24 September 2001
Director General Telecommunications Policy Branch Industry Canada 300 Slater Street Ottawa, Ontario K1A 0C8
Dear Sir:
Re: Canada Gazette Notice DGTP-004-01; Proposal to Introduce the Mobile Service on a Co-primary Basis with the Broadcasting Service in the Frequency Band 746-806 MHz
In response to Canada Gazette Notice DGTP-004-01, the Canadian Association of Broadcasters (CAB) hereby files the enclosed submission.
We would be pleased to discuss any aspects of this submission with Industry Canada, should further clarification be required.
Sincerely yours,
Michael McCabe President & CEO
Canada Gazette Notice DTGP-004-01
Proposal to Introduce the Mobile Service on a Co-Primary Basis with the Broadcasting Service in the Frequency Band 746-806 MHz
Comments submitted by
The Canadian Association of Broadcasters/ L’Association canadienne des radiodiffuseurs
24 September 2001 Table of Contents
Submission Summary
Section Page
1. Introduction 1
2. Background 1
3. Rationale for Implementing Over-the-Air DTV Services 4
4. Factors Affecting the DTV Roll-out in Canada 6
5. The Private Broadcasters’ DTV Roll-out Proposal 8
6. Impact of the Current Proceeding on the DTV Roll-out 8
7. Current Sharing Opportunities for Mobile Services 10
8. Specific Recommendations on General Policy Issues 11
9. Specific Recommendations on Proposed Allocation Table Amendments 12
10. Concluding Remarks 13
Appendix 1: Technical Feasibility Report: Sharing of TV Channels 60-69 by Mobile Services
Submission Summary
TV broadcasters have a number of concerns with respect to any modifications that may be made to the existing spectrum allocation policies for the 746-806 MHz band (TV channels 60-69). They are especially anxious to ensure that the addition of Mobile as a primary service in this band does not have a negative impact on analog TV stations currently using it, on new analog TV stations that may be licensed before the industry fully converts to digital television (DTV) and on future transitional DTV implementations.
Broadcasters clearly must plan to use over-the-air (OTA) channels to deliver DTV services. At present, 29%-35% of all viewing hours for local stations are still achieved through OTA reception. In Canada there is a substantial existing and projected use of Channel 60-69. Eleven regular analog UHF-TV stations are licensed. Almost ten percent of Canada’s DTV allotments are slated to use this band. An examination of current DTV allotment plan for Canada shows that three of our four largest TV markets depend heavily upon the use of Channel 60-69 for the roll-out of DTV services. Moreover, about 20% of Canada’s LPTV stations licensed in Canada are expected to implement DTV versions of their services using Channels 60-69, according to the 1999 Industry Canada Allotment Plan.
Industry Canada’s decisions respecting future sharing of Channels 60-69 will affect the timing of the DTV roll-out that is being planned by the broadcasters. On the surface, it may seem reasonable to encourage broadcasters to implement new DTV services below Channel 60, leaving the higher channels for mobile use, as is being done in the USA. However, such a policy could lead to a longer DTV roll-out period rather than a shorter one, by creating an artificially high demand for the lower channels that could only be resolved through competitive public hearings. Moreover, adding Mobile as a primary allocation in 746-806 MHz may also reduce Industry Canada’s flexibility to modify the TV Allotment Plan, should this prove necessary as more information on the performance of the 8-VSB North American DTV standard becomes available.
As part of its assessment of the issues connected with TV/Mobile sharing, the CAB has investigated the extent to which mobile services might actually be able to operate in Channels 60-69 during the DTV transition, without interfering with TV allotments and assignments. We find that there is virtually no opportunity for such sharing in those areas where the demand for both TV and mobile services is highest.
In summary, the CAB makes the following recommendations and comments with respect to the allocation of the 746- 806 MHz band to the Mobile service:
• Industry Canada should commission and release studies detailing the estimated demand for mobile spectrum in the subject band, along with engineering studies showing how any proposed sharing with TV could actually work.
• Industry Canada should not institute a policy that would encourage or require broadcasters to use DTV channels above Channel 59 only as a last resort.
• The preferred option of the broadcasters is that the band 746-806 MHz be identified for possible future use by mobile service, but that no operating licences be granted until the DTV transition is complete.
• If proposals are to be made calling for TV/Mobile sharing prior to the termination of the DTV transition period, the CAB recommends that Industry Canada not propose band sharing throughout Canada, but rather restrict any such proposals to areas where it is technically feasible to do so.
• If technical sharing rules are proposed, it is vital that they ensure at least the same degree of protection to TV as the US provides under its domestic rules.
Part 3 of Notice DGTP-004-01 The CAB has several comments and recommendations on the proposed wording of amendments to the Canadian Table of Frequency Allocations and these are detailed at the end of this submission.
ooOOOoo 1
1. Introduction
1.1. These comments in response to Canada Gazette Notice DGTP-004-01 are filed by the Canadian Association of Broadcasters (CAB), an industry association representing the vast majority of Canada’s private television and network broadcasting licensees.
1.2. Our members have a keen interest in the issues being discussed in this public process, since broadcast television is currently the sole user of the radio spectrum from 746-806 MHz (Channels 60-69) in Canada.
1.3. TV broadcasters have a number of concerns with respect to any modifications that may be made to the existing spectrum allocation policies for the subject band. The most important of these is that any changes be implemented in such a way that there is no adverse impact on:
• analog TV stations that currently broadcast on Channels 60-69; • new analog TV stations that may be licensed in this band before the industry fully converts to digital television (DTV); and • future transitional DTV implementations in Channels 60-69.
1.4. The CAB appreciates that, at this time, Industry Canada (herein after referred to as “the Department”) is only asking for public input on the question of whether the mobile service should be added as a co-primary allocation in the band 746-806 MHz. Assuming that such a decision is in fact taken, it is our understanding that the Department will initiate a further public process to develop a spectrum utilization policy stipulating how the band may be used by new mobile licensees.
1.5. Notwithstanding this, the CAB believes that it is appropriate to consider some of the “how” issues as part of this initial consultation process. There is little value in proceeding to the next stage of such a process if the practicability of the concept is not considered right at the start. Consequently, the CAB’s comments in this submission will also address whether the objectives of this project, as stated by the Department, are reasonably achievable.
2. Background
2.1. The issue of allowing mobile services to have co-primary allocation status with TV broadcasting in Channels 60-69 has arisen in Canada primarily because such action has already been taken in the United States1. The CAB suggests that, had the US not already taken this step, it is extremely unlikely that Canada would have initiated such as policy proposal on its own. As a consequence, it is useful to examine the context in which the US decision was taken to see if parallel circumstances exist in Canada, thus warranting similar spectrum utilization policies in both countries.
1 The US Plan calls for the termination of all conventional TV broadcasting in Channels 52-69 (698-806 MHz), once this service has completed its transition to digital signal (DTV) delivery. With the exception of 24 MHz set aside for public safety services, all the spectrum that becomes available in the subject band will be auctioned. Efforts will be made in the US to clear TV services from Channels 60-69 (746-806 MHz) even before the DTV transition is complete. However, wherever TV services remain, they are to be protected against interference from incoming services. 2
2.2. It is important to recall that the rationale behind the US plan to introduce mobile services was two-fold. A key imperative in the US re-allocation plan is the anticipated accrual to the federal government of billions of dollars in revenues as a result of auctioning any TV spectrum that can be released for other services. This revenue was an integral part of long-range government budget planning by the previous US administration and in fact has become a major driving force behind that country’s DTV conversion strategy. In short, unless DTV moves ahead quickly, spectrum cannot be liberated for auctioning.
2.3. The US pre-occupation with budget-balancing was translated into a DTV policy for broadcasters that compels most private licensees to implement DTV versions of their analog transmissions no later than May 2002. Failing this, they may forfeit the DTV channels the FCC has allotted to them. As the US DTV conversion plan also calls for the termination of all over-the-air analog TV broadcasts by 31 December 2006 (subject to achieving acceptable receiver penetration), there is a powerful incentive for broadcasters to implement DTV sooner rather than later.
2.4. When the US DTV Allotment Plan was developed, the FCC made a considerable effort to limit the number of allotments above Channel 51, so as to facilitate the implementation of the re-allocation/auction policy. The Commission was able to virtually eliminate the need to establish future DTV services in the channel range 60-69; however, it was not as successful in Channels 52-59. Table 1 shows the breakdown of TV allotments in the USA, by channel groupings (regular stations only). Table 1. CHANNEL ANALOG DTV 2-6 231 17.3% 27 2.0% 7-13 331 24.8% 72 5.4% 14-51 622 46.6% 1093 81.8% 52-59 71 5.3% 130 9.7% 60-69 81 6.1% 14 1.0% TOTAL 1336 100.0% 1336 100.0%
2.5. This table illustrates that 11.4% of analog and 10.7% of US DTV stations will have to operate in the range 52-69 until the DTV transition is complete, at which time it is hoped that channels below 52 can be found for these transmitters2. In absolute numbers, 95 TV stations will have to be protected by any new mobile services using Channels 60-693. While this may well be feasible, it does not seem likely that the same can be said for the 201 stations that will have to occupy Channels 52-59 for the time being. This may explain recent moves in the US to delay any auctioning of TV spectrum in Channels 52-59.
2.6. As was the case in the US, Canada’s efforts to develop a new TV allotment plan that would accommodate both analog and DTV services in the interim were directed at avoiding the use of Channels 52-69 wherever possible. This strategy was motivated more by the assumption
2 The option exists in both Canada and the US for DTV stations to revert to the channels used by their analog counterparts, once analog transmissions cease.
3 Procedures governing the amount of interference that TV stations must accept from co-channel and adjacent- channel mobile services are set out in the FCC Rules, Sections 27.50 and Part 90.309.
3 that Canada may wish to harmonize its post-transition TV spectrum with the US, rather than because there is a huge proven demand for this band by other services.
2.7. In any event, Canada was less successful than the US in avoiding the use of the subject channels for regular stations, as can be seen in Table 2.
Table 2. CHANNEL ANALOG DTV 2-6 185 26.1% 5 0.7% 7-13 338 47.6% 64 9.0% 14-51 158 22.3% 507 71.4% 52-59 18 2.5% 66 9.3% 60-69 11 1.5% 68 9.6% TOTAL 710 100.0% 710 100.0%
2.8. The table shows that about 19% of all future DTV allotments will be located above Channel 51, with half of these in the range 60-69. Having a large number of DTV allotments in the top ten channels in Canada was inevitable. Since the US had avoided using these channels for TV, they were more readily available in large Canadian cities near the US border.
2.9. An examination of current DTV allotment plan for Canada shows that three of our largest TV markets depend heavily upon the use of Channel 60-69 for the roll-out of DTV services4. Table 3 shows the situation in Toronto/Barrie/Hamilton, Montreal and Ottawa-Hull.
Table 3. % DTV Market in Ch 60-69 Montreal 33 Ottawa/Hull 50 Toronto/Barrie/Hamilton 50
2.10. In addition to future DTV requirements, the coverage of existing analog stations operating on Channels 60-69 needs to be protected. Table 4 lists the regular stations that have been licensed in this range.
2.11. There are also 68 low-power, unprotected (LPTV) assignments currently operating in Channels 60-69 in Canada. These were all licensed on the understanding that they would not interfere with higher-priority licensed undertakings. If the mobile service is added as a co- primary allocation in this band, these TV licensees would be obliged to shift channels, should they become incompatible with mobile requirements.
2.12. While some of these LPTV stations are operated by the CBC and larger private TV companies, many are owned by community associations and other not-for-profit organizations. Almost all of them operate in areas where it is uneconomic to provide TV services. Thus, the advent of a spectrum utilization policy that creates the need to shift to another channel may produce a financial hardship for these licensees.
4 Ref: Digital Television (DTV) Transition Allotment Plan, Issue 2, April 1999 4
Table 4.
CHAN CLASS CITY PR CALL LICENSEE
60 C OTTAWA ON CFMT-TV-2 ROGERS 60 B WINDSOR ON CHWI-TV-60 CHUM 61 C KITCHENER ON CBLFT-8 CBC 62 B MONTREAL QU CJNT-TV CTEQ TV 64 B CHATHAM ON CBLN-TV-3 CBC 65 C OTTAWA ON CITY-TV-3 CHUM 66 B BRIGHTON ON CKWS-TV-1 CORUS 67 C SEVERN FALLS ON CHCH-TV-3 On TV 68 B SARNIA-OIL SPRINGS ON CBLFT-17 CBC 69 B SPILLIMACHEEN BC CBUBT-6 CBC 69 C LONDON ON CFMT-TV-1 ROGERS
2.13. Moreover, 378 of the 1,875 LPTV stations licensed in Canada (20.2%) are expected to implement DTV versions of their services using Channels 60-69, according to the 1999 allotment plan.5
2.14. Because it must accommodate all existing analog stations, plus a DTV “twin” for each, the transitional TV allotment plan is very densely packed in the most populated regions of the country. There is virtually no room at all to add new “drop-in” channels. The CAB believes that it would be fruitless to attempt to eliminate Channels 60-69 from the plan and re-arrange the remaining channels to provide for the entire national requirement for analog and DTV allotments. Inevitably, some stations would not be accommodated if this were to be done.
3. Rationale for Implementing Over-the-Air DTV Services
3.1. Broadcasters have looked seriously at the feasibility of implementing DTV delivery via Broadcast Distribution Undertakings (BDU), without building new over-the-air (OTA) transmitters. Were this possible, they would be able to avoid a considerable capital investment in new transmission technology, as well as increased operating costs during the transition period.
3.2. The main difficulty in providing signals directly to BDUs is the loss of viewing hours that would result. At present, a substantial percentage of all TV viewing hours comes via TV receivers that are not connected to BDUs such as cable, direct-to-home (DTH) satellite, or multi-channel multi-point distribution services (MMDS)6. Charts 1 and 2 show the OTA viewing figures for public and private TV in Canada. For English TV, 29% of all viewing hours come as a result of OTA viewing. The comparable figure for French TV is 35%. (Individual statistics for the large broadcast groups are shown in each chart.)7
5 Six of the proposed LPTV DTV channels in Channel 60-69 currently have analog services in Channels 60-69.
6 Also known as “wireless cable” services.
7 Source: Nielsen, 1999-2000 5
Chart 1. English-Language Viewing
Viewing from BDUs Viewing from OTA
100% 90% 18% 19% 29% 29% 21% 23% 30% 27% 80% 41% 45% 70% 60% 50%
40%
30% 20% % of total viewing hours of total viewing % 10% 0% t
WIC CTV
CHUM
Other Cdn Other
Ont. Global Educational
CBC Main CBC Main Ne
CanWest: Total All OTA Stations OTA All
anWest Ont. outside
Chart 2. C French-Language Viewing
Viewing from BDUs Viewing from OTA
100% 90% 23% 24% 35% 35% 30% 29% 80% 37% 44% 70% 60% 72% 50%
40%
30% 20%
hours viewing of total % 10% 0% A r
Others
Cogeco
Quebeco Inter-Rives Groupe TV Radio-Nord Radio CanadaRadio Tele-Quebec All OTA Stations 6
3.3. This viewing accrues from receivers in homes where:
• the residents do not have access to BDU services for whatever reason; • the residents cannot afford BDU subscriptions or choose not to subscribe; and • BDU services are present but not all receivers in the home are connected.
3.4. Perhaps just as important for broadcasters, BDU mandatory carriage priorities and other mechanisms, such as simultaneous program substitution, flow directly from the fact that OTA service exists. Were broadcasters to forego OTA services, the continued existence of these measures, which are critical to achieving Canada’s public policy objectives for broadcasting, could be jeopardized.
3.5. OTA DTV will also provide broadcasters with the opportunity to provide auxiliary program- related and non-program-related services within their digital multiplexes. Continuing to provide OTA delivery in the digital era ensures that these new services will not be constrained by BDUs that may lack the carriage capacity (or the will) to deliver broadcaster auxiliary services that compete with their own.
3.6. As well, while it may be feasible for digital cable systems to provide delivery of the DTV versions of all local TV stations within their licensed territories (primarily urban), the same cannot be said of DTH and MMDS systems. Both have finite channel capacities, albeit of different magnitudes. Certainly, for the foreseeable future, it will not be possible for every local Canadian TV station to be carried by the two national DTH licensees. With only 90 MHz of spectrum to work with, MMDS has even less capacity to implement DTV versions of local stations, especially if they are transmitting high-definition digital signals (HDTV). As a result of these important limitations, remote and rural areas will be largely deprived of many local DTV services if the stations involved do not implement OTA transmitters.
3.7. Another reason for building DTV transmitters is that they will serve as an economic means of delivering digital services to BDU head-ends. If such transmitters do not exist, a huge number of point-to-point microwave, satellite and optical fibre links will be required to feed DTV programs from local studios to existing BDU systems. Many broadcasters will find that the cost of building and operating DTV transmitters will more than offset the cost of providing multiple BDU feeds by alternative means.
4. Factors Affecting the DTV Roll-out in Canada
4.1. An important consideration in allocating mobile services in Channels 60-69 will be the matter of how soon they might have exclusive use of the spectrum. As noted previously, broadcast use of the subject band will have to continue until the DTV transition is complete. As the roll- out of services has yet to commence, it is difficult to gauge just how long the transition may take.
4.2. The key factor governing the termination of analog TV services is public acceptance of the technology. The CAB believes strongly that the US approach of threatening the public with the termination of analog TV services after a fixed date is doomed to failure. Television 7 viewing simply looms too large in people’s everyday lives to imagine that the public will stand still for a government policy that prematurely obsoletes their analog receivers – especially when the average person would have trouble understanding why this is being done.
4.3. The CAB considers that the only reasonable approach is to allow the marketplace to decide when analog services should be discontinued. To a great extent, this will be governed by the public’s perception of DTV as an improvement and a “must-have” new technology. In turn, this has several aspects: picture quality and signal reliability will be important, but perhaps even more so will be the many attractive new features that DTV promises to provide8.
4.4. Another factor affecting the timing of DTV will be the regulatory approach taken by the Commission. The Commission appears inclined to create a transitional DTV licence regime that will make it fairly simple for broadcasters to apply to build new DTV transmitters that, for the most part, will simulcast existing programming9. Responses to a number of OTA licensing policy issues were provided to the Commission by the CAB on September 7th, 2001. Further reply comments will be filed by October 26th, 2001. If the Commission’s DTV transition policy is straightforward, then broadcasters will be encouraged to proceed soon. If the transition policy does not support the key elements required for broadcasters to implement DTV, then the process will be slowed considerably.
4.5. One of the issues that is foremost in the minds of broadcasters, and which will have a significant bearing on the timing of applications to implement DTV transmitters, is the question of whether mandatory BDU carriage of these new DTV signals will be required by the Commission. The CAB believes that the FCC made a serious public policy error in not requiring this in the US and has advised the Commission that a similar approach in Canada may likewise retard public acceptance of DTV in this country. Since most Canadians receive TV signals via BDUs, a relatively rapid penetration of new DTV receivers can only be reasonably expected if the public actually has access to these services via their chosen BDU.
4.6. In summary, the CAB believes that it will only be when analog TV transmissions terminate that significant efficiency improvements can be made in the current use of spectrum by the TV service. Because the public, through their use of consumer receiving equipment, are the principal users of broadcast spectrum, this is the sector that needs to be convinced that the technological conversion is worthwhile. While broadcasters are more than willing to help solve the “chicken-or-egg” dilemma by originating DTV broadcasts even before digital receivers are commonplace, it is the public that will ultimately decide how fast the transition takes place.
4.7. Assuming it is public policy in Canada that DTV should happen, then all sectors within the industry must carry an equitable share of the cost burden. If broadcasters must invest in providing parallel analog/digital services until the public acceptance gap is bridged for DTV, then it is only reasonable that BDUs should invest in the distribution facilities required to ensure that the digital signals are widely available. If the Department is eager to see the
8 Included among the features will be wide-screen, high-definition pictures, coupled with five-channel CD-quality sound. Program guides and interactivity will also attract many viewers, as will value-added program content carried simultaneously within digital broadcast multiplexes.
9 Ref: CRTC Public Notice 2001-62, “Call for Comments on a Proposed Policy to Oversee the Transition from Analog to Digital Over-the air Television Broadcasting”; 5 June 2001 8 spectrum efficiency improvements that will accrue as a result of DTV, then it should make it known to the Commission that mandatory BDU carriage of DTV will be an important factor in achieving this spectrum objective.
5. The Private Broadcasters’ DTV Roll-out Proposal
5.1. In November 2000, the CAB TV Board approved a proposal that, under the appropriate regulatory framework, could see DTV from private broadcasters rolled out in the major TV markets on a phased, market-driven basis, as follows.
In Phase 1:
• Transmitters would be built in Toronto, Montreal, Vancouver and Ottawa, with each consortium carrying four multiplexed SDTV local stations10. • These transmitters would cover approximately 37% of English speakers and 49% of French speakers. • Widescreen programming would be carried wherever available.
In Phase 2 (to be implemented when evaluation of phase 1 indicates strong public acceptance of DTV):
• Each station in the consortium would build its own transmitter in the Phase 1 markets. • More high-definition, widescreen and interactive programming would be available. • Transmission would begin in secondary markets (e.g. Winnipeg, Calgary, Edmonton, London, Windsor, Halifax, Québec). • DTV transmitters would, by then, cover approx. 60% of English speakers and 61% of French speakers.
5.2. The timing of the roll-out would be heavily dependent upon when the Commission releases the results of its current DTV licensing policy process. Since this process has only just begun, it is probably unrealistic to expect that the Phase 1 roll-out described above could be implemented before September 200211.
6. Impact of the Current Proceeding on the DTV Roll-out
6.1. To a certain degree, the Department’s decisions respecting future sharing of Channels 60-69 will also affect the timing of the DTV roll-out that is being planned by the broadcasters.
6.2. Notice DGTP-004-01 make the following statement with respect to potential spectrum sharing between the TV Broadcasting and Mobile services:
“The Department believes it is possible to accomplish this goal with a relatively minimal impact on the rollout of DTV in Canada. For example, broadcasters who want to
10 A single shared transmitter is the minimum scenario. The local broadcasters in each of these markets may opt to implement individual transmitters instead. 11 DTV signals are available now in Toronto and Ottawa, via the experimental transmitters operated by CDTV Inc. An additional transmitter is currently being planned for Montreal. 9
quickly move to broadcast DTV programming and whose channels are temporarily allotted in channel 60-69 (until being moved below channel 60) are encouraged to seek a DTV channel below channel 60. This would benefit broadcasters who quickly move to DTV by providing them earlier access to a permanent channel below channel 60. This would alleviate the costs of moving twice to different DTV channels. At the same time, this will free up spectrum above channel 60 to accommodate mobile services.”
While on the surface it may seem reasonable to encourage broadcasters to implement new DTV services below Channel 60, such a policy may in fact lead to a longer DTV roll-out period rather than a shorter one.
6.3. The DTV Allotment Plan was designed to provide a suitable channel for each analog transmitter that is now on the air. When the Plan was developed, the UHF-TV band was found to be already heavily packed with domestic and US analog stations. Moreover, the US DTV Allotment Plan had to be taken into account within 400 km of the border. As a consequence, in many TV markets, there are just enough DTV channels to go around.
6.4. If one examines the DTV Plan, it can be seen that not all the UHF DTV allotments are created equal. In fact, there are five different classes, as shown in Table 5.
Table 5.
Protected Class Service Radius (km) A 25 B 45 C 70 VU 82 VL 89
6.5. Canada’s DTV Plan was carefully crafted to ensure that each existing analog station will be able to operate DTV facilities that have a coverage that is close to its existing Grade B analog coverage. This means that it will be important to use an appropriate class of channel. If all the UHF DTV allotments had the same class, then it might be feasible for the early adopters of DTV to use the lower channels (below 60) first. However, each station will in fact be required to use a channel having a class that best suits its coverage needs during the DTV transition.
6.6. If the early adopters are compelled to use the lower UHF channels, they will often end up on channels that:
• provide less coverage than they are entitled to, thus serving as a disincentive to implement DTV at all; or • provide more coverage than they are entitled to, meaning that other stations with greater coverage entitlements in the same market will end up later with channels that are inadequate.
6.7. In markets where DTV channels below 60 have the largest coverage potential, the second scenario will create a “gold-rush” mentality among the local broadcasters. They will all want 10 to ensure that they have access to the channels that are outside the range 60-69 and also have the largest potential coverage.
6.8. This will necessitate competitive broadcast licence hearings, since there will be more applicants for these “preferred” channels than there are channels. In turn, this will slow down the roll-out process, as it is not possible for the Commission to deal with competing, mutually- exclusive applications using an abbreviated licensing process.
6.9. Adding mobile as a primary allocation in 746-806 MHz may also reduce the Department’s flexibility to modify the TV Allotment Plan, should this prove necessary as the DTV roll-out proceeds. The current plan was based upon very preliminary assumptions about the performance characteristics of consumer DTV receivers, consumer antennas and transmitting facilities. Now that practical field experience is being obtained in the US with respect to the performance of the ATSC 8-VSB transmission standard, thoughts are being expressed that changes to these assumptions may be necessary.
6.10. In April 2001, the Advanced TV Systems Committee (ATSC) released an ad-hoc study group report which provides a detailed technical assessment of the 8-VSB (A/53) transmission system12. The group reported that reliable indoor reception of DTV with set-top antennas will be possible only for a minority of viewers and concluded that “expectations of widespread indoor reception are inconsistent with the DTV planning factors”.
6.11. What this means is that the assumptions made by the regulators, with respect to the DTV operating parameters required to duplicate NTSC services, may have been optimistic. Much higher power levels may in fact be required if reliable reception of 19 MB/sec DTV datastreams is to occur using receivers with indoor set-top antennas. New field experience may also establish that additional channel allotments are required to achieve full coverage duplication. If such changes are required, they would be made more difficult by the presence of equal-priority mobile services in the same band.
7. Current Sharing Opportunities for Mobile Services
7.1. As part of its assessment of the issues connected with TV/mobile sharing, the CAB has investigated the extent to which mobile services might actually be able to operate in Channels 60-69 during the DTV transition, without interfering with TV allotments and assignments. Appendix 1 contains an engineering study, conducted by Wayne A. Stacey & Associates Ltd, that examines this issue.
7.2. The study assumes that all analog and DTV allotments and assignments in the current Canadian allotment plan would be protected against interference from new mobile services. It further assumes that the technical protection provided by mobile services would be identical to that required in the US in similar cases.
7.3. Our analysis establishes that there is almost no use that can be made of Channels 60-69 for mobile services in the entire area from Windsor ON to Quebec City, until such time as the
12 “Performance Assessment of the ATSC Transmission System, Equipment and Future Directions: Report of the VSB Performance Ad Hoc Group to the ATSC Task Force on RF System Performance”; April 12, 2001
11 DTV transition is complete. This geographic area is roughly equivalent to “Zone 1”, as defined in the Broadcasting Procedures and Rules, Part 413. Sharing possibilities are better outside this area. In the western provinces, many of the subject channels could be shared without impacting on TV allotments and assignments14. The situation is similar in the Atlantic provinces, although a number of the subject channels would be precluded in Nova Scotia and New Brunswick.
8. Specific Recommendations on General Policy Issues
8.1. Considering all of the above, the CAB has a number of comments and recommendations it wishes to make with respect to the proposal put forward by the Department to make mobile a co-primary allocation in TV Channels 60-69 and to take further steps to identify the conditions under which such licensing could occur.
8.2. The CAB notes that neither the Department nor the mobile industry has published studies backing up the claim that spectrum shortages for mobile in fact exist in this country. While apocryphal information may have been obtained from time to time from regional Industry Canada offices, no one seems to have produced a thorough analysis, showing exactly where shortages exist and forecasting how much future spectrum may be required to meet the demand. If they exist, the CAB recommends that the Department make these studies public along with any future proposals it may put forward with respect to how TV/mobile spectrum sharing can actually work. If such studies have not been done, then they should be commissioned by the Department as soon as possible.
8.3. The CAB believes that it would be counter-productive for the Department to encourage broadcasters to first use DTV allotments that are below Channel 60. They will naturally do this anyway, when it is possible to do so without creating objections from other stations in the same market. Therefore , the CAB recommends that the Department not institute a policy that would encourage or require broadcasters to use DTV channels above 59 only as a last resort.
8.4. The CAB feels relatively confident that the future channel requirements for the TV service can be met using channels below 60, once the DTV transition is complete and analog TV transmissions have totally ceased. This would mean that the subject band could be released for use by other services at that time. Therefore, our preferred option is that the band 746- 806 MHz be identified for possible future use by mobile service, but that no operating licences be granted until the DTV transition is complete.
8.5. Broadcasters are not in favour of attempting to share the band between these two services in the meantime. We believe that the service requirements of these spectrum users are highly incompatible. Moreover, in areas where the mobile service says it is experiencing its most severe spectrum shortages, the usage of Channel 60-69 for television will be intense, due to the demands of the DTV service.
13 In addition to the Zone 1 area, substantial restrictions would apply in Ontario as far north as Sudbury and North Bay.
14 The technical analysis did not cover secondary LPTV assignments in Channels 60-69, some of which might be made untenable if a primary mobile service were to be authorized on a related frequency. 12
8.6. It seems quite clear that little or no interim sharing of Channels 60-69 could occur in any event in two of the three major metropolitan areas that the Department has identified as lacking in mobile channels (Toronto and Montreal). Nevertheless, if the Department decides to go to the next step and prepare ground-rules for sharing, there are several issues that need to be carefully considered.
8.7. If proposals are to be made that call for TV/mobile sharing prior to the termination of the DTV transition period, the CAB recommends that the Department not propose band sharing throughout Canada, but rather restrict any such proposals to areas where it is technically feasible to do so. Essentially, this would mean confining sharing to TV Zone II (as defined in BPR-4), excluding the Muskoka area of Ontario and Sudbury/North Bay.
8.8. Finally, if sharing rules are proposed, it is vital that they ensure at least the same degree of protection to TV as the FCC requires under the US domestic rules. If this is not done, then it will give US mobile users more flexibility to encroach on Canada’s TV services across the border than they are permitted with respect to their own TV stations.
9. Specific Recommendations on Proposed Allocation Table Amendments
9.1. Part 3 of Notice DGTP-004-01 contains proposed wording for amendments to the Canadian Table of Frequency Allocations. The CAB has several comments and recommendations in this regard.
9.2. The table for 746-806 MHz that has been proposed by the Department reads as follows:
“Proposal
746-806 MHz BROADCASTING MOBILE CWW CZZ S5.293
MOD (WRC-2000) S5.293 Different category of service: in Canada, Chile, Colombia, Cuba, the United States, Guyana, Honduras, Jamaica, Mexico, Panama and Peru, the allocation of the bands 470-512 MHz and 614-806 MHz to the fixed and mobile services is on a primary basis (see No. S5.33), subject to agreement obtained under No. S9.21. In Argentina and Ecuador, the allocation of the band 470-512 MHz to the fixed and mobile services is on a primary basis (see No. S5.33), subject to agreement obtained under No. S9.21.
ADD CWW The use of part of the frequency band 746-806 MHz for the mobile service, as television broadcasting evolves to digital transmission, will be subject to a spectrum utilization policy developed through public consultation.
ADD CZZ The international in-country footnote S5.293 has allocated the bands 470-512 MHz and 614-746 (sic) MHz for fixed and mobile services on a co-primary basis with the broadcasting service. The Canadian Table of Frequency Allocations will not bring the provisions of S5.293 into force, at this time, in the frequency bands 470-512 MHz and 614-746 MHz, as this is core broadcasting spectrum for digital television.”
9.3. This proceeding covers only 746-806 MHz and does not include the other bands mentioned in International Footnote S5.293 (470-512 MHz and 614-806 MHz). Therefore, the CAB fails to see the relevance of Footnote CZZ. We recommend that it not be included, since Footnote CWW seems to cover adequately the situation for 746-806 MHz.
13 9.4. Moreover, the CAB recommends that the Table of Allocations covering 470-512 MHz and 614-746 MHz not be modified in any way during these proceedings. That is, the sole allocation for these bands should remain as “BROADCASTING”. We consider that it is neither necessary nor advisable to add International Footnote S5.293 and Footnote CZZ to the table for these bands at this time.
9.5. The CAB also notes that International Footnote S5.293 gives co-equal status to the Fixed service, as well as to Broadcasting and Mobile. The CAB agrees strongly with the Department’s apparent desire to exclude Fixed services from the band 746-806 MHz at this time. Should the addition of this service be considered for the subject band in the future, the CAB recommends that the Department initiate a further public consultation before doing so.
10. Concluding Remarks
10.1. The CAB wishes to commend the Department for the manner in which it has put forward the spectrum allocation proposals contained in Notice DGTP-004-01. This procedure has provided a good opportunity for the many views on the future use of this band to be considered by all interested parties.
10.2. The CAB trusts that its comments and proposals will be useful to the Department as it considers the next steps in both spectrum re-allocation and utilization. Our staff and advisors would be pleased to meet with Department officials to clarify or expand upon anything contained in this submission.
All of which is respectfully submitted this 24th day of September 2001.
THE CANADIAN ASSOCIATION OF BROADCASTERS/ L’ASSOCIATION CANADIENNE DES RADIODIFFUSEURS
APPENDIX 1
Technical Feasibility Report:
Sharing of TV Channels 60-69 by Mobile Services
Prepared by
Wayne A. Stacey & Associates Ltd. 5-1420 Youville Drive Ottawa ON Canada K1C 7B3 tel (613) 830-6985 fax (613) 830 8124 e-mail: [email protected]
Project 2000-A-25
24 August 2001 Table of Contents
Page
1. Introduction 1
2. Study Methodology 1
3. Results of the Study 4
Zone 1: Windsor to Quebec 4
Zone 2: 15 Larger Markets Outside Zone 1 5
Populations Where Channel 60-69 Mobile Services are Precluded 6
4. Report Conclusions 7
Appendix 1: Proposed Canadian Mobile / TV Protection Tables
Appendix 2: Zone 1 Maps
Appendix 3: Channel Usability in Zone 2 Markets
Appendix 4: Regular Allotments and Assignments - Channel 60-69
Appendix 5: FCC Rules: Section 90.309
Wayne A. Stacey & Associates Ltd Project 2000-A-25 1
1.Introduction
This report discusses the results of an engineering study that was conducted to determine the extent to which the 746-806 MHz band (TV Channels 60-69) might be shared between the TV and Mobile services in those areas of Canada where the spectrum demand for both services is highest. This study was conducted by Wayne A. Stacey & Associates Ltd, on behalf of Canada’s broadcasters, as part of preparatory work associated with submissions to Industry Canada on the issue of adding the Mobile Service as a co-primary allocation in the subject band15.
The objective of the study was to examine the technical feasibility of assigning mobile services interstitially, while maintaining the integrity of the current TV channel allotment plan. Specifically, the study was designed to examine the density of TV use in the subject band and to find channel “holes’ that might be used by mobile services during the period when TV must continue to operate in the band16.
A key assumption inherent in this study is that any new mobile services will be designed to fit around existing TV assignments and allotments in the subject band. This assumption is reasonable because a national TV allotment plan already exists, whereas there is no existing plan for mobile services in the subject band. In the TV plan, channels are clearly identified with respect to locations and operating parameters (class); consequently, the required protected service areas can be readily determined. Moreover, the current Canadian TV allotment plan has been previously negotiated with, and accepted by, the United States and thus has an official status internationally.
Ideally, it would be desirable to examine every TV market in Canada; however, the time required for this would be excessive. Instead, it was decided to concentrate the analysis on the region of the country where virtually all radiocommunication services experience the highest demand: the Windsor-to-Quebec corridor (Zone 1). The second phase of the study involved examining the situation for 15 specific large markets located outside Zone 1.
2. Study Methodology
As noted above, the tentative locations and classes of TV assignments and allotments are already well established17. These are listed in the Digital Television (DTV) Transition Allotment Plan (the Plan), published by Industry Canada18. The Plan contains a list of current NTSC (analog) assignments, unused NTSC allotments, as well as a companion DTV allotment for each analog assignment and allotment. A few changes to the original Plan came about as a result of negotiations
15Ref: “Proposal to Introduce the Mobile Service on a Co-Primary Basis with the Broadcasting Service in the Frequency Band 746-806 MHz”, Industry Canada Gazette Notice DGTP-004-01, 8 June 2001.
16While DTV is being introduced in Canada (the Transition Period), a large number of off-air TV channels will be required, since existing analog and new DTV services must be simulcast on separate transmitters in order to ensure no loss of service to the public.
17 For the purposes of this report, the term “allotment” means a channel that is identified in the national plan, but which is currently unused. An “assignment” is an allotment that has been licensed for use by a TV broadcasting undertaking.
18 Ref: Digital Television (DTV) Transition Allotment Plan, Issue 2, April 1999; available at http://strategis.ic.gc.ca/spectrum
Wayne A. Stacey & Associates Ltd Project 2000-A-25 2 with the US concerning the accommodation of its DTV channels in border areas; however, it remains essentially as published in 199919.
By taking the electronic version of the Plan, and re-assembling and sorting, it was possible to create a smaller database containing only analog assignments and vacant allotments, plus DTV allotments, that are located in the range 60-69. Each record in the database contains geographic co-ordinates for the existing or tentative transmitter site, plus a station class designator. The regular assignments and allotments included in this study are listed in Appendix 4.
Analog UHF-TV channels have three classes (A, B, and C), while digital channels have five (A, B, C, VU and VL)20. Each class has a typical protected service radius associated with it, as detailed in Table 1. Table 1.
Protected Class Service Radius (km) A 25 B 45 C 70 VU 82* VL 89* * DTV only
Having specified the various protected radii around TV assignment and allotments, it was then necessary to determine the required operating parameters and resulting interference contours that would be produced by mobile stations. Since the US has already developed such criteria for domestic sharing, it was decided to assume that the same technical principles would be used in Canada. This is considered reasonable, since the mobile services in both countries obtain their equipment from essentially the same sources. Moreover, if mobile services are to share the TV bands in both countries, the FCC will likely press Canada to adopt the US domestic criteria in order to facilitate cross-border co-ordination.
The ERP and HAAT limits21 that apply to US mobile services operating in the subject band are detailed in Section 27.50 of Part 27 of the FCC Rules. Briefly, the US rules state that maximum
19 Ref: Letter of Understanding Between the Federal Communications Commission of the United States of America and Industry Canada Related to the Use of the 54-72 MHz; 76-88 MHz, 174-216 MHz and 470-806 MHz Bands for the Digital Television Broadcasting Service Along the Common Border; Published January 2001.
20 The US has only a single UHF class, with a protected radius of 88.5 km (roughly equivalent to Canada’s VL class).
7 ERP = Effective Radiated Power HAAT = Antenna Height Above Average Terrain
Wayne A. Stacey & Associates Ltd Project 2000-A-25 3 base station operating parameters are limited to 1000 watts ERP / 305m HAAT (or equivalent). Control and mobile transmitters are limited to 30 watts ERP and hand-held units to 3 watts ERP.
Section 27.60 of the FCC Rules details the desired-to-undesired (D/U) signal ratios that must be observed by mobile services when protecting TV, as follows:
§ 27.60 TV/DTV interference protection criteria.
Base, fixed, control, and mobile transmitters in the 747-762 MHz and 777-792 MHz frequency bands must be operated only in accordance with the rules in this section to reduce the potential for interference to public reception of the signals of existing TV and DTV broadcast stations transmitting on TV Channels 59 through 68.
(a) D/U ratios. Licensees must choose site locations that are a sufficient distance from co-channel and adjacent channel TV and DTV stations, and/or must use reduced transmitting power or transmitting antenna height such that the following minimum desired signal-to-undesired signal ratios (D/U ratios) are met.
(1) The minimum D/U ratio for co-channel stations is 40 dB at the hypothetical Grade B contour (64 dBµV/m) (88.5 kilometers (55 miles)) of the TV station or 17 dB at the equivalent Grade B contour (41 dBµV/m) (88.5 kilometers (55 miles)) of the DTV station.
(2) The minimum D/U ratio for adjacent channel stations is 0 dB at the hypothetical Grade B contour (64 dBµV/m) (88.5 kilometers (55 miles)) of the TV station or -23 dB at the equivalent Grade B contour (41 dBµV/m) (88.5 kilometers (55 miles)) of the DTV station.
Considering the co-channel situation, this means that the maximum permissible interfering contour from a mobile base installation at the limit of the TV protected service area is:
analog: 64 - 40 = 24dBu DTV: 41 - 17 = 24dBu
Likewise, for adjacent-channel situations, the maximum permissible interfering contour from a mobile base installation at the limit of the TV protected service area is:
analog: 64 - 0 = 64dBu DTV: 41 – (-23) = 64dBu
Section 90.309 of the FCC Rules takes into account a standard 88.5 km protected radius (for TV), the maximum permissible interfering contours (for mobile), and the permissible mobile operating parameters. These factors are combined into tables that show the minimum permissible distance between the TV and mobile base sites. Separate tables are provided for co-channel and adjacent- channel distances (see Appendix 5).
While the US table distances could be used directly for consideration of Canadian DTV Class VL allotments, it is necessary to derive new tables for those Canadian classes having protected service
Wayne A. Stacey & Associates Ltd Project 2000-A-25 4 radii smaller than 89 km. By analyzing the FCC’s tables , it can be established that the distances from the mobile base site to the TV protected service contour were calculated using the standard TV F(50,10) propagation curves. As an example, for the case of mobile base ERP 1000 watts / HAAT 152m, the minimum co-channel separation distance is shown as 209 km:
TV signal at its protected contour (88.5 km): 64 dBu
Undesired F(50,10) mobile signal at: (209-88.5) = 120.5 km: 24 dBu
D/U Ratio: 40 dB
A similar exercise reveals that the same methodology was used by the FCC for the adjacent-channel case.
If the basic US mobile-to-TV protection rules are assumed, it becomes a straightforward exercise to scale down and re-format the FCC minimum separation tables to account for the lower protected service radii for Canadian Class A, B, C and VU allotments. The resulting Canadian equivalent table is shown in Appendix 1.
Having a protection distance table, it is then possible to take the geographic location of each TV allotment or assignment and draw a circle around it that has a radius based upon the class of the TV station and typical operating parameters for a nearby mobile base station. This circle represents the area within which a mobile base using the assumed operating parameters cannot be located. Since there are nine typical operating parameter combinations for mobile shown in the Appendix 1 spacing table, each TV allotment or assignment would have nine concentric “no-go” circles drawn around its transmitter site, were this all to be mapped out. To reduce the number of individual calculations in the study, it was decided that the lowest mobile base operating parameters in the Appendix 1 table would be utilized. This gives the most optimistic picture of the mobile drop-in possibilities. Therefore, the analysis is based upon the assumption that mobile base parameters do not exceed ERP 125 watts / HAAT 31 metres.
3. Results of the Study
3.1. Zone 1: Windsor to Quebec
The graphical results of the analyses conducted for Zone 1 are contained in the maps displayed in Appendix 2. A separate map was prepared for each of the TV channels from 60-69, using MapInfo™. A site marker (cross) was placed at the geographical location where a related TV allotment or assignment is located. (For the Channel 60 map, allotments and assignments on Channel 59 were also taken into account.)
An appropriate “no-go” radius was then drawn around each TV site. The radius was taken from the Appendix 1 table, according to the class of the TV station involved and its channel relationship to
Wayne A. Stacey & Associates Ltd Project 2000-A-25 5 the channel being studied (i.e. co-channel or upper/lower 1st-adjacent channel). Each radius was coded according to Table 222.
Table 2.
Contour Relationship Code Co-Channel Solid line Lower Adjacent Short dashes Upper Adjacent Long dashes
By visually inspecting the maps, it is possible to see exactly where a mobile base station with parameters no larger than 125W/31m could be located without causing unacceptable interference to a related TV assignment or allotment. Specifically, the mobile base can only be located where its site would not be enclosed by a one of the coded circles on the map corresponding to the channel being examined.
It can be seen from the 10 maps in Appendix 2 that there is virtually no possibility of using any of the ten channels for mobile services in most of the heavily populated area between Windsor and Quebec City. This is certainly the case for the major cities of Toronto, Montreal and Ottawa, although a few of the subject channels may be usable east of Sherbrooke QC and in areas north of Toronto near Georgian Bay. As this analysis was prepared assuming the lowest mobile operating parameters in the Appendix 1 protection table, it tends to depict the most optimistic possibilities for new mobile services in Zone 1.
It can also be seen from Maps 1-10 in Appendix 1 that the US will also be unable to use any of the subject channels for mobile services in Detroit MI, with the possible exception of Channel 62 which would have to be shared with Windsor ON. The remaining nine channels, including all the ones the FCC has reserved for public safety use (63, 64, 68 & 69) would produce unacceptable interference to Canadian TV services on Canadian soil, according to the TV protection criteria used by the US itself. Similarly, US use of the subject band for mobile in Buffalo NY would be limited to channels 62 and 69.
3.2. Zone 2: 15 Larger Markets Outside Zone 1
As the number of TV allotments is substantially lower in those markets outside Zone 1, it was not necessary to resort to using display maps to demonstrate which channels in the subject band might be considered for mobile sharing. Appendix 3 contains a spreadsheet showing the results of the analysis. A “Y” in the table indicates that the channel could be used by mobile without constraining the TV Plan. Where a channel is prohibited, the conflicting TV assignment or allotment is identified. An “X” in the table means that the location has a 1st-adjacent allotment or assignment which prevents the use of that particular channel. The channels that would not be constrained by TV assignments and allotment are shaded in the spreadsheet.
22 Some locations have both an upper and lower 1st-adjacent allotment. Only one of these may be shown on the map, if they are of the same class and have the same no-go radius. Site markers with no associated radii are low-power unprotected TV assignment or allotments (LPTV).
Wayne A. Stacey & Associates Ltd Project 2000-A-25 6
Of the 15 main markets outside Zone 1, only Calgary, Regina, Winnipeg and St. John’s remain free of any constraints at all. The remainder have a number of constraints that would limit the use of specific channels for mobile services. Table 3 shows which of the four channels reserved by the US for Public Safety services (63, 64, 68, 69) cannot be used in the listed cities.
Table 3.
City Unusable Public Safety Channels Vancouver/Victoria 68, 69 Kelowna 68 Edmonton 64 Sudbury 64, 68, 69 North Bay 63, 64, 68, 69 Saint John 63, 68, 69 Fredericton 63, 68, 69 Moncton 68,69 Halifax 63, 64
3.3. Populations Where Channels 60-69 Mobile Services are Precluded
It can be seen from the results of this study that the presence of TV allotments and assignments places very severe constraints on where Channels 60-69 could be used, during the period until the DTV transition is completed. In order to further quantify the inhibiting effect of the TV channels, Chart 1 was prepared. This shows, for each channel in the range 60-69, the percentage of Canada’s total population that resides in the “no-go” areas where mobile base station facilities cannot be established
Wayne A. Stacey & Associates Ltd Project 2000-A-25 7
Chart 1.
Population in Areas Unusable for Mobile
100% 90% n 80% 70% 60% 50% 40% 30% 20% % of Total Canada Populatio Canada Total % of 10% 0% 60 61 62 63 64 65 66 67 68 69 Channel Num ber
It can be seen from the chart that these channels could not be used for mobile services in areas where the large majority of Canadians live (between 56% and 70%), presumably where the demand for such spectrum is the greatest.
4. Report Conclusions
This study demonstrates that the potential for using TV Channels 60-69 for mobile services will be very limited in Canada, until such time as this band has been vacated by television subsequent to a successful transition to DTV throughout North America.
In Central Canada, where the demand for new mobile spectrum is expected to be greatest, there is virtually no possibility of using any of the ten TV channels in the interim. Even when very minimal mobile base operating parameters are assumed, the protection of co-channel and adjacent-channel television allotments and assignments would require that mobile operations be confined essentially to non-urban areas in the Windsor-Quebec corridor.
In the Vancouver/Victoria area, there is a good possibility of sharing seven of the subject channels between TV and mobile. The three excluded channels include two of the four that the FCC has identified for Public Safety services (68 & 69). Any of the ten channels could be used in Regina, Calgary and Winnipeg; however, three channels would be excluded in Edmonton, including one of the four FCC Public Safety channels (64) .
Surprisingly, the North Bay/Sudbury area has little room for sharing, with only two channels feasible in each of these cities. A similar situation occurs in Saint John and Fredericton, with two and one possible mobile channels in each of these cities. The number of usable channels increases as one moves east, although four of the ten are excluded in Halifax. All ten channels could be used by mobile in St. John’s.
Wayne A. Stacey & Associates Ltd Project 2000-A-25 8
Industry Canada’s Notice DGTP-004-01 specifically identifies Toronto, Montreal and Vancouver as having the most critical demand for new mobile channels. This engineering report shows that the potential for sharing exists only in Vancouver. This begs the question of why a national sharing policy would be adopted when it could only be applied in a very small portion of the country in any event, for technical reasons. An option may be to allocate Channels 60-69 as co-primary only in those areas where they could be used effectively, i.e. only in the areas identified as “Zone 2” in the Canada-US TV Agreement.
WAYNE A. STACEY & ASSOCIATES LTD.
Wayne A. Stacey, P. Eng. Consulting Engineer
Wayne A. Stacey & Associates Ltd Project 2000-A-25 Appendix 1 Proposed Canadian Mobile / TV Protection Tables
Mobile's Interf. Mobile Base Operating Parameters F(50,10) 1000 1000 600 475 375 275 225 175 125 ERP (W) Field 152 137 122 106 92 76 61 45 31 HAAT (m) dBu Distance to Interfering Contour 24 (Co) 119 117 106 96 87 77 71 63 54 km 64 (Adj)19181512119 8 6 5km
Co-Channel Requirements
TV TV Class Gr B Dist Distance between TV site & Mobile Base A 25 144 142 131 121 112 102 96 88 79 km B 45 164 162 151 141 132 122 116 108 99 km C 70 189 187 176 166 157 147 141 133 124 km VU 82 201 199 188 178 169 159 153 145 136 km VL 89 208 206 195 185 176 166 160 152 143 km
Adjacent Channel Requirements
TV TV Class Gr B Dist Distance between TV site & Mobile Base A 25444340373634333130km B 45646360575654535150km C 70898885828179787675km VU 82 101 100 97 94 93 91 90 88 87 km VL 89 108 107 104 101 100 98 97 95 94 km
Appendix 2
Zone 1 Maps CHAMBERLAIN RIVIERE-DU HARRIS TOWNSHIP ED BEARN/FABRE
QUEBEC ELLIOT LAKESUDBURY
FOYMOUNT MONTREAL TOBERMORY(17) OTTAWA SHERBROOKE BALA
PETERBOROUGH PETERBOROUGH
CIRCLES BASED ON MOBILE KITCHENER BASE PARAMETERS ERP 125W, HAAT 31m LONDON FORT ERIE CH 60 PROT DIST. NORMANDALE CH 59 PROT DIST. CHATHAM WINDSOR CH 61 PROT DIST. 0 100 200
Kilometers MAP 1 CHANNEL 60 + ADJACENTS
DUCK LAKE CHAMBERLAIN KERNS TOWNSHIP BEARN/FABRE
QUEBEC WHARNCLIFFE LEE VALLEY
OTTAWA MONTREAL SHERBROOKE OTTAWA
PETERBOROUGH WINGHAM BRIGHTON CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, HAAT 31m KITCHENER CH 61 PROT DIST.
LONDON FORT ERIE CH 60 PROT DIST. NORMANDALE CH 62 PROT DIST.
WINDSOR 0 100 200 Kilometers
MAP 2
CHANNEL 61 + ADJACENTS DUCK LAKE SAVARD KENABEEK CABA VILLE-MARIE
QUEBEC
DESBARATSELLIOT LAKE LEE VALLEY
WHITNEY OTTAWA MONTREAL HULL SHERBROOKE
KINGSTON WINGHAM BRIGHTON TORONTO CIRCLES BASED ON MOBILE KITCHENER BASE PARAMETERS ERP 125W, HAAT 31m CH 62 PROT DIST.
CH 61 PROT DIST.
CH 63 PROT DIST. CHATHAM 0 100 200 Kilometers MAP 3
CHANNEL 62 + ADJACENTS KEARNS DUCK LAKE SAVARD KENABEEK CABA VILLE-MARIE TEWKESBURY
LAIRDWHARNCLIFFE LEE VALLEY NORTH BAY
EVANSVILLE WHITNEY HULL MONTREAL HULL SHERBROOKE
KINGSTON WINGHAM BRIGHTON TORONTO
CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, HAAT 31m CHATHAM CH 63 PROT DIST.
CH 62 PROT DIST.
CH 64 PROT DIST. MAP 4
0 100 200 CHANNEL 63 + ADJACENTS Kilometers KEARNS SAVARD RIVIERE-DU KENABEEK CABA VILLE-MARIE TEWKESBURY
SUDBURY LAIRD NORTH BAY
EVANSVILLE WHITNEY HULL MONTREAL SHERBROOKE OTTAWA
KINGSTON
CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, TORONTO HAAT 31m CH 64 PROT DIST.
CH 63 PROT DIST.
CH 65 PROT DIST.
CHATHAM 0 100 200 WINDSOR Kilometers
MAP 5
CHANNEL 64 + ADJACENTS KEARNS RIVIERE-DU
TEWKESBURY
SUDBURY LAIRD NORTH BAY NORTH BAY EVANSVILLE HULL MONTREAL SHERBROOKE/MAGOG OTTAWA
CIRCLES BASED ON MOBILE KINGSTON BRIGHTON BASE PARAMETERS ERP 125W, HAAT 31m TORONTO CH 65 PROT DIST. CH 64 PROT DIST.
CH 66 PROT DIST.
0 100 200 CHATHAM WINDSOR Kilometers WHEATLEY
MAP 6
CHANNEL 65 + ADJACENTS ROUYN-NORANDA
RIVIERE-DU
QUEBEC SUDBURY ELLIOT LAKE NORTH BAY
MONTREAL SHERBROOKE/MAGOG OTTAWA SEVERN FALLS
KINGSTON BRIGHTON CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, TORONTO HAAT 31m CH 66 PROT DIST.
KITCHENER CH 65 PROT DIST. SARNIA-OIL SPRINGS CH 67 PROT DIST.
CHATHAM 0 100 200 WINDSOR WHEATLEY Kilometers
MAP 7
CHANNEL 66 + ADJACENTS ROUYN-NORANDA
QUEBEC SUDBURY ELLIOT LAKE NORTH BAY
MADAWASKA MONTREAL SHERBROOKE OTTAWA SEVERN FALLS
KINGSTON BRIGHTON CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, TORONTO HAAT 31m CH 67 PROT DIST. KITCHENER CH 66 PROT DIST. SARNIA-OIL SPRINGS CH 68 PROT DIST.
0 100 200 WINDSOR Kilometers
MAP 8
CHANNEL 67 + ADJACENTS ROUYN-NORANDA
DUCK LAKE
QUEBEC SUDBURY BRUCE MINESELLIOT LAKE NORTH BAY
MADAWASKA MONTREAL SHERBROOKE OTTAWA SEVERN FALLS
KINGSTON CIRCLES BASED ON MOBILE BASE PARAMETERS ERP 125W, TORONTO HAAT 31m CH 68 PROT DIST. KITCHENER CH 67 PROT DIST.
SARNIA-OIL SPRINGS CH 69 PROT DIST.
0 100 200 WINDSOR Kilometers
MAP 9
CHANNEL 68 + ADJACENTS DUCK LAKE
SUDBURY BRUCE MINES NORTH BAY
MADAWASKA MONTREAL OTTAWA SHERBROOKE
CIRCLES BASED ON MOBILE KINGSTON BASE PARAMETERS ERP 125W, HAAT 31m CH 69 PROT DIST. TORONTO CH 68 PROT DIST.
SARNIA-OIL SPRINGS 0 100 200 Kilometers WINDSOR
MAP 10
CHANNEL 69 + ADJACENTS Appendix 3
Channel Usability in Zone 2 Markets
VANCOUVER/ CHANNEL VICTORIA KELOWNA CALGARY EDMONTON SASKATOON REGINA WINNIPEG SUDBURY 59 N/A CHBC-DT (C) N/A CFRN-DT (VL) CFQC-DT (VU) N/A N/A ALLOT (C) 60 Y X Y X X Y Y X 61 Y Y Y Y Y Y CBLFT-6-DT (VU) 62 Y Y Y Y Y Y Y 63 * Y Y Y Y Y Y Y 64 * Y Y X Y Y Y X 65 Y Y CBXFT-DT (VU) Y Y Y CFGC-DT (VU) 66 Y X Y X Y Y Y X 67 X CHKL-DT(VL) Y Y Y Y Y X 68 * CHEK-DT (VL) X Y Y Y Y Y CKNC-DT (VU) 69 * X Y Y Y Y Y Y X
CHANNEL NORTH BAY SAINT JOHN FREDERICTON MONCTON CHARLOTTETOWN HALIFAX ST.JOHN'S 59 N/A N/A ALLOT (C) DOR ALLOT(B) N/A N/A N/A 60 CKRN-3-DT (VU) Y X X Y Y Y 61 Y X X Y CJCB-2-DT (VU) Y Y 62 Y CBAT-DT (VL) CBAT-DT (VL) CBAT-DT (VL) Y X Y 63 * X X X Y Y CBHT-DT (VL) Y 64 * CFGC-2-DT (VL) Y Y Y Y X Y 65 X X X Y X CBHT-5-DT (C) Y 66 CHNB-DT (VL) CKLT-DT(VU) CKLT-DT(VU) X CBCT-DT (VU) Y Y 67 X X X CBAFT-DT(VU) X Y Y 68 * X X X X Y Y Y 69 * CICA-6-DT (VL) CIHF-DT(VU) CIHF-DT(VU) CIHF-DT(VU) Y Y Y
* Channels reserved by the FCC for Public Safety Services
Appendix 4: Regular Allotments and Assignments Channel 60-69
TYPE LNG LAT CH CL D/N CITY PR CALL (Deg W.) (Deg N.) 59 VL D EDMONTON AB CFRN-TV -113.213333 53.385000 59 B D COMOX(20) BC ALLOT -124.916667 49.666667 59 A N CRANBROOK BC ALLOT -115.766667 49.500000 59 B D FORT ST JOHN(14) BC ALLOT -120.850000 56.250000 59 C D KELOWNA BC CHBC-TV -119.527778 49.966667 59 VL D OOTSA LAKE BC CH4467 -126.009722 53.870833 59 C N PRINCE GEORGE(24) BC ALLOT -122.750000 53.916667 59 A D SPARWOOD BC ALLOT -114.883333 49.716667 59 B N ALONSA(14) MB ALLOT -98.966667 50.800000 59 B D MATHESON ISLAND(47) MB ALLOT -96.933333 51.733333 59 B D RUSSELL MB ALLOT -101.250000 50.783333 59 C D CARAQUET NB ALLOT -64.950000 47.800000 59 B D DORCHESTER NB ALLOT -64.516667 45.900000 59 VU D EDMUNDSTON NB CBAFT-2 -68.316389 47.390278 59 C N FREDERICTON NB ALLOT -66.650000 45.966667 59 A N PORT AU PORT(52) NF ALLOT -58.716667 48.550000 59 A D ST VINCENT'S NF ALLOT -53.633333 46.800000 59 A D CALEDONIA(42) NS ALLOT -65.033333 44.366667 59 C D CHETICAMP NS CBHFT-4 -60.984444 46.578056 59 B N BALA ON ALLOT -79.782778 44.970556 59 B N CHATHAM ON CICO-TV-59 -82.083333 42.450000 59 C N FOYMOUNT ON CBOT-1 -77.304167 45.430000 59 C D KAPUSKASING ON CFCL-TV-3 -82.357778 49.391111 59 B D KITCHENER ON ALLOT -80.483333 43.450000 59 C D SUDBURY ON ALLOT -81.000000 46.500000 59 C D THUNDER BAY(41) ON ALLOT -89.250000 48.383333 59 B N TOBERMORY(17) ON ALLOT -81.666667 45.250000 59 B D VERMILION BAY ON ALLOT -93.400000 49.850000 59 VU D MONTREAL QU CFTM-TV -73.592222 45.505556 59 B N MURDOCHVILLE(31) QU ALLOT -65.500000 48.966667 59 C N RIVIERE-DU-LOUP QU ALLOT -69.533333 47.833333 59 B N ST-RENE-DE-MATANE(41) QU ALLOT -67.383333 48.716667 59 B N FORT QU'APPELLE(27) SA ALLOT -103.800000 50.766667 59 VU D SASKATOON SA CFQC-TV -106.386667 52.191667 59 VU N CLINTON CREEK(8) YT ALLOT -140.613889 64.401944 60 VL D CAMPBELLTON NB CBAT-TV-4 -66.116667 48.135278 60 VL D ELLIOT LAKE ON CICI-TV-1 -82.669167 46.429722 60 B D FORT ERIE ON CIII-TV-55 -79.093333 42.926389 60 B D LONDON ON CICO-TV-18 -81.355556 42.955556 60 A D NORMANDALE ON CBLN-TV-6 -80.292222 42.726389 60 C N OTTAWA ON CFMT-TV-2 -75.564167 45.216944 60 C D PETERBOROUGH ON CFTO-TV-54 -78.533333 44.445556 60 B N WINDSOR ON CHWI-TV-60 -83.040000 42.316111 60 VU D BEARN/FABRE QU CKRN-TV-3 -79.377222 47.254444 60 VU D SHERBROOKE QU CHLT-TV -72.242222 45.311944 61 VU D ANTIGONISH NS CJCB-TV-2 -62.260833 45.545833 61 VU D MIDDLETON NS CBHT-6 -64.817222 45.077222 61 VU D ELLIOT LAKE ON CBLFT-6 -82.618333 46.389167 61 C N KITCHENER ON CBLFT-8 -80.602222 43.450000 TYPE LNG LAT CH CL D/N CITY PR CALL (Deg W.) (Deg N.) 61 VL D QUEBEC QU CFAP-TV -71.217222 46.807500 62 VL D ALLARDVILLE NB CBAFT-3 -65.439722 47.377500 62 VL D SAINT JOHN NB CBAT-TV -66.233889 45.477500 62 B D BRIGHTON ON CKWS-TV-1 -77.794444 44.043611 62 VU D OTTAWA ON CBOFT -75.850556 45.503056 62 VU D WINGHAM ON CKNX-TV -81.207222 44.090556 62 B N MONTREAL QU CJNT-TV -73.591667 45.505000 63 VL D HALIFAX NS CBHT -63.657778 44.650833 63 C D INVERNESS NS CBIT-19 -61.290000 46.102222 63 B D CHATHAM ON CBLFT-10 -82.083333 42.450000 63 C D KINGSTON ON CBLFT-14 -76.480556 44.289444 63 C D TORONTO ON CICA-TV -79.387500 43.642500 63 C D HULL QU CFGS-TV -75.292222 45.312222 63 VU D SHERBROOKE QU CKSH-TV -72.242222 45.311944 64 B N CHATHAM ON CBLN-TV-3 -82.083333 42.450000 64 VL D KEARNS ON CFCL-TV-2 -79.555278 48.135278 64 C D KINGSTON ON CICO-TV-38 -76.480556 44.289444 64 VL D NORTH BAY ON CFGC-TV-2 -79.411111 46.302778 64 VL D TORONTO ON CBLT -79.387500 43.642500 64 C D HULL QU CIVO-TV -75.850556 45.503056 64 VL D MONTREAL QU CBFT -73.592222 45.505556 65 VU D EDMONTON AB CBXFT -113.285278 53.514722 65 C D NEW GLASGOW NS CBHT-5 -62.637222 45.533333 65 B D CHATHAM ON CBLN-TV-3 -82.083333 42.450000 65 C N OTTAWA ON CITY-TV-3 -75.564167 45.216944 65 VU D SUDBURY ON CFGC-TV -80.959444 46.505278 65 C D TORONTO ON CIII-TV-41 -79.387500 43.642500 65 B D WINDSOR ON CHWI-TV-60 -83.040000 42.316111 65 VL D CARLETON QU CHAU-TV -66.116944 48.135556 66 VU D SAINT JOHN NB CKLT-TV -66.233889 45.477500 66 B N BRIGHTON ON CKWS-TV-1 -77.794444 44.043611 66 C D KINGSTON ON ALLOT -76.427778 44.167222 66 VL D NORTH BAY ON CHNB-TV -79.434167 46.063333 66 C D OTTAWA ON CFMT-TV-2 -75.564167 45.216944 66 C D TORONTO ON NEW -79.379167 43.649444 66 C D WHEATLEY ON CHWI-TV -82.446667 42.141667 66 VU D CHARLOTTETOWN PE CBCT -63.342222 46.212222 66 C D SHERBROOKE/MAGOG QU CFKS-TV -72.242222 45.311944 67 VL D KELOWNA BC CHKL-TV -119.527778 49.966667 67 VU D MONCTON NB CBAFT -64.903889 46.144722 67 VU D ELLIOT LAKE ON CBEC-TV -82.621111 46.387778 67 C D KITCHENER ON CBLN-TV-1 -80.444167 43.260833 67 C D OTTAWA ON CITY-TV-3 -75.564167 45.216944 67 B D SARNIA-OIL SPRINGS ON CBLFT-17 -82.338611 42.908611 67 C N SEVERN FALLS ON CHCH-TV-3 -79.782778 44.970556 67 B N MONTREAL QU ALLOT -73.592222 45.505556 67 VU D QUEBEC QU CBVE-TV -71.265000 46.784444 67 VU D ROUYN-NORANDA QU CFEM-TV -79.043611 48.265278 68 VL D VICTORIA BC CHEK-TV -123.169444 48.774444 68 VL D SYDNEY NS CJCB-TV -60.173889 46.121944 68 C D OTTAWA ON CHRO-TV-43 -75.564167 45.216944 68 B N SARNIA-OIL SPRINGS ON CBLFT-17 -82.338611 42.908611 68 VU D SUDBURY ON CKNC-TV -81.020278 46.500833 68 C D TORONTO ON CFMT-TV -79.387500 43.642500 TYPE LNG LAT CH CL D/N CITY PR CALL (Deg W.) (Deg N.) 68 C D WINDSOR ON CICO-TV-32 -82.951389 42.152500 68 C D SHERBROOKE QU CIVS-TV -72.242222 45.311944 69 B N SPILLIMACHEEN BC CBUBT-6 -116.343056 50.899722 69 VU D CAMPBELLTON NB CBAFT-7 -66.581389 48.082778 69 VU D SAINT JOHN NB CIHF-TV-2 -66.234167 45.477778 69 VU D MULGRAVE NS CBHFT-2 -61.413056 45.598889 69 VU D KINGSTON ON CKWS-TV -76.427778 44.167222 69 C N LONDON ON CFMT-TV-1 -81.355556 42.955556 69 VL D NORTH BAY ON CICA-TV-6 -79.434722 46.062778 69 C D WINDSOR ON CBEFT -82.951389 42.152500 69 B D MONTREAL QU CJNT-TV -73.591667 45.505000
Appendix 5
TITLE 47—FCC RULKS
PART 90--PRIVATE LAND MOBILE RADIO SERVICES
Sec. 90.309 Tables and figures.
Directions for using the tables. (1) Using the method specified in Sec. 73.611 or charts or maps of suitable scale, determine the distances (i) between the proposed land mobile base station and the protected cochannel television station and (ii) between the proposed land mobile base station and the protected adjacent channel television station. If the exact mileage does not appear in table A for protected cochannel television stations (or table B for Channel 15 in New York and Cleveland and channel 16 in Detroit) or table E for protected adjacent channel television stations, the next lower mileage separation figure is to be used. (2) Entering the proper table at the mileage figure found in paragraph (a)(1) of this section, find opposite, a selection of powers that may be used for antenna heights ranging from 15 m (50 ft) to 152.5 m (500 ft) (AAT). If the exact antenna height proposed for the land mobile base station does not appear in the proper table, use the power figure beneath the next greater antenna height. (3) The lowest power found using the tables mentioned in paragraphs (a)(1) and (a)(2) of this section is the maximum power that may be employed by the proposed land mobile base station. (4) In determining the average elevation of the terrain, the elevations between 3.2 km (2 mi) and 16 km (10 mi) from the antenna site are employed. Profile graphs shall be drawn for a minimum of eight radials beginning at the antenna site and extending 16 km (10 mi). The radials should be drawn starting with true north. At least one radial should be constructed in the direction of the nearest cochannel and adjacent channel UHF television stations. The profile graph for each radial shall be plotted by contour intervals of from 12.2 m (40 ft) to 30.5 m (100 ft) and, where the data permits, at least 50 points of elevation (generally uniformly spaced) should be used for each radial. For very rugged terrain 61 m (200 ft) to 122 m (400 ft) contour intervals may be used. Where the terrain is uniform or gently sloping, the smallest contour interval indicated on the topographic chart may be used. The average elevation of the 12.8 km (8-mile) distance between 3.2 km (2 mi) and 16 km (10 mi) from the antenna site should be determined from the profile graph for each radial. This may be obtained by averaging a large number of equally spaced points, by using a planimeter, or by obtaining the median elevation (that exceeded by 50 percent of the distance) in sectors and averaging those values. In the preparation of the profile graphs, the elevation or contour intervals may be taken from U.S. Geological Survey Topographic Maps, U.S. Army Corps of Engineers Maps, or Tennessee Valley Authority Maps. Maps with a scale of 1:250,000 or larger (such as 1:24,000) shall be used. Digital Terrain Data Tapes, provided by the National Cartographic Institute, U.S. Geological Survey, may be utilized in lieu of maps, but the number of data points must be equal to or exceed that special above. If such maps are not published for the area in question, the next best topographic information should be used. (5) Applicants for base stations in the Miami, FL, urbanized area may, in lieu of calculating the height of average terrain, use 3 m (10 ft) as the average terrain height.
Table A--Base Station--Cochannel Frequencies (50 dB Protection) Maximum Effective Radiated Power (ERP) \1\ ------Antenna height in meters (feet) (AAT) ------Distance in kilometers (miles): \2\ 30.5 91.5 106 122 137 152.5 15 (50) (100) 45 (150) 61 (200) 76 (250) (300) (350) (400) (450) (500) ------260 (162)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 257 (160)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 800 249 (155)...... 1,000 1,000 1,000 1,000 1,000 875 775 700 625 575 241 (150)...... 1,000 1,000 950 775 725 625 550 500 450 400 233 (145)...... 850 750 650 575 500 440 400 350 320 300 225 (140)...... 600 575 475 400 350 300 275 250 230 225 217 (135)...... 450 400 335 300 255 240 200 185 165 150 209 (130)...... 350 300 245 200 185 160 145 125 120 100 201 (125)...... 225 200 170 150 125 110 100 90 80 75 193 (120)...... 175 150 125 105 90 80 70 60 55 50 ------\1\ The effective radiated power (ERP) and antenna height above average terrain (AAT) shall not exceed the values given in this table. \2\ At this distance from transmitter site of protected UHF television station.
Table B--Base Station--Cochannel Frequencies (40 dB Protection) Maximum Effective Radiated Power (ERP) \1\ ------Antenna height in meters (feet) (AAT) ------Distance in kilometers (miles): \2\ 30.5 91.5 106 122 137 152.5 15 (50) (100) 45 (150) 61 (200) 76 (250) (300) (350) (400) (450) (500) ------209 (130)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 201 (125)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 850 750 725 193 (120)...... 1,000 1,000 1,000 1,000 900 750 675 600 550 500 185 4(115)...... 1,000 1,000 800 725 600 525 475 425 375 350 177 (110)...... 850 700 600 500 425 375 325 300 275 225 169 (105)...... 600 475 400 325 275 250 225 200 175 150 161 (100)...... 400 325 275 225 175 150 140 125 110 100 153 (95)...... 275 225 175 125 110 95 80 70 60 50 145 (90)...... 175 125 100 75 50 ...... ------\1\ The effective radiated power (ERP) and antenna height above average terrain (AAT) shall not exceed the values given in this table. \2\ At this distance from transmitter site of protected UHF television station. Table C--Mobile and Control Station--Distance Between Associated Base Station and Protected Cochannel TV Station [50 dB protection] ------Distance Effective radiated power (watts) of ------mobile unit and control station Kilometers Miles ------200...... 249 155 150...... 243 151 100...... 233 145 50...... 217 135 25...... 201 125 10...... 188 117 5...... 180 112 ------
Table D--Mobile and Control Station--Distance Between Associated Land Mobile Base Station and Protected Cochannel TV Station [40 dB protection] ------Distance Effective radiated power (watts) of ------mobile unit and control station Kilometers Miles ------200...... 209 130 150...... 201 125 100...... 193 120 50...... 185 115 25...... 177 110 10...... 169 105 5...... 161 100 ------
Table E--Base Station Adjacent Channel Frequencies Maximum Effective Radiated Power (ERP) \1\ ------Antenna height in meters (feet) (AAT) ------Distance in kilometers (miles): <SUP>2,3</SUP> 30.5 91.5 106 122 137 152.5 15 (50) (100) 45 (150) 61 (200) 76 (250) (300) (350) (400) (450) (500) ------108 (67)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 106 (66)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 750 104 (65)...... 1,000 1,000 1,000 1,000 1,000 1,000 1,000 825 650 600 103 (64)...... 1,000 1,000 1,000 1,000 1,000 1,000 775 625 500 400 101 (63)...... 1,000 1,000 1,000 1,000 1,000 650 450 325 325 225 99 (62)...... 1,000 1,000 1,000 1,000 525 375 250 200 150 125 98 (61)...... 1,000 1,000 700 450 250 200 125 100 75 50 96 (60)...... 1,000 1,000 425 225 125 100 75 50 ------\1\ The effective radiated power (ERP) and antenna height above average terrain (AAT) shall not exceed the values given in this table. \2\ At this distance from transmitter site of protected UHF television station. \3\ The minimum distance is 145 km (90 miles) where there are mobile units associated with the base station. See sec. 90.307(d).
Table ``F''--Decibel Reduction/Power Equivalents ------ERP permitted dB reduction below 1 kW (figures rounded) ------1...... 795 2...... 630 3...... 500 4...... 400 5...... 315 6...... 250 7...... 200 8...... 160 9...... 125 10...... 100 11...... 80 12...... 65 13...... 50 14...... 40 15...... 30 16...... 25 17...... 20 18...... 15 19...... 12 20...... 10 21...... 8 22...... 6 23...... 5 24...... 4 25...... 3 26...... 2.5 27...... 2 28...... 1.5 29...... 1.25 30...... 1 ------
(b) Directions for Using the Figures. (1) Determine antenna height above average terrain. (According to Sec. 90.309(a)(4).) (2) Locate this value on the antenna height axis. (3) Determine the separation between the LM antenna site and the nearest protected co-channel TV station. (According to Sec. 73.611.) (4) Draw a vertical line to intersect the LM/TV separation curve at the distance determined in step 3 above. For distances not shown in the graph use linear interpolation. (5) From the intersection of the LM/TV separation curve draw a horizontal line to the power reduction scale. (6) The power reduction in dB determines the reduction below 1 kW that must be achieved. (7) See table F for dB/power equivalents.