The Federal Communications Commission (FCC) grants broadcast licenses for exclusive coverage areas that are defined by geographic parameters. Historically, the FCC assigned Geographical Service Areas, a circle from the transmit site with a 35 mile radius, to both ITFS and MDS licenses. This licensing model is based on the typical transmission pattern of an omnidirectional antenna, and was well suited to a television model.

In 2004, the FCC decided to auction the unlicensed commercial spectrum in the 2.5 Gigahertz, and at that time, changed the license area for commercial service. The Commission adopted the Basic Trading Area, a model developed by Rand McNally for its Commercial Atlas. The FCC changed the name for 2.5 GHz commercial band to Broadband Radio Service (BRS). Older BRS licenses are GSAs, and newer BRS licenses are BTAs.

This has led to an anomaly. At the current time, the coverage areas for Educational Broadband Service (EBS) licenses and the newer Broadband Radio Service (BRS) licenses are based on different geographical models. Even though the channels from both can be used in the same broadband wireless network, the licensed coverage areas are not the same.

“19. In response to the concern about the protected service areas for MDS (BTAs) and ITFS being different, we must emphasize that the two services have differing purposes and authorization procedures. One is intended primarily to provide educational and cultural development to students enrolled in accredited schools and the authorization is issued to the best qualified applicant, while the other is commercial in nature and is subject to competitive bidding. Furthermore, unlike MDS stations, the protection afforded to ITFS operators is based upon receive sites and protected service area is defined in 47 CFR 74.903. Pursuant to this rule, the protected service area associated with the lease of excess channel capacity will also expand to a circle, 35 miles in radius, centered about the transmitter site of the ITFS stations. We note, however, that in a recent proceeding we adopted a 35-mile protection distance for ITFS receivers, a protection distance that is compatible with many BTAs, [FN18] and with the 35-mile protected service area for MDS stations which are authorized or previously proposed that we have separately adopted today.”

Filing Procedures in the Multipoint Distribution Service and in the Instructional Television Fixed Service, Including Electronic Filing and Competitive Bidding, MM Docket No. 94-131 and PP Docket No. 93-253, FCC 95-230, 60 FR 36524 (July 17, 1995)

The two services (ITFS/EBS and MDS/BRS) have different purposes and authorization procedures. The protected service area afforded to an ITFS station is based upon receive sites. In other words, ITFS is licensed on a “site-specific” basis, rather than by geographical area. The commercial nature of MDS gives rise to a protected service area based on market factors, and country boundaries were used to divide the licensed areas on the basic of economic interdependencies.

Nevertheless, the discrepancy between coverage areas presents problems to operators when channels from the same band are used together in a wireless broadband network. It is likely that the EBS licensed area will be converted or expanded to cover the entire BTA in which it is located when the rules for the upcoming auction of EBS white space are announced. There will always be EBS white space as long as all of the licenses are subject to the 35-mile radius model.