AFCCE Supports AM Synchronous Boosters (RM-11779)

In a recent Petition for Rulemaking, the petitioner asked the Commission to routinely authorize AM Synchronous Booster stations as a part of FCC rules and specified certain rules that would be necessary to achieve that result. AFCCE generally supports the proposals set forth in the Petition with regard to authorization of such systems on a permanent basis and believes that based on known technical data the application to such systems of certain of the Part 73 interference protection requirements will be adequate to prevent interference with other stations.

Read the complete AFCCE filing here:  AFCCE Comments FCC RM-11779 AM Synchronous Boosters

AFCCE Endorses ATSC 3.0

In Ex Parte Comments filed July 19, 2016, AFCCE fully supports the proposals with regard to authorization of the System Discovery and Signaling Layer of ATSC 3.0 as an optional transmission standard that can be utilized by television licensees, and believes that based on known technical data present interference protection requirements are adequate to prevent interference between ATSC 3 systems, between ATSC 1 and ATSC 3 systems, and between ATSC 3 and wireless LTE systems.

Link to AFCCE Ex Parte Comments in GN Docket 16-142

AFCCE considering further comments in FCC’s AM revitalization proceeding

On October 21, 2015 the FCC adopted a First Report and Order (First R&O), Further Notice of Proposed Rule Making (FNPRM), and Notice of Inquiry (NOI) in the matter of Revitalization of the AM Service, MM Docket No. 13-249. The text has been published. Don Everist, AFCCE’s FCC Liaison, has prepared a helpful preliminary overview of FCC actions and proposals, showing how they align with views as stated in AFCCE comments and reply comments submitted in the Docket in early 2014.

The First R&O initiates a process whereby AM licensees and permittees may file FM translator modification applications in 2016, and applications for new FM translators by auction in 2017. It also relaxes daytime and nighttime community coverage standards, eliminates the “ratchet rule,” allows wider use of Modulation Dependent Carrier Level control technologies, and reduces AM antenna efficiency standards by 25 percent.

The FNPRM proposes modifying AM protection standards, revising the rule on siting of FM cross-service fill-in translators, modifying partial proof of performance rules, modifying rules for Method of Moments proofs, and requiring surrender of licenses by dual expanded band / standard band licensees.

The NOI seeks comment on issues related to opening the Expanded Band to further development.  Comment is also sought on possibly modifying the main studio rule.

If you think AFCCE should seek reconsideration of the First R&O, or should take a position in the FNPRM or NOI, please let us know your specific suggestions as soon as possible, ideally including draft filing text. You can do so as comments to this post for others to see. Or, you can send your comments to Steve Crowley, AFCCE’s Engineering Rules and Standards Committee chairman, at Please submit comments on the First R&O by November 20, 2015, and comments on the FNPRM and NOI by December 4, 2015. If you have any questions, please contact Steve.

FCC acts on millimeter-wave spectrum and on broadcast/wireless interference

The following was written by Steve Crowley, PE, chairman of the AFCCE Rules and Standards Committee:
The FCC has approved two items that AFCCE might be interested in commenting on. One, adopted October 16, is a Second Report and Order and Further Notice of Proposed Rulemaking that, among other things, seeks comment on proposed rules to govern the interference relationship between broadcast and wireless in the 600 MHz Band following the incentive auction. The other, adopted October 17, is a Notice of Inquiry into the use of spectrum above 24 GHz for mobile broadband.
If you have comments on these you’d like to see AFCCE file, please post them here before November 30. I propose proceeding with the preparation of any AFCCE comments in a manner similar to what I describe in the October 1 post below on the TV white space NPRM. If there are any questions, please contact me at Check back here for any updates.


FCC eases NEPA rules to help broadband; call for comments

The following was written by AFCCE FCC Liaison Don Everist:
Ben Dawson has made a cursory examination of WT Docket No. 13-238 (see 13-238 NR (10-20-14) ). He directs attention to Paragraphs 145 and 181 regarding replacement structures, etc. :
145. Section 6409(a) includes a number of undefined terms that bear directly on how the provision applies to infrastructure deployments. Below, we address the meaning of “wireless tower or base station,” “transmission equipment,” “collocation,” and “substantially changes the physical dimensions.”
181. We agree with Alexandria et al., however, that “replacement,” as used in Section 6409(a)(2)( C), relates only to the replacement of “transmission equipment,” and that such equipment does not include the structure on which the equipment is located.  (Alexandria et al. Comments at 31 (arguing that replacement of a tower is not a “modification” of it and that Congress knew how to address “replacement” when that was its intent).
Even under the condition that it would not substantially change the physical dimensions of the structure, replacement of an entire structure may affect or implicate local land use values differently than the addition, removal, or replacement of transmission equipment, and we find no textual support for the conclusion that Congress intended to extend mandatory approval to new structures. Thus, we decline to interpret “eligible facilities requests” to include replacement of the underlying structure.
Ben recommends that AFCCE consider a Petition for Reconsideration.  If you are so inclined please leave a comment or contact me.

FCC adopts TV white space NPRM

The following was written by Steve Crowley, PE, chairman of the AFCCE Rules and Standards Committee:

On September 30 the FCC adopted a Notice of Proposed Rulemaking proposing, among other things, changes to Part 15 rules governing unlicensed operation in the TV band (TV white space), and new rules for operation in the duplex gap and guard bands of the forthcoming 600 MHz mobile band. The stated intent is to “allow for more robust service and efficient spectral use without increasing the risk of harmful interference to authorized users.”

The Notice can be found here: FCC-14-144A1   .

In addition to my role as AFCCE Secretary, I’m Chairman of its Rules and Standards Committee. I’m soliciting input from those who would like AFCCE to comment in this proceeding. If you have comments to suggest, please make them as comments to this post.

I’ll volunteer to serve as editor. Once views are expressed, I’ll work with those commenting to facilitate consensus and assemble the views into a draft filing. As a check, I propose to send the draft to the AFCCE Board of Directors for final approval.

The FCC comment deadline is 45 days after the date of publication of the Notice in the Federal Register. (Reply comment, 65 days). To facilitate a timely comment filing, please send any comments and proposed text by October 31, 2014. If there are any questions, please contact me at Check back here for updates on this topic.

Comments solicited for RM-11727 (“Class C4 FM”)

On January 22, 2013, SSR Communications, Inc. (“SSR”) filed a petition for Rulemaking to create a new Zone II FM broadcast station class, or “C4” allocation, and amend certain technical rules for the FM broadcast service.

The petition is here:  Class C4. The FCC has extended the deadline for filing statements in support of or in opposition to the SSR Petition by one month, until September 18, 2014. The deadline for filing replies to such statements is October 3, 2014.   See DA-14-1182A1. AFCCE members interested in this matter may post their comments on the web page.