The Enterprise Wireless Alliance filed Comments on February 10 supporting a Petition for Rulemaking filed by the National Wireless Communications Council (NWCC, formerly the Land Mobile Communications Council). The Petition proposes that Federal Communications Commission (FCC) Rule Section 90.309 governing the protection of television stations by land mobile systems operating in the 470-512 MHz band (T-Band) be modified in light of the mandatory migration of full-power and Class A television stations from the analog National Television System Committee (NTSC) format to the digital Advanced Television Systems Committee (ATSC) format. This change will enable greater use of T-Band by incumbent and eventually new applicants as the digital television (DTV) station contours to be protected will be more representative of actual coverage as opposed to excessively conservative analog contours.
EWA further noted that the problem is exacerbated by the fact that the television stations that land mobile applicants are required to protect include stations that are not operational and others whose digital channels are greatly separated from T-Band spectrum. The FCC’s February 2021 Public Notice released in connection with the partial lifting of the T-Band freeze included multiple stations that are off the air, in some cases for decades, as well as stations that are identified by their virtual (analog) channel rather than the digital channel on which they now transmit. This combination of an unnecessarily conservative protection standard and the inclusion on the Public Notice of television stations results in underutilization of T-Band spectrum in some of the most spectrum-constrained markets in the nation.