Enterprise Wireless Insider, Volume 13, Issue 16

900 MHz Broadband

While the timing of adoption of a Report and Order in this proceeding is not yet known, activity at the Federal Communications Commission (FCC) suggests that an item will be adopted in the near future. In anticipation of that action, on October 22, the Enterprise Wireless Alliance (EWA) and Anterix entered into an agreement under which EWA will assist in the process of facilitating 900 MHz incumbent transition services on behalf of Anterix. In this capacity, EWA will engage with 900 MHz incumbents to reconfigure spectrum assignments to conform with the anticipated realigned band plan.

On October 9, the Wireless Telecommunications Bureau (WTB) released an Order in which it modified the 900 MHz licensing freeze to allow incumbents to relocate out of the broadband segment and exchange channels on a 1:1 basis for channels in the band segments that will remain designated for narrowband operations. The Order stated that this greater flexibility will not disrupt the spectrum landscape or jeopardize the future availability of the 900 MHz band. Licensees that elect to exchange their channels will be required to vacate their channels in the broadband segment within 180 days after their modification application is granted. 

EWA Files Comments on Transition to Electronic Filing

• Exempted classes of users must begin filing applications electronically, and the six-month period proposed in the NPRM should provide ample time for these parties to switch to an electronic filing process; 
• Pleadings related to applications filed in the Universal Licensing System (ULS) and in the Antenna Structure Registration (ASR) system should be submitted electronically; 
• The FCC should update the ULS to permit electronic filing of subleases, leases contingent on assignments, two-step transactions, and authorizations for Special Temporary Authority (STAs) in certain market-based services as the manual filing of sublease applications discourages more extensive use of secondary market opportunities which is contrary to FCC and Congressional objectives; 
• All applicants, licensees and other parties that use the FCC’s wireless electronic systems for any type of filing should be required to provide one “primary” e-mail address to be used for all official communications and should be required to keep that e-mail addresses current; and   
• The FCC should cease mailing hard copies of authorizations upon request from licensee and instead encourage electronic download of authorizations from the ULS and ASR system and send other routine correspondence — dismissal letters, return letters, cancellation letters, termination letters, as well as notices of upcoming construction and renewal deadlines  — by e-mail rather than through the United States Postal Service. 

IIoT Coalition Takes Positions on Spectrum Access

• CBRS: The Coalition is opposed to allowing the proposed Cellular Market Area (CMA)-level bidding in major markets, effectively combinatorial bidding, which is an option favored by the carriers that had wanted PAL licenses auctioned in larger than county-sized licenses. Comments are due on October 28. The Coalition anticipates filing Reply Comments on November 12.  (AU 19-214) 
• Spectrum Access by Small and Rural Carriers: The Coalition intends to submit an ex parte filing urging the FCC to expand eligibility under whatever rules are adopted to include private enterprise entities and to apply build-out requirements for those entities that more accurately reflect their operating requirements. EWA and members have provided the Coalition with specific use case examples of why these entities need greater access to spectrum and how they would use it.  

Senators Reintroduce Legislation to Repeal T-Band Auction Mandate

The 800 MHz Rebanding End Is in Sight

On October 25, the FCC adopted an “Order and Sixth Further Notice of Proposed Rulemaking” in the 800 MHz rebanding proceeding. The action is described as “FCC Acts to Accelerate the Successful Completion of the 800 MHz Rebanding Process.” The Public Notice announcing the action states that over 2,000 licensees have been moved to new channels in the band with only 19 licensees remaining to be relocated. It explains that the Order will streamline certain rules and procedures to expedite completion of the process while the NPRM seeks comment on eliminating certain TA responsibilities to help conclude the program. (WT 02-55)

FCC Reverses Initium Novum Grant

After Initum Novum, LLC provided a less than fully responsive reply to an FCC request that they clarify their eligibility as a central station provider, the FCC rescinded its grant of authorization and returned the applications to pending status. EWA filed a letter on October 18 reminding the FCC that Initium Novum had not answered all of the FCC’s questions raised in their return letter and urged them to take no further action until the applicant responds accordingly. Depending on what happens with these applications, TMA may open another filing window for the two channels claimed by Initium Novum at each of 13 sites from Chicago to Boston.