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LMCC Requests FCC Review of List of Protected TV Stations

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LMCC Requests FCC Review of List of Protected TV Stations '1 Ailil nrT{J$t* "qTA$/1P ilil!ililil11 LAI{O MOBITE GOMMUI{ICATIONS COU]{GIL lllllllilll' Received & lnsPected JUN 3 0 202,| June 3o, zozr FCC Mail Floom Michelle M. Carey, Chief, Media Bureau Lisa M. Fowlkes, Chief, Public Safety and Homeland Security Bureau Joel Taubenblatt, Acting Chief, Wireless Telecommunications Bureau Federal Communications Commission 45 L Street, N.E. Washington, DC 2c;1,;24 Re: TV Stations to be Protected in the 47o-5rz MHz Band (T-Band) Dear Chief Carey, Chief Fowlkes, and Acting Chief Taubenblatt: The Land Mobile Communications Council (LMCC) appreciates the Federal Communications Commission (FCC) modiffing its zorz action suspending the acceptance of certain T-Band applications'following repeal of the T-Band Mandate." After an almost ro-year licensing hiatus, Public Safety and Industrial/Business entities are eager to make maximum use of this critical Part 90 spectrum. Doing so will depend in significant part on an accurate accounting of the TV stations entitled to protection from proposed land mobile operations. The Wireless Telecommunications and Public Safety and Homeland Security Bureaus (Bureaus) released a Public Notice on February 17,2o2t that updated the list of protected TV stations.s The Feb. Public Notice states that the referenced list is available at https://www.fcc.gov/general/oet-technical-documents and Attachment A, briefly, was able to be downloaded from that website, but it subsequently has been removed. Because the updated list is being used by the Bureaus in evaluating T-Band applications, the LMCC conducted its own review of the TV stations identified. Its findings, shown on Attachment B, indicate that a significant number of stations that land mobile applicants are supposed to protect (i) are no longer operating on their original channels but are transmitting on ' Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau Modify Suspensions of Acceptance and Processing of Certain Part zz and Part 9o Applications fof 47o-5rz MHz (T- Band) Spectrum, Public Nofice, DAzr-82 (WTB/PSHSB Jan. 19, zozr). 'z Middle Class Tax Relief and Job Creation Act of zorz, Pub. L. No. lz-96, Title VI, rz5 Stat. 156 (zorz). Section 6ro3 was codified as 47 U.S.C. $ r4r3. 3 Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau Update List of TV Stations to Be Protected in the T-Band, Public Notice, DA zr-r9o (WTB/PSHSB Feb. 17, zozr) ("Feb. Public Notice"). new digital channels that will not be impacted by T-Band systems (orange highlighting),4 (ii) are no longer operating at all (yellow highlighting), or (iii) have license information that differs from the information on the updated list by location or by channel (green highlighting).5 The inclusion of stations from the first two categories in the Bureaus’ review of T-Band applications is entirely contrary to the FCC’s commitment to promoting intensive use of valuable spectrum. It will prevent the deployment of land mobile systems that could not possibly have an adverse impact on TV transmissions. The information for the third category must be corrected as well so that the land mobile interference potential can be evaluated accurately. The Public Safety and Industrial/Business entities seeking T-Band licenses have waited almost a decade for this spectrum to be made available. The FCC undoubtedly can appreciate their frustration at being told their applications cannot be granted because they do not protect TV stations that clearly do not need and are not entitled to protection from land mobile systems.6 The LMCC urges the Bureaus not to return or deny T-Band applications because of a failure to protect TV stations in the first two categories until the list referenced in the Feb. Public Notice has been corrected. This should not require substantial time or FCC resources as the LMCC has provided a roadmap. The LMCC urges the FCC to complete this re-evaluation as promptly as possible and release a corrected list of protected TV stations so the long-delayed full potential of this band can be realized. Please feel free to contact me if you have any questions or comments. Sincerely, David Smith President Attachments cc: David Furth Brian Marenco Roger Noel Josh Smith 4 Only a single station from the original list of protected TV stations, WPHL in Philadelphia, has remained on its original channel that could be impacted by land mobile operations. 5 On June 24, 2021, the LMCC submitted a Petition for Rulemaking proposing an updated method to determine potential interference between T-Band stations and digital TV stations. As explained in the Petition, and as recognized in the FCC’s broadcast rules, TV stations transmitting in digital format are more immune to interference than were the analog stations on which the current Part 90 Subpart L protection criteria are based. 6 While not addressed on Attachment B, the LMCC also has found that not all new stations on the updated list comply with the distance separations specified in FCC Rule Section 73.623(e). The LMCC is in the process of evaluating the protected station list based on those criteria as well and urges the FCC to do the same. ATTACHMENT A ATTACHMENT A A B CDE F G H FREQUENCIES AVAILABLE TV STATION SITE URBANIZED AREA FOR LAND MOBILE USE TELEVISION FACILITIES TO BE CONSIDERED1 COORDINATES 1 (MHz) (NAD83) CO. CH., TV CALL CH. NO. ADJ. CH. TV STATION LOCATION N. LATITUDE W. LONGITUDE 2 IM & IF 3 WPTZ 14 CO. CH. Plattsburgh, NY 44-31-33.2 72-48-55.4 Channel 14 4 WGME-TV 15 ADJ. CH. Portland, ME 43-55-29 70-29-27 470-476 5 WHED-TV 15 ADJ. CH. Hanover, NH 43-42-30.2 72-09-14.3 6 WGME-TV 15 ADJ. CH. Portland, ME 43-55-29 70-29-27 BOSTON, MASSACHUSETTS 7 WHED-TV 15 ADJ. CH. Hanover, NH 43-42-30.2 72-09-14.3 42° 21' 24.4"/71° 03' 23.2" 8 Channel 16 WFFF-TV 16 CO. CH. Burlington, VT 44-31-33.19 72-48-55.44 9 482-488 WFNY-CD 16 CO. CH. Gloversville, NY 43-06-06.26 74-22-13.49 10 WPFO 17 ADJ. CH. Waterville, ME 43-55-29 70-29-27 11 WPXQ-TV 17 ADJ. CH. Newport, RI 41-29-41.7 71-47-4.7 12 WJJY-TV 14 CO. CH. Jacksonville, IL 39-45-52.1 90-30-29.5 13 WCMU-TV 14 CO. CH. Mt. Pleasant, MI 43-34-24.1 84-46-21.0 14 Channel 14 KFXB-TV 14 CO. CH. Dubuque, IA 42-31-09 90-37-11 15 470-476 WLAJ 14 CO. CH. Lansing, MI 42-41-19 84-22-35 16 WGBA-TV 14 CO. CH. Green Bay, WI 44-21-30 87-58-48.4 17 WXSP-CD 15 ADJ. CH. Grand Rapids, MI 43-00-59.3 85-44-24.2 18 WMTV 15 CO. CH. Madison, WI 43-03-03 89-29-13 19 WICD 15 CO. CH. Champaign, IL 40-04-10 87-54-46 CHICAGO, ILLINOIS 20 WICS 15 CO. CH. Springfield, IL 39-48-15 89-27-40 41° 52' 28.1"/87° 38' 22.2" 21 WTTK 15 CO. CH. Kokomo, IN 39-53-20 86-12-07 22 WXSP-CD 15 CO. CH. Grand Rapids, MI 43-00-59.3 85-44-24.2 Channel 15 23 WOHL-CD 15 CO. CH. Lima, OH 40-46-31.6 84-07-14.2 476-482 24 WCWF 15 CO. CH. Suring, WI 44-24-32 87-59-31 25 WNDU-TV 16 ADJ. CH. South Bend, IN 41-36-20 86-12-46 26 WTVO 16 ADJ. CH. Rockford, IL 42-17-14 89-10-15 27 WFWC-CD 16 ADJ. CH. Fort Wayne, IN 41-05-56.9 85-08-42 28 WOBC-CD 16 ADJ. CH. Battle Creek, MI 42-17-16.7 85-09-54.3 29 KYTX 15 ADJ. CH. Nacogdoches, TX 31-54-21 95-05-06 30 KSHV-TV 16 CO. CH. Shreveport, LA 32-39-58.5 93-56-00.7 31 DALLAS, TEXAS Channel 16 KOCM 16 CO. CH. Norman, OK 35-33-36.9 97-29-07.6 32 32° 47' 09.5"/96° 47' 38.0" 482-488 KBTX-TV 16 CO. CH. Bryan, TX 30-33-16.5 96-01-52.3 33 KTEN 17 ADJ. CH. Ada, OK 34-21-34.3 96-33-35 34 KNCT 17 ADJ. CH. Belton, TX 31-19-19.2 97-19-03.0 35 KBTX-TV 16 ADJ. CH. Bryan, TX 30-33-16.5 96-01-52.3 36 HOUSTON TEXAS Channel 17 KLWB 17 CO. CH. New Iberia, LA 30-20-33.0 91-57-46.6 ATTACHMENT A A B CDE F G H 37 Channel 17 KNCT 17 CO. CH. Belton, TX 31-19-19.2 97-19-03.0 38 HOUSTON, TEXAS KCRP-CD 17 CO. CH. Corpus Christi, TX 27-46-11.1 97-26-55.9 39 29° 45' 26.8"/95° 21' 37.8" 488-494 KVHP 18 ADJ. CH. Lake Charles, LA 30-17-27 93-34-36 40 KPBS-TV 15 ADJ. CH. San Diego, CA 32-41-52.7 116-56-06.3 Channel 14 41 KTLD-CD 15 ADJ. CH. Bakersfield, CA 35-26-17.1 118-44-26.3 470-476 42 KWHY-TV 22 IF Beat Los Angeles, CA 34-13-36.0 118-04-02.3 43 KPBS-TV 15 ADJ. CH. San Diego, CA 32-41-52.7 116-56-06.3 44 KTLD-CD 15 ADJ.
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