The FCC should ensure BRS channel 1 and 2 licensees move from the...

FCC officials. It said upstream data operations on BRS channels 1 and 2 can’t co- exist with downstream AWS operations under the AWS spectral mask (43+10 log(P)). “In the case of BRS/AWS the zones of interference to BRS could be quite large in markets where, as is usually the case, upstream BRS operations are part of a system that utilizes a single ’supercell’ [a receive antenna system mounted higher in the air than those used in more cellularized systems] that has an extensive coverage area,” the group said. WCA also stressed that BRS channels 1 and 2, often used together, must be moved together to “avoid undue disruption of existing BRS operations and to eliminate the possibility of adjacent interference between BRS channel 2 and AWS were only BRS channel 1 moved.” WCA also urged the FCC to make it “absolutely clear” AWS auction winners bear responsibility for BRS relocation costs, including “any expenditures necessary to clear the 2496-2500 MHz band of incumbent users with whom BRS channel 1 and 2 licensees cannot co-exist.” Such incumbents include grandfathered co-channel broadcast auxiliary service (BAS) licensees. Those relocation costs should be shared with Globalstar whose deployment of an ancillary terrestrial component would benefit from clearance of BAS, the group said. While calling Commission rules and procedures for point- to-point microwave services “a useful starting point,” WCA said they “must be modified to accommodate the unique circumstances associated with relocating BRS.” It said the fact that BRS is a point-to-multipoint, mass-market, consumer-based service “implicates additional cost factors that do not exist in the point-to-point model.” Moreover, it said, unlike previously relocated point-to-point services, BRS spectrum often is leased to non-licensee spectrum operators: “Accordingly, the legitimate interests of BRS spectrum lessees must be accounted for and addressed in any relocation paradigm for BRS channels 1 and 2.” WCA also said the spectrum at 2496-2502 MHz/2618-2624 MHz designated for BRS relocation won’t be available in some BRS channel 1 or 2 licensees’ markets that haven’t been transitioned to the new 2.5 GHz bandplan. It reiterated that “once a market has been transitioned, the responsible AWS licensees should be required to reimburse the ‘proponent’ for the pro rata share of the proponent’s transition costs” related to making the 2496-2502 MHz/2618-2624 MHz bands available for BRS channels 1 and 2. The Commission should let AWS and relocated BRS licensees negotiate alternative interim arrangements pending transition of the channels to the new 2.5 GHz band plan, the group said. WCA urged the FCC to issue its BRS relocation rules “as soon as possible” to end regulatory uncertainty that chills investment, delays deployment of new BRS services and keeps potential AWS auction bidders from factoring BRS relocation costs into valuations of spectrum they are bidding on.