Enterprise Wireless Insider® Volume 8, Issue 3

New Professionals at PSCA

Public Safety Coordination Associates (PSCA) has welcomed Stu Overby to its board of directors and Wendy Jeffres as the Assistant National Frequency Coordinator. Overby comes with over 39 years of experience; a career spanning 27 years at his former position, Senior Director, Spectrum Strategy at Motorola, and 12 years at the Federal Communications Commission. During his FCC tenure, Overby’s experience covered broadcast licensing, field enforcement and mobile spectrum allocation. Jeffres hails from APCO with over 14 years of experience which includes coordination of public safety spectrum and FCC regulatory issues.

PSCA’s Chairman Paul M. Leary stated, "We are extremely pleased and fortunate to have two such experienced and talented people join our organization. PSCA's goal is to provide the fastest, most efficient, and most economical frequency coordination services to all public safety licensees.  Stu and Wendy will certainly help us meet that goal."

EWA works very closely with PSCA in support of its public safety application and frequency coordination requirements.

OSHA Says Tower Deaths Must be Stopped

In a recent announcement, the Occupational Safety and Health (OSHA) division of U.S. Department of Labor noted the significant increase in deaths at communication towers in 2013 and stated that these deaths were preventable, occurring due to a “lack of fall protection.”  It further reminded tower industry employers that it is their responsibility to reduce the occurrence of such incidents and to recognize and prevent workplace hazards. Additional information on protecting workers in communications work can be viewed at http://www.osha.gov/doc/topics/communicationtower/index.html

FCC Process Reform

On February 14, the FCC issued a Public Notice seeking comment on its Report on FCC Process Reform.  The PN explains that “The Report seeks to further the goal of having the agency operate in the most effective, efficient and transparent way possible” and includes recommendations in areas such as improving the efficiency of the FCC’s decision-making process; processing items more quickly and transparently; streamlining agency processes and data collections; and eliminating outdated rules.  EWA intends to participate in this proceeding.  Comments on the Report are due on March 31.

Take Another 60 Days

On February 11, the FCC adopted an Order extending by 60 days, until April 30, the deadline by which Consumer Signal Boosters marketed, distributed or sold must comply with the new technical requirements, although consumers may only operate “legacy” signal boosters with the consent of and upon registration of those boosters with their carrier.  The FCC acknowledged that the complexity of the rules and the Federal Government shutdown delayed finalizing test procedures needed to be conducted before new devices could be certified by the FCC. 

International Tussle Over the 470-698 MHz Band

Members of the FCC’s Advisory Committee for the 2015 World Telecommunication Conference were unable to reach an agreement on designating the 470-698 MHz band as available for either broadcast, or “new mobile broadband applications.” Opposed by broadcast interests and supported by a variety of wireless carriers and equipment vendors, EWA intends to track the issue closely, and may submit a comment on the matter since the future of I/B T-Band frequencies is an open issue in the ongoing FCC rulemaking proceeding. A decision to allow the band to be used for mobile broadband purposes could be viewed as prejudging the outcome of that proceeding.

LMCC To Seek Expansion/Guard Band Access Solution

On February 19, nineteen representatives from member organizations of the Land Mobile Communications Council (LMCC) met with Public Safety and Homeland Security Bureau (PSHSB) and the Wireless Telecommunications Bureau (WTB) staff to discuss FCC rules and proposed frequency coordination procedures applicable to the future filing of applications for 800 MHz Expansion Band (“EB”) and Guard Band (“GB”) spectrum made available as a result of the 800 MHz rebanding proceeding, including a draft Memorandum of Agreement (MOA) developed by the LMCC to avoid instances of mutual exclusivity in the filing of such applications.

In light of concerns expressed by the FCC staff about conformance of the draft MOA with certain FCC rules governing this spectrum, the LMCC attendees decided to seek LMCC agreement to submit a Petition for Rulemaking in this matter.  The proposed Petition would promote prompt and intensive use of these frequencies by limiting eligibility for EB and GB spectrum to incumbent 800 MHz licensees seeking to expand existing system capacity or coverage in a market at least for some period of time. It was suggested that this approach was similar to an industry proposal for the licensing of currently unlicensed Educational Broadband Service spectrum and to the FCC’s previous, limited freeze on Industrial/Business 900 MHz spectrum.

Doesn’t Anybody Know What Time It Is?

American Time & Signal’s (ATS) licenses will eventually get squared away with EWA’s unsolicited assistance. Earlier this year, the FCC ruled that ATS would be permitted to license its product - data based clock mechanisms - at customer premises with an MO6 station class (!) on ATS’s authorization to ease their administrative licensing burden. Fortunately, with EWA’s prodding, the FCC subsequently issued a clarification stating that “[N]othing in the Order suggests that the Division intended to waive any operating rules governing ATS’s customer locations or otherwise modify their status. Consequently, all relevant service rules apply to ATS’s operations to the same extent as if no waiver had been granted ....” With that in mind, EWA took the opportunity to suggest to ATS and the FCC that it would appear that these clock installations are subject to FCC Rule Section 90.235 and, therefore like any other Secondary Fixed Signaling operation, must employ system features to prevent inadvertent, continuous transmissions from unattended transmitters that would risk causing interference to co-channel incumbent operations. In other words, ATS’s customer clock installations are authorized on a secondary, non-interference basis to primary co-channel voice operations.

Subsequently, a review of ATS’s license revealed another critical oversight. EWA noted that virtually every MO6 station listed on WQFW336 shows an “11K2F3E” emission designator which informs anyone paying attention that the systems are utilizing analog voice equipment.  Recognizing that licensing information is inaccurate, EWA requested that the FCC advise ATS to amend its license to reflect the proper data emission designator for its equipment. We are unsure whether that would be 11K2F1D, 11K2F2D, or a data emission designator that is unique to ATS’s equipment FCC type-acceptance, but it certainly is not 11K2F3E.  EWA Informal Request