Enterprise Wireless Insider, Vol. 11, Issue 7

EWA Advocates 5-Year License Terms and Renewal Certifications

Acknowledging that there is little expectation that the Federal Communications Commission (FCC) will award additional allocations for site-based licensing, EWA recently filed comments supporting the FCC proposal to require applicants for site-based renewals to certify that the license represents their actual operating system. Inadvertently or intentionally, licensees renew licenses for systems that are not operating or overstate the scope of the system which unnecessarily removes frequencies from the available pool of spectrum that otherwise might be used by other deserving applicants.  

Although not proposed in the Notice of Proposed Rulemaking (NPRM), EWA also urged the Commission to revisit the 10-year license term for site-based Part 90 private land mobile radio (PLMR) licenses, having been convinced that they do more harm than good. When licensees do not proactively update or cancel licenses, incorrect license data remains in the FCC Universal Licensing Service (ULS), which prevents other entities from using available, often vacant spectrum. A 5-year renewal requirement would facilitate the removal of invalid ULS data at an accelerated pace.

Finally, EWA expressed its concerns associated with the FCC’s efforts to “harmonize” renewal showings for all geographic licensees. The proposed Renewal Showing in the NPRM is premised on the assumption that all geographic licensees can and should expand their operations beyond meeting their build-out requirements. While that may be a reasonable expectation for licensees that utilize 5, 10 or 20 MHz of spectrum to offer wireless services to the consumer marketplace over expansive amounts of geography, it is not realistic when a license is authorized only 20, 30, 50 or 125 kHz of bandwidth, typically for use within a single Basic Economic Area (“BEA”). EWA urged the FCC not to treat all geographic licenses as comparable, but to tailor renewal showings based on the specific spectrum and geographic limitations of the various services.

Weather Satellites at 460-470 MHz?

The LMCC sent a letter to the Federal Advisory Committee for the 2019 World Radiocommunications Conference (WAC) warning that Resolution 766, which would allow various space agencies to use the 460-470 MHz band on a primary basis for weather satellite communications, could adversely impact more than 100,000 private land mobile radio (PLMR) systems. LMCC made several recommendations to address this concern and intends to participate in the development of rules for and the testing of these satellite operations before any primary satellite usage commences. 

EWA Supports Waiving Certain Regulatory Fees

In its 2017 Notice of Proposed Rulemaking (NPRM) regarding regulatory fees, the FCC has proposed raising the de minimis exemption from $500 to $1,000. It also asks if the de minimis standard should be applied to “multi-year” wireless licenses, which include shared and exclusive-use Private Land Mobile Radio Service (PLMRS) licenses, that are renewed at different times throughout the year. Additionally, and consistent with discussions EWA had with the FCC last year, it is asking whether it should eliminate certain regulatory fee categories entirely, such as Commercial Mobile Radio Service (CMRS) Messaging (paging), the category applicable to most Part 90 and Part 22 CMRS systems. Comments are due on June 22 and Reply Comments on July 7. (MD 17-134; FCC 17-62)

Antenna Structure Registration Procedures Now at EWA’s Website

EWA’s Regulatory Counsel Liz Sachs and colleague, Katherine Patsas Nevitt, have prepared a “Refresher on Antenna Structure Registration Procedures” memo that provides an extremely useful overview of recent changes to FCC rules regarding towers. The document, which provides an overview of FCC rules related to antenna structure registration and when registration is required, has been posted to EWA's website.

“Be Forewarned” Crosby Blog Series Promotes Common-Sense Awareness

A recent series of blog posts from Enterprise Wireless Alliance President Mark Crosby is intended to promote greater awareness about the predatory solicitations that members and their customers may receive from Federal Licensing, Inc., and its affiliated entity Federal License Management.  The solicitations are designed to engender fear and create an illusion that the Federal Government is seeking an immediate response along with fee payments. Federal Licensing and Federal License Management warn of potential fines and license revocations which are pure fantasy, but unfortunately, not recognized as such by many unsuspecting recipients. Advise your customers that such solicitations are entirely bogus, responses are unnecessary, and that these solicitations should be read for amusement purposes only!  Visit “Crosby’s Blog” at EWA’s website to read the series. 

Remembering Ken Knight

Ken Knight, who served as Chairman of the Board of EWA’s predecessor organization “SIRSA” from 1980-1983, and who until 2005, was a member on the Board of Directors of both the Industrial Telecommunications Association and EWA, passed recently after a long illness. “Ken was a true believer in our association’s mission, a friend to all who had the privilege to serve with him on the Board of Directors, and a staunch advocate of the staff, reminding me often that the number one asset of any organization are its faithful employees,” stated Mark Crosby.  Ken, thank you for your friendship, support, contributions, service and the memories. 

How Shall FCC Treat “Twilight Towers”?

In a Notice of Proposed Rulemaking, the FCC is considering how to handle so-called “Twilight Towers,” those constructed between 2001-2005, completed without the now required environmental analysis. One proposal is to exempt them from that requirement and treat them like towers constructed prior to 2001. EWA plans to participate in this proceeding. Comments are due on June 9 and Reply Comments on July 10.  (WT 17-79; FCC 17-38)

Part 95 Rewrite Total and Complete

On May 19, the FCC adopted rules “modernizing” the Part 95 Personal Radio Services Rules, such as General Mobile Radio Service (GMRS), Family Radio Service (FRS,) Multi-Use Radio Service (MURS) and others. It reorganized the entire Part, so virtually every service is affected even if the rules governing it were not substantively modified. The new rules will be effective 30 days after publication in the Federal Register. (WT 10-119; FCC 17-57)

FCC & OSHA Release Communication Tower Best Practices

“Every tower climber death is preventable,” says Federal Communications Commission Chairman Ajit Pai. In an act of prevention, the FCC and the Occupational Safety and Health Administration (OSHA) have released Communication Tower Best Practices, a 22-page booklet. 

The booklet collects best practices gathered from industry stakeholders and participants in the Department of Labor/FCC Joint Workshops on Tower Climber Safety, October 14, 2014 and February 11, 2106. According to the booklet, these “best practices are focused on the ways in which each level in the contracting chain can build a positive culture of safety and accountability,” which is a necessary first step in creating a safer environment for industry employees.