41
ROBERT J. BUTLER HARRY F. COLE ANNE GOODWIN CRUMP DONALD J. EVANS PAUL J. FELDMAN KEVIN M. GOLDBERG FRANK R. JAZZO M. SCOTT JOHNSON DANIEL A. KIRKPATRICK MITCHELL LAZARUS CHENG-YI LIU STEPHEN T. LOVELADY JONATHAN R. MARKMAN SUSAN A. MARSHALL HARRY C. MARTIN MICHELLE A. McCLURE MATTHEW H. McCORMICK FRANCISCO R. MONTERO RAYMOND J. QUIANZON DAVINA SASHKIN PETER TANNENWALD JAMES U. TROUP KATHLEEN VICTORY HOWARD M. WEISS * NOT ADMITTED IN VIRGINIA 1300 NORTH 17th STREET, 11th FLOOR ARLINGTON, VIRGINIA 22209 OFFICE: (703) 812-0400 FAX: (703) 812-0486 www.fhhlaw.com www.commlawblog.com October 24, 2014 RETIRED MEMBERS VINCENT J. CURTIS, JR. RICHARD HILDRETH GEORGE PETRUTSAS JAMES P. RILEY OF COUNSEL THOMAS J. DOUGHERTY, JR. ROBERT M. GURSS* KATHRYN A. KLEIMAN TONY S. LEE ROBERT J. SCHILL LAURA A. STEFANI* RICHARD F. SWIFT MITCHELL LAZARUS (703) 812-0400 LAZARUS@FHHLAW.COM Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: WT Docket No. 10-153, Amendment of Part 101 to Facilitate Wireless Backhaul Ex Parte Communication Dear Ms. Dortch: On behalf of the National Spectrum Management Association (NSMA) 1 , pursuant to Section 1.1206(b)(1) of the Commission’s Rules, I am electronically filing this written ex parte communication in the above-referenced docket. NSMA requests the Commission’s assistance in the correction of ULS database errors. We believe an FCC Public Notice, as discussed below, would greatly facilitate improvement in ULS database accuracy and as a result increase the efficiency and accuracy of frequency coordination among multiple services. The Broadcast Auxiliary Services (BAS)-Fixed Service (FS) Committee of Working Group 3, Coordination Procedures, of the National Spectrum Management Association (NSMA WG3) has been working since 2010 to develop guidelines for coordination of sharing 7 and 13 GHz Part 74 TV Broadcast 1 The NSMA is a voluntary international association of microwave radio/wireless and satellite frequency coordinators, licensees, manufacturers and regulators. Established in 1984, the Association provides a forum to develop industry guidelines for efficient use and management of the frequency spectrum by the wireless telecommunications community. NSMA provides a linkage between government regulations and industry practice by developing recommendations that streamline and standardize procedures used by the frequency coordination community. FLETCHER, HEALD & HILDRETH, P.L.C.

Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

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Page 1: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

ROBERT J. BUTLER HARRY F. COLE ANNE GOODWIN CRUMP DONALD J. EVANS PAUL J. FELDMAN KEVIN M. GOLDBERG FRANK R. JAZZO M. SCOTT JOHNSON DANIEL A. KIRKPATRICK MITCHELL LAZARUS CHENG-YI LIU STEPHEN T. LOVELADY JONATHAN R. MARKMAN SUSAN A. MARSHALL HARRY C. MARTIN MICHELLE A. McCLURE MATTHEW H. McCORMICK FRANCISCO R. MONTERO RAYMOND J. QUIANZON DAVINA SASHKIN PETER TANNENWALD JAMES U. TROUP KATHLEEN VICTORY HOWARD M. WEISS * NOT ADMITTED IN VIRGINIA

1300 NORTH 17th STREET, 11th FLOOR ARLINGTON, VIRGINIA 22209

OFFICE: (703) 812-0400

FAX: (703) 812-0486 www.fhhlaw.com

www.commlawblog.com

October 24, 2014

RETIRED MEMBERS

VINCENT J. CURTIS, JR. RICHARD HILDRETH GEORGE PETRUTSAS

JAMES P. RILEY

OF COUNSEL THOMAS J. DOUGHERTY, JR.

ROBERT M. GURSS* KATHRYN A. KLEIMAN

TONY S. LEE ROBERT J. SCHILL

LAURA A. STEFANI* RICHARD F. SWIFT

MITCHELL LAZARUS (703) 812-0400

[email protected]

Marlene H. Dortch, SecretaryFederal Communications Commission445 12th Street, S.W. Washington, DC 20554

Re: WT Docket No. 10-153, Amendment of Part 101 to Facilitate Wireless Backhaul Ex Parte Communication

Dear Ms. Dortch:

On behalf of the National Spectrum Management Association (NSMA)1, pursuant to Section 1.1206(b)(1) of the Commission’s Rules, I am electronically filing this written ex parte communication in the above-referenced docket.

NSMA requests the Commission’s assistance in the correction of ULS database errors. We believe an FCC Public Notice, as discussed below, would greatly facilitate improvement in ULS database accuracy and as a result increase the efficiency and accuracy of frequency coordination among multiple services.

The Broadcast Auxiliary Services (BAS)-Fixed Service (FS) Committee of Working Group 3, Coordination Procedures, of the National Spectrum Management Association (NSMA WG3) has been working since 2010 to develop guidelines for coordination of sharing 7 and 13 GHz Part 74 TV Broadcast

1 The NSMA is a voluntary international association of microwave radio/wireless and satellite frequency coordinators, licensees, manufacturers and regulators. Established in 1984, the Association provides a forum to develop industry guidelines for efficient use and management of the frequency spectrum by the wireless telecommunications community. NSMA provides a linkage between government regulations and industry practice by developing recommendations that streamline and standardize procedures used by the frequency coordination community.

FLETCHER, HEALD & HILDRETH, P.L.C.

Page 2: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Marlene H. Dortch, Secretary October 24, 2014

Page 2

Auxiliary Service (BAS)/Part 78 Cable Television Relay Service (CARS) spectrum with Part 101 Fixed Service (FS) stations.2 The sharing arrangement was created in the WT Docket 10-153 rulemaking, effective October 27, 2011.3

An issue of growing concern for FS-BAS sharing is protecting fixed-link Part 74 stations with missing receive-end data in ULS. Effective protection of incumbent stations requires that accurate technical parameters be available in the Commission’s databases for use in interference calculations. NSMA WG3 suspects the missing data is the result of the conversion process that required manual transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown over 200 fixed-link TV BAS licenses that have a transmitting antenna bearing that does not match the calculated bearing for the coordinates of record.5

While progress has been made with persuading TV BAS licensees that have missing fixed-link information to file applications providing this missing data, NSMA believes that it would be helpful if the Commission were to issue a new public notice, again advising TV BAS fixed-link licensees of the need to ensure that their information is both complete and accurate.6 With FS links sharing the 7 and 13 GHz TV

2 This effort is in cooperation with representatives of the National Association of Broadcasters (NAB), the Society of Broadcast Engineers, Inc. (SBE), and Engineers for the Integrity of Broadcast Auxiliary Service Spectrum (EIBASS).

3 Use of Microwave for Wireless Backhaul, Report and Order, Further Notice of Proposed Rulemaking, and Memorandum Opinion and Order, 26 FCC Rcd 11614 at ¶¶ 9-34 (2011) (effective Oct.27, 2011.)

4 The missing data was originally thought to have been because versions of FCC Form 313 earlier than August 1981 did not require fixed-link TV BAS stations to report their receive-end coordinates, receive-end site elevation, receive-end antenna make/model, or receive-end antenna height. However, most of the 7 GHz TV BAS fixed-link records and 13 GHz TV BAS fixed-link records with missing receive-end data were authorized after 1981. NSMA WG3 now believes that the primary reason for the missing data was the transferring of Form 313 information to the Universal Licensing System (ULS), which apparently required the legacy Form 313 data to be manually converted.

5 This recent analysis also reveals that most of the TV BAS fixed-link stations with missing receive-end coordinates have a “license converted” August, 1999, entry in their “history” field, and the vast majority of these records are for stations authorized after 1981, when receive-end data had to have been reported. The attached documents KRU72, WME861, and WLP763 provide examples of issues encountered.

6 This would also be an opportunity to provide a warning that, in the event a properly coordinated newcomer FS link becomes operational and is found to cause or receive harmful interference involving an existing but inaccurately licensed TV BAS or CARS fixed link, the Commission may decide that the TV BAS or CARS fixed link must make corrective modifications, and not the newcomer FS station.

Page 3: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Marlene H. Dortch, Secretary October 24, 2014

Page 3

BAS bands, and basing their frequency coordination studies only on what is in the ULS (and COALS, for 13 GHz CARS links), and often with no local BAS coordinator familiarity with broadcast sites or “historical” BAS/CARS frequency usage, the accuracy of the ULS records has heightened importance. Given that the primary cause for the missing data appears to be internal data processing, NSMA suggests that the updated notice not require archival documentation that receive-end information once existed; that is, it should be sufficient that the receive-end information is now missing. Many fixed-link BAS licensees do not have a copy of the original application filed decades earlier. If an ownership change has occurred (sometimes multiple ownership changes), a copy of an original application filed years earlier is again unlikely to be available. NSMA WG3 also suggests that applications filed solely to provide missing data or correct data when no physical change to the path is involved be exempt from the transmitting antenna azimuth correction limit of ±1°, and any filing fees if possible.

REGULATORY BACKGROUND

In an October 16, 2003, Order to the ET Docket 01-75 rulemaking, intended to update and, where possible, harmonize the Part 74 BAS rules with the Part 101 FS rules, the Commission recognized the missing fixed-link receive-end data problem.7 To encourage licensees with missing receive-end data to add that information, that Order stated that it would be Commission policy to allow applications to add missing receive-end data, without a prior coordination notice (PCN) exhibit, if a showing that the missing receive-end data was the result of using an early version of Form 313 that did not ask for this information, or if receive-end information was previously licensed or provided in an application to the Commission.8

Additionally, the calculated revised azimuth based on the revised receive-end coordinates must match within ±1° of the transmitting antenna azimuth of record (this has always been required information). NSMA notes that Section 1.929(d)(1)(ix) of the Commission’s rules, now applicable to both services, defines a change in the azimuth of a fixed-link’s transmitting antenna of greater than ±1° as a major change. Although a May 7, 1999, Commission Public Notice regarding the problem of inaccurate fixed-link BAS records was previously issued,9 that was fifteen years ago. (A copy of the notice is attached).

REQUEST

NSMA WG3 requests the Commission send notification letters to all 7 and 13 GHz TV BAS and CARS fixed-link licensees with a “license converted” entry in their ULS history section and any of the following:

7 Revisions to Broadcast Auxiliary Service Rules in Part 74, Order, 18 FCC Rcd 21134 at ¶ 3 (Office of Engineering and Technology 2003).

8 Id. at ¶ 13.

9 Wireless Telecommunications Bureau Makes Broadcast Auxiliary Radio Station License Databases Available for Review Prior to ULS Implementation, Public Notice (released May 7, 1999) (attached).

Page 4: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Marlene H. Dortch, Secretary October 24, 2014

Page 4

1. missing receive-end data (coordinates, site elevation, receive antenna make/model, and receive antenna height);

2. receive-end coordinates identical to the transmit-end coordinates;

3. coordinates inconsistent with the transmitting antenna azimuth of record;

4. path lengths of less than 3 km or greater than 161 km.

This set of licenses would not include stations that are at a location entirely different from their licensed location; that is, stations that have relocated their links without prior authorization, and also those stations with no change in their emission designator, except xxxF8W for xxxF9W. To be clear, the NSMA does not condone unauthorized path moves, and is not proposing an amnesty, de facto or otherwise, for stations in this situation.

NSMA requests that applications filed solely to provide missing data or correct data when no physical change to the path is involved be exempt from the transmitting antenna azimuth correction limit of ±1° and any filing fees so as to promote a higher participation rate. Similarly, notwithstanding a recent Notice of Apparent Liability that proposed a forfeiture in part for operating facilities at variance with BAS authorizations,10 we request that licensees filing solely to provide missing data or to correct data be granted amnesty from enforcement actions. Otherwise, the Midessa Television NAL will drive participation to near zero. We suggest that the public interest in a complete and correct coordination database justifies the Commission’s overlooking offenses that relate solely to past filing errors and omissions.

Should a properly coordinated newcomer FS link become operational and it is determined to cause or receive harmful interference involving an existing, but inaccurately licensed TV BAS or CARS fixed link, the Commission may decide that the TV BAS or CARS fixed link must make corrective modifications, and not the newcomer FS station. The NSMA recommends a corollary Enforcement Advisory be issued by the Commission’s Enforcement Bureau to clarify its position on this matter.11

10 Midessa Television Limited Partnership, Notice of Apparent Liability for Forfeiture, File No. EB-SED-14-00016720, FCC 14-159 (released Oct. 14, 2014).

11 Examples of other advisories are at http://transition.fcc.gov/eb/Enforcement_Advisories/Welcome.html.

Page 5: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Marlene H. Dortch, Secretary October 24, 2014

Page 5

CONCLUSION

The NSMA believes that an FCC policy allowing BAS licensees to correct their records would be fair and beneficial for all spectrum users. NSMA is interested in meeting with Commission staff to discuss this matter further.

Respectfully submitted,

Mitchell LazarusCounsel for the National Spectrum Management Association

cc: Stephen Buenzow by e-mail: [email protected] John Schauble by e-mail: [email protected] John Leibovitz by e-mail: [email protected]

Blaise Scinto by e-mail: [email protected] Williams, NAB by e-mail: [email protected]

Dennis Wallace, SBE by e-mail: [email protected] Ericksen, EIBASS by e-mail: [email protected] Meyer, NSMA by e-mail: [email protected]

Attachments

Page 6: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

ATTACHMENT

May 7, 1999 Public Notice

Page 7: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

10/9/14, 6:52 PM

Page 1 of 3http://transition.fcc.gov/Bureaus/Wireless/Public_Notices/1999/pnwl9111.txt

1 News media information 202 / 418-0500 Fax-On-Demand 202 / 418-2830 Internet: http://www.fcc.gov ftp.fcc.gov 1 PUBLIC NOTICE

Federal Communications Commission 445 12th St., S.W. Washington, D.C. 20554

Released: May 7, 1999

WIRELESS TELECOMMUNICATIONS BUREAU MAKES BROADCAST AUXILIARY RADIO STATION LICENSE DATABASES AVAILABLE FOR REVIEW PRIOR TO ULS IMPLEMENTATION

This notice instructs licensees in the following services on how to access and reviewthe WirelessTelecommunications Bureau's licensing database and how to submit corrections if necessary:

Low Power and Remote Pick Up Broadcast Auxiliary Aural and Television Microwave Broadcast Auxiliary

The Bureau is developing a Universal Licensing System (ULS) to combine 11 separatedatabases andprovide greater efficiencies in the entire licensing process. This system will providethe public with electronicfiling as well as online querying and mapping capabilities. In order to maximize thebenefits of these tools,licensing data must be current and accurate. Prior to transferring licensing data fromour existing databasesinto the ULS, we are making these databases available via the Internet so those licenseesmay review thedata.

How to access the databases. Licensees may access the databases via the Internet athttp://www.fcc.gov/wtb/database_info.html. Licensees may review a database online onecall sign at a time,or download an entire database for analysis on the user's computer. Both the online searchand the databasefiles contain only current authorizations. Each licensee should confirm that alladministrative and technicaldata shown in the database is correct and that its operating parameters are consistentwith those provided byits license.

To query licenses, click on "Search the Wireless Databases Online" and use the GeneralMenu Reports toretrieve license data.

To download an entire database, click on "Download the Wireless Databases". There are twofiles of

Page 8: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

10/9/14, 6:52 PM

Page 2 of 3http://transition.fcc.gov/Bureaus/Wireless/Public_Notices/1999/pnwl9111.txt

Microwave authorizations (micro1.zip and micro2.zip) and five files of Land Mobileauthorizations(WTBgrnt1.zip through WTBgrnt5.zip). Some of the database files are very large.A_SIZES.txt fileprovides information on the approximate site of each database in megabytes. A definitionof the SYBASEtable structure is provided in the WTBread.txt, micro1.txt, and micro2.txt files. Fortechnical supportconcerning these files, you may contact Technical Support by e-mail at [email protected] orby phone at(202) 414-1250 between the hours of 8 AM and 6 PM EST. -over-

How to submit corrections. Licensees may notify the Bureau of database errorsinformally. Inthose instances where there is no record of the license in the database, or where site,frequency, or technicaldata is missing or incorrect, licensees should submit a copy of the station authorizationor a copy of theoriginal application for authorization and any subsequent applications for modification ofthe license. Anydocumentation should clearly indicate the data that is missing from the licensing databaseor the correctionsthat are required. Wherever possible, copies of applications should reflect the FCCstamped receipt date. Toensure that the Bureau has ample time to take timely corrective action prior to conversionof the data to theULS, corrections must be received in the Bureau by July 1, 1999.

Where to submit corrections. Corrections should be mailed to:

Federal Communications Commission Wireless Telecommunications Bureau Information Technology Division 1270 Fairfield Road Gettysburg, PA 17325-7245

ATTN: Broadcast Auxiliary Database Corrections

Questions may be directed to Melissa Hower at (717) 338-2544 or by e-mail [email protected].

NOTICE TO INDIVIDUALS REQUIRED BY THE PRIVACY ACT OF 1974 AND THE PAPERWORK REDUCTION ACT OF 1995

We have estimated that each response to this collection of information will take anaverage of 30 minutes per response. Ourestimate includes the time to read instructions, look through existing records, gather andmaintain required data, and complete andreview the response. If you have any questions concerning this estimate, or how we canimprove the collection of information andreduce the burden it causes you, please write to the Federal Communications Commission,AMD-PERM, Washington, DC 20554,Paperwork Reduction Project (3060-0827). We will also accept your comments via electronicmail at [email protected].

Page 9: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

10/9/14, 6:52 PM

Page 3 of 3http://transition.fcc.gov/Bureaus/Wireless/Public_Notices/1999/pnwl9111.txt

You are not required to respond to a collection of information sponsored by the Federalgovernment, and the government may notconduct or sponsor this collection, unless we provide you with this notice and display acurrently valid OMB control number. Thiscollection of information has been assigned an OMB control number of 3060-0827.

The FCC is authorized under the Communications Act of 1934, as amended, to collect theinformation requested in this form. Wewill use this information to update the Commission's licensing databases.

This notice is required by the Privacy Act of 1974, Public Law 93-579, December 31, 1974,5 USC Section 552a(e)(3) and thePaperwork Reduction Act of 1995, Public Law 104-13, October 1, 1995, 44 USC 3507.

-FCC-

Page 10: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

ATTACHMENT

KRU72

Page 11: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Reference CopyCall SignKRU72

LICENSEE: NBC TELEMUNDO LICENSE LLC

File Number

Radio ServiceTS - TV Studio Transmitter Link

FCC Registration Number (FRN): 0019509470

NBC TELEMUNDO LICENSE LLC300 NEW JERSEY AVE, N.W. SUITE 700WASHINGTON, DC 20001

RADIO STATION AUTHORIZATION

Wireless Telecommunications Bureau

SMSA Station ClassFXO

LOCATION

Fixed Location Address or Area of Operation:39 INDUSTRIAL AVECity: HASBROUCK HEIGHTS County: BERGEN State: NJ

Federal Communications Commission

Expiration Date06-01-2015

Effective Date04-01-2011

Grant Date12-31-1991

Print Date

Loc No. Location Name Latitude Longitude ElevationAntenna StructureRegistration No.

001 40-50-57.3 N 074-04-17.5 W 1.5002 40-42-43.3 N 074-00-47.5 W

Frequency(MHz)

Tol(%)

EmissionDesig

EIRP(dBm)

ConstrDate

PathNo

Seg EmitLocNo

Ant Hgt(m)

Gain(dBi)

Beam (deg)

POL AZIM(deg)

RecLocNo

RecCallSignReflector

Ht(m)xWd(m)

FREQUENCY PATHS

7075.0- 25M0F9W 109.300 001 0011 6.1 0027100.0

Waivers/Conditions:

The Facility ID of the Associated Broadcast Parent Station for this license is 73333.

Conditions:Pursuant to §309(h) of the Communications Act of 1934, as amended, 47 U.S.C. §309(h), this license is subject to the following conditions: This license shall not vest in the licensee any right to operate the station nor any right in the use of the frequencies designated in the license beyond the term thereof nor in any other manner than authorized herein. Neither the license nor the right granted thereunder shall be assigned or otherwise transferred in violation of the Communications Act of 1934, as amended. See 47 U.S.C. § 310(d). This license is subject in terms to the right of use or control conferred by §706 ofthe Communications Act of 1934, as amended. See 47 U.S.C. §606.

FCC 601-MAugust 2007Page 1 of 1

REFERENCE COPYThis is not an official FCC license. It is a record of public information contained in the FCC's licensing database on the date that this reference copy was generated. In cases where FCC rules require the presentation, posting, or display of an FCC license, this document may not be used in place of an official FCC license.

B8

WNJU(TV), D36 (V47), Linden, NJApplication specifiedan EIRP of 5,888watts, or 67.7 dBm.Further, themaximum EIRP for 7GHz is 85 dBm.

VPOL wasspecified but nowmissing

162°T wasspecified but nowmissing

Antenna gain of36.4 dBi wasspecified but nowmissing

HPBW of 2.5° wasspecified, but nowmissing

NAD83 coordinates,converted from NAD27coordinates onapplication

This license was canceled on 1-31-2014, because the path is no longer in use. However, itremains an example of ULS data loss.

Page 12: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

FCC Home | Search | Updates | E-Filing | Initiatives | For Consumers | Find People

Universal Licensing SystemFCC > WTB > ULS > Online Systems > License Search FCC Site Map

TV Studio Transmitter Link License - KRU72 - NBC TELEMUNDO LICENSE LLC

HistoryNew Search Refine Search Return to Results Printable Page Reference Copy Map License

Call Sign KRU72 Radio Service TS - TV Studio Transmitter Link

Return to Admin

History

04/22/2011 FRN Association email sent: ULS email

04/06/2011 Action PN Generated

04/02/2011 Authorization Printed

04/01/2011 License Modified

04/01/2011 Administrative Update Applied

03/31/2011 Application receipt email sent: ULS email

02/09/2011 Action PN Generated

02/05/2011 Authorization Printed

02/03/2011 Authorization Printed

02/02/2011 License Modified

11/04/2009 Administrative Update Applied

11/03/2009 Application receipt email sent: CORES email

06/04/2008 Action PN Generated

05/31/2008 Authorization Printed

05/30/2008 License Modified

05/14/2008 Action PN Generated

05/08/2008 Authorization Printed

05/07/2008 License Modified

04/29/2008 FRN Re-association email sent: CORES email

02/06/2008 Action PN Generated

02/02/2008 Authorization Printed

02/01/2008 License Renewed

03/06/2007 Authorization Printed

03/05/2007 Internal Correction Applied

03/05/2007 Internal Duplicate Requested

03/05/2007 Internal Correction Applied

01/10/2003 License Status Set to Expired

08/13/1999 License Converted

08/14/1998 Internal Correction Applied

08/13/1999 License Converted

Page 13: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

August 1981 Form 313

Page 14: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 15: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 16: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

ATTACHMENT

WME861

Page 17: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Reference CopyCall Sign

WME861

LICENSEE: LIN LICENSE COMPANY, LLC

File Number0005662737Radio Service

TT - TV Translator Relay

FCC Registration Number (FRN): 0012638094

LIN LICENSE COMPANY, LLCONE WEST EXCHANGE STREET SUITE 5APROVIDENCE, RI 02903

RADIO STATION AUTHORIZATION

Wireless Telecommunications Bureau

SMSA Station ClassFXO

LOCATION

Fixed Location Address or Area of Operation:6.5 MI SECity: PE ELL County: LEWIS State: WA

Federal Communications Commission

Expiration Date02-01-2015

Effective Date02-23-2013

Grant Date08-27-1993

Print Date 02-23-2013

Loc No. Location Name Latitude Longitude ElevationAntenna StructureRegistration No.

001 46-29-20.3 N 123-12-55.4 W 947.9002 46-27-39.3 N 123-33-02.5 W 864.1

Frequency(MHz)

Tol(%)

EmissionDesig

EIRP(dBm)

ConstrDate

PathNo

Seg EmitLocNo

Ant Hgt(m)

Gain(dBi)

Beam (deg)

POL AZIM(deg)

RecLocNo

RecCallSignReflector

Ht(m)xWd(m)

FREQUENCY PATHS

7050.0- 25M0F9W 001 0011 13.7 0027075.0

Waivers/Conditions:

The Facility ID of the Associated Broadcast Parent Station for this license is 35374.

Conditions:Pursuant to §309(h) of the Communications Act of 1934, as amended, 47 U.S.C. §309(h), this license is subject to the following conditions: This license shall not vest in the licensee any right to operate the station nor any right in the use of the frequencies designated in the license beyond the term thereof nor in any other manner than authorized herein. Neither the license nor the right granted thereunder shall be assigned or otherwise transferred in violation of the Communications Act of 1934, as amended. See 47 U.S.C. § 310(d). This license is subject in terms to the right of use or control conferred by §706 ofthe Communications Act of 1934, as amended. See 47 U.S.C. §606.

FCC 601-MAugust 2007Page 1 of 2

REFERENCE COPYThis is not an official FCC license. It is a record of public information contained in the FCC's licensing database on the date that this reference copy was generated. In cases where FCC rules require the presentation, posting, or display of an FCC license, this document may not be used in place of an official FCC license.

K34DC-D, D34, Astoria, ORre-broadcasting KOIN(TV), D40 (V06), Portland, OR

B8

polarization (V)was reported butnow missing

Azimuth (264°T)was reported butnow missing(calculated azimuthis 263.2°T)

EIRP of 14,130watts (71.5 dBm)was reported butnow missing

antenna gain (40.0dBi) was reportedbut now missing

beamwidth (1.7°)was reported butnow missing

NAD83 coordinates,converted from NAD27coordinates onapplication

Page 18: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Reference CopyWaivers/Conditions:

WAIVER OF SECTION 74.661 IS GRANTED PROVIDED THIS RELAY STATION USES TYPE ACCEPTED NON-HETRODYNE EQUIPMENT WHICH WILL MAINTAIN THE CARRIER FREQUENCY TO WITHIN 0.005% OF THE ASSIGNED FREQUENCY (FAC ID 35374)

FCC 601-MAugust 2007Page 2 of 2

File Number: 0005662737 Print Date: 02-23-2013Call Sign: WME861

Licensee Name: LIN LICENSE COMPANY, LLC

Page 19: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

FCC Home | Search | Updates | E-Filing | Initiatives | For Consumers | Find People

Universal Licensing SystemFCC > WTB > ULS > Online Systems > License Search FCC Site Map

TV Translator Relay License - WME861 - LIN LICENSE COMPANY, LLC

HistoryNew Search Refine Search Return to Results Printable Page Reference Copy Map License

Call Sign WME861 Radio Service TT - TV Translator Relay

Return to Admin

History

02/23/2013 Administrative Update Applied

02/22/2013 Application receipt email sent: CORES email

10/24/2012 Action PN Generated

10/23/2012 FRN Association email sent: CORES email

10/23/2012 FRN Association email sent: CORES email

10/23/2012 Authorization Printed

10/20/2012 License Modified

01/12/2011 Action PN Generated

01/06/2011 Authorization Printed

01/05/2011 License Modified

04/01/2010 Application Receipt Letter sent

04/01/2010 Administrative Update Applied

03/31/2010 Application receipt email failed: ULS email

03/31/2010 Application receipt email sent: ULS email

03/30/2010 FRN Association Letter sent

03/29/2010 FRN Association email failed: ULS email

03/29/2010 FRN Association email sent: ULS email

03/24/2010 Action PN Generated

03/17/2010 Authorization Printed

03/16/2010 License Modified

10/14/2009 Action PN Generated

10/08/2009 Authorization Printed

10/07/2009 Action PN Generated

10/07/2009 License Modified

10/03/2009 Authorization Printed

10/02/2009 License Modified

08/19/2009 Action PN Generated

08/13/2009 Authorization Printed

08/12/2009 License Modified

Page 20: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

11/14/2007 Action PN Generated

11/08/2007 Authorization Printed

11/07/2007 Action PN Generated

11/07/2007 License Modified

11/02/2007 Authorization Printed

11/01/2007 License Renewed

09/20/2006 Action PN Generated

09/16/2006 Authorization Printed

09/16/2006 Authorization Printed

09/15/2006 License Modified

08/10/2006 FRN Disassociation email sent: CORES email

08/09/2006 FRN Disassociation email failed: ULS email

08/09/2006 FRN Disassociation email sent: ULS email

07/27/2006 FRN Disassociation email sent: CORES email

07/26/2006 FRN Disassociation email failed: ULS email

07/26/2006 FRN Disassociation email sent: ULS email

05/23/2006 FRN Disassociation email sent: CORES email

05/22/2006 FRN Disassociation email failed: ULS email

05/22/2006 FRN Disassociation email sent: ULS email

04/12/2006 Action PN Generated

04/08/2006 Authorization Printed

04/08/2006 Authorization Printed

04/07/2006 License Modified

02/15/2006 Action PN Generated

02/08/2006 Action PN Generated

02/07/2006 Authorization Printed

02/07/2006 Authorization Printed

02/06/2006 License Modified

02/01/2006 Authorization Printed

02/01/2006 Authorization Printed

01/31/2006 License Modified

01/03/2006 FRN Re-association email sent: ULS email

10/13/2004 Action PN Generated

10/05/2004 Authorization Printed

10/05/2004 Authorization Printed

10/04/2004 License Modified

09/29/2004 Action PN Generated

09/25/2004 Authorization Printed

09/25/2004 Authorization Printed

09/24/2004 License Modified

09/22/2004 Action PN Generated

09/15/2004 Authorization Printed

09/15/2004 Authorization Printed

Page 21: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

09/14/2004 License Modified

04/21/2004 Action PN Generated

04/17/2004 Authorization Printed

04/17/2004 Authorization Printed

04/15/2004 License Modified

01/29/2003 Action PN Generated

01/22/2003 Authorization Printed

01/21/2003 License Modified

08/11/2001 Administrative Update Applied

02/25/2000 Authorization Printed

02/24/2000 Internal Correction Applied

08/14/1999 License Converted

06/29/1999 Internal Correction Applied

09/08/1998 Internal Correction Applied

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08/14/1999 License Converted

Page 22: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 23: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 24: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 25: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 26: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

November 1989 edition of Form 313

Page 27: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 28: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 29: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 30: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

ATTACHMENT

WLP763

Page 31: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Reference CopyCall SignWLP763

LICENSEE: KCETLINK

File Number

Radio ServiceTT - TV Translator Relay

FCC Registration Number (FRN): 0001529213

KCETLINK2900 WEST ALAMEDA AVE.BURBANK, CA 91505

RADIO STATION AUTHORIZATION

Wireless Telecommunications Bureau

SMSA Station ClassFXO

LOCATION

Fixed Location Address or Area of Operation:SOLEDAD MTN.City: MOJAVE County: KERN State: CA

Federal Communications Commission

Expiration Date12-01-2006

Effective Date04-17-2012

Grant Date07-31-1990

Print Date

Loc No. Location Name Latitude Longitude ElevationAntenna StructureRegistration No.

001 34-58-44.9 N 118-10-05.2 W 922.0

Frequency(MHz)

Tol(%)

EmissionDesig

EIRP(dBm)

ConstrDate

PathNo

Seg EmitLocNo

Ant Hgt(m)

Gain(dBi)

Beam (deg)

POL AZIM(deg)

RecLocNo

RecCallSignReflector

Ht(m)xWd(m)

FREQUENCY PATHS

V 38.06875.0- 25M0F9W 001 0011 7.6 1.0 0016900.0

Waivers/Conditions:

The Facility ID of the Associated Broadcast Parent Station for this license is 13058.

The license term is concurrent with the parent station licensed with FAC ID 13058

Conditions:Pursuant to §309(h) of the Communications Act of 1934, as amended, 47 U.S.C. §309(h), this license is subject to the following conditions: This license shall not vest in the licensee any right to operate the station nor any right in the use of the frequencies designated in the license beyond the term thereof nor in any other manner than authorized herein. Neither the license nor the right granted thereunder shall be assigned or otherwise transferred in violation of the Communications Act of 1934, as amended. See 47 U.S.C. § 310(d). This license is subject in terms to the right of use or control conferred by §706 of the Communications Act of 1934, as amended. See 47 U.S.C. §606.

FCC 601-MAugust 2007Page 1 of 2

REFERENCE COPYThis is not an official FCC license. It is a record of public information contained in the FCC's licensing database on the date that this reference copy was generated. In cases where FCC rules require the presentation, posting, or display of an FCC license, this document may not be used in place of an official FCC license.

KCET, D28 (V28), Los Angeles, CA

B1

original application reported EIRP as 72.3dBm but this data is now missing

original application reported RX-endcoordinates and antenna height but this datais now missing

Soledad Mountain to Laurel Mountain

original application reported TXantenna gain as 41.9 dBi but thisdata is now missing

Page 32: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

Reference CopyWaivers/Conditions:

The license term is concurrent with the parent station licensed with FAC ID 13058.

FCC 601-MAugust 2007Page 2 of 2

File Number: Print Date: Call Sign: WLP763

Licensee Name: KCETLINK

Page 33: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

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TV Translator Relay License - WLP763 - KCETLINK

HistoryNew Search Refine Search Return to Results Printable Page Reference Copy Map License

Call Sign WLP763 Radio Service TT - TV Translator Relay

Return to Admin

History

03/14/2014 Application receipt email sent: CORES email

03/05/2014 FRN Association email sent: CORES email

01/23/2013 Action PN Generated

01/17/2013 Authorization Printed

01/16/2013 License Modified

04/27/2012 FRN Association email sent: CORES email

04/25/2012 Action PN Generated

04/18/2012 Authorization Printed

04/17/2012 Administrative Update Applied

04/17/2012 License Modified

04/13/2012 Application receipt email sent: CORES email

04/02/2003 Action PN Generated

03/28/2003 Authorization Printed

03/27/2003 License Modified

01/29/2003 Action PN Generated

01/22/2003 Authorization Printed

01/21/2003 License Modified

08/14/1999 License Converted

11/09/1998 Internal Correction Applied

09/11/1998 Internal Correction Applied

ULS Help ULS Glossary - FAQ - Online Help - Technical Support - Licensing Support

ULS Online Systems CORES - ULS Online Filing - License Search - Application Search - Archive License Search

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08/14/1999 License Converted

Page 34: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 35: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 36: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 37: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 38: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

34-58-44.9 N, 118-10-05.3 W, NAD83

35-28-47.9 N, 117-41-02.2 W, NAD83

6.6 dB line/splitterloss

Page 39: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown

matches topo;bracketing contourlines are 3,020 and3,040 feet AMSL

Page 40: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown
Page 41: Federal Communications Commission 445 12th Street, S.W. · transfer of information from Form 313 to the Universal Licensing System (ULS).4 As evidence, a recent analysis has shown