Subject: [NEXTEL-1] CTIA requests a four-week extension of time to file comments in response to the “Supplemental Comments of the Consensus Parties"

From: Marcel <[email-masked]>
Date: Mon, 13 Jan 2003 15:10:51 -0500

Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Improving Public Safety Communications
in the 800 MHz Band ) WT Docket No. 02-55
Consolidating the 900 MHz Industrial/
Land Transportation and Business Pool
Channels

MOTION FOR EXTENSION OF TIME

The Cellular Telecommunications & Internet Association (“CTIA”), pursuant to
Part 1.46 of the Commission’s rules,1 respectfully requests that the Commission grant a
four-week extension of time to file comments in response to the “Supplemental
Comments of the Consensus Parties,” which were filed on December 24, 2002. 2 As
further detailed below, CTIA believes that there is good cause for the Commission to
provide an extension of the comment and reply deadlines specified in the Commission’s
1 47 C.F.R. § 1.46.

2 See Supplemental Comments of Aeronautical Radio, Inc., the American Mobile
Telecommunications Association, the American Petroleum Institute, the Association of
Public-Safety Communications Officials-International, Inc., the Forest Industries
Telecommunications, the Industrial Telecommunications Association, Inc., the
International Association of Chiefs of Police, the International Association of Fire
Chiefs,
Inc., the International Municipal Signal Association, the Major Cities Chiefs Association,

the Major County Sheriffs’ Association, the National Sheriffs’ Association, National
Stone, Sand and Gravel Association, Nextel Communications, Inc., the Personal
Communications Industry Association, and the Taxicab, Limousine and Paratransit
Association, WT Docket No. 02-55 (filed Dec. 24, 2002) (hereinafter “Supplemental
Comments”)..January 3, 2003, Public Notice,3 and therefore requests that the Commission
extend the
comment deadline to March 3, 2003, and the reply comment deadline to March 18, 2003.

The spectrum management issues and proposals raised in this docket are of
critical importance to CTIA’s members, the public safety community and members of the
general public, and the outcome of this proceeding will substantially affect the interests

of all involved stakeholders. CTIA notes that the Supplemental Comments, which were
filed on Christmas Eve, cover approximately 150 pages, including 7 detailed appendices
addressing critical elements of the “Consensus Parties’” plans for funding, relocating 800

MHz incumbents, interference protections and border realignment plans. Analysis of the
comments and appendices by CTIA’s members, expert personnel, and other stakeholders
will take substantial time and resources. Under the current deadline, however, it is
impossible for CTIA’s members to thoroughly review the plan presented in the
Supplemental Comments and provide thorough comments that would assist the

Commission in this critical proceeding.

Granting this Motion would be in the public interest because it would give
commenters sufficient time to address the detailed technical and financial issues raised
by
the Supplemental Comments, and would provide the Commission with a more complete
record upon which to base its decision. Furthermore, grant of this Motion will not
prejudice any other party and will serve the interests of informed decision-making. CTIA
notes that the “Consensus Parties” themselves took 62 days beyond the self-imposed
deadline of October 23, 2002, to file funding information for the “Consensus Plan,” thus
3 See Wireless Telecommunications Bureau Seeks Comment on “Supplemental
Comments of the Consensus Parties” Filed in the 800 MHz Public Safety Interference
Proceeding – WT Docket No. 02-55, Public Notice, DA 03-19 (rel. Jan. 3, 2003).
2.demonstrating that time is not of the essence in what will be a multi-year relocation
process.4 Therefore, it is far better for the public interest to take the modest
additional
time at the outset to provide detailed information that will assist the Commission in
arriving at the best long-term solution.

4 See Comments of Aeronautical Radio, Inc., the American Mobile
Telecommunications Association, the American Petroleum Institute, the Association of
American Railroads; the Association of Public-Safety Communications
Officials-International,
Inc., the Forest Industries Telecommunications, the Industrial
Telecommunications Association, Inc., the International Association of Chiefs of Police,
the International Association of Fire Chiefs, Inc., the International Municipal Signal
Association, the Major Cities Chiefs Association, the Major County Sheriffs’
Association, the National Sheriffs’ Association, National Stone, Sand and Gravel
Association, Nextel Communications, Inc., the Personal Communications Industry
Association, and the Taxicab, Limousine and Paratransit Association, WT Docket No.
02-55, at 10 (filed Sep. 23, 2002) (“We expect to finalize and file with the Commission
these funding arrangements by no later than October 23, 2002.”).

3.4

Respectfully submitted,
/s/ Michael Altschul
CELLULAR TELECOMMUNICATIONS &
INTERNET ASSOCIATION
1250 Connecticut Avenue, N.W.
Suite 800
Washington, D.C. 20036
(202) 785-0081
Michael Altschul
Senior Vice President & General Counsel
Diane Cornell
Vice President for Regulatory Policy
Christopher R. Day
Staff Counsel
Dated: January 13, 2003

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513402335

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