Enterprise Wireless Insider® Volume 7, Issue 3

Sweeping Changes to Experimental Rules

The FCC adopted what it described as “sweeping changes” to its experimental rules to provide “innovators greater flexibility in how they conduct research and development” including adding three new types of experimental licenses – program experimental, medical testing, and compliance testing – streamlining existing rules while protecting incumbents from interference.  Requests to require more than 30 days prior notice when tests are to be conducted under these new procedures were denied.  FCC Report & Order

Commission Announces Part 22 Auction

Auction 95 has been announced for 5,905 upper and lower band Part 22 paging channels that were either not purchased in the three previous auctions or were recovered by the FCC is scheduled for July 16, 2013.  Further public notices will announce filing deadlines.

A list of available licenses can be found on the FCC’s website, with both spreadsheet and pdf links to Attachment A, Part 1, for full BEAs, and Attachment A - Part 2, for partitioned licenses.

EWA will be communicating with individual members in the coming days on the opportunities available through this auction.

San Diego Told that Spectrum Cupboard is Bare

A waiver request from San Diego Metropolitan Transit System and San Diego Transit Corporation was recently denied because the channel already had been identified as a replacement frequency in two rebanding projects that would be short-spaced to San Diego’s proposed locations. San Diego had requested assignment of a single 800 MHz conventional channel that had been returned to the FCC by the University of California six weeks earlier. The frequency was to be used to expand its Regional Transit Management System.  FCC Order

NTIA Announces $121.5 Million State Planning- Grant Program

The planning–grant program will be overseen by FirstNet and is designed to assist states in planning to be part of the nationwide 700 MHz public safety broadband network, and covers a performance period of three years. Additional information and frequently asked questions regarding the grant can be found here.

Urgent Communications

Narrowbanding Tool - Better Late Than Never

A new FCC "Narrowbanding Process" capability was launched earlier this month, making it easier for licensees to amend their call signs directly online to add or change to narrowband compliant emission designators, without FCC filing fees. EWA has been advised by FCC representatives that this new license modification process will only accept changes to the first three digits of an existing licensed emission designator. In other words, attempts to change from an analog to a digital emission designator will not be possible through this expedited process, and will continue to require evidence of frequency coordination.

Members interested in this new Narrowbanding Tool must call 1-877-480-3201, option 5, for a unique narrowbanding access code that enables processing.

CPNI Reminder

Customer Proprietary Network Information (CPNI) reports are due to the FCC by March 1, 2013. While this is an important Commission initiative required by Congress, it has never been clear whether non-interconnected private carrier systems are absolutely obligated to follow CPNI certifications. As a consequence, some private carriers faithfully file CPNI certifications on March 1st every year, others choose not to on the basis that they are exempt. Multiple requests by EWA for FCC clarification has resulted in only vague answers that have been of no value for those that seek an unambiguous answer. Please see the FCC’s Enforcement Advisory and EWA’s recent article in the Enterprise Wireless Insider publication for more information.

LMCC Developing Best Practices

In response to an FCC request, the LMCC continues to work on drafting a “Best Practices” document intended to facilitate the deployment of analog and digital conventional and trunked systems that are deployed within the shared 150-470 MHz land mobile bands. It is anticipated that a reasonably complete document will be available for the Commission’s consumption by April 1. Recommendations included within these Best Practices are intended to promote, among other objectives, greater awareness among new licensees, sales and service organizations of what newly granted licenses permit and what is not permitted in the way of system operations. Rule requirements, obligations and responsibilities to incumbent operations will also be included. 

Licensed Versus Reality

EWA responded to American Time & Signal’s recent rebuttal noting that it is clear that ATS has unfortunately confused the FCC’s licensing rules with their own product’s operational necessities.  The fact that the FCC waived its rules to allow ATS to license fixed wireless clock mechanisms as mobile-only private carrier systems (MO6s!) as a licensing convenience for relatively high-site, high-power facilities did not magically change their physical characteristics and the application of rules associated with fixed data systems.  In its letter, ATS argued that no clarification of the granted waiver was needed noting that  EWA’s questions and concerns about how these facilities should be treated in the coordination process was irrelevant because the FCC had licensed them as mobiles. If it could only be that easy. EWA’s CEO Mark Crosby blogged about how this ATS issue appears to be an episode from The Twilight Zone.