Enterprise Wireless Insider® Volume 9, Issue 7

Unknown Interference Harms Dealer’s Business

A dealer providing radio sales and rentals was experiencing interference across its entire system, to the point that the dealer could not risk renting radios, and customers were noting that the dealer’s radios simply were not working.  EWA identified possible sources of interference, which the dealer then contacted in an attempt to pinpoint and rectify the issue. None of these leads proved to be the source. The dealer next conducted a spectrum analysis of its entire system in order to determine whether the source of interference might be internal. No such luck. After having conducted a thorough search with no resolution, the dealer asked EWA to forward the matter to the FCC Enforcement Bureau for investigation.

Making the Move to Keep the Peace

A large oil and gas company with operations in 15 states called EWA because it had been contacted by a water supply company advising that its operations were causing interference to the water company’s radio system. The oil and gas company, whose system is some 300 mobile units large, called on EWA to confirm the potential that its system was responsible.  EWA investigated and confirmed that the oil and gas company was the likely source of the co-channel interference with the water supply company. The water supply company has a large service territory using a fleet of 30 mobile units. Recognizing that it could not operate its system effectively at a lower power level, the oil and gas company requested that EWA identify alternative frequencies and file a license modification.  EWA symbolically tips its hat to the oil and gas company for being a good neighbor and “keeping the peace”!
 

FCC Creates Citizens Broadband Radio Service at 3.65 GHz; Rights of Incumbents Unclear

The FCC adopted rules in this proceeding on April 17, creating a Citizens Broadband Radio Service and authorizing advanced spectrum sharing among commercial and federal operators.  It is unknown at this time, how long critical infrastructure information (CII) and other licensees of the 3.65 GHz band that have been merged into this new allocation will have grandfathered rights for their current operations. 

FCC Dismisses Havens Petition for Reconsideration

On April 20, the FCC released a Third Order on Reconsideration dismissing as repetitious a Petition for Reconsideration filed by Warren C. Havens.  In its order, the FCC cautioned Havens against additional filings related to Havens petition to deny captioned applications filed by MariTEL, Inc. and its subsidiaries.

FCC denies Wake Forest Baptist’s Appeal for Reconsideration

On April 20, the FCC released its denial of a petition for reconsideration from Wake Forest Baptist Hospital. The hospital had sought an 800 MHz Expansion Band frequency pair in Region 31, which is not among the regions available for licensing at the moment.

FCC Seeks Comment on Auction Procedures

On April 17, the FCC issued a Public Notice requesting additional comment on matters related to its auction procedures.  In particular, the FCC is seeking input on Designated Entity qualifications that will promote participation by small businesses and other such applicants without creating “unjust enrichment” issues.  (WT 14-170)

FCC Clarifies App Process for PS Expansion Band Licensees

In a Public Notice released on April 10, the FCC clarified its process for accepting applications for expanded coverage or additional channels from public safety licensees that have elected to remain in the 800 MHz Expansion Band (815-816/860-861 MHz).

The process consists of the Public Safety and Homeland Security and the Wireless Telecommunications Bureaus:

• Establishing a date on which eligible entities can begin filing applications for Expansion Band channels in specified regions
• Instructing frequency coordinators to pre-coordinate applications for Expansion Band channels prior to the filing date in order to resolve conflicts

Applications from public safety licensees that chose to remain on Expansion Band channels will be subject to the same process outlined above. Any public safety licensee that needs to expand coverage or add channels in the Expansion Band before the filing date established by the Bureaus may seek a waiver for early access but must demonstrate a compelling reason that it is unable to wait for the filing date to submit.

Nancy Gruen Joins EWA’s Spectrum Operations

Nancy Gruen is now a spectrum advisor with the EWA’s Spectrum Operations department where she will be able to leverage her vast experience and rules knowledge for the benefit of her customers. 

No “Imminent” Action at T-Band

Recent conversations with the FCC indicate that there are no “imminent” plans to introduce rules that would implement the repurposing of the T-Band away from public safety and Industrial/Business for broadband purposes, at least until late 2016 at the earliest.  The FCC must consider several options that would enable it to address the specific directives while taking into consideration the absence of suitable replacement spectrum.        

LMCC to File Comments on 800 MHz Interstitial Channels

As reported in the last Insider, the FCC has adopted a Notice of Proposed Rulemaking to introduce full power, interstitial 12.5 kHz “offset” channels in the 809-817/854-862 MHz band (800 MHz Mid-Band), subject to certain protections designed to safeguard 800 MHz incumbents from interference—in response to a Petition for Rulemaking filed by EWA in 2009. The proposal creates the opportunity for 319 additional voice-grade channels for use by Public Safety, Business/Industrial, General Category, and high-site Specialized Mobile Radio licensees. The LMCC is meeting for the purpose of developing frequency coordination procedures that will accommodate all technologies available for use in this critical spectrum. Comments are due on May 11, and Reply Comments on May 26.

EWA and PDV Present Draft 900 MHz PEBB Rules

Last week, EWA and Pacific DataVision (PDV) met with representatives from API, AAR, UTC and NRTC for the purpose of reviewing proposed rules that would facilitate the EWA/PDV proposal to realign the 900 MHz band to accommodate both a 3/3 MHz broadband opportunity and a 2/2 MHz allocation for narrowband B/ILT and SMR voice and data systems. EWA has pursued this opportunity on behalf of its members because it offers the potential to create a broadband network opportunity dedicated exclusively to business enterprises and critical infrastructure industry entities. Based on the input gathered at this meeting, EWA and PDV will prepare and file the proposed rules with the FCC by the end of the month.

LMCC Volunteers to Develop VRS v Data Telemetry Coordination Procedures

LMCC has volunteered its services to the FCC to develop frequency coordination procedures which will serve to facilitate the use of both vehicular repeater (VRS) and data telemetry systems on six 173 MHz channels that are currently reserved for data telemetry systems only. LMCC member organizations represent users who invest in both types of system technologies, and every Industrial/Business and Public Safety FCC-certified frequency advisory committee is a member of the LMCC, making it the optimum source for developing necessary spectrum management protocols that will protect both types of systems.

In its letter to the FCC requesting this responsibility, filed April 20, the LMCC stated that it “is capable of developing the necessary frequency coordination procedures quickly and with the full support of the organizations whose members use these very different system technologies that must be coordinated intelligently to derive maximum use of this spectrum while minimizing the potential for interference.”

FCC Denies SNG Waiver Requests

On April 13, 2015, the FCC released an Order denying requests for waivers for applications filed by Spectrum Networks Group, LLC (SNG) and several other parties for 900 MHz Business/Industrial/Land/Transportation (B/ILT) Pool channels.  Between October 2013 and January 2014, SNG and the other parties filed a total of 47 applications for 900 MHz B/ILT Pool channels in twenty-two states with the intent to provide wireless services to Part 90 eligibles on a non-common carrier basis.

EWA filed informal objections to these applications, stating that without a waiver granting authority to conduct Specialized Mobile Radio (SMR) service operations, the applications should be dismissed. In its decision, the FCC sided with EWA, stating that the Commission is “reluctant to grant waiver requests that effectively circumvent the Commission’s rulemaking function.” The Order noted that applications involved more than 2,000 channels in approximately 150 of the 186 Basic Economic Areas (BEAs), including the last remaining 900 MHz B/ILT channels in most of the top 10 markets where any channels were still available, and that the primary benefit to using 900 MHz spectrum appeared to be that it would enable SNG to acquire spectrum without going through an auction or purchasing it in the secondary market.  Having concluded that the waiver would undermine the purpose of its rules, the Order suggested that SNG was free to file a Petition for Rulemaking to achieve its desired flexibility.  SNG also has the option of requesting reconsideration of the FCC’s decision.

FACs May Ignore Non-Compliant Wideband Emissions

The FCC recently clarified that frequency coordinators may ignore licenses that list only non-compliant narrowband emission designators during frequency coordination processes that seek 150-470 MHz exclusive use channels to be used within hybrid or centralized trunked systems.  EWA has sought this capability for some time and is pleased to note that the FCC has clarified its position regarding licensees not in compliance with the narrowbanding mandate. This clarification gives EWA and its customers more latitude when seeking exclusive channels.

Yesterday, EWA announced this rule change to members and customers, pointing out the opportunity for dealers to work with non-compliant licensees. For all intents and purposes, these entities no longer have licenses.  EWA offers a report, a standard component of its Premiere Reporting service, which may be of value to wireless system sales and service organizations. Call your spectrum advisor or EWA Customer Service at 800-482-8282 for more information.