Industry Groups Ask for 800 MHz Interstitial Rules Changes Before FCC Vote
Monday, October 22, 2018 | Comments

A coalition of industry organizations urged the FCC to revise draft rules on 800 MHz interstitial channels. The groups commented on two items — the placement and currency of the Adjacent Channel Reciprocal Interference Matrix and a recommendation by the Land Mobile Communications Council (LMCC) to use an F(50/50) curve for the interference contour.

The Enterprise Wireless Alliance, Association of Public-Safety Communications Official (APCO) International, Forest Industries Telecommunication, and Utilities Technology Council (UTC) jointly filed the ex parte letter.

In the draft report and order and order, the FCC placed the matrix, developed by the LMCC in 2015, within the body of the rules instead of as an appendix. This action departed from the process used in several recent proceedings that have involved coordination protocols, such as that for vehicular repeater systems.

If the matrix remains within the body of the rules, any change — however minimal — may be made only through a rulemaking proceeding, which can take years.

Further, whether or not the commission accepts the recommendation to remove the matrix from the rules, the coalition urges the FCC to adopt the LMCC’s recommended use of an F(50/50) curve for the interference contour, a factor that will be specified in the rules.

The frequency advisory committees (FACs) that constitute the LMCC represent all users of 800 MHz spectrum, and after careful consideration, determined that an F(50/50) curve, with appropriate derating factors, would allow the use of interstitial channels in areas where spectrum is needed while still providing appropriate protection for adjacent 25-kilohertz bandwidth licensees.

If the FCC chooses to retain the F(50,10) curve, the parties strongly encourage the commission to allow for modification of the matrix before it can be implemented by the 800 MHz FACs because the matrix values are no longer correct because they were based on the LMCC recommendation of use of the F(50/50) curve.

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