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Commission Document Attachment

DA-13-1613A2

Technical Appendix:

Constraint Files Generation

1

Table of Contents

1.
Introduction to Technical Appendix....................................................................................3
2.
Generating Pairwise Constraints from Cell-Level Interference Data..................................5
2.1 Release of TVStudy Version 1.2 ....................................................................................5
2.2 Parameters chosen in TVStudy.......................................................................................6
2.3 Relevant Output Files from TVStudy............................................................................9
2.4 Post Processing of TVStudy Data into Pairwise Constraints (Option 2) ....................13
3.
Generating Domain and Interference_Paired Files ..........................................................16
3.1 Overview .....................................................................................................................16
3.2 Step One: Input and Map Relevant Data....................................................................17
3.3 Step Two: Generating the Domain File......................................................................19
3.4 Domain File.................................................................................................................22
3.5 Step Three: Generating the Interference_Paired File ................................................22
3.6 Preliminary Interference_Paired File .........................................................................23
4.
Details of Constraint Inputs and Assumptions ..................................................................25
4.1 U.S. Stations to U.S. Stations (Option 2) ....................................................................25
4.2 U.S. Stations to Canadian Allotments .........................................................................27
4.3 U.S. Stations to Mexican Allotments ..........................................................................29
4.4 U.S. Stations to Land Mobile Operations....................................................................33
4.5 Channel 37...................................................................................................................36
4.6 U.S. Station to Offshore Radiotelephone Services......................................................37
2

1. Introduction to Technical Appendix
The Incentive Auction Task Force, which is comprised of staff from the Commission's Office of
Engineering and Technology, Office of Strategic Planning and Policy Analysis, and the
International, Media, and Wireless Telecommunications Bureaus, is releasing in conjunction
with today's

Public Notice

a set of constraint files based on certain preliminary assumptions that
could be used in an incentive auction to check the feasibility of assigning permissible channels to
sets of stations and ultimately to assign channels to those stations. These constraint files are for
illustrative purposes only, and necessarily reflect certain preliminary assumptions that are subject
to a final decision by the Commission. These constraint files consist of two files for each station:
1) A Domain file (called Domain_2013July15.csv) defining the domain of available
channels of any station given certain fixed constraints.
2) An Interference_Paired file (called Interference_Paired_2013July15.csv) defining
which pairs of stations cannot operate co-channel, upper-adjacent channel, or lower-
adjacent channel to each other given the amount of the potential interference between
them.
The constraint files will be accessible via a link on the FCC's LEARN website under the
http://wireless.fcc.gov/incentiveauctions/learn-program/repacking.html">Repacking Section, which can be found at http://wireless.fcc.gov/incentiveauctions/learn-
program/repacking.html. Alternatively, these files will be posted at
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.
In this

Technical Appendix

of today's

Public Notice

, the Task Force outlines both the
processes used and preliminary assumptions applied to create these constraint files. The Task
Force also describes the format of these files by providing illustrative sample data within this

Technical Appendix

.
With the information provided in

Technical Appendix

, as well as the preliminary Domain and
Interference_Paired files accessible via the FCC LEARN website, interested parties will have
sufficient information to conduct their own repacking analyses based on their own assumptions
about which stations stay on the air and are assigned channels in the incentive auction repacking
process.
In addition to this

Introduction

, this

Technical Appendix

is divided into the following sections:
a)

Section 2:

Describes some of the new features of TVStudy Version 1.2 relevant for
repacking analysis. This new software, an instruction manual, baseline station
engineering data including populations served, and contour maps for U.S. stations
will be posted at http://data.fcc.gov/download/incentive-auctions/OET-69/">http://data.fcc.gov/download/incentive-auctions/OET-69/.
In addition,

Section 2

provides descriptions of each of the output files from TVStudy
necessary for any repacking analysis and an outline of the post-processing required to
transform these files into pairwise constraints. These pairwise constraints are
contained in the Interference_Paired file for each station. It should be noted that the
Interference_Paired file reflect staff application of the second of three proposals in
3

the Incentive Auctions NPRM for making all reasonable efforts to preserve
population served in the repacking process.1 As noted above, the approach taken is
preliminary in nature and only for illustrative purposes and does not reflect any final
determination by the Commission.
b)

Section 3:

Provides an overview of how the Domain and Interference_Paired files
were generated. It also reviews the format of each of these files.
c)

Section 4:

Provides more details on the inputs, preliminary assumptions and rules
that underlie these constraint files. The inputs include U.S. television stations,
Mexican television allotments, Canadian television allotments, and Land Mobile
("LM) and Land Mobile Waiver ("LMW") stations. A full list of each of these inputs
will be posted at http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.
The section also discusses other limitations on repacking in the incentive auction such
as radio astronomy and medical telemetry operations in Channel 37.


1 Incentive Auctions NPRM, 27 FCC Rcd 12357, 12394 106 (2012) ("Under this approach, no individual channel
reassignment, considered alone, could reduce another station's specific population served on February 22, 2012 by
more than 0.5 percent.").
4

2. Generating Pairwise Constraints from Cell-Level Interference Data
This section discusses in detail how the TVStudy software can be used to generate the pairwise
interference data used as an input to create the Interference_Paired file. Pairwise interference
data are essentially yes-or-no determinations of whether interference is predicted from one
television station to another at a particular location called a "cell." The second and third of the
three approaches proposed in the NPRM for making all reasonable efforts to preserve population
served in the repacking process are based on "pairwise" analysis of data.2 This

Technical
Appendix

assumes application of the second option ("Option 2"), which would require that the
Commission seek to preserve "the same specific viewers for each eligible station."3
2.1 Release of TVStudy Version 1.2
http://data.fcc.gov/download/incentive-auctions/OET-69/">TVStudy Version 1.2 will be available at http://data.fcc.gov/download/incentive-auctions/OET-
69/. This new version includes the following functionality not available in prior releases of
TVStudy:

Ability to automatically conduct pairwise studies
Ability to define the specific parameters of Mexican allotments that lack height and
power in the Commission's CDBS database4
Ability to automatically invert negative electrical beam tilts that would otherwise cause
inaccurate predictions of coverage and interference
Ability to choose the contour level within which Longley-Rice propagation analysis is
conducted independent of the Longley-Rice parameters
Ability to add Desired and Undesired stations independently and at any time
The command line is no longer needed to run TVStudy on the Mac platform
Ability to choose which output files to create
New "summary" output file, which condenses the results of multiple scenarios into a
single file
Additional information is included in the output cell-level file, such as the coordinates of
the study point in each cell
Study parameters are now grouped into tabs instead of one long list
A complete list of changes from Version 1.1 is included in the Upgrade Guide available
at the URL above
One of the key advantages of the TVStudy Version1.2 software is its ability to easily replicate
multiple stations to generate various nationwide scenarios. The update to the TVStudy software
also creates new output data files that are more suitable for post-processing into pairwise
constraints. In particular, it creates "truth tables" which indicate whether a particular "study
station" has interference-free service in any particular 2 km x 2 km cell based on thresholds as


2 See Incentive Auctions NPRM, 27 FCC Rcd at 12394 106-107.
3 Incentive Auctions NPRM, 27 FCC Rcd at 12394 106.
4 FCC Consolidated Database System, available at http://transition.fcc.gov/mb/databases/cdbs/.
5

specified in OET Bulletin 69.5 This cell-level data from TVStudy can then be used to create
pairwise constraints between U.S. television stations and between U.S. and Canadian television
stations. A short description of this process follows in the sections below, and includes a
description of the output files generated by TVStudy Version 1.2.
2.2 Parameters chosen in TVStudy
The following were the study parameters used by TVStudy in generating the output files
described. It is emphasized that the use of these parameters does not reflect any final
determination by the Commission.

Study parameter settings:

General

Grid type = Global
Cell size = 2
Average terrain database = 1-second
Average terrain profile resolution = 10
Path-loss terrain database = 1-second
Path-loss profile resolution = 1
U.S. population = 2010
Canadian population = 2011
Mexican population = 2010
Round population coordinates = No
Spherical earth distance = 111.15
Rule limit extra distance = 129
Co-channel MX distance = 30
Minimum Channel = 2
Maximum Channel = 51

CDBS

Respect CDBS DA flag = No
Use generic patterns for Canadian records = Yes
Mexican digital ERP, VHF low = 45
Mexican digital HAAT, VHF low = 305
Mexican digital ERP, VHF high = 160
Mexican digital HAAT, VHF high = 305
Mexican digital ERP, UHF = 1000


5 Interference-free service or interference-free population is defined here as people who reside within a station's
service area at locations where the station's service is not subject to interference from another station or stations.
See OET Bulletin No. 69 (Feb. 6, 2004), available at
http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet69/oet69.pdf (OET Bulletin
69). OET Bulletin 69 "provides guidance on the implementation and use of Longley-Rice methodology for
evaluating TV service coverage and interference in accordance with sections 73.622, 73.623 and 74.704 of the FCC
rules." Id. In the NPRM, the FCC proposed to define "population served" for purposes of section 6403(b)(2) of the
Spectrum Act as populations with interference-free service. See NPRM, 27 FCC Rcd at 12388 94, 12392 103
(stating that "OET Bulletin 69 and the Commission's rules address `population served' in terms of the persons who
reside within a station's service area at locations where the station's service is not subject to interference from
another station or stations.").
6

Mexican digital HAAT, UHF = 365
Mexican analog ERP, VHF low = 100
Mexican analog HAAT, VHF low = 305
Mexican analog ERP, VHF high = 316
Mexican analog HAAT, VHF high = 305
Mexican analog ERP, UHF = 5000
Mexican analog HAAT, UHF = 610

Patterns

Depression angle method = True geometry
Use mechanical beam tilt = No
Mirror generic patterns = No
Beam tilt on generic patterns = Offset
Invert negative tilts = Yes
Digital receive antenna f/b, VHF low = 10
Digital receive antenna f/b, VHF high = 12
Digital receive antenna f/b, UHF = 14
Analog receive antenna f/b, VHF low = 6
Analog receive antenna f/b, VHF high = 6
Analog receive antenna f/b, UHF = 6

Contours

Use real elevation patterns for contours
Digital full-service contour, VHF low = 28
Digital full-service contour, VHF high = 36
Digital full-service contour, UHF = 41
Digital Class A/LPTV contour, VHF low = 43
Digital Class A/LPTV contour, VHF high = 48
Digital Class A/LPTV contour, UHF = 51
Analog full-service contour, VHF low = 47
Analog full-service contour, VHF high = 56
Analog full-service contour, UHF = 64
Analog Class A/LPTV contour, VHF low = 62
Analog Class A/LPTV contour, VHF high = 68
Analog Class A/LPTV contour, UHF = 74
Use UHF dipole adjustment = Yes
Dipole center frequency = 615
Propagation curve set, digital = F(50,90)
Propagation curve set, analog = F(50,50)
Truncate DTS service area = No
DTS distance limit, VHF low Zone I = 108
DTS distance limit, VHF low Zone II/III = 128
DTS distance limit, VHF high Zone I = 101
DTS distance limit, VHF high Zone II/III = 123
DTS distance limit, UHF = 103
HAAT radial count = 8
Minimum HAAT = 30.5
Contour radial count = 360
Service distance limit, VHF low = 0
7

Service distance limit, VHF high = 0
Service distance limit, UHF = 0

Replication

Replication method = Equal area
Digital full-service minimum ERP, VHF low = 1
Digital full-service minimum ERP, VHF high = 3.2
Digital full-service minimum ERP, UHF = 50
Digital full-service maximum ERP, VHF low Zone I = 10
Digital full-service maximum ERP, VHF low Zone II/III = 45
Digital full-service maximum ERP, VHF high Zone I = 30
Digital full-service maximum ERP, VHF high Zone II/III = 160
Digital full-service maximum ERP, UHF = 1000
Digital Class A/LPTV maximum ERP, VHF = 3
Digital Class A/LPTV maximum ERP, UHF = 15

Pathloss

Longley-Rice error handling = Assume service
Receiver height AGL = 10
Minimum transmitter height AGL = 10
Digital desired % location = 50
Digital desired % time = 90
Digital desired % confidence = 50
Digital undesired % location = 50
Digital undesired % confidence = 50
Analog desired % location = 50
Analog desired % time = 50
Analog desired % confidence = 50
Analog undesired % location = 50
Analog undesired % confidence = 50
Signal polarization = Horizontal
Atmospheric refractivity = 301
Ground permittivity = 15
Ground conductivity = 0.005
Longley-Rice service mode = Broadcast
Longley-Rice climate type = Continental temperate

Service

Set service thresholds = No

Clutter

Apply clutter adjustments = No
8

2.3 Relevant Output Files from TVStudy
TVStudy provides the following output files (in .csv format) with the specified data elements,
which are used in developing the constraint files:

A. Stations.csv

Data Element

Data Type

Description

Sample Value

The unique integer number (assigned by MB) that
facilityid
integer
identifies a station
24518
channel
integer
Channel assignment
32
0=Station was not studied as desired; its coverage
was not evaluated
1=Station was studied as desired; its coverage
des (desired) flag
integer
was evaluated
1
0=Station was not studied as undesired; it could
not cause interference to desired stations
1=Station was studied as undesired; it may
und (undesired) flag
integer
contribute interference to desired stations
1
servicetypekey
varchar(2)
Type of service the facility provides
DT
callsign
varchar(10)
Callsign of facility
KDOC-TV
city
varchar(25)
City in which the station is located
ANAHEIM
state
varchar(2)
State in which the station is located
CA
countrycode
varchar(2)
Country: US, CA, MX
US
status
varchar(5)
Status
LIC
filenumber
varchar(25)
Station file number
BLCDT20060626ACV

Description:

This file lists all stations on the channels they are currently assigned in the study's
"baseline scenario."6 Thus, this file contains records exactly as they appear in the FCC's
Consolidated Database System ("CDBS").7 The des (desired) flag field in this table is a 1 if the
station is flagged for study in the baseline scenario (the "Des" box is checked in the UI), or 0 if
not. Stations flagged as "desired" for study in the baseline scenario will have service and
interference data in the other tables. Since the baseline scenario is built manually, such stations
can be included or not, as desired.


6 The "baseline scenario" for purposes of this Technical Appendix includes a full power or Class A television
station's channel and operating parameters reflected in its license, or pending application for license to cover a
construction permit, on February 22, 2012, as preliminarily determined by staff. The "baseline" scenario also
includes construction permits, granted pursuant to court order, modifying the facilities of KJWY(TV), Wilmington,
DE and KVNV(TV), Middletown Township, NJ. As discussed further below, the baseline scenario is limited to
facilities the Commission must seek to preserve based on the proposed statutory interpretation in the NPRM,
facilities the Commission proposed to seek to preserve as a matter of discretion, and two facilities that were the
subjects of a court order. As discussed in the Public Notice, the inclusion or exclusion of facilities in the baseline
scenario is intended for study purposes only and does not indicate which facilities the Commission will ultimately
make all reasonable efforts to preserve in the repacking. Interested parties may add facilities to, or subtract facilities
from, the baseline scenario to analyze different preservation assumptions using the process described herein, and the
Task Force invites submissions based on such analyses.
7 FCC Consolidated Database System, available at http://transition.fcc.gov/mb/databases/cdbs/.
9

B. Baseline.csv

Data Element

Data Type

Description

Sample Value

The unique integer number (assigned by MB) that
facilityid
integer
identifies a station
24518
channel
integer
Channel assignment
32
countrykey
integer
Country: 1= US, 2= Canada, 3 = Mexico
1
noiselimitedarea
numeric
The area within noise-limited contour
43,048
noiselimitedpopulation
numeric
The population within the noise-limited contour
17,560,396
The area within the noise-limited contour
terrainlimitedarea
numeric
excluding cells blocked by terrain
33,625
The population within the noise-limited contour
terrainlimitedpopulation
numeric
excluding cells blocked by terrain
16,074,975
The area within the noise-limited contour
interferencefreearea
numeric
excluding the area of cells blocked by terrain and
of cells with interference from other stations
33,465
The population within the noise-limited contour
excluding the population of cells blocked by
interferencefreepopulation
numeric
terrain and of cells with interference from other
stations
15,982,341

Description

: This file lists the coverage area and population totals for stations as they appear in
the baseline scenario, including interference from all stations included in the baseline scenario
whether or not they are part of the pair study.8 When a station has coverage in more than one
country, there will be multiple rows in this table for that facility ID and channel, one per country,
with the countryKey indicating which row corresponds to coverage in each country.

C. Replication.csv

Data Element

Data Type

Description

Sample Value

The unique integer number (assigned by MB) that
facilityid
integer
identifies a station
40517
channel
integer
Channel assignment on proxy channel
3
countrykey
integer
Country: 1= US, 2= Canada, 3 = Mexico
1
noiselimitedarea
numeric
The area within noise-limited contour
18,011
noiselimitedpopulation
numeric
The population within the noise-limited contour
383,630
The area within the noise-limited contour
terrainlimitedarea
numeric
excluding cells blocked by terrain
17,659
The population within the noise-limited contour
terrainlimitedpopulation
numeric
excluding cells blocked by terrain
383,392

Description:

This file lists the coverage totals for stations involved in a pair study after
replication to a "proxy channel" in each band.9 Each station will have a row for each channel
studied.


8 More specifically, the baseline scenario includes the set of aggregate population and area data (1) within the
station's noise-limited service contour ("noise-limited"), (2) not affected by terrain losses ("terrain-limited"), and (3)
not lost to interference from other stations ("interference-free"). When determining a U.S. station's interference-free
population, we considered existing interference coming from other U.S. stations, as well as predicted interference
from existing Canadian and Mexican allotments. These data are an output of the software that implements OET
Bulletin 69. See OET Bulletin 69 at 12.
9
In 6403 (b)(3) of the Spectrum Act, Congress has instructed the FCC that it may not involuntarily reassign a
broadcast television licensee from one of these bands to another. See Middle Class Tax Relief and Job Creation Act
10

Given the computational burden of considering each station pair on every possible channel
during a multi-round auction, Commission staff selected a single channel in each of the three
television spectrum bands as a proxy for that band to conduct the pairwise study. In this
analysis, Channel 20 is used for replication of stations in the UHF television band, which ranges
from 470 MHz to 698 MHz (Channels 14 to 51). Channel 10 is used for replication of stations in
the high VHF television band, which ranges from 174 MHz to 216 MHz (Channels 7 to 13).
Channel 3 is used for replication of stations in the low VHF television band, which ranges from
54 MHz to 88 MHz (Channels 2 to 6).
Staff recognizes that both coverage and interference may vary from channel to channel within
each band, but notes that if the Commission were to ultimately adopt an approach that uses proxy
channels in its feasibility checking during the incentive auction bidding process, the Commission
could analyze the variance between the proxy channel and a provisional channel assignment at
the end of the reverse auction bidding process and attempt to address any variances by
considering alternative assignments for stations during the final channel assignment process.10

NOTE:

For illustrative purposes, staff used the following proxy channels for its replication
studies:

a. Channel 3 proxy channel for low VHF band
b. Channel 10 proxy channel for high VHF band
c. Channel 20 proxy channel for UHF band

D. Points.csv

Data Element

Data Type

Description

Sample Value

pointkey
integer
Unique identifier of 2x2km cell
52571303
celllatitudeindex
integer
Identifier of cell point latitude
114205
celllongitudeindex
integer
Identifier of cell point longitude
421036
countrykey
integer
Country: 1= US, 2= Canada, 3 = Mexico
3
latitude
numeric
latitude of study point within the cell (pop. Centroid)
32
longitude
numeric
longitude of study point within the cell (pop. Centroid)
117
area
numeric
Area of the 2x2 cell (in square kilometers)
4
population
numeric
Population of the cell
0

Description:

This file provides the location (latitude, longitude and country) of each 2 km x 2
km cell involved in the study. It also provides the area of and population within each cell. This
is a lookup table for use with the service and interference tables.




of 2012 (Spectrum Act), Pub. L. No. 112-96, 6403(b)(3), 125 Stat. 156 (2012). Inclusion of data for all bands
allows for the possibility of voluntary band changes.
10 The Commission could, for example, use TVStudy to compare each station's interference-free population on a
provisional channel (the channel provisionally assigned to the station during the auction as being feasible based on
interference calculations using proxy channels) to the station's baseline interference-free population and then use
optimization algorithms to attempt to mitigate interference for cases that exceed a threshold by reassigning the
station to another feasible channel.
11

Each point is a "study point" (population
centroid) of a 2 km x 2 km cell found
within an (inter)national grid of these cells.
IF cells have no population, the study
points will be the center of the cell.
For each 2 km x 2 km cell (shown here),
we know the area and population, if any,
within it.

E. Service.csv

Data Element

Data Type

Description

Sample Value

pointkey
integer
Unique identifier of 2x2km cell
52571303
The unique integer number (assigned by MB) that
facilityid
integer
identifies a station
10238
channel
integer
Channel assignment
18
1 = acceptable coverage signal, 0 = unacceptable
serviceflag
integer
signal
1

Description:

This file lists study points that are within the service contours of stations studied,
with points for each studied channel (baseline or proxy) tabulated separately. In the service table
when the serviceFlag is 0, the point is inside the station's contour on that particular channel so
the point is part of the noise-limited coverage, but the terrain-limited signal strength is below the
applicable coverage threshold so the point is not part of the terrain-limited coverage.

F. Interference.csv

Data Element

Data Type

Description

Sample Value

pointkey
integer
Unique identifier of 2x2km cell
55442949
The unique integer number (assigned by MB) that
facilityid
integer
identifies a station
38430
channel
integer
Channel assignment of studied station
3
interferingfacilityid
integer
The station identifier of the interfering station
58,978
interferingchannel
integer
The channel assignment of the interfering station
3

Description:

This file lists all points of interference found between all stations in the study, with
each channel tabulated separately. For each facility, this table provides a list of points that have
interference on their current channel and proxy channels, as well as the station causing that
interference. For each channel assignment (both current and proxy) of the studied station, this
table provides co-channel (Channel N), upper-adjacent (Channel N+1), and lower-adjacent
(Channel N-1) interference caused by the interfering stations having those channel relationships.
??

NOTE

: TVStudy uses the default "culling" distances when determining which stations to
consider in its replication scenarios (both current and proxy):

a) When considering co-channel interference, TVStudy uses a default culling distance of
429 km.
12

b) When considering adjacent channel interference, TVStudy uses a default culling
distance of 229 km.
These default "culling distances" are cell-to-transmitter distances and are based on culling
distances specified in Table 7 of the OET Bulletin 6911 plus an additional distance margin.
??????
2.4 Post Processing of TVStudy Data into Pairwise Constraints (Option 2)
Some post processing of the truth tables generated by TVStudy is required to turn the cell-level
data into pairwise constraints. As stated above, the NPRM specified three interference protection
options for making all reasonable efforts to preserve "population served" in the repacking
process.12 For purposes of this study, staff developed pairwise constraints using Option 2 where
a single interfering station, when examined alone, is not permitted to reduce the interference-free
population of a current station (moved to a proxy channel) by more than 0.5%.

Example:

Assessing the impact on Station 10001's interference-free population13 caused by
Station 10002 when studied on proxy channel 3.

STEP 1:

Determine the interference free population of Station 10001 on its existing channel 9.
This is its baseline interference free population.


BLUE = Station location;
GREEN = Original interference-free population;
YELLOW = Population with no service due to terrain;
RED = Population with no service due to interference.


11 See OET Bulletin 69 at 12 Table 7 (providing guidance on how to cull undesired stations based on maximum
distances from cell to undesired stations; more specifically, OET Bulletin 69 requires a culling distance of 300 km
when considering DTV-to-DTV co-channel interference and 100 km when considering DTV-to-DTV adjacent
channel interference).
12 NPRM, 27 FCC Rcd at 12392 103 (stating "we propose three alternative approaches to fulfilling the requirement
to make all reasonable efforts to preserve population served in the repacking process.").
13 Staff defined "interference-free population" as the station's "population served" at its original or existing channel
for purposes of this study. See supra text accompanying note 5 (defining interference-free service or population).
When determining the baseline interference-free population for U.S. stations, we considered existing interference
coming from other U.S. stations, as well as predicted interference from existing Canadian and Mexican allotments.
13

STEP 2:

From the interference table, find Station 10001's interference (in cells that were part of
Station 10001's baseline interference-free population) on proxy channel 3 caused by Station
10002 on a co-channel (channel 3) or an adjacent channel (channels 2 or 4).
BLUE = Station location;
GREEN = Original interference-free population;
ORANGE = Interference caused by Station 10002;
facilityid
channel
interferingfacilityid
interferingchannel
pointkey integer
integer
integer
integer
integer
1
59899596
10001
3
10002
3
2
59929509
10001
3
10002
3
3
59959419
10001
3
10002
3
4
59989329
10001
3
10002
3
5
60019239
10001
3
10002
3
6
60049149
10001
3
10002
3
7
60049152
10001
3
10002
3
8
60079041
10001
3
10002
3
9
60079059
10001
3
10002
3
10
60079062
10001
3
10002
3
From the interference table, Station 10001 (on proxy channel 3)
receives co-channel interference from Station 10002 (also on
channel 3) in the ten cells indicated.

NOTE:

For each of the three proxy channels considered by the FCC (3, 10, 20), interference
analysis is conducted for the co-channel, and upper-and lower-adjacent channels.14 Thus, nine
separate calculations must be made and compiled into pairwise constraints.


14 Protecting each channel from co-channel and upper- and lower-adjacent channel interference is consistent with
OET Bulletin 69 for Digital Television to Digital Television Protections. See OET Bulletin 69 at 8 Table 5A
(providing interference criteria for co- and adjacent channels).
14

STEP 3:

Sum the population of the points causing interference (shown in ORANGE) on Station
10001's baseline interference-free population.
Sum of Population of Interference Points for Station 10001 on proxy channel caused by Station
10002
= 180,844
Baseline Interference-Free Population for Station 10001 on current Channel = 1,709,743
Percent of Baseline Interference-Free Population impacted by this potential assignment =
180,844/1,709,743 = 10.58%
>>> Since 10.58% is greater than 0.5%,15 Station 10001 on proxy channel 3 cannot exist
with Station 10002 also on channel 3, so a constraint is added to the Interference_Paired
file to reflect that fact.

NOTE:

In a small number of cases, the study station (in this example, Station 10001) may see a
change (gain or loss) in its original interference-free population (as calculated by TVStudy on its
original channel) because its noise-limited population changed on the replicated proxy channel
due to the use by TVStudy of an "equal area" approach to replication rather than replicating the
original noise-limited contour. The choice of an "equal area" or "contour distance" approach to
replication is discussed in the NPRM.16
Similarly, the study station could see a change (gain or loss) in its interference-free population
(as calculated by TVStudy on its original channel) because its terrain-limited population on the
replicated proxy channel changed. This could be the case even if TVStudy was able to replicate
exactly the original noise-limited contour because of differences in propagation losses on the
new proxy channel due to terrain.
For purposes of creating the constraint files referenced in this

Technical Appendix

, the staff did
not count any changed population cells (either due to changes in noise-contour or terrain-limited
contour) in determining whether the 0.5% threshold is reached. As noted above, if the
Commission were to ultimately adopt an approach that uses proxy channels in its feasibility
checking, the Commission could analyze the variance between interference on the proxy channel
and a provisional channel assignment at the end of the reverse auction bidding process and
attempt to address any variances by considering alternative channel assignments for stations
during the final channel assignment process.


15 The NPRM proposes to define "de minimis" interference as not allowing greater than 0.5% additional
interference. See NPRM, 27 FCC Rcd at 12394 106.
16 See NPRM, 27 FCC Rcd at 12391 100.
15

3. Generating Domain and Interference_Paired Files
3.1 Overview
The Task Force is making available two files in conjunction with this

Technical Appendix

for
each station:
(1) a Domain file (called Domain_2013July15.csv)
(2) an Interference_Paired file. (called Interference_Paired_2013July15.csv)
A link to these files will be posted on the FCC LEARN website under the Repacking Section at
http://wireless.fcc.gov/incentiveauctions/learn-program/repacking.html">http://wireless.fcc.gov/incentiveauctions/learn-program/repacking.html. Alternatively, one will
find these files posted at http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.
As mentioned previously, these files are based on preliminary assumptions by the staff and are
for illustrative purposes; they do not reflect any decisions made by the Commission. Moreover,
these files do not reflect which channels ultimately will be assigned to television stations in the
repacking process or how the Commission will select bids in the reverse auction. However,
these files could be used by interested parties to perform their own repacking analyses based on
their own assumptions about which stations stay on the air and are assigned channels.
These files define constraints based on the domain of available channels and interference
between stations on different bands, respectively.
To generate the Domain and Interference_Paired files, the staff combined the interference "truth
tables" generated by TVStudy with additional fixed constraints imposed by Land Mobile ("LM"),
Land Mobile Waiver ("LMW" - which are LM stations operating under waiver), Canadian
television allotments, Mexican television allotments and Channel 37 incumbents. We provide an
overview of the process below in

Sections 3.2

through 3.6. Like pairwise constraints between
U.S. stations, pairwise constraints between U.S. and Canadian allotments are also based on
interference calculations from the TVStudy software. LM, LMW and Mexican television
allotments, however, are protected by distance restrictions.

Section 4

provides more detailed information on each of these sources of constraints including
any preliminary assumptions made by the staff as they relate to each of these inputs.
16

3.2 Step One: Input and Map Relevant Data
The first step in creating the constraint files is to collect the data inputs that are relevant for
generating the constraints. These include the following:
(a) List of U.S. stations considered for the baseline (called
US_Station_Baseline_2013July15.xlsx);
(b) List of Canadian broadcast television allotments (analog and digital) along the U.S.-
Canadian border (called Canadian_Allotment_List_2013July15.xlsx);
(c) List of Mexican broadcast television allotments (analog and digital) along the U.S.-
Mexican border (called Mexican_Allotment_List_2013July15.xlsx);
(d) List of LM stations (called LM_City_Center_List_2013July15.xlsx);
(e) LMW stations (operating under a waiver) (called
LMW_Station_List_2013July15.xlsx)
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">These files will be available for download at http://data.fcc.gov/download/incentive-
auctions/Constraint_Files/.
We provide a sample of the type of data captured in each of the data input files for illustrative
purposes immediately below.

U.S. Stations

Canadian Allotments

Mexican Allotments

(excluding territories)
(2,557)
(603)
(2,177)
1. Facility ID
1. Facility ID
1. Facility ID
2. Call Sign
2. Call Sign
2. Call Sign
3. Channel
3. Channel
3. Channel
4. Service Type
4. Service Type
4. Service Type
5. Specs
5. Specs
5. Specs
6. Latitude/Longitude
6. Latitude/Longitude
6. Latitude/Longitude

LM City Centers

LMW Stations

(25)
(424)
1. Facility ID
1. Facility ID
2. Call Sign
2. Call Sign
3. Channel
3. Channel
4. Fixed/Mobile
4. Fixed/Mobile
5. Latitude/Longitude
5. Latitude/Longitude
In

Section 4

, we revisit each of these data inputs, providing the complete list of preliminary
assumptions necessary for interested parties looking to recreate the constraint files for
themselves. We also provide the list of fields and their formats for each of these data input files.
17

Second, once all the relevant data is captured, staff applied the relevant interference rules to do
the following:
1) Map the protection zones for fixed constraints (e.g., land mobile incumbents).
2) Cull the relevant set of stations that need to be considered for each station's pairwise
constraints.

APPLY

INTERFERENCE

RULES

NOTE

: Green dots represent U.S. DTV and Class A stations; blue dots represent Canadian
allotments, red dots represent Mexican allotments; orange circles represent fixed, distance-based
constraints.
18

3.3 Step Two: Generating the Domain File
In order to protect LM base stations, LMW base stations, Mexican allotments, Canadian
allotments and Channel 37, the FCC staff had to consider these as fixed constraints which will
limit the channels on which any U.S. television station can be assigned or reassigned in the
incentive auction repacking process. These fixed constraints reduce the number of available
channels listed in the Domain file for each station (a station cannot be assigned a channel that
does not appear in the Domain file).
As shown in the graphics below, Land Mobile (LM and LMW) and Mexican allotments are fixed
constraints that are based on distance separation, whereas Canadian stations are fixed constraints
based on interference calculations using OET Bulletin 69. In addition, for purposes of this
analysis, staff removed Channel 37 from the list of available channels.
This section is meant to provide a quick snapshot of the rules associated with each of the
constraints that impact the Domain file. More detailed staff assumptions necessary for creating
the constraints associated with each of these data inputs are provided in

Section 4

.

LAND MOBILE17

US and Land Mobile

DTV to Land Mobile

DTV to LM Waiver

Operations

(LM) City Center
(LMW) Base Station
Co-Channel:
250 km
185 km
Adjacent Channel:
176 km
96 km


17 So-called "television band" ("T-Band") land mobile licensees have been granted certain interference protections
from broadcast television stations operating in co- or adjacent channels. Under current FCC rules, the Commission
does not accept petitions to amend the Digital Television ("DTV") Table of Allotments, applications for new DTV
stations, or applications to change the channel or location of authorized DTV stations that would use channels 14
20 where: (a) the distance between the DTV reference point would be located less than 250 km from the city center
of a co-channel land mobile operation; or (b) the distance between the DTV reference point would be located less
than 176 km from the city center of an adjacent channel land mobile operation. See 47 C.F.R. 73.623(e). Staff
derived similar distance separation requirements for Land Mobile Waiver base stations from the rules for traditional
Land Mobile operations as well as additional staff analysis further explained in Section 4 of this Technical
Appendix.
19

MEXICO18

US and Mexico

DTV to DTV

DTV to NTSC

Operations

Station

Station

Co-Channel VHF:
273 km
273 km
1st Adj. Channel VHF:
48-96 km
18-100 km
Co-Channel UHF:
223 km
244 km
1st Adj. Channel UHF:
32-88 km
10-88 km
2 UHF:
-
24-32 km
3 UHF:
-
24-32 km
4 UHF:
-
24-32 km
7 UHF:
-
24-95 km
8 UHF:
-
24-32 km
+ 14 UHF:
-
24-95 km
+ 15 UHF:
-
24-96 km


18 The DTV arrangement with Mexico applies to territory of the United States and Mexico within 275 km of the
U.S.-Mexico border. Because Mexico has not yet completed its DTV transition, the FCC must consider interference
not just between U.S. stations and Mexican DTV allotments (either occupied by a Mexican DTV station or vacant),
but also interference between Mexican analog (NTSC) allotments (either occupied by a Mexican NTSC station or
vacant) and U.S. DTV stations operating in border regions. The DTV arrangement specifies minimum distance
separations between DTV stations operating on the same or adjacent channels. The arrangement also specifies
minimum distance separations between DTV stations and NTSC stations. See Memorandum of Understanding
between the Federal Communications Commission of the United States of America and the Secretaria De
Comunicaciones Y Transportes of the United Mexican States 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
(1998) (1998 USA-Mexico DTV Memorandum of Understanding).
20

CANADA19

Desired:

Canadian Channel

Undesired:

Channel

Station

(Canada)

USA Station

(USA)
% POP
10001
43
10002
42
0.55
10001
43
10002
43
5.26
10001
43
10002
44
0

CHANNEL 37

Channel 37 is currently allocated for radio astronomy and wireless medical telemetry20 and for
purposes of this preliminary analysis is assumed to be unavailable as a channel for repacking.


19 The current agreement with Canada defines the interference protection requirements using the methodology
described in OET Bulletin 69. In 2008 Industry Canada defined its long-term DTV needs in its post-transition
allotment plan, which was finalized through an Exchange of Letters ("EOL") with the FCC. Canada's plan provides
a digital replacement channel on channels 2 to 51 for each full-service analog operation within 360 km of the
common border. The plan also incorporates numerous vacant allotments as placeholders for potential future use. In
addition, for those analog ("NTSC") Canadian stations outside of urban areas that are not mandated to convert to
digital, we use the relevant interference protections for analog allotments. See Exchange of Letters Between Canada
and the United States Concerning Digital Television, Dec. 20, 2008 (2008 USA-Canada DTV Exchange of Letters).
See also 2000 USA-Canada DTV Letter of Understanding (describing modifications to the table of allotments for
analog television stations). For purposes of this analysis only and as further described in Section 4 of this Technical
Appendix, to determine whether a repacked U.S. Station can be co-channel or adjacent channel to a Canadian
allotment we follow the same approach applied to the study of interference between U.S. DTV stations. This
requires using TVStudy software to determine the current interference-free populations of each Canadian allotment
(digital or analog) and then performing interference calculations with all possible U.S. stations (within the culling
distance) on a co-channel and an upper- and lower-adjacent channel according to OET Bulletin 69. However,
because Canadian allotment channels were assumed to be fixed, TVStudy did not use proxy channels when
performing these calculations; rather, only their current channel was used.
20 47 C.F.R. 2.106. "Table of Frequency Allocations".
21

3.4 Domain File
For each U.S. TV station, the Domain file provides a list of channels that the station may be
assigned to in the incentive auction repacking process taking into account the fixed constraints
highlighted in

Section 3.3

.21
A sample of the comma-delimited format of this file appears immediately below (it is a sample
and does not reflect real station data). This demonstrated format should match exactly the
released preliminary Domain file (called Domain_2013July15.csv) to be made available for
download at http://data.fcc.gov/download/incentive-auctions/Constraint_Files/" title="http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">

PRELIMINARY Domain File Format:


Station ID

Available Channels

DOMAIN, 10001, 2, 3, 4, 5, 6, 19, 20, 21, 48, 49, 50, 51
DOMAIN, 10002, 2, 3, 4, 5, 6, 7, 8, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 38, 39, 40, 41, 47, 48, 49, 50, 51
DOMAIN, 10003, 2, 3, 4, 5, 6, 7, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 34, 35, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51
DOMAIN, 10004, 2, 3, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 33, 34, 35, 36, 38, 39, 40, 41, 42, 43, 44, 45
DOMAIN, 10005, 2, 3, 4, 5, 6, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 33, 34, 35, 36, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47,
DOMAIN, 10006, 2, 3, 4, 5, 6, 7, 8, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 34, 35, 36, 38, 39, 40, 41, 42, 46, 47, 48, 49, 50, 51
DOMAIN, 10007, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 21, 22, 23, 24, 25, 26, 27, 49, 50, 51
DOMAIN, 10008, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 17, 18, 19, 20, 21, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50,
DOMAIN, 10009, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 25, 26, 27, 28, 29, 35, 36, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51

In words, the first line reads:

In re-packing, Station #10001 may only be placed on channels 2, 3, 4, 5, 6, 19, 20, 21, 48, 49, 50,
or 51. A channel assignment algorithm could not place Station #10001 on any other channel.
3.5 Step Three: Generating the Interference_Paired File
In this step, the post-processed TVStudy output data detailed in

Section 2

is incorporated into the
Interference_Paired file. As described previously, staff used TVStudy to analyze pairs of U.S.
stations and assigned proxy channels in low VHF (based on analysis conducted on proxy channel
3), high VHF (based on proxy channel 10) and UHF (based on proxy channel 20). Again, under
Option 2 from the NPRM, for each station pair scenario, if the interfering station reduces the
baseline interference-free population by more than 0.5%, those two stations cannot exist on that
pair and a constraint is created to reflect that prohibition.


21 Section 6403 (b)(3) of the Spectrum Act states that the Commission may not involuntarily reassign a UHF
broadcast television licensee to the VHF band or a high VHF broadcast television licensee to the low VHF band.
See Spectrum Act 6403 (b)(3). Nonetheless, channels in bands below a licensee's current band may still appear in
its Domain file record because the licensee may voluntarily choose to relinquish its usage rights in its current
television band in exchange for compensation from auction proceeds and the right to broadcast in a lower band. See
Spectrum Act 6403 (a)(2) (defining eligible relinquishment options in the reverse auction). Moreover, the Domain
file
may also contain channels in bands above a licensee's current band because in certain limited instances such
involuntarily moves may be permitted. See Spectrum Act 6403 (g)(1)(B).
22

This section provides an overview of how the Interference_Paired file is created with more
detailed staff assumptions listed in

Section 4,

which may be necessary to replicate the results of
the sample files.
1. GENERATE STATION PAIRS
2. RUN TVSTUDY

Station1

Proxy

Station2

Channel2

Channel

10001
3
10002
2
10001
3
10002
3
10001
3
10002
4
10001
10
10002
9
10001
10
10002
10
10001
10
10002
11
10001
20
10002
19
10001
20
10002
20
10001
20
10002
21
3. PERFORM POST

PROCESSING

4. GENERATE RESULTS

Station1

Proxy

Station2

Channel2

% POP

Channel

10001
3
10002
2
0
10001
3
10002
3
2.66
10001
3
10002
4
0
10001
10
10002
9
0
10001
10
10002
10
3.03
10001
10
10002
11
0
10001
20
10002
19
0.29
10001
20
10002
20
3.83
10001
20
10002
21
0.63
3.6 Preliminary Interference_Paired File
For each station, the Interference_Paired file provides a list of other stations that cannot be
assigned the same channel or an adjacent channel if the station were placed in one of the three
television bands (1) Low VHF (**divided into two bands due to spacing a 4 MHz gap
between Channel 4 and Channel 5), (2) High VHF, or (3) UHF band.
This file includes:
Interference type: co-channel, upper-adjacent channel, lower-adjacent channel
23

Frequency Band: Low VHF (Channels 2-4 and Channels 5-6), High VHF (Channels 7-
13), and UHF (Channels 14-51), expressed in terms of the lowest and highest channels in
the band ("band limits")

Study Station: The Facility ID of the Study Station

Interfering Stations: The Facility IDs of stations that cannot be assigned on a co-channel
or adjacent channel in the spectrum band
A sample of the comma-delimited format appears below (it is a sample and does not reflect real
station data) and this format is used in the preliminary Interference_Paired file (called
Interference_Paired_2013July15.csv) to be made available for download at
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/" title="http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.

PRELIMINARY Interference_Paired File Format:
Interference Type


Band
Limits Study Station ID ID of Interfering Stations

CO, 2, 4, 10036, 10057, 10066, 10118, 10282, 10345, 10438
CO, 5, 6, 10036, 10057, 10066, 10118, 10282, 10345, 10438
CO, 7, 13, 10060, 10045, 10079, 10286
CO, 14, 51, 10049, 10012, 10077, 10123, 10125, 10345, 10476, 10656, 10777, 10789, 10790, 10882, 10993, 11475
ADJ+1, 2, 4, 10913, 10281, 10761, 10864
ADJ+1, 5, 6, 10913, 10281, 10761, 10864
ADJ+1, 7, 13, 10437, 10564, 10657, 10768, 10884, 10923, 10945, 11043, 11462, 10999, 11223, 11345
ADJ+1, 14, 51, 10090, 10006, 10425, 10543, 10549
ADJ-1, 2, 4, 10442, 10037, 10675
ADJ-1, 5, 6, 10442, 10037, 10675
ADJ-1, 7, 13, 10235, 10002
ADJ-1, 14, 51, 10636, 10532, 10546, 10555, 10675

In words, the first line reads:

After re-packing, if Station #10036 is placed in the Low VHF band (channels 2 4 or channels 5
6), then Stations #10057, #10066, #10118, #10282, #10345, and #10438 cannot be placed on
the

SAME

channel (co-channel).

For example, in words, the seventh line reads:

After re-packing, if Station #10437 is placed in the High VHF band (channels 7 13), then
Stations #10564, #10657, #10768, #10884, #10923, #10945, #11043, #11462, #10999, #11223,
#11345 cannot be placed on the first adjacent channel

ABOVE

it (meaning cannot be upper-
adjacent to Station #10437)
.

For example, in words, the twelfth (last) line reads:

After re-packing, if Station #10636 is placed in the UHF band (channels 14 51), then Stations
#10532, #10546, #10555, and #10675 cannot be placed on the first adjacent channel

BELOW

it
(meaning cannot be lower-adjacent to Station #10636).
24

4. Details of Constraint Inputs and Assumptions
4.1 U.S. Stations to U.S. Stations (Option 2)
The list of U.S. stations (excluding U.S. territories) used in creating the sample
Interference_Paired and Domain files are those listed in the U.S. Station Baseline List (in a file
called US_Station_Baseline_2013July15) to be made available for download at
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/. In generating the list of US
stations, staff used criteria consistent with the NPRM, which proposed to "interpret the mandate
to preserve `as of the date of this Act' to require preservation only with regard to facilities that
were licensed, or for which an application for license to cover authorized facilities already was
on file with the Commission, as of February 22, 2012." 22 Thus, this list contains full power or
Class A television station's that had a license, or license to cover application pending, on
February 22, 2012, as preliminarily determined by staff, including Class A-Eligible LPTV
stations that had a Class A license to cover application pending on February 22, 2012.
The U.S. Station Baseline List also includes certain authorized facilities the Commission
proposed to protect in the NPRM, including: new full power television stations that held a
construction permit, but not a license, by February 22, 2012; channel substitutions authorized in
rulemaking proceedings completed by February 22, 2012; and the initial digital conversion
facilities of Class A stations whether or not authorized prior to Feb. 22, 2012.23 Finally, it
includes two facilities, which subsequent to the NPRM, were modified pursuant to federal court
order.24
The facilities included in this list are intended for illustrative purposes only, so that interested
parties can conduct an analysis of the technical aspects of repacking and auction design. In order
to release these files prior to adoption of a Report & Order in this proceeding, some assumptions
had to be made about which facilities to include for protection. Because the Commission has not
yet decided which facilities will be protected, it was simplest to assume protection only of those
facilities that the Commission must seek to preserve, based on the statutory interpretation
proposed in the NPRM, as well as those facilities the Commission proposed in the NPRM to
seek to preserve in the exercise of its discretion. This does not in any way signal, however,
which facilities the Commission ultimately will seek to preserve. Interested parties may add


22 See NPRM, 27 FCC Rcd at 12390 98 (citing the Spectrum Act Section 6403(b)(2), which mandates preservation
of coverage area and population served for each "broadcast television licensee" which is defined as "the licensee of
(A) a full power television station; or (B) a low power television station that has been accorded primary status as a
Class A television station under Section 73.6001(a)" of the Commission rules). See 6403(b)(2); 47 C.F.R.
73.60001(a).
23 See NPRM, 27 FCC Rcd at 12397 114 (proposing to protect new full power television stations); id. at 12397
115 (proposing to protect initial Class A digital conversion facilities); and id. at 12398 116 (suggesting need to
protect facilities authorized to effectuate a channel substitution).
24 PMCM LLC, TV v. FCC, 701 F.3d 380 (D.C. Cir. 2012); In the Matter of Reallocation of Channel 3 from Ely,
Nevada to Middletown Township, New Jersey,
Report and Order, 28 FCC Rcd 2825 (MB 2013); In the Matter of
Reallocation of Channel 2 from Jackson, Wyoming to Wilmington, Delaware
, Report and Order, 28 FCC Rcd 2828
(MB 2013).
25

facilities to, or subtract facilities from, this list to analyze different preservation assumptions
using the process described herein, and the Task Force invites submissions based on such
analyses.
The data contained and the format of this U.S. Station Baseline List is shown below:

Data Element

Data Type

Description

Sample Value

channel
integer
Channel assignment
14
The service (e.g., Digital Television Station, etc.) of interest.
a. Where "DT" stands for Digital TV (the primary service of interest)
service
character varying(2)
b. Where Class A stations are indicated by "CA" and "DC".
c. Where "DD" are Distributed Transmisson Systems (used actual facility coordinates for
interference protection, but reference facility coordinates - which has ant_id of 0 - for
distance protections)
CA
country
character varying(2)
Country (where "US" = America, "CA" = Canada, "MX" = Mexico)
US
state
character varying(10)
State abbreviation
CO
city
character varying(50)
City
DENVER
lat
character varying(7)
Latitude of tower (expressed in degrees, minutes and seconds as DDDMMSS)
394345
lon
character varying(7)
Longitude of tower (expressed in degrees, minutes and seconds as DDDMMSS)
1051412
fac_callsign
character varying(20)
Call Sign (where a Call Sign is a set of characters that serve as the public identification for a
broadcast radio or television station. For example, WCAU or WGBS-TV)
KDVR
arn
character varying(30)
Application Reference Number (CDBS assigned)
BLCDT20090917ACG
app_id
integer
Application ID (CDBS assigned)
1331145
a. Where "LICEN" stands for Licensed
status
character varying(10)
b. Where "CP Mod" stands for modification of construction permit
LICEN
Height above average terrain (in meters)
haat
numeric
a. NOTE: If the authorized antenna height above average terrain (HAAT) is zero or
negative, the value in the table has been rounded up to a positive 0.
314
Directional Antenna (whether a directional antenna is used - (Yes ("D"-digital/"C"-class A)
da
character varying(2)
or No ("No"))
D
erp
numeric
Effective Radiated Power (kW)
1000
facility_id
integer
The unique integer number (assigned by MB) that identifies a station
126
rcamsl
numeric
The height of the radiation center above mean sea level (meters)
2323
ref_az
numeric
Reference Azimuth (in whole degrees)
0
ant_id
integer
The CDBS-assigned antenna id number (an integer)
101908
A few additional assumptions should be noted with respect to interference between U.S. to U.S.
stations when the sample files were generated:
1) With respect to these pairwise constraints, interference between a pair of stations is
generally not symmetric; that is, the interference station B causes station A is not the
same as the interference station A causes to station B, rather both cases must be
examined. In determining whether a pair of stations can co-exist on a particular channel
relationship, both relationships must be examined.
26

"Protected" Station
"Interfering" Station
B - Channel 4
A - Channel 3
B - Channel 3
B - Channel 2
A - Channel 4
B - Channel 3
A - Channel 3
A - Channel 2
In the above situation, station B could be upper-adjacent in two scenarios with respect to
station A. First, if station A is the "protected" station placed on the proxy channel 3 and
station B is the "interfering" station on channel 4. Second, if station B is the "protected"
station placed on channel 3 and station A is the "interfering" station on channel 2. If the
interference calculations in these two scenarios differ, the staff used the more
conservative estimate the one with the higher interference percentage.
2) There is 254 MHz of spectrum between stations on Channels 13 (the highest high-band
VHF channel) and 14 (the lowest UHF channel). Because of this gap, there is no
interference between UHF and VHF stations. Similarly, there is 86 MHz between
Channels 6 (the highest low-band VHF channel) and 7 (the lowest high-band VHF
channel) and there is no interference between low VHF and high VHF channels. There
is also another gap between Channels 4 and 5 and there is no interference between those
channels.25 Because of this gap, the Interference_Paired file must consider the low VHF
band separately between Channels 2 4 and Channels 5 6.
4.2 U.S. Stations to Canadian Allotments
For purposes of this analysis only, to determine whether a repacked U.S. Station can be co-
channel or adjacent channel to a Canadian allotment, FCC staff followed the same pairwise
approach applied to the study of interference between U.S. DTV stations with one minor


25 See 47 C.F.R. 73.610(c)(2); 47 C.F.R. 73.613(b).
27

difference.26 The staff used TVStudy software to determine the current interference-free
populations in Canada of each Canadian allotment (digital or analog) on its current channel.
Calculating the interference-free population of a Canadian station requires TVStudy to consider
predicted interference from other existing Canadian allotments and existing interference from
U.S. stations. TVStudy's replication engine is then used to calculate pairwise interference with all
possible U.S. stations (within the culling distance). The one difference is that in performing this
pairwise analysis, FCC staff did not use proxy channels for Canadian allotments as staff assumed
that these channel assignments were fixed. Whether a U.S. station can be placed on a co-
channel, upper-adjacent channel or lower-adjacent channel to the Canadian allotment depends on
the interference data produced by TVStudy according to the methodology in OET Bulletin 69.27
As with the interference protections applied to U.S. stations (namely, Option 2 listed in the
NPRM), staff has used the relevant cap of 0.5% new pairwise interference in studies involving
Canadian allotments.28
Because the Canadian channel allotments are fixed for purposes of this analysis, there is,
however, a significant difference in the way staff used the pairwise interference calculations
resulting from TVStudy from Canadian allotments. If the relevant 0.5% cap is exceeded, staff
removed the relevant channel(s) from the set of domains available to the U.S. station, which
violated this pairwise cap. Thus, the constraints on U.S. stations caused by Canadian allotments
are captured in the Domain file, rather than the Interference_Paired file.
The staff protected all Canadian allotments as specified in Table A of the Exchange of Letters for
purposes of this preliminary analysis, regardless of whether there is a Canadian station actually
operating on that channel.29 Moreover, the staff has also included any mutually agreed upon
modifications to Table A that have taken place since Table A was first released and which has
subsequently been captured in CDBS.30 In addition, the staff has also included all Canadian
analog allotments as currently tracked in CDBS. Although the DTV transition has largely been
completed in Canada's mandatory markets, there are Canadian stations along the U.S. border that
are outside of major Canadian urban centers that continue to operate as analog stations, and thus,
we conservatively protect all analog allotments.31 This preliminary list of Canadian DTV and
analog allotments which are considered by the TVStudy software is found in the Canadian
Allotment List (in a file called Canadian_Allotment_List_2013July15.xlsx) to be made available


26 This pairwise approach has been used for illustrative purposes; it is the subject of ongoing negotiations with
Canada.
27 2008 USA-Canada DTV Exchange of Letters at 2 (stating "[f]or compatibility relative to digital
assignments/allotments, the technical methodologies used in the development of Tables A and B (i.e. OET-69) are to
be used.").
28 NPRM, 27 FCC Rcd at 12393 106.
29 2008 USA-Canada DTV Exchange of Letters at Table A.
30 See FCC Consolidated Database System, available at http://transition.fcc.gov/mb/databases/cdbs/.
31 2008 USA-Canada DTV Exchange of Letters at 2 (stating "to assess the compatibility of a drop-in channel relative
to an analog assignment/allotment, the technical provisions of the 2000 Letter of Understanding are to be used"); see
2000 USA-Canada DTV Letter of Understanding; see also FCC Consolidated Database System, available at
http://transition.fcc.gov/mb/databases/cdbs/.
28

for download at download at http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/.32
The file format of this preliminary Canadian Allotment List is similar to that for the U.S. Station
Baseline List shown in

Section 4.1

.
A few additional assumptions should be noted with respect to interference between U.S. and
Canadian stations for purposes of this preliminary analysis:
1) The staff protected the Canadian digital service code DT and the Canadian analog service
codes TV and TA. No protection was afforded to foreign translators (service codes TX
and LD).
2) Similar to the approach described for interference between U.S. stations, FCC staff does
not assume symmetric pairwise interference. That is, the interference station B causes to
station A is not assumed to be the same as the interference station A causes station B. If
the interference calculations in these two scenarios differ, the staff used the more
conservative estimate (i.e., the one with the higher interference percentage).
3) Similar to U.S. to U.S. stations, the staff recognized the spectrum gaps between certain
DTV channels: There is no interference between UHF and VHF stations, between low
VHF and high VHF channel, or between Channels 4 and 5.
4.3 U.S. Stations to Mexican Allotments
The U.S. agreements with Mexico utilize distance-based protections between U.S. stations and
Mexican allotments.33 Because the Mexican allotments are assumed to be on fixed channels for
purposes of this analysis the constraints on U.S. stations caused by Mexican allotments are
captured in the Domain file, rather than the Interference_Paired file.
As with Canada, the staff protected Mexican digital television allotments in the U.S.-Mexico
border region as provided for in the Agreements and regardless of whether the channel is
currently in use.34 Because the Mexican DTV transition is still underway, there are also a
significant number of analog Mexican station allotments that must be protected.35 However,
the staff also captured mutually agreed upon modifications to either the Mexican Table of DTV
allotments or Mexican Table of NTSC allotments that have occurred since these original
agreements were signed. The preliminary list of Mexican allotments (both digital and analog) in


32 Although TVStudy considered all Canadian allotments listed in the Canadian Allotment List, TVStudy ran a mutual
exclusivity check prior to starting its calculations which suppresses analog allotments if they have been subsequently
been replaced by a digital allotment which overlaps the original allotment.
33 1998 USA-Mexico DTV Memorandum of Understanding at Table A (listing DTV to NTSC distance separation
requirements) and Table B (listing DTV to DTV distance separation requirements).
34 Id. at Appendix 3 (listing Mexican DTV allotments within 275 km of the U.S.-Mexico Border).
35 Id. at Appendix 1 (listing Mexican NTSC allotments within 400 km of the U.S.-Mexico Border for VHF and 320
km for UHF).
29

the U.S.-Mexico border region is found in the Mexican Allotment List (in a file called
Mexican_Allotment_List_2013July15.xlsx) to be made available for download at
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/. The format of this
preliminary Mexican Allotment List is similar to that for the U.S. Station Baseline List shown in

Section 4.1

.

Distance Restrictions

:
These distance restrictions were used in accordance with agreement obligations:

Table 136

DTV to DTV Television Distance Separation Requirement

Required Distance Separation

Channels

Channel Separation

Lower Boundary (km)

Upper Boundary

(km)
2 13
Co-Channel
0
273
2 13
1
48
96
14 69
Co-Channel
0
223
14 69
1
32
88

Table 237

DTV to NTSC Television Distance Separation Requirement

Required Distance Separation

Channels

Channel Separation

Lower Boundary (km)

Upper Boundary

(km)
2 13
Co-Channel
0
273
2 13
1
18
100
14 69
Co-Channel
0
244
14 69
1
10
88
14 69
2
24
32
14 69
3
24
32
14 69
4
24
32
14 69
7
24
95
14 69
8
24
32
14 69
+14
24
95
14 69
+15
24
96
For "truth table" generation for Mexican allotments, staff used the following process:
1) Each Mexican allotment was buffered by the distances (both co-channel and first adjacent
channel) outlined in the table below. The buffered allotments are called "protected


36 Id. at Table B.
37 Id. at Table A.
30

Mexican stations". Because some of the distances listed above are ranges (for example:
10-88 km), buffers are created that look like donuts.
2) Staff generated a list of all U.S. stations that fall within the buffers of the Mexican
allotments.
3) Staff generated "truth table" values based on the following scenarios:
a. DIGITAL (DTV)

Scenario 1:

If U.S. station falls within the co-channel buffer (outer circle) but
outside the adjacent-channel buffer (inner circle), then the U.S. station cannot
exist co-channel, but can exist either of the adjacent channels. Example:
Station facility_id = 40993 in map above.

Scenario 2:

If a U.S. station falls within both the co-channel buffer (outer
circle) and adjacent channel buffer (inner circle), then the U.S. station cannot
exist on co-channel or adjacent channel (either upper- or lower-adjacent).
Example: Station facility_id = 35095 in map above.
b. ANALOG (NTSC)

Scenario 1:

If a U.S. station falls within the co-channel buffer (outer circle)
only, then the U.S. station cannot exist co-channel, but can exist on the
adjacent channels. No example shown.

Scenario 2:

If a U.S. station falls within both the co-channel buffer (outer
circle) and other adjacent channel buffers ( 1, 2, 3, 4, 7, 8, +14, +15), then
the U.S. station cannot exist co-channel, or those other adjacent channels. No
example shown
.
Staff also applied the following other criteria with respect to interference between U.S. stations
and Mexican allotments:
1) With respect to the DTV and NTSC separation requirements above, because there is 254
MHz of spectrum between Channels 13 and 14, there are no distance separation
31

requirements between UHF and VHF channels. Similarly, there is 86 MHz between
Channels 6 (the highest low-band VHF channel) and 7 (the lowest high-band VHF
channel), so there is no distance separation requirement between low VHF and high VHF
channels. Finally, there is also gap between Channels 4 and 5, so there is no distance
separation requirement between those channels.
2) The staff protected the Mexican digital service codes DT and the Mexican analog service
codes TV and TA. Foreign translators (service code TX and LD) are not protected.
"Short Spacing" Situations involving Mexican Allotments
Because Mexican allotments are protected based on separation distance for the purpose of this
analysis, staff made several preliminary simplifying assumptions regarding existing "short
spacing" situations (situations for which the U.S. and Mexican governments have agreed to
allow operation at locations less than the minimum distance separations):
1) Co-Channel: If a U.S. station is currently short-spaced to a Mexican DTV allotment on
any given channel, then staff allowed the U.S. station to occupy the same channel after
repacking (and therefore continue to be short-spaced). A U.S. station currently short-
spaced with a co-channel Mexican DTV allotment was also allowed to occupy channels
adjacent to the channel occupied by the Mexican allotment.
2) Adjacent Channel: If a U.S. station is currently short-spaced with an adjacent-channel
Mexican DTV allotment, then staff allowed the U.S. station to be on an adjacent channel
above or below the Mexican allotment channel after repacking (assuming symmetry).
3) Because short-spacing conditions negotiated on a station-by-station basis, no other co-
located U.S. stations were allowed to create short-spaced situations during repacking.
4) Moreover, because these are distance-based specifications with respect to Mexican
allotments, the staff assumed symmetry with respect to interference.
5)

For short-spacing situations between U.S. DTV stations and Mexican NTSC

(analog) allotments, staff followed these guidelines:38
a. US-DTV station to MX-NTSC (Analog) allotment: If a U.S. station and a
Mexican allotment are currently short-spaced and operate co-channel, then the
same U.S. station may to continue to be short-spaced to the same Mexican
allotment on a co-channel or on an adjacent-channel (upper- or lower-adjacent)
after repacking.


38 These rules apply only to distance separation requirements between U.S. DTV stations and Mexican analog
(NTSC) allotments. Because the United States' Agreement with Mexico utilizes distance separation for stations
that are beyond the immediate upper- and lower-adjacencies (1 channel), some special rules are required. A few
conservative assumptions were made with respect to those existing short-spacing situations. See 1998 USA-Mexico
DTV Memorandum of Understanding at Table A (listing DTV to NTSC distance separation requirements).
32

b. US-DTV station to MX-NTSC (Analog) allotment: If a U.S. station and a
Mexican allotment are currently short-spaced on an upper- or lower-adjacent
channel, then the same U.S. station may continue to be short-spaced to the same
Mexican allotment on an upper- or lower-adjacent channel after repacking, but
there was no short-spacing relaxation beyond upper- or lower-adjacent channels
for this pair of stations (i.e., distance requirements for any adjacent channel
beyond 1 must be met).
c. US-DTV station to MX-NTSC (Analog) allotment: If the U.S. station and
Mexican allotment are currently short-spaced on an adjacent channel beyond 1
channel (e.g., adjacent 2 channels), then staff allowed the same U.S. station to be
short-spaced to the same Mexican allotment only on that specific adjacent channel
relationship. Thus, if a US-DTV and a MX-NTSC allotment are short spaced on a
upper third-adjacent channel (i.e., adjacent +3 channels), they could continue to
be short-spaced on either upper third-adjacent or lower third-adjacent channel
(due to symmetrical treatment inferred by the distance-based rules).
4.4 U.S. Stations to Land Mobile Operations
As with Mexico, FCC rules require distance-based protections between U.S. stations and Land
Mobile ("LM") city center coordinates or Land Mobile Waiver ("LMW") base stations.39 The
staff treated these operations as fixed constraints which limit the number of channels available to
nearby U.S. stations. These constraints on U.S. stations are captured in the Domain file.
The preliminary list of Land Mobile and Land Mobile Waiver locations currently considered is
found in the Land Mobile City Center List (in a file called
LM_City_Center_List_2013July15.xlsx) and in the Land Mobile Waiver Station List (in a file
called LMW_Station_List_2013July15.xlsx) both to be made available for download at
http://data.fcc.gov/download/incentive-auctions/Constraint_Files/">http://data.fcc.gov/download/incentive-auctions/Constraint_Files/. Land mobile operations are
allocated by rule on certain channels between Channel 14 and Channel 20 in 13 designated urban
centers (although operations are authorized in only 11 of these locations due to border
restrictions involving Canada).40 The spectrum of TV channels 14-20 is commonly referred to
as "television-band" ("T-Band") Land Mobile spectrum. Land Mobile stations that do not fall in
these protected urban centers require a waiver to operate and are therefore listed separately.
The data contained in and the format of this preliminary Land Mobile City Center List is shown
below:


39 47 C.F.R. 73.623(e). Land Mobile Waiver ("LMW") licensees currently operate on waivers, which they applied
for under the exception process in Section 1.925, and which allow them to operate in variance with these specified
locations and channels between 14 and 20. See 47 C.F.R. 1.925.
40 47 C.F.R. 90.303 (listing Boston, Chicago, Dallas/Fort Worth, Houston, Los Angeles, Miami, New York,
Philadelphia, Pittsburgh, San Francisco/Oakland and Washington D.C. as urbanized areas where land mobile
operations are authorized in the portion of the UHF band from 470-512 MHz (channels 14-20). This section also
lists Cleveland and Detroit in the list of urbanized areas but notes in the footnotes that channels designated for land
mobile operations are "not available, until further order from the Commission." See 47 C.F.R. 90.303 n.2 and n.3.
33

Data Element

Data Type

Description

Sample Value

facility_id
integer
The unique integer number (assigned by MB) that identifies a station
999001
Call Sign (where a Call Sign is a set of characters that serve as the public
fac_callsign
character varying(5)
identification for a broadcast radio or television station. For example, WCAU or
WGBS-TV)
LM-14
fac_channel
integer
Channel assignment
14
city
character varying(100)
City
Boston
stateabbr
character varying(2)
State abbreviation
MA
lat_deg
numeric
Latitude degrees
42
lat_min
numeric
Latitude minutes
21
lat_sec
numeric
Latitude seconds
24
lon_deg
numeric
Longitude degrees
71
lon_min
numeric
Longitude minutes
3
lon_sec
numeric
Longitude seconds
25
latitude
numeric
Latitude transformed to standard format
42.35666667
longitude
numeric
Longitude transformed to standard format
-71.05694444
geom
geometry
Geometry of point (used by spatial database)
GEOM
The data contained and the format of this preliminary Land Mobile Waiver Station List is shown
below:

Data Element

Data Type

Description

Sample Value

The unique integer number (assigned by MB) that identifies
facility_id
integer
a station
999101
Call Sign (where a Call Sign is a set of characters that serve
fac_callsign
character varying(10)
as the public identification for a broadcast radio or
television station. For example, WCAU or WGBS-TV)
WIJ783
fac_channel
integer
Channel assignment
19
Radio Service where IG = Industrial/Business Pool
(Conventional); PW =Public Safety Pool (Conventional); YG =
fac_service
character varying(2)
Industrial/Business Pool (Trunked); YK = Industrial/Business
Pool (Commercial, Trunked); YW = Public Safety Pool
(Trunked).
YK
county
character varying(20)
County Name
MONMOUTH
stateabbr
character varying(2)
State abbreviation
NJ
location_number
integer
Location number
1
These base stations are "fixed (F)" and "mobile" (M)
location_type
character varying(20)
designation of station. Note: Only type "F" protected
F
lat_deg
numeric
Latitude degrees
40
lat_min
numeric
Latitude minutes
12
lat_sec
numeric
Latitude seconds
13.4
lat_direction
character varying(20)
Latitude direction
N
lon_deg
numeric
Longitude degrees
74
lon_min
numeric
Longitude minutes
16
lon_sec
numeric
Longitude seconds
13.5
lon_direction
character varying(20)
Longitude direction
W
latitude
numeric
Latitude transformed to standard format
40.20372222
longitude
numeric
Longitude transformed to standard format
-74.27041667
geom
geometry
Geometry of point (used by spatial database)
GEOM

Distance Restrictions

:
The staff applied the following distance separations to establish whether a constraint prohibiting
co- or adjacent-channel operation between Land Mobile and DTV should be established:41


41 Staff obtained the DTV to Land Mobile City Center protection distances of 250 km for co-channel and 176 km
for adjacent channel directly from 47 C.F.R. 73.623(e). Staff derived the separation distances for Land Mobile
Waiver base stations as follows. Because 47 C.F.R. 90.305(a) allows Non-Waiver Land Mobile base stations to be
34

US and Land Mobile Operation

DTV to LM City Center

DTV to LMW Base Station

Co-Channel:
250 km
185 km
Adjacent Channel:
176 km
96 km
Staff used the following process to generate LM city center and LMW base stations' truth tables:
1. Each LM city center and LMW station was buffered by the distances (both co-
channel and first adjacent channel) outlined in the table above (shown below).
The buffered stations are the "protected LM stations".
2. A list of all U.S. stations that fall within the buffer distances of the LM city
centers and LMW stations is identified.
3. Truth table values are computed based on the following scenarios:




located to 80 km from the city center, staff subtracted 80 km from the Land Mobile City Center distances of 250 km
and 176 km to arrive at "buffer" distances of 170 km and 96 km for individual Land Mobile Waiver base stations.
However, staff determined that 15 km extra buffer would be required for co-channel Land Mobile Waiver base
stations as follows. Staff estimated that the 41 dBu F(50,90) contour of a 1 MW UHF DTV station at 600 m HAAT
extends 121 km. 47 C.F.R. 90.305(b) allows associated mobiles to operate up to 48 km from base stations. If the
separation is only 170 km, staff assumed that mobiles might operate at the edge of DTV service area, and those
mobiles could cause interference to nearby DTV receivers. The 40 dBu F(50,10) coverage of a 50-watt mobile at 30
m HAAT extends about 15 km. So, staff added an additional 15 km to the 170 km derived separation distance, for a
total of 185 km.
35

Scenario 1:

If a station falls within co-channel buffer (outer circle) only, then the
U.S. station cannot exist co-channel, but can exist on an adjacent channel.
Example: Station facility_id = 450 in map above.

Scenario 2:

If a station falls within both the co-channel buffer (outer circle) and
adjacent channel buffer (inner circle), then the U.S. station cannot exist co-
channel or on an adjacent channel.
Example: Station facility_id = 73288 in map above.
4. Staff protected waiver-based land mobile licensees based on their tower
locations.42

Short Spacing Rules and Land Mobile

Staff used the following rules about short spacing when protecting LM city centers and LMW
base stations:
1)

Co-Channel

: When a television station is currently short-spaced on the same channel
with either an allocated LM or a LMW base station, staff allowed that same station to
continue to be short-spaced on the same or an adjacent channel in repacking.
2)

Adjacent Channel

: Similarly, the staff allowed any television station currently short-
spaced on an adjacent channel with either an allocated LM or a LMW base station to
continue to be short spaced on an adjacent channel following repacking. Because these
restrictions are distance-based, staff assumed symmetry with respect to interference.
3) Staff did not allow other stations located the same tower as the currently short-spaced
television station (co-located stations) to be short-spaced with the land mobile base
station following repacking.
4.5 Channel 37
As noted in

Section 3.3

, Channel 37 is allocated for radio astronomy and wireless medical
telemetry43 and staff assumed it to be unavailable as a channel for repacking for purposes of this
analysis. No additional constraints with respect to repacking television stations into adjacent
channels (channels 36 and 38) were imposed.


42 The transmitter site for T-Band licensees' base stations cannot be located more than 80 km (50 miles) from the
geographic center of the urbanized area unless they operate under a waiver. Moreover, mobile units must be
operated within 48 km (30 miles) of their associated base station or stations. See 47 C.F.R. 90.305. The staff's
conservative approach to measuring separation distances (from LM city centers or from the tower location of LMW
base stations) and the separation distances themselves makes this assumption of only protecting base stations
reasonable. Moreover, because the LM end user devices are mobile, using base station locations for determining
separation distances is the only practical option.
43 47 C.F.R. 2.106. "Table of Frequency Allocations".
36

4.6 U.S. Station to Offshore Radiotelephone Services
Offshore Radiotelephone Service ("ORTS") licensees operating under this service are limited to
off-shore operations on Channel 17 off the coast of Southern Louisiana (Zone A), Channel 16 off
the coast of the border area between Southern Louisiana and Texas (Zone B), and Channel 15 off
the coast of Southern Texas (Zone C).44 This service is considered a primary allocation within
these offshore regions.45 FCC rules state, however, that offshore ORTS licensees must not
transmit from locations within 241 kilometers of any full-service television station that transmits
on the TV channel containing the channel on which the offshore station transmits.46
According to the FCC's Universal Licensing Service ("ULS"), there is only one licensee
operating under this service in Zones B and C.47 Based on the authorized operations of this one
licensee and the fact that ORTS transmitters must not operate within 241 kilometers of a full-
service television, staff did not apply any additional repacking constraints to protect co-primary
ORTS operations from repacked television stations.
However, despite the lack of any current operating services, staff added a repacking constraint
for the primary allocation given in Hawaii to Channel 17 for common carrier control and
repeater stations for point-to-point inter-island communications as no distance separation
requirement applies.48


44 47 C.F.R. 22.1007.
45 47 C.F.R. 2.106. "Table of Frequency Allocations".
46 47 C.F.R. 22.1009(a).
47 FCC Universal Licensing System, available at http://wireless.fcc.gov/uls/weeklypn.htm?&job=home.
48 47 C.F.R. 2.106. "Table of Frequency Allocations".
37

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