In reply comments to an FCC notice of proposed rulemaking (NPRM) on the 800 MHz band and proposed changes to Part 90 rules, controversy in the industry involves the rules governing priority access to the 800 MHz expansion band (EB) and guard band (GB) spectrum.Public Notice Outlines E9-1-1 Location Accuracy Report Guidance for Carriers
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While not all members supported the Land Mobile Communications Council (LMCC) proposal, particularly with respect to SMRs, the LMCC’s reply comments recommended that all existing 800 MHz incumbents, whether business/industrial land transportation (B/ILT), public safety or SMR should be afforded time-limited priority access to available channels within the EB/GB.
The American Association of State Highway Transportation Officials (AASHTO) said that the LMCC’s proposed language referring to incumbents “in the market” is insufficiently defined. AASHTO proposed defining “in the market,” by borrowing language from Part 90.623, as a 64-kilometer maximum distance from any proposed base station to a licensed or pending one under the same federal registration number.
The Government Wireless Technology & Communications Association (GWTCA) said the LMCC and FCC did not provide an actual definition of “incumbent” or define how the preference would be instituted.
The LMCC offered to work with the FCC in developing protocols that would support the efficient use of the UHF spectrum under consideration in the NPRM. “UHF spectrum that can be assigned on an exclusive basis is simply too scarce to be sequestered, unused by any entity, if effective coordination procedures would permit its deployment,” the LMCC commented.
The LMCC recommended adopting the Central Station Alarm Association’s (CSAA) proposal, which the council said represents a balance between the future spectrum needs of the central station alarm monitoring providers and those of other PLMR constituencies.
In its reply comments, the Enterprise Wireless Alliance (EWA) questioned the claims of several entities with apparent ties to machine-to-machine (M2M) Spectrum Networks, which submitted individual letters opposing any incumbent priority access at 800 MHz. EWA suggested that the FCC seek answers to certain questions about M2M’s purported activities in the 800 MHz band.
Questions posed by EWA included:
• M2M said that it is operating its own network, using 800 MHz and other frequencies. What frequencies are being used under what call signs, and how are the multiple bands integrated?
• Why does M2M need 800 MHz spectrum that is designated for base/mobile, primary voice operation for what appears to be its proposed non-voice, primarily fixed internet of things (IoT) applications?
• Several affiliated M2M entities in comments claimed that they are using M2M’s network. What 800 MHz equipment are M2M’s customers using? EWA said it has not located FCC-certified 800 MHz IoT equipment.
MRFAC specifically addressed the American Association of Railroad (AAR) proposal to allow the use of 30-watt boosters on channels adjacent to and overlapping those used by manufacturers and others. MRFAC said it is concerned that the use of the 30-watt boosters on outer channels in rail yards and terminal areas could cause interference to manufacturing plants and provided an engineering statement.
Other entities that filed reply comments included CSAA, M2M Spectrum, Motorola Solutions, New York Communications Co, the Utilities Technology Council (UTC), Wireless Infrastructure Association (WIA) and Mobile Relay Associates (MRA). The reply comments are here.
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