You can coordinate anything you want and hopefully the coordination process and 
back-and-forth negotiation with other coordinators and licensees will take care 
of any issues.  The rules do say that no response to a PCN can be considered an 
agreement or clearance of the proposal.  However, you are also supposed to do 
actual engineering and interference analysis before even coordinating and this 
analysis would have clearly seen the licensed, co-located system.  So your 
coordination exhibit cannot simply ignore the fact that you predict 
interference into another licensed user.  Whether this user responded to the 
PCN or not – he still enjoys first in-place protection afforded by his license.

In the case of a non-operational, licensed system, you should gather proof 
(photos, spectrum analyzer photos, etc.) that the other party is not operating 
and file this with the FCC WTB to get the licenses formally canceled per 
101.65.  This is strongly recommended to protect your interests in-case the 
other user decides to fire his system up or even sell it and transfer the 
license to someone else to operate under the existing license.

There are hundreds if not thousands of records in the ULS database of licensed 
paths that are no longer in operation.  The FCC relies solely on the licensee 
to keep things up-to-date, and if he takes a path down or moves it from one 
location to another without properly removing the old path from the license, 
the FCC and everyone else assumes the old path is still there.  You also have 
the problem of bankruptcy and the debtor-in-possession treating the licenses 
(whether operating or not) as assets.

It’s hard to keep track of all of this but a good competent coordinator should 
be constantly maintaining his own database and keeping track of changes, and 
deletions that he knows about outside of ULS action.  Relying solely on ULS, 
which is known to be incomplete and have numerous errors, omissions and extra 
non-operational data could lead the coordinator to unnecessarily reduce power, 
upgrade antennas or even fail the path completely.


From: Af [mailto:[email protected]] On Behalf Of Forrest Christian (List 
Account)
Sent: Wednesday, March 02, 2016 8:10 PM
To: af
Subject: Re: [AFMUG] Fixed Point to Point Microwave Stations License 
Requirements- Hypothetical


Let me ask another hypothetical here, the answer of which may be part of your 
answer.

If you were able to convince a coordinator to send out pcns for the exact same 
path and frequencies as the existing license,  and no one replied, is it legal 
to complete the license filing and operate on that path?

If ISP B is just refusing to take any action as opposed to actively opposing 
the transfer this might be an option.  Coordinating on different frequencies 
may be another.

But consult a lawyer.   Just a thought to check into.
On Mar 2, 2016 3:00 PM, "cjwstudios" 
<[email protected]<mailto:[email protected]>> wrote:
I have a hypothetical I would appreciate some opinions on, knowing no one is a 
lawyer;
If ISP A acquires ISP B's fixed microwave point to point stations which have 
operating licenses in an asset acquisition, and ISP B refuses to transfer said 
licenses to ISP A, which CFR or ruling governs ISP A's solution?  Since ISP A 
is now the operator of the control point they would be illegally operating the 
point to point stations without assuming them from ISP B, am I correct?
Any rulings, court cases, opinions would be super. Thanks in advance.

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