Groups Comment on FCC’s 700 MHz Rules for P25 CAP Compliance, Vehicular Repeaters, Motorola Petition
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Following are responses from 800 MHz Transition Administrator (TA) Deputy Program Manager Brett Haan to questions regarding how the cost matrices are used and the current pace of rebanding.
MCC: How does the TA use the cost metrics? Is the TA relying too heavily on these metrics?
Haan: The TA’s cost review seeks to ensure that costs in licensees’ agreements are reasonable, prudent and the minimum necessary to provide them with comparable facilities. The metrics are used in the cost review process as guidelines and not fixed thresholds. If there is any uncertainty or there are questions regarding certain costs, the TA requests additional information through the RFI process. Generally, licensees are able to provide the additional information needed to support cost estimates.
MCC: Do you think the cost-metric analyses could be skewed too low because they reflect earlier, smaller systems?
Haan: The cost metrics documents reflect the most recent public-safety agreements, along with any applicable amendments approved by the TA through that date. The published metrics provide several slices of the data — licensee system size based on the number of subscriber units, stage and implementation cost category. The metrics also provide data not only at the median but also at the 25th and 75th percentiles, providing a range of cost information.
With all this taken into account, the metrics used by the TA reflect the overall agreements that have been approved and any related amendments. Considering that the majority of licensees, including the majority of licensees with complex large systems have FRAs, the cost metrics do not reflect only smaller systems that entered into FRAs earlier on in the program.
MCC: What actions is the TA taking to ensure the rebanding process continues to move forward as quickly as possible?
Haan: The TA is monitoring the planning activities of the licensees that do not have an FRA and ensures that the parties negotiate an FRA in a timely manner. In addition, the TA has been scheduling implementation planning sessions (IPS) and interoperability meetings to ensure that licensees account for their interdependencies when they commence physical reconfiguration and develop a regional schedule that keeps the licensees in a region informed of other licensees’ progress. Following the IPS, the TA works with licensees, Sprint and vendors to monitor implementation schedule progress and to identify and mitigate items that may hinder continued progress.
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