What is a PCN and why am I receiving it?

When a party is attempting to license a new microwave point-to-point path or make a significant modification to an existing path the FCC requires that party undertake a frequency coordination activity to demonstrate through analysis of existing systems that no harmful interference will be created. Once this internal study has been completed the system operators of record within a set distance of the proposed path are notified via Prior Coordination Notice (PCN) of the path and are typically given 30 days to review the proposed path's impact on their system(s).

If you receive a PCN that describes a path that you believe will negatively impact your system, you should immediately notify the owner of the proposed system of your concern, and provide your own analysis to support your objection. If you do not respond within the timeframe indicated in the PCN you are assumed to approve the proposed path.

NOTE: Contact information from your license is used when distributing these PCNs. It is very important to keep your contact information current on all licenses to ensure you receive all PCNs that may have an impact on your system(s). If you include an email address in you contact information, ensure that the email is monitored and any spam filters are allowing the PCNs through. The FCC does not charge a fee to update this information when you file an Administrative Update.

Why are PCNs even necessary?

The FCC would like to avoid being in the middle of every path dispute that arises. PCNs provide the applicant and existing system operator(s) an opportunity to mutually resolve any potential causes for harmful interference between their systems prior to an application being filed, thus preventing delays in the application processing itself. Disagreements may arise for many reasons, including:

• Inconsistent reporting and updating of equipment manufacturer names and model numbers to the FCC.
• Incomplete data regarding existing systems in the FCC records. This is particularly an issue with older systems that pre-date the FCC ULS database, but happens even in more recent systems.
• Differences between coordinators on how aggressively they push interference limits and equipment capabilities even though there is a recognized minimum standard to meet.
• Differences in frequency coordination analysis software.

I don't have the resources or tools to check every PCN. What are my options?

There are three different routes you can take but because all situations are unique we will not attempt to recommend any one as better than the others. You should apply your own cost/benefit analysis to determine the best way forward.

• Do nothing. This approach depends upon the assumption that the frequency coordinator has done their job properly and you trust their assertion of no interference. The FCC's rules are in your favor here, as the onus of correcting interference usually lies with the more recent licensee when they first switch on, but tends toward shared responsibility if the interference takes a while to reveal itself. Can you spot a slight degradation in your path in a timely manner?
• Have a second frequency coordinator or path engineer analyze the path(s) in question. This is usually contracted on a per-path or hourly basis, and can be combined with "doing nothing" based on your knowledge of intervening terrain and other mitigating factors. The resulting analysis can be used to block the proposed system if necessary, before equipment is installed and mitigation costs increase.
• Contract for frequency protection. When you sign up for frequency protection the protection provider will receive a copy of each PCN that you normally receive. They will perform an interference analysis on those PCNs and contest any that will have an adverse effect on your operation. These services are usually billed on a per frequency per month basis. As frequency protection is often a side business of frequency coordination, there is a risk that the company providing your protection is also the one representing the party proposing the new path. Ideally, frequency protection should be provided by an independent entity that does not provide frequency coordination and thus does not have a potential conflict of interest.

The PCN system isn't perfect

There are a number of shortcomings with the PCN system:

• As mentioned earlier, if your contact information is out of date you may not receive the PCN distribution.
• It is left to the frequency coordinator to decide who must be notified. Per section 101.3 of the FCC Rules and Regulations, prior coordination is defined as

  "A bilateral process conducted prior to filing applications which includes the distribution of the technical parameters of a proposed radio system to potentially affected parties for their evaluation and timely response."

  Some coordinators choose to interpret "potentially affected parties" to exclude other frequency coordinators. Why? You would have to ask them. We distribute PCNs to all microwave coordinators and to all system operators within the prescribed distance of the proposed path.
• There is little financial burden on the owner of the proposed system. It is not uncommon to see multiple modifications to a PCN issued to correct path data whether due to errors in the original specification or analysis, or in reaction to negative feedback on an earlier release of the PCN. While relatively free of cost to the owner of the proposed system, these modifications can cost PCN recipients as they are faced with repeating their analysis with each release.
• PCNs can be issued to lock up frequencies "reserved for future growth". While such PCNs are allowed under the FCC rules, they are often inadequately advertised, can cause an area to appear more congested than it actually is, and may lead to delays in the coordination process. While there is a provision in the FCC rules to disregard these reservations when no other frequencies are available, applications filed in this manner can be met with significant resistance by the holder of the reservation.
• Frequencies reserved for future growth through the PCN process consume available bandwidth just as if they were constructed, but the FCC receives no licensing income from these frequencies and the end-point tower operators lease no space.
• The layout and format of PCNs differ by issuer, complicating the analysis process if you don't have specialized tools.