64. One example of an expected change to the methodology is the commercial system base station configuration. In developing the interference calculation methodology for coordination, WG1 performed a basic analysis using a network of base stations placed along a uniform grid. However, it is expected that any coordination will use the actual site locations for planned base station deployments. This raises the question of whether other modifications of the methodology may be needed to provide a more realistic assessment of the interference calculation. With the goal of facilitating a fair and equitable coordination process, should the Commission jointly establish with NTIA minimum requirements for the interference analysis and/or a set of best practices for conducting the engineering analysis? If so, what requirements are needed? Are there additions or improvements to these parameters that should be considered? Are there any other technical requirements or techniques that should be set in this proceeding? Are there established models and methodologies in existing standards or regulatory bodies that could be adopted? Commenters are asked to discuss the pros and cons of the recommended methodology, and provide detailed arguments on any improvements that can be made to the recommended analysis.
65. Coordination Procedures. We seek comment on what coordination procedures would best effectuate the recommendations of the WG1 Final Report. As noted above, the Commission has employed a variety of coordination models in different wireless and satellite services. We seek comment on whether any existing coordination models--or elements of those coordination models--may be applicable to the 1695-1710 MHz band. To the extent that existing models do not or only partially apply, we seek comment on other approaches that address the unique circumstances surrounding Federal/non-Federal sharing in this band. We especially seek comment on any and all issues related to coordination that are expressly mentioned in the WG1 Final Report.
66. Process Initiation. We ask commenters to propose methods by which a licensee can initiate the coordination process. Should we provide any guidance on coordination timelines? Should we set a specific time frame by which licensees are required to initiate the coordination process, i.e., how much advance notice should a licensee provide prior to commencing operations? Should there be time limits established on various phases of the coordination process itself? If a licensee intends to alter operating plans after reaching a coordination agreement, should it have to fully re-coordinate with the applicable Federal agencies? How should the Commission coordinate with NTIA in facilitating an effective coordination procedure, consistent with our respective roles under the Spectrum Act?
67. AWS-1 Precedent. In particular, we seek comment on whether the coordination procedures established for non-Federal licensees to gain early access to adjacent AWS-1 uplink band (1710-1755 MHz) could serve as a model for coordination in the 1695-1710 MHz band. In AWS-1, recognizing the importance of protecting the Federal operations while opening up the spectrum to newly licensed commercial users, the Commission worked closely with NTIA to craft a coordination procedure before the full band transition was completed. Prior to operating, the AWS-1 licensee was required to contact the appropriate Federal agency to get information necessary to perform an interference analysis. The AWS-1 licensee would first perform the interference analysis and then send it to the appropriate designated agency contact for review. At the end of 60 days, if the Federal agency raised no objection, the AWS-1 licensee was permitted to commence operations. NTIA required Federal agencies to cooperate with AWS-1 licensees and provide, within 30 days of a request from an AWS-1 licensee wishing to operate within a coordination zone, site-specific technical information that would allow the licensee to complete the interference analysis. NTIA also required agencies that disapprove of an interference analysis submitted by an AWS-1 licensee to provide the licensee with a detailed rationale for its disapproval. Finally, Federal agencies were required to work in good faith to identify the source of the harmful interference and work with AWS-1 licensees to eliminate or mitigate the interference. Would a similar procedure work here? If so, what exact procedures and timelines would be appropriate? What is the best way to ensure balanced treatment of Federal and non-Federal users' interests? Commenters are asked to provide the reasoning for their suggestions, and to discuss our authority to implement these suggestions, where applicable.
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