Give Motorola proposal more attention in 800 MHz interference proceeding, airtime service companies tell FCC
Four commercial mobile radio system operators with facilities in the 800 and 900 MHz bands have noticed that the FCC singled out for special attention a frequency reallocation plan involved in the commission’s effort to improve public safety radio communications in the 800 MHz band. They want the same attention to be paid to alternative plans.
The FCC designated for public comment a spectrum reallocation plan crafted by signatories to a reply comment submitted to the agency in its WT Docket No. 02-55 proceeding intended to reduce or eliminate interference to public safety radio communications. The signatories call themselves the “Private Wireless Coalition,” and because they reached a consensus among themselves, they called their proposal the “Consensus Plan.” (Related story.)
The FCC asked for comment about the Consensus Plan in a public notice issued Sept. 6. The agency set a Sept. 23 deadline for comments. (Related story.)
The four commercial system operators, Creative Airtime Services, Fisher Wireless Services, FleetTalk Partners and Industrial Wireless Technologies, call themselves the “Joint Commenters.”
The Joint Commenters made their request in a comment filed in response to the Sept. 6 public notice. They characterized the Private Wireless Coalition’s plan as “substantive.” They told the FCC that all substantive plans received during the reply comment cycle were worthy of the special attention afforded by a public notice with a comment period.
The Joint Commenters said that the FCC should seek specific comment on a proposal submitted by Motorola as part of the company’s reply comment in WT Docket No. 02-55. They described Motorola as “an entity whose long-standing involvement in all aspects of the wireless industry offers unique insight into the issues under consideration in this proceeding.”
The Joint Commenters said that they applauded the efforts made by various entities in proposing frequency reallocation plans in their reply comments, and that all those plans deserved thoughtful consideration by the FCC and other interested parties.
“[We] find it surprising, therefore, that the commission has elected to solicit further comment only on the Consensus Plan. That plan has much to recommend it, including the endorsement of Nextel, public safety representatives and representatives of private land mobile radio interests. However, in light of Motorola’s recognized technical expertise as well as its multiple-decade role as a pre-eminent equipment supplier to the public safety, PLMR and commercial mobile radio service industries, its proposal surely warrants careful evaluation as well,” the four airtime service companies told the FCC.
“By identifying only the Consensus Plan in its public notice, the commission may have foreclosed the opportunity to develop the full and complete record its analysis requires. Its invitation may be perceived inadvertently as an indication that the Consensus Plan warrants further consideration while other plans, such as Motorola’s, do not,” the Joint Commenters said.
The Joint Commenters want the FCC to “issue an erratum or otherwise publicly correct the public notice and set a new date on which the FCC will accept comments on the Consensus Plan, the proposal described in Motorola’s reply comment and any other credible interference solution submitted in the reply comments stage.”
The four companies said that they were unaware of proposed solutions other than the Consensus Plan and Motorola’s proposal that were not submitted until the reply comment cycle. But a source close to the Small Business in Telecommunications membership organization said that SBT’s reply comment included a proposed solution. (Related story.)
The Joint Commenters cautioned the FCC that if it did not expand the scope of the Sept. 6 inquiry into proposed interference solutions beyond singling out the Consensus Plan, a future action taken by the agency that might require licensees to migrate their systems to different frequencies “could be undone by a challenge, not to the determination itself, but to the process by which that decision was reached.”