WPC- 2a BKf Z CG Times#|j=Xw PE37XP",tB^ f ^;C]ddCCCdCCCCddddddddddCCY~~vCN~sk~CCCddCYdYdYCdd88d8ddddJN8ddddYYdYd4dddddCddddddddd8YYYYYY~Y~Y~Y~YC8C8C8C8ddddddddddYdddddsdXdXXXddx|X~d~d|XdddddddC8ddddCdoddd|8|H~d<|8dtddddHHdlLlLlLkd|H|8~ddddddddXXXd~ddkd~ddxCddCCCWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNdddCYQQddddddFddddFCChhd44ddzzdddvooChdF"dhd9dCCzCddoddCdYds]zUvdYYCCCCz~ozoY~NYdYC8YooYdYzsdzdd~YYzozzz~CdzYzzzzCCdddddddzCsdYC\   pxtll\tll@\@\`LHP LaserJet 4M (PCL) rm 332-1HPLA4MPC.PRSXw PE37\f X` hp x (#%'0*,.8135@8:fx6X@`7X@3zH?,+Vz2pPG;6ND,s$2pPG;a$G,',YG\  P6G;Pa$I,',#II4  pG;7jC:, Xj\  P6G;XP7nC:,#Xn4  pG;XW!@(#,9h@\  P6G;hPDisplayWrite 4.0, 4.2, or 5.0XyWrite III Plus 3.52- W<   D4p+V  #2pPG;s$#FEDERAL COMMUNICATIONS COMMISSION`(#(#X WASHINGTON, DC 20554`(#(#X  X<C!#Xj\  P6G; XP# March 29, 1995  aE X }Q #G\  P6G;YP#IN REPLY REFER TO:  X-  Xt4 PRN 1800B3BJB  X X01Í ÍX01Í ÍX Mr. Jim Nabors Miami International Airport Authority 5700 NW 20th Street Miami, FL 33159  X$ -huRe:NEW(FM), Miami, FL huMiami International Airport hu Authority huBPEX941215MA Dear Mr. Nabors: The Commission has under consideration the abovecaptioned application for a new experimental FM noncommercial broadcast station on Channel 228A in Miami, Florida, filed on behalf of the Miami International Airport Authority ("MIAA"). For the reasons stated below, we are returning the application.  X-zV BACKGROUND  X- According to Exhibit A of the application, entitled "Statement of Program Service of Broadcast  X-Applicant," the proposed experimental operation would serve two purposes: (1) "to determine the ability of current FM receivers used in the vicinity of the airport to receive interference free service in areas predicted by the FCC rules to receive interference from two second adjacent collocated FM stations;" and (2) "to enable the traveling public in the vicinity of the airport to receive information regarding airline arrivals and departures and how to best traverse the urban Miami areas safely and in a timely manner." MIAA feels that if the interference tests were successful, they would provide a basis for the Commission to relax the distance separation requirements of 47 C.F.R.  73.207.  X"-   VDISCUSSION  X#-   X$-Experimental Operations Section 74.102 of the Commission's Rules states, in pertinent part, that a license for an experimental broadcast station will be issued for the purposes of carrying on research and experimentation for the development and advancement of new broadcast technology. This new broadcast technology can take the form of equipment, systems, or services which are more")0*0*0*(" extensive than that which currently exists or which require other modes of transmission than can be accomplished by using a licensed broadcast station under an experimental authorization. Pursuant to 47 C.F.R.  74.15(a), such stations are licensed for a one year period only. The license will only be renewed upon a showing of significant experimental progress that sufficiently demonstrates the need to continue the experimental operation. As the word "experimental" implies, any such operation has to be of such a unique nature   that it could only be achieved via this special type of authorization.  XH- The Proposal  X - MIAA's application proposes a facility that would be shortspaced to the following three licensed FM Broadcast stations: (1) WTMI(FM), Channel 226C, Miami, FL; (2) WBGF(FM), Channel 226A, Belle Glade, FL; and (3) WLVE(FM), Channel 230C, Miami Beach, FL. If analyzed under the contour overlap requirements of 47 C.F.R.  73.215(a), the proposed facility would not cause or receive any interference with respect to WBGF. However, under  73.215(a), the proposed facility would both cause and receive interference with respect to WTMI and WLVE. Specifically, the proposed 100 dBu interfering contour would be completely encompassed by the 60 dBu coverage contours of both WTMI and WLVE. Furthermore, the proposed 60 dBu protected contour would partially overlap the 100 dBu interfering contours of both WTMI and  XK-WLVE.<Kx_ X-ԍ Pursuant to 47 C.F.R.  73.215, WTMI must be protected as if it were operating at maximum Class C facilities (100 kW ERP at 600 meters HAAT). However, WLVE is licensed pursuant to  73.215 and is only protected to its actual facilities (100 kW ERP at 307 meters HAAT).< (See attached exhibits.) The application does not include the concurrence of WTMI, WLVE, or WBGF. MIAA recognizes that the application does not comply with the rules and proposes that its experimental nature is intended to demonstrate that no interference would be caused. MIAA suggests that such results would demonstrate that the Commission's interference protection standards are too stringent.  X-    Planned Measurement of Interference  X- The proposal states that measurements would be taken of interference received by various car radios operating with different types of antennas for the purpose of measuring the ability of FM receivers in the area to receive interferencefree service and, potentially, to provide the Commission with a basis for relaxing distance separation requirements. To the extent that the program may be aimed at measuring receiver characteristics, these measurements would more properly be conducted in a laboratory on a controlled basis. In such an environment, tests could be conducted utilizing many different types of receivers in a manner which could be experimentally reproduced and verified. A mobile receiver, such as a car radio, will encounter constantly varying signal strengths from numerous stations, resulting in a continuously changing potential for interference. Due to the unpredictable nature of such interference and the difficulty involved in eliminating it, the Commission has long held that mobile receivers are not protected"!40*(( "  X-from interference. See 47 C.F.R.  73.318(b). It follows then that the proposed program of measuring interference utilizing car radios is unlikely to produce any reliable data with respect to  X-receiver characteristics.   Likewise, this methodology would not be an appropriate means for studying propagation phenomena. To be useful, such measurements must be made with laboratory quality equipment and an exact knowledge of the propagation path, distance, atmospheric conditions, etc. Additionally, because of the statistical nature of FM propagation, such measurements would need to be taken over a period of more than a decade. In short, the scope and caliber of the planned measurements fall far short of those necessary to demonstrate  XH-that  modification of the current spacing rules is appropriate.  X1-   X - Travelers Information  X - The proposal is also aimed at providing travelers information in the airport vicinity. However, the Commission has already established procedures for the operation of travelers information  X -stations in the AM band, 47 C.F.R. 90.242, and MIAA is licensed by the Commission to operate Travelers Information Station WNQM383. This station has been granted waivers to operate with facilities in excess of those normally authorized to a travelers information station. Specifically, it is allowed to operate with 90 watts transmitter power output (TPO) to produce a  Xb-6.0 mV/m signal strength at 1.5 kilometers.b X-ԍ Pursuant to the restrictions  90.242, travelers information stations are limited to 10 watts TPO and a signal of 2.0 mV/m at 1.5 kilometers. Given MIAA's access to an existing travelers information station, it has not shown that operation of a travelers information station in the FM band is necessary to fulfill its public information goals.  X- An Alternative The State of Florida, Department of Management Services, Division of Communications ("the State") is currently operating station WAEM(FM) pursuant to experimental license application  X-BLEX940331KZ.N_b X-ԍ The State filed experimental construction permit application BPEX930513MA on May 13, 1993. That permit was granted on May 18, 1993. The State proceeded to construct the station and filed license application BLEX940331KZ on March 31, 1994. WAEM has been authorized to operate under program test authority since May 20, 1994. The State's continued authority to operate WAEM is currently under study pursuant to an Application for Review filed by the licensee of WMXJ(FM), Pompano Beach, Florida and a staff inquiry letter dated January 27, 1995.N The State's construction permit was granted in part based on a technical  X-program of studying the effect of the highrise Miami urban environment on vertical polarization.  X$-ԍ To some extent that program also proposed to determine the accuracy of the propagation models. However, this was not a factor in the grant of the application. In addition, as part of a stateinitiated program, WAEM would disseminate public safety information to foreign tourists. It is our understanding that WAEM is currently broadcasting"e# 0*((" approximately fifteen minutes of messages in a continuous loop. Since the WAEM programming is of such a short duration, MIAA may wish to contact the State of Florida about the possibility of WAEM broadcasting the information along with its current broadcast  X-messages.  X4-ԍ This suggestion is only for MIAA's information and does not imply any Commission decision regarding the Application for Review filed against the grant of WAEM's construction permit or the operating status of WAEM in general.   X-JV  X-CONCLUSION JV< The facility requested in the instant application is predicted to cause secondadjacent channel interference to two operating FM stations. Furthermore, the proposed measurement program is not sufficient to produce useful technical data. Therefore, we find that MIAA's proposal does not warrant the grant of an experimental authorization. Accordingly, experimental application BPEX940915MA IS HEREBY RETURNED. This action is taken pursuant to 47 C.F.R.  0.283.  X -X  0*,.8135@8: