Not for the faint of heart
The last time I broached the subject of the pain and suffering that one must endure to secure approval from Industry Canada (IC) as a precondition to receive a 150-470 MHz license from the Federal Communications Commission (FCC)—whether Industrial/Business (I/B) or Public Safety (PS)—the few friends I had in Canada at the time called me saying that I was out of line. So I know up front that I am risking any remaining relationships that I may have north of the border by writing this article. Nevertheless, the process that licensees must follow if they choose to remain in compliance with applicable rules, procedures and treaties is ridiculous at best.
Let’s start with the fact that virtually every single request that is submitted by the FCC to the IC for approval will receive the now infamous “Harmful Interference Anticipated (HIA)” automatic return notice. Simply expect it, as it is the destiny of these applications. There is little accompanying explanation, certainly no recommended technical solutions, and seemingly no hope for success—at least for the channels requested. It doesn’t matter whether there is a Canadian user one mile over the border or operating on the Hudson Bay, an HIA bounce is the norm on the first pass. To improve an application’s chances for initial success, EWA will attempt to select channels where the Canadian incumbents are at least a province away. Of course, this is nearly impossible.
And be sure to never let a license that is located within 75-miles of the Canadian border to expire unless that license has a COSER reference (Canadian Co-channel Serial Coordination System). It doesn’t matter that there were no interference issues ever with anyone in Canada, the inevitable HIA will result and the continued availability of the channel is not guaranteed by any stretch of the imagination. They got you. This also goes for applications that might move the antenna closer to Canada, add a new antenna to provide better coverage, or increase the power. All of these applications are at risk. An “increase” in anything generates a return—and all receive the dreaded HIA notice.
But remember, this is the first required step. You have to give the IC the opportunity to say “no” first. Depending upon the geographic location, sometimes EWA will seek approval of more frequencies than are needed by the applicant, all at the same time hoping that the IC will approve one or two out of the channel batch. Know that this effort is never about accommodating system technologies or promoting spectrum efficiency south of the border. We don’t have that luxury. All spectrum efforts are directed toward securing IC approval for a frequency or frequencies, and any frequency will do—just so long as it is approved by IC.
Step 2 is the same as Step 1. Maybe you light a few candles and conduct a closer review of the Canadian database to make sure that you identify where the closest Canadian operations are located and you remove those channels from any consideration. Simply lowering the power as a potential solution won’t work—a second HIA will result. Actually, the applicant needs the second rejection, as further application submittals send the IC the message that the applicant is serious about its need for spectrum and that the applicant is not going to go away—at least not if EWA is the frequency coordinator. At this point in the process, maybe six months to a year have transpired.
This is when the approval process can now get serious. This is when, and only when, the applicant can provide a Longley-Rice interference study that shows that the potential signal strength to the Canadian incumbent is less than -148 dBw—which, by the way, is at a noise level that only dogs can hear—within a 25-mile radius of the Canadian user’s potential mobile area of operation. Read that several times for a sanity check. I am not making it up. Sometimes the FCC will add comments supporting this third showing, sometime they won’t. Sometimes the IC will concur at this point with this additional engineering showing. Sometimes it won’t. Then, and only then, may the applicant request that the FCC and the IC conduct an actual on-air test (OAT) to verify the results of the Longley-Rice analysis.
This last OAT effort usually succeeds and one only can hope that the licensee by this time—sometimes as long as 18 months or more after the application was initially submitted—hasn’t asked for its money back, returned tickets to a hockey game in Toronto, or simply walked away. Trying to explain this process to an applicant is difficult and rarely understood. “You can’t be serious?” is usually the response. “But we’re public safety.” That doesn’t matter. “But we won’t cause interference as our radio signal doesn’t even reach the border.” That also doesn’t matter.
Securing Canadian clearance is an excessive burden on licensees and entities that sell and service wireless systems to those licensees. It’s not for the faint of heart.
Mark Crosby is the president/CEO of the Enterprise Wireless Alliance.