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Hello Stanislav, I also had the chance to make a
few more calls to discuss this today and now believe my answer was incorrect
regarding your scenario. Please accept my amendment: Q: Is the following scenario allowed?... A: Yes. Assuming the TVBD confirms its desired channel with a
database prior to transmitting, there is no restriction on the strategy a TVBD may
employ to select the “best” channel for its situation. Specifically,
innovative strategies like yours that implement a more efficient spectrum use
are encouraged. To help me visualize your use
cases I sketched up the attached, both of which I believe are allowed. Hello Chen, I believe Mr. Shellhammer is
correct, in that a TVBD may use any (or none) of the channels it receives from the
database according to whatever strategy it may chose to implement. Best regards, Jesse Caulfield. From: Stanislav Filin
[mailto:sfilin@xxxxxxxxxx] Dear Jesse, Hi
Jesse, Thank
you for the clarification. For
the scenario you mentioned, if the transmitter gets the list of available
channels directly from the authorized database, and in addition it uses the
optimal frequency plan from the non-transmitter as advices to its operation in
TV band, that should be allowed. Please
let me know if I am wrong. Thank you very much again. Best regards Chen SUN National
Institute of Information and Communications Technology (NICT) Email: sun@xxxxxxxxxx
OR csun@xxxxxxxx From: Jesse Caulfield [mailto:caulfield.jesse@xxxxxxxxx] 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 |
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