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Following today’s call I have made a few phone calls
and re-reviewed the rules. Following are my answers to some of your questions. Please
know the following represents my own personal interpretations of the rules and
does not represent any form of legal opinion or advice. Q: May a non-transmitting entity (i.e. a computer
software) query a TV Bands database and receive a channel list? A: YES. This is specifically allowed and anticipated according
to the text in 47 CFR 15.713(j)(iii): “it is acceptable for a TV bands database to
distribute lists of available channels by means other than contact with TVBDs
to provide list of channels for operation” Furthermore, there is no restriction on the information a
non-transmitter may request. Specifically and for example, a non-transmitter
may request a spectrum information at any location and for any time (e.g. past/present/future),
as described in 47 CFR 15.715(e): “Database administrators may allow prospective
operators of TV bands devices to query the database and determine whether
there are vacant channels at a particular location.” Note however that Databases are not required to provide
channel lists to a non-transmitting entity. Q: May a transmitting entity (e.g. fixed or mode II
device) provide its channel list to a non-transmitting entity? A: YES. This is not discussed in the rules, however it
was anticipated that channel lists may be collected from transmitters and
analyzed for network planning and management purposes. Q: Is the following scenario allowed? Step 1) A non-transmitter receives a channel list(s) from a Database
to develop an optimal frequency plan. Step 2) The non-transmitter sends an optimal frequency plan
to a transmitter(s) Step 3) A transmitter(s) then communicate with a Database to
verify the “optimal” frequency plan is valid or that a desired
frequency is available A: Most likely NO. The intention is that transmitters
get their channel lists exclusively and directly from an authorized Database. I hope this is helpful to the discussion. Best regards, -- Jesse Caulfield Key Bridge Global LLC 1600 Tysons Blvd., Suite 450 McLean, VA 22102 |