The following information applies only to broadcasters wishing to find and apply for Broadcast Auxiliary Service (BAS) licenses in the 944.000 to 952.000 MHz band. This frequency band is reserved for Broadcast Studio to Transmitter Links. Applications for Remote Pick-Up Systems (RPU), and applications to license below 900 MHz, do not require the Pre-Coordination Notification (PCN) letter process. This licensing requires filling out the ULS Form 601 and utilizing local coordination (yes, this is still required and the process is similar to previous rules).

Obtaining a complete Path Terrain study is the obvious starting point - if the path doesn't work, you don't want to apply for it. Skipping this step is like betting on a hand of cards you haven't seen. You may acquire a new license only find the path is obstructed or has an intolerable fade margin because of vegetation.

Modern computer programs using 3 second terrain databases have taken this tedious job to a more tolerable experience. Most manufacturers of STL / ICR equipment have in-house terrain programs to assist in the selection of hardware.

Here is an example of a terrain study:

The second half of the path study is selecting equipment. You need something guaranteeing sufficient fade margin in all weather conditions. In certain parts of the United States the path must be designed with extra fade margin to offset heavy rain or heavy snow conditions. Minimum receiver signal strength for maximum allowable noise performance is available from the equipment manufacturer and must be used for setting the allowable fade margin.

Test Table

Transmitter coordinates: N. Lat. 373728 W. Lng. 1044651

Receiver coordinates: N. Lat. 373758 W. Lng. 1045259

Transmitter Antenna Height: 144.38 Mtrs AG

Receiver Antenna Height: 45.53 Mtrs AG

Path Length: 9.07 km

Azimuth: 275.91 degrees

Frequency: 952.5 MHz

Obstruction loss: 0 dB

Free Space loss: -111.2 dB

Transmission line loss: -2.8125 dB

Receiving line loss: -3.125 dB

Connector loss: -2 dB

Other losses: 0 dB

Total losses: -119.14 dB

Transmitter output power: 6.31 Watts, 38 dBm

Transmitter antenna gain: 14.226 dBi

Receiver antenna gain: 14.226 dBi

Other gains: 0 dB

Total gains: 66.45 dB

Expected receiver signal: -52.69 dB

Desired receiver signal (sensitivity): 39.81 microVolts, -75.0 dBm

Available fade margin: 22.31 dB

Minimum fade margin Recommended: 3.17 dB

Freestanding towers are prone to walk and twist in heavy winds. Studio towers are usually lighter duty to help meet aesthetic and zoning restrictions. Light duty TV antenna towers and towers with narrow face width should be avoided. As little as 2.5° of tower twist can make significant changes in path performance. Consult a tower manufacturer to ensure your proposed tower is capable holding the microwave antenna you select.

Odd as it seems, Antenna Structure Registration (ASR) problems occur at this stage. Note this because it affects your time and money. If the FCC finds a problem with your STL application, the application will be returned and you may forfeit your filing fee.

Two common ASR problems involve: 1.) Unexpected impact to Airport Glide Slope (glide slope is the path an airplane takes when descending onto the runway); 2.) Neglected attention of ASR registration when the airport extends its runways.

Many broadcasters express frustration after realizing they forgot to take FAA airspace restrictions into account. Even more broadcasters pale when realizing the local airport has extended one or more of its runways since the last time they checked structure registrations.

Thus, scrutinize your proximity in regard to local airports before applying for anything. Also, make sure your tower is registered correctly. Remember, even towers below 200 ft are required to obtain an ASR if they impact the glide slope protection of a runway.

• What to expect if these problems arise: Loss of money, loss of time, loss of sanity

• Helpful Tools

Note: The FCC online 601 form has a new self checking feature which weeds out errors and alerts you to missing data...and it alerts you if your site fails TOWAIR. Thus, check your tower with TOWAIR before you start the 601 form. You will waste valuable time and money if you fill out the 601 and find your engineering is not complete. It is wise to do a quick check in TOWAIR at this stage to make sure your work will not be wasted.

The next two sections tackle: 1.) Modifying an existing licensed system; 2.) Determining an available frequency.

• Application for initial authorization;
• Any substantial change in ownership or control, including requests for partitioning and desegregation;
• Application for renewal of authorization;
• Application or amendment requesting authorization for a facility that would have a significant environmental effect, as defined by §§1.1301 through 1.1319 of the rules;
• Application or amendment requiring frequency coordination pursuant to the Commission's rules or international treaty or agreement;
• Application or amendment requesting to add a frequency or frequency block for which the applicant is not currently authorized, excluding removing a frequency.

• Any change in transmit antenna location by more than 5 seconds in latitude or longitude for fixed point-to-point facilities (e.g., a 5 second change in latitude, longitude, or both would be minor); any change in coordinates of the center of operation or increase in radius of a circular area of operation, or any expansion in any direction in the latitude or longitude limits of a rectangular area of operation, or any change in any other kind of area operation;
• Any increase in frequency tolerance;
• Any increase in bandwidth;
• Any change in emission type;
• Any increase in transmit antenna height (above mean sea level) more than 3 meters, except as specified in paragraph (d)(3) of this section;
• Any increase in transmit antenna beam width, except as specified in paragraph (d)(3) of this section;
• Any change in transmit antenna polarization;
• Any change in transmit antenna azimuth greater than 1 degree, except as specified in paragraph (d)(3) of this section.

• Any pro forma assignment or transfer of control;
• Any name change not involving change in ownership or control of the license;
• Any address and/or telephone number changes;
• Any changes in contact person;
• Any change to vessel name on a ship station license;
• Any change to a site-specific license, except a PLMRS license under Part 90, or a license under Part 101, where the licensee's interference contours are not extended and co-channel separation criteria are met, except those modifications defined in paragraph (c)(2) of this section; or
• Any conversion of multiple site-specific licenses into a single wide-area license, except a PLMRS license under Part 90 or a license under Part 101 of this chapter, where there is no change in the licensee's composite interference contour or service area as defined in paragraph (c)(2) of this section.

At this point, the STL path is configured and you are certain it has adequate fade margin. Next comes frequency selection. You have several options: 1.) Contact an SBE frequency coordinator; 2.) Do your own search using FCC tools; 3.) Contact a consulting firm who has the capability to locate available frequencies. If no SBE coordinator works in your area (this is likely in less populated parts of country), the game changes slightly. You can opt to do your own frequency search or you can hire professional help.

• Using a Traditional SBE Frequency Coordinator

• Using Your Own Wit

• Hiring a Professional

The ULS Database is in terrible condition...and the Wireless Branch knows it. The old FCC 313 form didn't request as much information as the new FCC 601. Increases in data requirements also increased the bogus information logged due to human error. Also, some correct information has been altered in the last five years due to technical problems when the FCC consolidated their information. Thus, many current licenses have missing or incorrect data.

This effects you directly. If you hold a Part 74 or Part 101 microwave license, check to make sure the data on the license is correct and up to date.

If the address on the license is not current, you may not get PCN letters from other broadcasters who are about to use your frequency. Companies doing PCN letter notification only have to be as accurate as the ULS database. They will not track you down if your letter bounces at the post office. If you don't get the PCN letter, you lose your opportunity to protest a new system that may cause you problems. Yes, if you have a license and you are on the frequency first, they can't make you move. But, if interference occurs, the burden of proof is placed on you...not the new guy.

To protect yourself from this situation, heed the following principles:

In October 2003, with the update of Part 74 rules, the FCC imposed a Pre-Coordination Notification (PCN) requirement for all new applications of microwave facilities on frequencies over 900 mhz. This new policy aligns Part 74 applications with those in the Part 101 industrial microwave band. The new PCN requirement burdens broadcasters with another step in the application process and with a filing delay of at least 30 days. In this section, we look at the practical things about PCN that impact the broadcaster. The full PCN requirement is outlined in TIA/EIA TSB 10-F. Contact Munn-Reese Inc. if we may assist you in this process.

Now, you must coordinate with an area that is wider than you might think. To meet FCC standards, you must send a PCN letter to anyone with a current license or pending application within a 200 Km radius (and it expands to 400 Km in the keyhole) of your proposed transmit site. To give you a visual example, look at the radius that must be covered if applying for a major change in Kalamazoo, MI. Notice you would send PCN letters to broadcasters from Detroit to Chicago, and from Grand Rapids to Fort Wayne, IN!

Also bear in mind the PCN requirement includes the entire STL band from 944.000 MHz to 952.000 MHz, not just the frequency you apply for. In the above scenario, major cities like Detroit and Chicago can easily push the PCN letter count over 200 letters. Better plan on using those self-sticking stamps.

The PCN letter must notify all users of the STL band that your station is planning a major change. The letter should include a cover page, written in basic language, introducing who you are and what you're doing. It should also include ALL of the technical data about your proposed system so the recipient can evaluate your proposed system to his currently licensed system for compatibility. The letter should also state the recipient has 30 days to respond to you if they feel the system is not compatible with their currently licensed system.

Have a place to store letters returned due to wrong address and any response letters protesting your move. Each needs to be retained. Letters that protest the proposed system require both parties to resolve interference issues before proceeding with licensing. This may require you to start the PCN process over with a modified technical proposal.

No matter how well written your cover letter is, or how well you explain what you are doing, the phone is going to ring. Because it is a new procedure, many other frequency band users have no clue why they got the letter. But, instead of reading what you painstakingly wrote, they are more pleased to chat with you over phone about the letter and why they got it. Expect 15% of the letters to come back because of an incorrect address. Expect another 15 % of letter recipients to call you on the phone with questions.

Thirty days after the PCN mailing, data can be compiled and the FCC 601 PCN attachment document can be created. The 601 form will require you to state the coordination process was completed and all complaints, if any, were resolved (you must include a list of companies / stations that were contacted in the key hole area).

If you prefer to avoid this hassle, contact a trusted, experienced professional. Contact Munn-Reese, Inc. to see if our firm is right for you.

Before you can log in to the ULS, you must have the FRN number and password for your station. If you don't have these items, contact the station's communication attorney or the station owner and inquire.

If your station has never applied for an FRN or password, you need to go to the "FCC CORES" site with your IRS tax ID number and file for the FRN. You will be asked to pick a password, to complete some simple ownership information and to enter all your current Part 74 call signs or Antenna Structure Registration numbers.

If you have an FRN number, but you have lost the password, call Ed Trombley at Munn-Reese, Inc. He will explain how to contact a nice lady by the name of Gladys who will get your password changed. This predicament is more common than you may know. Once you have FRN and password in hand, you are ready to log on.

Big Hint: The ULS on line 601 form requires a huge pile of Java code that must be loaded before you can even open the form. Don't attempt to file the FCC 601 on a slow computer or on a dial-up connection. You may not live long enough to complete the form. Also, check on the ULS for versions of web browsers that are not compatible with the ULS on line filing system.

This is like doing your taxes...blanks, head scratching, confusion and attachments. The latest version of the FCC 601 is much improved. If you leave something blank, the system will not let you advance to the next page. It will pop up an error window giving you a hint as to what the system thinks is missing. You can save the form and log out at anytime, then log back in to work on it again.

Big Hint: Not all blanks in the 601 need data. Don't print a blank 601 form and spend 2 weeks digging up information to fill every blank. Only about 30% of the blanks require data. Blanks that are grayed out will not accept data. Remember, the FCC 601 form is a "one size fits all" licensing form. When you log, in the system asks you for the type of service. "AS" is for STL's and "AI" is for ICR's. The system then tailors the form by adding the correct schedules for the requested service. When you have made it to the last page and have entered all the data, there is a button for error checking. If you come up with no errors, your form is almost ready for submission.

Your FCC 601 form requires an attachment stating 1.) how the PCN coordination was conducted, 2.) which stations the PCN letters were sent too, 3.) if any of these stations protested your proposed system and 4.) how you solved the protested issues.

If you're a Non-Commercial Broadcaster, your FCC 601 form requires an attachment stating your corporation name. You will also need to identify you are a "Not for Profit" corporation operation under 501C3 of the IRS code. This attachment is required to waive the FCC 601 filing fee.

All attachments can be Word documents and are uploaded by using the attachment tool on the FCC 601 form.

When you have all the attachments loaded and you think you're ready, use the submit button to upload the form. The system will let you know if the process was successful or not. Wait a few minutes for the system to attach a file number to your form. After this, print a copy for your files...hang on to the file number; you're going to need it to track the process of the application. If you are to busy to wade through the ULS mess, contact Munn-Reese, Inc. and we will help!

If you're a Commercial Broadcaster, you have a filing fee to pay. The ULS gives you two options: 1.) Paying with a credit card or 2.) Printing and mailing the FCC 159 Fee form to Pittsburgh, PA. Taking the credit card option is, by far, the easiest method. If you grab your boss's plastic, you'll be done in 10 minutes.

If you grab for a stamp, things will get a bit more complicated. Payment for your application using the paper FCC 159 Fee form must reach Pittsburgh, PA in 10 days or your application will be canceled. If you're going to do the paper 159 Fee form, you had better watch somebody print the check and then hand deliver it to the post office. A good number of applications are lost every year because somebody "sat on" the check request. Then somebody gets to file them again.

It doesn't matter who files your application, you can track it through the ULS system with some simple tools off the ULS web site. By going to the FCC ULS page and using the "application search" function, you can enter the file number of the application. Find the application "history file" and open it. By tracking the history information, you will know quickly if there is a problem or hang up with part of the application. Before, the PCN requirements, applications were completely processed in about 45 days. After PCN, the time lag seems to have tripled. When the application is granted, the FCC will print the license and send it to you in the mail.

With the re-write of Part 74 came some gifts for the broadcaster: clarifications to past rules! The old 720 hour Short Term operation rule is still alive and well...and maybe just a little new and improved. It is in Part 74.24 and is listed below. Also, note that Part 74.25 grants Temporary Conditional Operating Authority while your application is on file with the FCC.