‘Joint Commenters’ support 800 MHz rebanding

Twenty-four entities described as the Joint Commenters have thrown their support to the Private Wireless Coalition 800 MHz rebanding plan. The names of the entities are listed at the end of this story.

Among the JC are Economic Area licensees that would be required to accept different assignments if the PWC plan is adopted (Motient Communications and Western Communications). Also among JC signatories are North Sight Communications and other EA licensees that would remain with their existing allocations. Finally, the JC includes 800 MH licensees, such as New York Communications, that are experiencing interference and that would need to relocate to new channels.

In a reply comment filed with the FCC in WT Docket No. 02-55 to improve public safety communications in the 800 MHz band and eliminate interference, the JC said that the PWC plan’s greatest strength may be that it doesn’t fully satisfy anyone. “Each party suffers some,” the comment reads.

The JC said that the PWC plan is the least expensive and least burdensome of any rebanding proposal submitted in the proceeding.

The JC’s comment spoke to the notion that under the PWC plan, giving Nextel spectrum in the 2 GHz band amounts to a huge spectrum give-away. “Nextel has paid handsomely for most of the spectrum which it holds, either by paying extremely significant dollars to buy out incumbent licensees and/or by purchasing spectrum in public auctions where any entity could participate,” the JC comment reads.

“A resolution to interference cannot be based merely upon how much Nextel acquired its existing spectrum for, because Nextel played by the rules established at that time by the commissio, just as initial cellular licensees paid little other than application-related fees for their authorizations, or had and additional cost of an FCC hearing which pailes in comparison to the value of that same spectrum today,” the JC wrote.

The JC holds Nextel accountable for the interference it causes. The JC’s members demand compensation for rebanding. But they do not expect Nextel to accommodate licensees whose authorized radio communications facilities are not in operation. They want the FCC to conduct a spectrum audit to smoke out spectrum hoarders.

The JC wants the FCC to ban all cellularized systems in the 851-860 MHz band to prevent a recurrence of interference should licensees in that band contemplate cellularizing their systems.

The JC doesn’t support moving public safety operations to 700 MHz, for several reasons. It wouldn’t solve interference to private systems, many of which have public safety users. If technical restrictions can solve interference to 800 MHz private systems, then similar public safety systems needn’t move. Moving public safety to 700 MHz might increase the potential for interference to private systems if the vacated public safety spectrum were auctioned and then occupied by cellularized systems. And moving public safety to 700 MHz would reduce the size of the 800 MHz equipment market for non-cellularized radios, raising equipment prices for private system users. Finally, separating public safety and private systems into incompatible frequency bands would reduce service, interoperability and affordability gains in systems shared by public safety and non-public safety users.

The JC wants the FCC to apply the following criteria in evaluating the proposals put before it in the 800 MHz proceeding:

1. Does it resolve interference, both short-term and long-germ (with the implementation of new equipment)?

2. Does the plan have a reasonable price tag (or is it designed merely to extract every dollar possible from Nextel)?

3. What is the implementation timing?

4. Is it spectrum-neutral (or potentially a public safety gain without a private wireless loss)?

Signatories to the JC reply comment are:

• Palomar Communications

• Ragan Communications

• Bell Interconnect

• Skyline Communications

• Motient Communications

• Commtronics of Virginia

• WS Electronics

• Western Communications

• G&P Communications

• KLL Wireless

• CNY

• William J. Young

• Pete’s Communications

• Aeronautical Radio

• United Airlines

• Northwest Airlines

• North Sight Communications

• JPJ Electronic Communications

• Sid Richardson Energy Services

• Intel

• New York Communications

• SR Communications Associates

• Communications and Industrial Electronic Corp.

• Wecom