRS figure of 7.3 million
transmitters is grossly overstated. Based on corrected data of present
authorizations this 1980 figure is reduced to 2.6 million.
The
solution to land mobile congestion does not involve more spectrum. An IRAC
report, June 1968, states in Los Angeles "the immediate problem can be
solved with resources already available."
Management deficiencies
contribute to land mobile congestion. Block allocation is outmoded and results
in situations such as unused Forestry Conservation frequencies in New York City
while at the same time Business channels are seriously congested. Block
allocation should be abandoned in favor of the interservice sharing recommended
in the JTAC report.
Frequency
coordination through voluntary user organization is inadequate and can never
hope to implement the goal of spectrum/area/time sharing. Lack of cooperation between
users in the sharing of spectrum is a serious problem where neighboring local
jurisdictions cannot agree on cooperative use of frequencies for inter-system
communications or, even worse, where a city government fails to integrate the
needs of its own municipal departments into one communications system. In
addition to improved sharing, a greater use of common user or common carrier
services can go a long way toward relieving the congestion.
It is not
true that frequencies above 806 MHz cannot be used immediately by land mobile.
The bands returned from the DTM could be used with very little modification of
existing equipment. A 1956 Motorola report attests to this fact. This is
further supported by the extensive analysis of Kelly Scientific Corporation for
MST which shows that the performance at 900 MHz compares favorably with 450
MHz.
Congress
and the FCC have strongly supported an 82 channel TV system which would be
irreparably damaged if the Commission's proposals are adopted. Sharing of
channels 14-20 is based on faulty engineering which tends to minimize the
interference potentials. There is no reliable data to justify ignoring
"taboos" as done in 18261. The proposed Grade B contours are
unrealistic since they are based on ERP of IMW, whereas FCC Rules permit up to
5 times that much power. Also, the F(50, 50) curves have not been adopted by
the Commission and tend to shorten Grade B distances.
In Docket
15398, the Commission proposed, but has not yet initiated, field tests to
determine the actual interference from UHF - TV sharing. Such tests are
necessary to determine (1) TV interference from strong local mobile signals;
(2) additive effects of multiple mobile transmitters; (3) current validity of
"taboos."
The SRI
studies must be analyzed and supplemented by a comprehensive traffic monitoring
program before any reallocation of UHF - TV spectrum. Traffic monitoring would
provide information on the type of communications on land mobile channels,
which together with the channel loading data obtained by SRI, will yield a
clearer picture of land mobile use.
Further
reduction of STL frequencies 942-952 MHz must not be adopted. Though present
use may be low statistically, industry growth and technological developments
will greatly increase it. Docket 17873 for instance proposes a new use of these
channels for remote control of transmitters. STL operations are far superior to
wireline facilities in reliability and in the quality of stereo and SCA
transmission.
National
Association of Educational Broadcasters (NAEB)
Dockets
18261 and 18262 must be considered together and in the context of earlier
Docket 14229 dedicated to expanded use of UHF channels.
The
Commission has always held the view that channels must be reserved for
educational interests to prevent their having to compete with commercial
broadcasters. Use of these reserved channels has progressed with the aid of
Congress though the Educational Television Facilities Act of 1962, the
All-Channel Television Receiver Act of 1962, and the Public Broadcasting Act of
1967. Since VHF reservations have been filled, educational television now
depends almost entirely on the use of UHF facilities for future growth.
Several
issues and proposals affecting the future of educational broadcasting are outstanding
in Docket 14229 which must be resolved before embarking on radically different
proposals for the use of UHF channels. Unresolved questions involve possible
revision of the UHF table of assignments, use of channels 70-83 for low power
community educational stations, and exclusive use of channels 70-83 for
translators.
NAEB would
support proposals designed to relieve land mobile congestion if it could be
assured that adequate channels would be reserved for educational needs and that
existing assignments are not adversely affected. But such is not the case in
the instant proposals. An engineering report prepared for NAEB by Jansky and
Bailey concludes the Commission did not apply appropriate engineering in the
proposals of 18261. In computing separation distances, existing curves, not the
F(50, 50) curves, must be used together with a maximum ERP of 5 MW instead of
the assumed 1 MW. All terrain between transmitter and Grade B contour must be
considered, not just from 2 to 10 miles as proposed. Insufficient showing has
been made that all "taboos" other than adjacent and co-channel
protection can be ignored. Nor has it been shown what the combined effect of
multiple mobile transmitters might be on television reception. An in-depth
study of these problems must also take into account the effect on existing and
proposed assignments on channels 21-35 in addition to those on channels 14-20.
Of particular concern is the probable interference to assignments on channels
21 and 22, similar to what is now being experienced on channels 14 and 15 from
land mobile operations in the 450-470 MHz band.
Pending
evaluation of current studies into allocation and assignment practices in the
land mobile services by the FCC staff, JTAC, SRI, and the President's Task
Force, the present proposals should be treated as a tentative solution, i.e.,
use only as many channels as necessary for immediate relief. 18261 should not
be treated as a 10-20 year solution. First, however, an experiment should be
conducted to determine the actual effects of sharing. The Commission must
proceed cautiously with sharing of TV channels by other services. It must be
careful not to set a hasty precedent that will open the way for even greater
demands.
Docket
18262 poses an even greater threat to educational television through the
complete and irrevocable loss of channels 70-83. The Commission should adopt
NAEB's proposal (Docket 14229) for a saturated assignment plan including all 70
UHF channels. This approach is more consistent with educational interest than
considering channels 14-69 and 70-83 as separate allocations for separate
purposes. The Commission's proposal in Docket 14229 to use the upper 14
channels for low power broadcast stations is not responsive to the needs of
educational stations to provide wide area coverage as well as coverage to local
school systems. Instead, the upper 14 channels should be reserved for full
power educational use to provide the diversity of special programming now
deficient in many areas due to a lack of educational assignments. At the very
least, the Commission should revise its proposals in Docket 18262 to provide
some reservation of full-power channels for educational television.
The
Commission has not presented adequate justification for a departure from its policy
to foster the future development of educational television. It has not
substantiated the alleged need of land mobile users for UHF spectrum. The
Commission's proposals come at a time when educational television is on the
verge of rapid expansion and contradict the proposals of Docket 18433 to
require comparable ease of tuning for all channels.
National
Broadcasting Company, Inc. (NBC)
Conditions
leading to adoption of the All Channel Receiver Act of 1964 have not changed. An
82 channel TV system is still needed. But now, even before the full effects of
the above Act are felt, the Commission proposes in Docket 18262 to reallocate
17% (14 out of 82) of these channels to meet immediate and long range land
mobile needs which have not been substantiated. If it is later found that
replacement of these 14 channels must be made elsewhere in the spectrum, the
nation would face another receiver compatibility crisis. Whatever needs are
found to exist for additional public safety frequencies can be met through
interservice sharing together with the use of the 26 MHz returned from the DTM.
No
reduction should be made in the 942-952 MHz STL band. Recent equipment advances
will stimulate greater demands for this service. In addition to regular STL
operations, low power microphones create saturated conditions in this band
during major news events. Crowding would be intolerable if only half this space
were available. Can it be that questionable future land mobile needs outweigh
the existing needs of broadcasters who have developed the necessary equipment
and are presently using these frequencies efficiently and for valuable
services?
If
implemented, the proposals in Docket 18261 would result in severe interference
to TV stations. Proper attention to engineering is not evident in the
proposals. The separation distances are based on unrealistic maximum powers for
TV stations and on unproven propagation curves. Taboo interference problems are
dismissed in an off-hand manner without proper analysis.
Nationwide
Communications, Inc.
(Same as D.
H. Overmyer Telecasting Company, Inc.)
North
Alabama Broadcasters, Inc.
(Same as D.
H. Overmyer Telecasting Company, Inc.)
Philadelphia
Mobile Telephone Company
Philadelphia
Mobile agrees with the proposed reallocation for public as well as private land
mobile users.
In
contradiction to the basic principles of spectrum management, valuable
frequencies in the UHF band are lying fallow in metropolitan areas where land
mobile services are severely congested. To divert a small portion of this
spectrum to land mobile would not materially affect the growth of TV service.
The
Commission must not be swayed by statements that land mobile radio is but a toy
or status symbol. The vital public interest in this service is well established
in FCC records.
Philip Y.
Hahn, Jr.
(Same as D.
H. Overmyer Telecasting Company, Inc.)
Small
Business Administration (SBA)
Commends
the Commission on its proposals in Dockets 18261 and 18262, but views them both
as only temporary solutions to land mobile frequency congestion. Improved land
mobile techniques will provide no meaningful relief. Long range needs can be
met only by extending the geographic reallocation proposed in Docket 18261 to
all UHF - TV channels that, although "assigned", are not presently in
use in the top 25 urban areas. There is no justification for reserving idle
"assignments" in major cities for future TV use which may never
materialize. Limitation such as 6 feet AAT and 5 watts ERP are unresponsive to
land mobile requirements and must be relaxed if any measurable relief is to be
provided in such areas as New York, Chicago and Los Angeles. The Commission
should further re-examine the entire allocation structure and carefully weigh
the needs and public benefits of the various radio services. In comparing TV
with land mobile, it might be well to weigh the value of the typical commercial
TV programming (a second re-run of "I Love Lucy") against that of
improved service by ambulances, fuel and maintenance vehicles, etc.
Steel City
Broadcasting Company
(Same as D.
H. Overmyer Telecasting Company, Inc.)
John J.
Tibiletti
Opposes
either sharing in 18261 or reallocation in 18262. Translators extend service to
areas unable to support local TV stations. The upper channels also provide the
only potential growing space for UHF - TV. Some possible future uses of these
channels include low power TV outlets and satellite broadcasting. More
consideration must be given to limiting land mobile eligibility and improving
its technical standards.
WBJA-TV,
Inc.
(Same as
D.H. Overmyer Telecasting Company, Inc.)
Westport
Television, Inc.
(Same as
D.H. Overmyer Telecasting Company, Inc.)
PARTIES FILING SEPARATE REPLY
COMMENTS IN DOCKET 18262
Aeronautical
Radio, Inc. (ARINC)
Expresses
interest in the AT&T's proposed air-ground service but cannot support the
allocation of 20 MHz for that purpose without further evaluation of the actual
system and its potential impact on the air transport industry.
Association
of Home Appliance Manufacturers (AHAM)
AHAM agrees
with those who are using 915 MHz for microwave heating that reduction to +/- 4
MHz would render the band useless for its intended purpose. It disagrees with
Voss-Tinga's proposal to cut ISM to +/- 10 MHz (this proposal was later
withdrawn by Voss-Tinga itself). Because of the many technical questions raised
in the comments about the immediate usefulness of 806-960 MHz for land mobile
communication, AHAM recommends the proposals be dropped until these matters are
thoroughly resolved. It offers to work with the Commission to reduce the amount
of spectrum required for microwave heating.
American
Telephone and Telegraph Company (AT&T)
There is
unanimous agreement among those responsible for land mobile service that the
proposed frequencies are needed and usable for land mobile purposes; that 5-10
years will be required to develop suitable equipment; and that the proposed
allocation should be made now so that appropriate study and developmental
programs may proceed. Opposing arguments - that land mobile does not need more
spectrum or that existing services which are now allegedly using these
frequencies efficiently would be disrupted or deprived of future growth - have
already been considered specifically by the Commission and rejected in the
Notice.
Improvements
in land mobile management would provide some degree of relief, but it would be
minimal compared to the need for additional spectrum. Better utilization
practices are equally applicable to all services including broadcasting. In
fact, land mobile has a uniquely impressive record of striving to increase
spectrum efficiency. Similar advances in other services such as narrow banding
the STL allocation, reducing ISM bandwidth, and increasing ISM use of 2450 MHz
in lieu of 915 MHz are all desirable steps in coping with increasing demands on
the spectrum.
AT&T
repeats its earlier position that a firm allocation of 75 MHz to the common
carrier service is necessary if funds are to be committed to the study and
development of a high-capacity system. There is no legal impediment to WCCs
providing a dispatch service, as contended by Motorola and NARS. Both direct
and operator dispatch systems have been provided by AT&T since 1946. The
tariffs for a high-capacity system would offer a communications service rather
than the leasing of lines or equipment.
Any
immediate suballocation of the common carrier spectrum between WCCs and RCCs
would be arbitrary without the benefit of studies to define the optimum
bandwidths required by the services to be accommodated. Suballocation should be
deferred for 18 months until completion of phase I of AT&T's study and
exploratory development.
Communications
Bureau of the City of Milwaukee
Submits a
statement by Telcom, Inc. which gives the interim results of recent tests
(Winter 1968-1969) performed in Milwaukee for purpose of comparing 150, 450 and
950 MHz for teleprinters. Included are curves showing that little difference exists
in signal path loss for the three bands. Based on these results "it
appears that. . . using any of the three frequency bands is practical." It
emphasizes, however, that the tests were run only with base-to-mobile
transmission, and that no conclusions should be drawn for the reverse
situation. It is also noted that foliage losses were minimum during the winter
months when the tests were run.
General
Electric Company (G. E.)
G. E.
reiterates its original position that 915 +/- 25 MHz should not be reduced
because it is impossible under existing technology to produce an economical
microwave generator for home or industry capable of +/- 4 MHz, or any bandwidth
less than the present. Tens of thousands of microwave ovens are in use in homes
throughout the country. The locations of these units are largely unknown, and
their conversion to +/- 4 MHz would not be practical.
G. E.'s
position is supported by Raytheon comments which state in short that (1) a
tolerance of +/- 25 MHz is needed for magnetron operation; (2) reduction of
bandwidth would prevent multimoding and result in uneven illumination and
heating; (3) tighter tolerances would increase rejection rate by 20% in
magnetron production, require tighter temperature tolerances, and necessitate
the use of ferrite isolators or circulators to prevent frequency changes due to
load variations; and (4) the net result would be a doubling of cost over
present devices.
G. E. also
summarizes comments by Voss-Tinga Associates stating similar views regarding
the detrimental effects of the proposal, but offering a compromise proposal to
reduce bandwidth to +/- 10 MHz. This is not a sound proposal since load
variations alone cause a fundamental frequency deviation of 26 MHz (+/- 13).
API's support of the Commission's proposal without suggesting how it might be
done, shows it obviously is not acquainted with the technical and economic
problems involved. Before any reduction of 915 ISM band is considered, new
basic techniques must be developed, possibly through a joint industry/FCC study
program.
G. E. also
reaffirmed its position that final reallocation of UHF-TV spectrum may preclude
any future consideration of this band for space broadcasting. It also urges
close adherence to TV taboos in any land mobile sharing of translator channels.
International
Association of Fire Chiefs (IAFC)
The
evidence in these dockets proves beyond doubt that land mobile needs are
immediate and that additional spectrum is required to enable either short or
long term growth. Frequency congestion must be remedied if the nation's fire
protection services are to be fully effective.
International
Municipal Signal Association (IMSA)
Despite
what AMST has said, the 26 MHz returned from the DTM is not enough to meet the
needs of land mobile. It is clear from the comments of equipment manufacturers
and other experts in the land mobile field that 900 MHz will not be immediately
usable. Regardless of what growth projections are used, congestion is a fact in
the cities and it will not improve until additional spectrum is provided.
Land Mobile
Communications Council (LMCC)
LMCC is not
unsympathetic to the needs of educational television. However, it assumes that
the FCC fully considered these needs and the remaining issues in Docket 14229
before issuing the proposals in this proceeding. If there are conflicting
issues in these dockets affecting the use of 806-890 MHz which have not yet
been resolved, interested parties should be afforded another opportunity to
comment.
Despite the
arguments of AMST, it is clear that substantial land mobile spectrum is needed
in addition to the 26 MHz returned from the DTM. The unanimous position of land
mobile interests is that frequencies in the 900 MHz range can meet certain land
mobile requirements. This band can even be used for conventional two-way
communications over wider areas if potential users are willing to pay the
higher costs of relay stations. However, there is no equipment available off
the shelf which can be pressed into immediate mobile service at 900 MHz. As
shown by EIA and others, at least 7 to 10 years will be needed to develop
suitable and reasonably priced equipment for this band.
Land Mobile
Communications Section Industrial Electronics Division Electronic Industries Association
The Section
confirms its original statement that (1) frequencies near 900 MHz, though long
term in nature, should be allocated to land mobile immediately; (2) the
Commission should adopt an extensive developmental program to determine technical
and economic feasibility of 900 MHz operation and to develop marketable
equipment; (3) the Commission should not suballocate these frequencies either
within the private services or between common carrier and private service until
a developmental program is complete.
The Section
agrees with ISM industry that no sound engineering solutions have been offered
to the problem of reducing 915 MHz band to +/- 4 MHz. To go ahead with the
proposal would conflict with the state-of-the-art. In the interest of spectrum
conservation, however, industry and government should study this problem
further to see if the band can be reduced in the future.
AMST's
block diagram of 450 MHz equipment modified for 900 MHz use is an inaccurate
drawing of an experimental set-up used in the laboratory 10 years ago, and
illustrates their lack of technical knowledge of land mobile equipment. MST's
data on propagation is obviously wrong when it shows a 150 MHz 110 watt base
station with a 100 foot 6 db antenna as having a coverage of only 3.18 miles.
Other data, such as receiver noise figures, ambient noise levels and mobile
antenna heights are inconsistent with land mobile technology. MST's
consideration of "flutter" is based on AM systems and would not apply
to FM techniques used in land mobile.
The Section
adheres to its original belief that 7-10 years is required for 900 MHz
development. Actually, the full use of 900 MHz will closely parallel that of
450 MHz, taking 10-15 years. Equipment in the latter band is still more costly
than in lower land mobile bands. Some costs involved in conversion to 900 MHz
are (1) an additional multiplier stage and resonant cavity in the receiver
oscillator-multiplier chain; (2) an increase in the RF preselector for adequate
spurious response control; (3) a frequency change in the first IF; (4) an
additional transmitter frequency doubler and output resonant cavity; and (5)
changeover of the IPA and PA output circuits to resonant cavities. Such changes
would require re-tooling and development outside the time frame of immediate
land mobile relief.
MST's
naivete is further illustrated by its contention that land mobile congestion
can be lessened through the use of common carrier provided dispatch service.
Experience has shown common user systems wasteful of spectrum and less
effective than private systems. Such system should not be considered in this
proceeding.
Motorola,
Inc.
Motorola
addresses its reply to the comments of AMST and principally Exhibit E of Part
III regarding the feasibility of using 900 MHz for land mobile service. As a
general matter Motorola reaffirms its position that the proposed allocation of
115 MHz to the land mobile service is a necessary step in the efficient
development of this part of the spectrum, but is not a substitute for immediate
relief in the form of lower UHF-TV channels.
Motorola
adheres to the position that a 7 to 10 year leadtime will be required at 900
MHz in order to fully assess the usefulness of the band for land mobile
operation and to produce marketable equipment. Present data on coverage at 900
MHz is inadequate. However, based on what is now known, conventional private
services will be limited to about 35% coverage reliability over a range of 4 to
5 miles. AMST's statement on the time in which 900 MHz can be used for land
mobile is misleading and incorrect. The following sequence of events outlined
by AT&T will also apply in the private sector over the next 5 to 7 years:
(a) exploratory work, (b) subservice, (c) equipment design, (d) field trials, (e)
market studies, and (f) prototype system.
AMST's
comments concerning the ease of modifying 450 MHz equipment is based on a 1952
experiment conducted by Motorola. Land mobile equipment now in use cannot be
converted by straight forward means for the following reasons: (1) compact
equipment layout does not provide space for added components; (2) present 450
MHz power tubes (8643) have little or no output at 900 MHz; (3) the old
equipment which was converted for experimental use employed 2C39 power tubes
(operational to 2GHz) which have since been replaced by the more rugged 8643
tube. Modifications necessary to convert an existing 450 MHz receiver would
seriously degrade (up to 36 db) its spurious image performance. The latter will
be especially serious on frequencies immediately above the UHF-TV channels. It
is clear that an entirely new line of equipment will be required to provide
satisfactory performance at 900 MHz. Such equipment would typically employ
cavity resonators and other mechanical configurations much more complex and
costly than lumped constant and printed circuits used in lower bands. This
difference in cost will be a factor even after suitable equipment has been
developed for 900 MHz.
AMST
concludes that the 26 MHz returned from the DTM will satisfy the immediate and
long term land mobile needs if the Commission will make it mandatory that
private users subscribe to common carrier dispatch service. First, there is no
proven need for common carrier dispatch service. There are also legal and
technical questions pointed out in Motorola's filing in Docket 11997 and which
are summarized in the original comments in the present proceeding.
National
Association of Manufacturers (NAM)
NAM
supports the proposed reallocation and recommends that a portion of the 806-960
MHz band be reserved for industrial telemetry purposes such as those permitted
by footnote US5 in the Government band 217-219 MHz. The growing requirements
for telemetry in a variety of research and development programs in such fields
as oceanography and automobile safety warrant an exclusive telemetry
allocation. However, NAM is not yet prepared to suggest exactly how much
spectrum will be required.
National
Committee for Utilities Radio (NCUR)
NCUR terms
as unreasonable and unrealistic AMST's contention that the 26 MHz returned from
the DTM will meet whatever immediate and long term frequency needs exist in the
land mobile services. Statements by equipment manufacturers and common
carriers, who have the greatest motivation and expertise to develop this part
of the spectrum for land mobile service, unanimously agree that it will be many
years before suitable and reasonably priced equipment will be available. Even
so, it is well substantiated that frequencies in the upper UHF band, though
suitable for specialized applications, cannot satisfy the bulk of land mobile
requirements now being served on frequencies below 470 MHz, and which can be
served in the future only by reallocation of channels 14-21.
Special
Industrial Radio Service Association, Inc. (SIRSA)
Allegations
by AMST that land mobile licensees require no additional spectrum are
contradicted by its own recommendation that 26 MHz returned from the DTM be
given to the land mobile service. The overwhelming evidence and the
Commission's own calculations indicate that substantially more than this amount
will be required. AMST's statements regarding the ease of producing suitable
land mobile equipment in the vicinity of 900 MHz are overshadowed by the
authoritative statements of Motorola and others most familiar with land mobile
equipment and design and manufacture. AT&T also approaches the use of these
frequencies with caution and estimates a developmental program ranging from 5
to 7 years.
Uncertainties
expressed in comments by AT&T and others regarding the development of a
common carrier dispatch service, add weight to SIRSA's original suggestion that
a portion of the proposed common carrier 75 MHz be held in reserve until more
is known of the eventual needs of all land mobile services in this part of the
spectrum.
With regard
to NAEB's concern over the unresolved issues in the Commission's Docket 14229,
it must be assumed that these matters were all adequately considered by the
Commission before the instant proposals were issued. If not, the Commission
should afford interested parties another opportunity to comment on its ultimate
proposals for the use of the 806-890 MHz band.
PARTIES FILING JOINT REPLY COMMENTS
IN DOCKETS 18261 & 18262
All-Channel
Television Society (ACTS)
LMCC's
proposal for outright reallocation of the lower 7 channels ignores (1) probable
loss or reduction of TV service in many areas; (2) degradation of the quality
of service; (3) loss of viewers who are just now becoming familiar with UHF
stations; (4) public investment in all channel tuners.
The
overwhelming evidence now before the Commission is that the allocation of any
additional spectrum to land mobile would not solve the basic causes of
congestion which are antiquated allocation policies and a lack of user
discipline. Actual assignment congestion is placed in serious doubt when, as
AMST shows, only about 66% of licensed land mobile transmitters are actually in
use. Certainly a massive relocation and disruption to UHF-TV such as LMCC
proposes cannot be justified until all other approaches have been fully
exhausted, which is far from the case now. AMST has shown that better
management practices could double present occupancy in portions of the land
mobile spectrum. The hundreds of pages of land mobile comments have failed to
show any facts that present frequencies are being used efficiently.
LMCC does
not attempt to solve the interference problems it foresees under the
Commission's sharing proposals, but instead uses this as a justification for
outright reallocation. It makes this recommendation while at the same time
conceding that the Commission does not have sufficient facts on which to base a
final allocation.
ACTS
recommends the Commission (1) evaluate its land mobile records; (2) require
usage data from land mobile licensees; (3) undertake program of traffic
monitoring; (4) suspend the present system of land mobile block allocations
while providing necessary channels to essential public safety users.
American
Broadcasting Company (ABC)
Solution to
the immediate land mobile congestion problem does not rest in the allocation of
additional frequencies, but as convincingly shown by SRI, AMST and others, in the
reform of land mobile operating and licensing practices. The impracticality of
the Commission's proposal in Docket 18261 is clear from the almost unanimous
opposition received from both sides. The broadcasters are concerned about the
strong probability of serious interference to TV reception, while land mobile
users complain they would be so restricted that the frequencies would be of
only meager value. The LMCC counterproposal for outright reallocation of the
lower 7 channels would cause a severe disruption of broadcasting service and is
wholly inconsistent with Commission policy to foster UHF development. If the
Commission ultimately decides that additional land mobile frequencies are
required, it should look to the upper UHF channels which will probably never be
used as extensively for television as the lower channels. By the time land
mobile management reforms have been implemented and additional frequencies are
needed for future development, suitable equipment will be available for use in
these higher frequencies.
Association
of Maximum Service Telecaster (MST)
The key
point MST wants to make is that there is general agreement between SRI, the
President's Task Force, and JTAC that management "reforms and improvements
would conserve enormous amounts of spectrum presently allocated to land
mobile," even if such reforms are "purely short-range" in
nature. Thus there is no need to reallocate or share UHF-TV spectrum. Should
some additional land mobile spectrum be required until management reforms are implemented,
immediate use can be made of the 26 MHz returned from the DTM above 900 MHz.
To
substantiate its conclusions, MST draws heavily on the findings of SRI in its
interim report. Some of these conclusions and the supporting pages from Part B
of the SRI report are: land mobile congestion is caused not by a lack of
frequencies but by uneven channel loading (page 61); contributing to this
problem are obsolete block allocation policy (page 61), inaccurate data (pages
7, 45, 50), and inadequate frequency coordination (page 62); these are in turn
the results of insufficient FCC funds and staff (page 61); the immediate and
long range cure lies not in the reallocation of TV channels but in increased
interservice sharing (pages 61, 62) and a greater reliance on communication
service companies, in combination with technological advances such as
multiplexing, trunking, car location, data services, etc.
SRI also
points out that the 220 "tertiaries" in the 150 MHz band are fully
usable in urban areas, since 101 of them are already in use in Detroit and 142
in Los Angeles.
The
remainder of the MST reply comments focuses on the positions and counter
proposals presented in land mobile comments.
Growth
predictions included in the LMAC report and those submitted in Dockets 18261
and 18262 by various land mobile entities (LM-EIA, and NAM) are mutually
inconsistent. For example NAM predicts 150 thousand transmitters in the
manufacturers service by 1980, LM-EIA predicts 250 thousand transmitters in
that service by 1980, and LMAC predicted 1.3 million same service same date.
The total number of industrial transmitters licensed by 1980, NAM predicts will
be 3.05 million, LM-EIA predicts 4.98 million, and LMAC predicts 7.90 million.
Such differences and confusion are obviously the result of inaccurate data and
shallow analyses. None of these predictions take into account that the area of
the major cities is expanding even faster than the population. The result will
be the ability to reassign land mobile frequencies on a geographical basis
within the same urban complex, thus easing rather than increasing congestion
problems. In other words, land mobile needs are more a function of urban
population density which is increasing much slower than overall population, or
even declining.
In contrast
to what land mobile comments would have us believe, wide coverage is not needed
by most land mobile users. Little attention is given to tailoring ERP, antenna
height, etc. to actual system coverage requirements. This problem is also mentioned
in the SRI report. Large systems requiring wide coverage might achieve more
efficient channel use through multiple low powered repeaters. Small users would
be served best by communication service entities such as RCCs.
Frequencies
above 900 MHz are immediately usable by land mobile. Reluctance of land mobile
users to accept this band is based on alleged long development time, short
range coverage, high cost, and inferior performance. However, as mentioned
above, wide area coverage is not a major requirement. Also, AT&T has stated
in its comments that 900 MHz frequencies appear to be completely satisfactory
for land mobile use. General O'Connell stated before the Senate that 900 MHz is
potentially usable within two or three years. Kelly Scientific Corporation
shows (Exhibit 2) that coverage and performance at 900 MHz is comparable to 450
MHz in urban environments. "The great equalizer" is the immunity of
900 MHz to man-made noise. Foliage losses, though increasing somewhat with
frequency are not very important in the city. Shadow losses are diminished at
the higher frequencies due to "fill-in" between tall buildings. In
overall coverage, a 1952 report by W. R. Young of Bell Telephone Labs
demonstrates on the basis of extensive field trials that 900 MHz compares
favorably with 150 and 450 MHz. Using ERPs of 250 watts, 125 watts and 250
watts respectively at 150 MHz, 450 MHz and 900 MHz, Young found that the
probability of receiving at least commercial quality signals over a 15-23 mile
suburban range are 45%, 64%, and 52%, respectively. The urban environment would
be even more favorable to 900 MHz because of decreased foliage loss. AT&T
states that powers of several hundred watts per channel are attainable at 900
MHz, again contradicting the arguments of the private users.
New Land
mobile uses alleged to require additional spectrum can be accommodated on
present land mobile or operational fixed channels. These uses include helmet
radios, wrist radios, vehicular repeaters, hospital emergencies and data transmissions,
remote control, etc.
The Cullum
proposal for outright reallocation of channels 14-20 is technically unsound and
unworkable. Analysis of this proposal was prepared for MST by Howard Head of A.
D. Ring Associates (Exhibit 4). It is concluded that all existing UHF
assignments on these channels cannot be accommodated on channels 21-69 as
claimed by Cullum. To ignore or reduce taboo separations due to IM, IF, and
image considerations would create intolerable interference to existing
stations. Contrary to Cullum's assumptions, the data in Lab Report L-6201
indicates 20 miles is a conservative TV station separation to protect against
the effects of intermodulation. As for IF beat interference this same data
shows that 20 miles separation, which Cullum assumes can be ignored, is
actually insufficient protection. Reducing the separation distances for image
frequency protection would increase what is already substantial interference
from this source. The situation is even worse for color sets which have poorer
image rejection than do the black and white sets on which the present
separation distances are based.
Even if the
Cullum approach were technically sound, which it is not, 15 TV assignments
would be lost in 14 cities totaling over 4 million in population. Moreover,
coverage of present stations forced to move to higher channels would be
reduced. To regain this coverage would require costly modifications such as
increased power or transmitter relocation. The cost of changing frequency and
making other necessary adjustments could range up to $ 500,000 per station
instead of $ 125,000 estimated by the land mobile advocates. The cost for 77
stations could thus be as much as $ 39,000,000. This does not account for
modification or reorientation of public receiving equipment in schools or in
cable or translator systems. Nor does it account for lost advertising and the
public's association of a TV station with its present channel number. The
expenses of changing channels would be ruinous for many UHF stations operating
with marginal finances.
Part of
MST's filing, a report by economists Robert R. Nathan Associates, criticizes
the FCC proposals as not being supported by studies necessary to make informed
judgments. It also criticizes LMAC's presentation on the relative economic
values of land mobile and television as not worthy of consideration. It assigns
through a system of "shadow pricing" a value of $ 101.6 billion
annually to television broadcasting, making it "the most efficient and
productive element in the economy." It endorses the AMST suggestion that
common carriers can provide more efficient and beneficial land mobile service
than can private users.
In the
latter regard, an analysis is made of the relative costs and benefits of the
private land mobile system versus common carrier dispatch service. It is
concluded that a common carrier system would be viable if it has at least 1000
mobile units (200 customers with 5 units each). Such a system will require
several frequencies and must use multichannel mobile units to realize full
benefits of uniform channel loading. Although very large private users may find
their own systems more economical and efficient than common carrier service,
the vast majority of users are small and will benefit from subscription
service. Even instances where common carrier service is more costly, it has
other advantages over private systems such as telephone interconnection; 24
hour, 7 day service; instant channel access in emergency; message store and
relay service; greater coverage areas; full duplex operation. By encouraging
multiple radio common carrier operations in the same city (in lieu of a WCC
monopoly) the public would further benefit from lower prices generated by free
competition.
Central
Committee of the American Petroleum Institute (API)
Endorses
the LMCC filing. No convincing evidence has been presented by AMST or others to
warrant a delay in adopting 18261 for immediate, but limited relief, and 18262
as a long term solution to land mobile requirements.
AMST seeks
to preserve what has never existed. An 82 channel TV system is in reality only
a 67 channel system 55 of which are in the UHF band.
To suggest,
as AMST does, that the solution to land mobile congestion is the application of
stringent priorities and limitations on eligibility assumes an overall spectrum
scarcity which just does not exist. Congestion on land mobile channels is due
to an inequitable share of a resource which is generally and even increasingly
plentiful. Improvements can be made in the internal efficiency of any radio
service, especially broadcasting, but this is not the immediate or long term
answer to the land mobile problem. Congestion is a reality regardless of what
method one chooses to employ to predict future land mobile growth. Congestion
is not something land mobile users have contrived from the Commission's
assignment records, inaccurate though they may be. It is the inability to
communicate within a reasonable waiting time; it is intolerable interference
and interruptions; it is the unavailability of additional public safety
channels to meet the increasingly complex and intense needs of a mushrooming
urban population. One need only scan the spectrum between 25 and 890 MHz in a
city like New York to see where the real congestion and inefficiencies lie.
The
Commission has long since recognized that the public interest requires radio in
services which are both necessary and convenient. It has also recognized the
value of providing the public a choice or privately owned or common carrier
radio services. To impose artificial and unnecessary eligibility limitations or
to force all private users into common carrier or common user systems as AMST
suggests betrays the fundamental spirit of the Communications Act. AMST
recklessly urges such a plan to perpetuate the broadcasters' own gross
inefficiencies. It further suggests that police users be concentrated in the
150 MHz band while forcing "lower priority" users into common carrier
systems at 900 MHz. This gives no consideration whatsoever to the unique value
each band of the spectrum has in providing optimum coverage in a wide range of
rural and urban environments.
Land mobile
growth is closely tied to population growth which AMST's statistical analysis
cannot predict. It is likely that land mobile will grow even faster than
population if we consider the additive effects of advancing technology,
increasing mobility, and rising affluency.
Further
evidence of AMST's lack of knowledge of land mobile service is reflected in its
simplistic "proof" of the ease of converting equipment to 900 MHz and
in its reliance on a uniform maximum channel loading factor of 60 units per
channel and in the assumption that the majority of land mobile systems are of
the "dispatch" type. There is, of course, a need to define channel
loading in concrete terms, but it cannot be assumed that the same relationships
apply equally to police as to business or even that "units per
channel" is a meaningful measure of actual channel usage.
AMST's
concern that severe TV interference would be caused by the proposals in both
18261 and 18262, is based on Grade B contours derived from outmoded propagation
charts in the Commission's Rules and not on the slightly modified ones proposed
in Docket 16004. Both sets of curves, however, yield contours considerably
larger than the actual Grade B coverage which can be determined only by
measurement.
City of
Dallas, Texas
Urges
adoption of 18261 which will provide channels 14 through 19 for land mobile licensees
in the Dallas-Fort Worth urbanized area, and 18262 as a means of meeting future
land mobile service. The need for additional land mobile spectrum in urban
areas is well documented in Congressional, FCC, and other reports. Dallas
police congestion problems mentioned in the original comments in this
proceeding have been taken care of for now in the 450 MHz band, but it is
estimated that in 5 years the same excessive degree of channel loading will be
reached. In addition to the City's present assignment of 62 channels, it will
need exclusive use of another 100 public safety channels by 1974. One hundred
fifty more channels will be needed by 1980 for planned expansion of mobile
services including voice, teleprinter, data, signaling and others. Another 100
channels will be required for car locators, telemetry, video, facsimile,
traffic control, computer data, forestry and parks, etc. This degree of
expansion can be made possible only through the allocation of substantial land
mobile spectrum.
Georgia State
Board of Education (GSBE)
GSBE
opposes the LMCC counterproposal for outright reallocation of the lower 7
channels. Cost to Georgia taxpayers of converting four educational stations
under LMCC's proposal would be $ 1,363,770. The FCC's sharing plan is premature
and would likely result in destructive interference. If such a plan is adopted,
however, it should be done on a trial basis only.
The
Commission's proposal with regard to channels 70-83 overlooks the unsettled
issues and pleadings in Docket 14229, wherein GSBE and NAEB strongly urge the
reservation of adequate educational assignments. There is a national need for
additional ETV assignments obtainable only from this spectrum. This need exists
apart from the availability of ITFS facilities. Educational needs must be held
paramount to any land mobile service except those involving safety of life and
property.
National
Association of Broadcasters
In short,
the Commission should abandon Dockets 18261 and 18262 and implement better land
mobile frequency assignment practices to correct the spectrum exposed by SRI.
Review of the SRI interim report reveals fallacies in the Commission's present
approach to solving land mobile congestion. Important findings of that report
are: (1) inequitable channel occupancy or no occupancy at all on 49% of the
railroad channels in Detroit and 500 land mobile channels in Los Angeles; (2)
general lack of correlation between the number of assignments on a channel and
its actual occupancy; (3) inadequate FCC records which show assignments on only
about half the channels found to be occupied in Detroit. SRI concludes most
urban congestion can be cured by implementing first an area monitoring
capability then an assignment plan based on the principle of equal-channel-occupancy.
This all points to the futility of attempting to solve the land mobile problem
by allocating additional spectrum. As stated by SRI "any new spectrum made
available to land mobile users would soon be as inequitably distributed as the
present spectrum, unless more effective spectrum management procedures are
implemented." SRI concludes this even though its own monitoring technique
of sampling peak usage over a 5 minute period tends to inflate the occupancy
data.
LMCC's
(Cullum) counterproposal, in addition to lying beyond the scope of the instant
Notice, is technically infeasible. Even if it were possible to ignore the
taboos, 14 cities would lose TV assignments under LMCC's plan. The test data
(from FCC Report L6201) on which LMCC's proposals are based do not apply to the
broader band-pass color TV sets. A December 28, 1967 study by Kear &
Kennedy for NAB concludes these taboos "very much apply to modern
receivers."
Land mobile
interests understate the cost of converting UHF-TV stations to other
frequencies. An MST survey of licensees shows an average cost of $ 167,000
simply to change frequency. The costs would be as much as $ 500,000 if other
changes are necessary, such as taller or more directive antennas, higher power,
new buildings, towers, etc. At this rate, the total costs for the 26 licensees
surveyed would be $ 13 million, and would mean certain bankruptcy to many
stations operating on marginal funds.
The Nathan
Report for AMST refutes in all respects the economic findings of LMAC regarding
the relative values of land mobile and television broadcasting.
National
Association of Educational Broadcasters (NAEB)
Docket
18262 seeks to deprive educational television of essential growth potential in
the upper 14 UHF channels without adequately considering the issues in Docket
14229, wherein NAEB has supported the reservation of full power ETV assignments
on channels 70-83. The Commission's proposals threaten the continued use of
translators and the essential function they serve in extending UHF television
and educational coverage to underserved areas. At a time when federal matching
funds are just becoming available to educational broadcasters for auxiliary
services, the Commission would give away half the 942-952 MHz band to highly
speculative future land mobile services.
Serious
doubts have been raised that a real need exists for additional land mobile
frequencies. AMST, JTAC, the President's Task Force, and SRI all indicate that
wasteful practices within the land mobile services have created an artificial
frequency shortage. Lacking basic administrative reforms, any reallocation
would be premature and would make the real causes of congestion more difficult
to deal with.
LMCC's
counterproposal to move all UHF-TV assignments on channels 14-20 to channels
above 21, besides being technically unsound, would place an unreasonable
financial burden on marginally funded educational stations. There is serious
question about the credibility of the land mobile position in Docket 18262
which, on the one hand, advocates total reallocation of the upper 14 UHF
channels and on the other hand, emphasizes the limited suitability of these
frequencies for the bulk of land mobile requirements. Hopefully, the Commission
will not be led by such arguments to reject its national goals for educational
and commercial television, both of which depend so heavily on the continued
availability of an 82 channel allocation.
National
Association of Radiotelephone Systems (NARS)
In Docket
18261 the Commission should view a total reallocation of the lower 7 channels
as the long range goal, but in the interim provide a sharing arrangement such
as that proposed. It is imperative that RCCs be eligible for these frequencies
in addition to private LM users. RCCs provide the type of disciplined service
SRI reports as essential to efficient use of land mobile frequencies. This also
applies to Docket 18262 in which NARS has requested that half of the common
carrier 75 MHz be allocated to RCCs. NARS supports Motorola's arguments against
allowing wireline carriers to furnish private dispatchtype service. This is
traditionally and rightfully an RCC function. The Commission should issue an ad
hoc statement that RCCs have access to frequencies involved in these dockets
and adopt a liberal policy of issuing authorizations for the development of RCC
services.
Taft
Broadcasting Company
As licensee
of WNEP-TV, channel 16, Scranton, Pennsylvania, Taft opposes LMCC proposal for
total reallocation which would shift WNEP to channel 26. Total cost of
conversion would be in the neighborhood of $ 220,000, not to mention the loss
of advertising revenue spent in promoting its public image on channel 16. Aside
from these costs, conversion to channel 26 would be difficult if not impossible
due to the 20-mile IF and IM taboo requirements involving neighboring stations.
LMCC's contention that such taboos can be ignored is not supported by fact. The
fact is even these taboos may not adequately protect color receivers, which are
more susceptible to interference than the top-of-the-line monochrome sets to
which LMCC's data (taken from Lab Report L6201) applies.
AMST's
recommendations for better administration of existing land mobile spectrum must
be thoroughly evaluated by the Commission before adopting any proposals which
would irreparably disrupt public UHF television.
Zenith
Radio Corporation
Zenith
concurs with filings of AMST and NAB, rejecting proposals to divert UHF
spectrum from television to land mobile. An important additional reason for
abandoning these proposals stem from Docket 11279 wherein the Commission
recently authorized subscription television which is totally dependent on UHF
channels for initial and long term growth.
National TV
Translator Association (NTTA)
NTTA is
composed of approximately 400 TV translator "clubs,"
"cities," "towns," "counties," "tax
districts," ETV licensees and other non-profit organizations operating
some 6000 translators serving more than 15 million persons.
NTTA,
speaking for the interests of Rural America as well as those in cities
dependent on translators for television reception, is strongly opposed to the
proposals in Dockets 18261 and 18262 and urges that they be rejected forthwith
by the Commission.
NTTA is
familiar with the comments of AMST in Dockets 18261 and 18262 and believes them
to be an effective, comprehensive and forceful statement of the reasons why the
Commission should not adopt its proposals in Dockets 18261 and 18262.
There is
sufficient spectrum already allocated to land mobile, assuming efficient
allocation, licensing, coordination, management and use of the spectrum.
The future
growth and development of UHF television, including the future expansion of diverse
and competitive free television service is an important national goal which
should not be obstructed or subverted by reallocation of UHF TV channels.
Therefore, NTTA incorporates by reference and specifically adopts the comments
of AMST as its comments in Dockets 18261 and 18262.