Outstanding Narrowbanding Issues
During a recent meeting among LMCC and FCC representatives, it was reported that non-compliant wideband systems that have a pending waiver request to extend their system compliance deadlines would not have authority to operate the affected wideband systems, pending the outcome of the waiver request after January 1, 2013. The FCC continues to encourage, however, the filing of waiver requests. Representatives from the Wireless Telecommunications Bureau noted that they typically will respond to waiver requests within 24-48 hours. The FCC also recently confirmed that after January 1, 2013, the Fee-Exempt policy/procedures for on-line ULS filing of "Straight" narrowbanding applications will continue. Filers are reminded to check "yes" to the fee exemption question and to include a "Fee Exemption" attachment.
Category:6.25 kHz or Equivalent Technology Only?
We are unsure why Ritron waited until virtually the last minute, but in a “Petition to Delay Implementation …”, Ritron has argued that there are no 6.25 kHz equipment technology standards and that the policy requiring that effective January 1, 2013, all new 150-512 MHz equipment submitted for type-acceptance must be 6.25 kHz or operate at an equivalent efficiency, unfairly disadvantages small vendors like itself with no countervailing public interest benefit. The FCC asked for comments, and subsequently, Icom America opposed and APCO supported the petition. Icom Comments Public Notice
Category:FCC Issues (Perhaps) its Last Narrowbanding Notice
On November 30, the FCC released its latest Public Notice, reminding licensees of the January 1, 2013, narrowbanding deadline. The Notice provided some helpful answers regarding exceptions to the deadline and under what circumstances non-compliant systems may be repaired or replaced. However, the notice did not accurately address the LMCC’s request that effective February 1, frequency advisory committees would not have to consider during spectrum analyses non-compliant wideband systems that did not have either a pending or granted waiver request, or an application on file with a frequency advisory committee (see article above). The discrepancy was brought to the FCC’s attention, and it is anticipated that the FCC will make a decision as soon as possible.
Category:Narrowband Compliance Process Approved by FCC
In response to a request submitted by the Land Mobile Communications Council (LMCC), both the Wireless Telecommunications and Public Safety & Homeland Security Bureaus agreed December 7 that “licensees that have completed narrowbanding, or will complete narrowbanding by the January 1, 2013, deadline, but have not yet had their applications coordinated and will not have had their applications coordinated and submitted to the Commission by the deadline will not be regarded as being in violation of the deadline.” The new FCC-approved process supports narrowbanding objectives and reasonably accommodates licensees that, although perhaps late with their application submittals, presumptively have narrowbanding-compliant equipment in place.
The LMCC membership has agreed that all frequency advisory committees will prepare a list of call signs for which applications have been received requesting necessary system narrowbanding license amendments, and these lists will be submitted electronically to the Commission and to all other frequency advisory committees no later than January 3, 2013.
NSTAR Electric Granted T-Band Waiver
Several years back, NSTAR launched a major upgrade to its legacy communications systems to better serve its utility customers throughout the greater Boston, Massachusetts metropolitan area. Given the scope of the project while also accommodating the FCC’s narrowbanding requirements, the work needed to be conducted in multiple phases. Unfortunately, the implementation and licensing of the third and final phase got caught up in the FCC’s T-Band application suspension debacle earlier this year, and NSTAR’s applications appeared doomed along with the completion of the project. NSTAR filed a waiver request in September seeking reinstatement of its applications.
EWA supported NSTAR’s waiver request questioning the wisdom of imposing a freeze on all spectrum in all T-Band markets almost a decade before the reallocation mandated by the Spectrum Act. EWA also noted that the FCC’s application freeze fails to consider the benefits that accrue to the American public through the use of T-Band spectrum by companies such as NSTAR. Fortunately, in this instance, the FCC agreed that NSTAR’s operations were important, and granted the waiver to “allow NSTAR to improve the reliability of its service offerings and better safeguard its employees.” ORDER
Wireless Clock Waiver Granted – Critical Questions Remain
Under the premise that requiring customers to hold individual licenses “would impose a burden out of proportion to any benefit”, the FCC issued a waiver to American Time & Signal (ATS) that will allow it to define as mobiles for licensing purposes what are actually fixed, perhaps as high as 40-watt, wireless clock systems. EWA had opposed the request as inconsistent with long-standing Part 90 requirements and proper spectrum management. In response to these objections, ATS agreed to license central coordinates and an operating area for each of its customer’s locations on ATS’ own licenses, which the FCC adopted as a requirement for waiver relief. The FCC Order did not address whether these facilities are subject to the normal monitoring requirement; whether this fixed data is secondary on the primary voice channels ATS is using; and how ATS is able to satisfy the FCC’s licensee control requirements as a private carrier mobile only system operator (MO6) as these devices are operated around the country by ATS’s customers. EWA will be raising these outstanding issues with the FCC. ORDER
Category: EWA On Your SideVacated Spectrum in Demand
As reported by EWA earlier this month, The FCC announced via FCC Public Notice DA 12-1839 that FCC-certified frequency coordinators may file applications on January 17, 2013, on behalf of public safety applicants for channels in the 809.5-815/854.5-860 MHz band that have been relinquished by Sprint Nextel in twenty-one (21) non-border NPSPAC regions. Consistent with FCC policies for previously released Sprint Nextel-vacated channels, EWA and other participating frequency advisory committees on December 11 conducted their "pre-coordination" notification process to resolve any potential conflicts.
Beginning January 17, 2013, the FCC-certified frequency coordinators may file applications within ULS on behalf of eligible applicants for the locations released by the Public Notice. Although unlikely given the pre-filing review processes, mutually exclusive applications filed with the FCC will be dismissed. Please contact Ila Dudley at ila.dudley@enterprisewireless.org, 703-797-5125 to learn more about these spectrum opportunities and application processing requirements.
What a Year!
Thank you to all of EWA’s members for the opportunity to represent your interests before the FCC, and to provide you with member services, critical industry news, licensing assistance and spectrum solutions this past year. What an unprecedented year of activity it has been for all us. It is a privilege to assist you.
Category: EWA On Your Side