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Cricket Request for Waiver of DTV Protection Criteria in Chicago

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Released: January 31, 2014


Federal Communications Commission

News Media Information 202 / 418-0500
445 12th St., S.W.
Fax-On-Demand 202 / 418-2830

Washington, D.C.20554

TTY 202 / 418-2555

DA 14-113

Released: January 31, 2014



WT Docket 14-17

Comment Date: March 3, 2014
Reply Comment Date: March 18, 2014

By this Public Notice, the Wireless Telecommunications Bureau (Bureau) seeks comment on the
request for a waiver and associated technical studies filed by Cricket License Company, LLC (Cricket).1
Cricket seeks a waiver of Commission rule Section 27.60, which requires 700 MHz wireless licensees to
comply with certain interference protection requirements when operating near existing TV and DTV
broadcast stations transmitting on TV Channels 51 through 68.2
Cricket is required to protect the adjacent Channel 51 DTV broadcast station, WPWR-TV,
operated by Fox Television Stations, Inc. (Fox) and seeks a waiver of the Section 27.60 protection criteria
to deploy a Lower 700 MHz A Block license (call sign WQJQ707) in the Chicago-Gary-Kenosha, IL-IN-
WI BEA (BEA 064).3 Cricket states that a grant of the requested waiver is in the public interest because
“the growing demand for wireless broadband services and the surging need for network capacity are well
documented, principally in urban areas,”4 that any LTE operations deployed to serve the populous urban

1 Petition of Cricket License Company, LLC (Cricket) for a Waiver of DTV Protection Criteria, Attachment,
Universal Licensing System (ULS) File No. 0006046277 (filed Dec. 6, 2013) (Cricket Waiver Request). Cricket’s
supporting exhibits can also be accessed in ULS under Application Search (File No. 0006046277) through the
“Admin” tab, followed by “All Attachments.”
2 47 C.F.R. § 27.60. Section 27.60 requires that “base, fixed, control and mobile transmitters in the 698–763 MHz,
775–793 MHz, and 805–806 MHz frequency bands must be operated only in accordance with the rules in this
section to reduce the potential for interference to public reception of the signals of existing TV and DTV broadcast
stations transmitting on TV Channels 51 through 68.” Section 27.60 further requires that wireless licensees reduce
the potential for interference to existing TV and DTV stations by selecting one of four methods: 1) utilizing the
geographic separation tables specified in the rule; 2) calculate geographic separation in accordance with the required
desired–to-undesired signal (D/U) ratios; 3) submit an engineering study justifying proposed separations; or 4)
obtain written concurrence from applicable TV/DTV stations. See id.
3 See id. See Cricket Waiver Request at 1. We note that Fox filed a request for leave to file an Opposition to the
Cricket Waiver Request by February 17, 2014. See Letter from Joseph M. Di Scipio, Vice President, Legal and
FCC Compliance, Fox Television Stations, Inc., to Marlene H. Dortch, Secretary, Federal Communications
Commission (Jan. 17, 2014). The pleading cycle in this Public Notice establishes comment and reply comment
deadlines falling after the February 17, 2014 deadline requested by Fox, and we therefore dismiss as moot Fox’s
request for leave to file an Opposition by February 17, 2014.
4 See Cricket Waiver Request at 18-19, 21.

center of Chicago “would exceed the D/U threshold in the rule and have the potential to cause
interference into DTV operations, albeit only to a de minimis number of viewers,”5 and grant of the
waiver would promote rapid deployment of the Lower 700 MHz A Block spectrum in Chicago.6
Cricket’s waiver is accompanied by an independent laboratory test and probability analysis,7
which conclude that the proposed deployment would impact only 20 viewers watching the Channel 51
broadcast station’s signal over-the-air while operating an LTE handset more than 1.5 meters away from
the DTV receiver antenna.8 Cricket states that the testing methodology and predictive engineering
models employed in Cricket’s analysis are fully consistent with the Commission’s testing approaches and
prior precedent waiving DTV protection criteria.9 We seek comment on the technical analysis provided
in Cricket’s waiver request.
Finally, Cricket requests that any waiver relief granted be transferrable to a future successor of
Cricket that acquires de facto control of the license, as contemplated in the pending application seeking
approval to transfer control of Cricket to AT&T, Inc.10 Cricket claims that if its interference analysis
were scaled for deployment by a successor carrier, the projected number of affected viewers would still
be de minimis.11

Procedural Matters

Comments on the request are due

March 3, 2014

. Reply comments are due no later than

March 18, 2014

. All filings should reference the docket number of this proceeding,

WT 14-17.

This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with
the Commission's ex parte rules.12 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of

5 Id. at 7.
6 See id. at 1.
7 Id. at 3. See ULS File No. 0006046277, Attachments (Exhibit B – Intertek Report, Exhibit C – Newfield Report)
(filed Dec. 6, 2013).
8 Id. at 3-4;
9 See id. at 14.
10 See id. at 5; See Application of AT&T Inc. and Cricket License Company, LLC for Consent to Transfer Control of
Licenses and Authorizations, ULS File No. 0005860676 (lead application) (filed Aug. 1, 2013; amended Nov. 1,
11 See Cricket Waiver Request at 5-6.
12 See 47 C.F.R. §§ 1.1200(a), 1.1206.

electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
Comments may be filed using the Commission's Electronic Comment Filing System (ECFS) or
by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg.
24121 (1998). Comments filed through the ECFS can be sent as an electronic file via the Internet to
http:// Generally, only one copy of an electronic submission must be filed. If
multiple docket or rulemaking numbers appear in the caption of this proceeding, however, commenters
must transmit one electronic copy of the comments to each docket or rulemaking number referenced in
the caption. In completing the transmittal screen, commenters should include their full name, U.S. Postal
Service mailing address, and the applicable docket or rulemaking number. Parties may also submit an
electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters
should send an e-mail to, and should include the following words in the body of the
message, “get form.” A sample form and directions will be sent in reply.
Parties who choose to file by paper must file an original and one copy of each filing. If more than
one docket or rulemaking number appears in the caption of this proceeding, commenters must submit two
additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S.
Postal Service mail). All filings must be addressed to the Commission's Secretary, Office of the
Secretary, Federal Communications Commission.
-Effective December 28, 2009, all hand-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., S.W., Room TW-A325, Washington, DC 20554.
All hand deliveries must be held together with rubber bands or fasteners. Envelopes must be disposed of
before entering the building. The filing hours at this location are 8:00 a.m. to 7:00 p.m.



The Commission’s former filing location at 236 Massachusetts Ave., N.E. is permanently
-Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must
be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
-U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be addressed to 445
12th Street, S.W., Washington, DC 20554.
Parties are requested to send one copy of their comments and reply comments to Best Copy and
Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, DC 20554, (800) 378-
3160, e-mail
The request, and comments and reply comments filed in response to this Public Notice are
available for viewing via the Commission's Electronic Comment Filing System (ECFS) by entering the
docket number,

WT 14-17

. The documents also will be available for public inspection and copying
during business hours in the FCC Reference Information Center, Portals II, 445 12th Street S.W., Room
CY-A257, Washington, DC 20554. They may also be purchased from Best Copy and Printing, Inc.,
telephone (800) 378-3160, facsimile (202) 488-5563, TTY (202) 488-5562, e-mail
Alternate formats of this Public Notice (computer diskette, large print, audio recording, and
Braille) are available to persons with disabilities by contacting the Consumer & Governmental Affairs
Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to

For further information, contact Ms. Becky Schwartz of the Mobility Division, Wireless
Telecommunications Bureau at (202) 418-7178, or via e-mail at
Action by the Chief, Mobility Division, Wireless Telecommunications Bureau.
- FCC -

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