Subject: [NEXTEL-1] Re: STA for expired license?

From: [email-masked]
Date: Mon, 28 Jul 2003 01:46:31 -0400

-------- Original Message --------
From: Jack Daniel <[email-masked]>
Subject: Re: STA for expired license?

Alan,
Thank God for any "public safety trump card" as you call it. It's saved
a lot of public safety agencies from having to shut dowm and buy new
equipment just because they made an honest error in not renewing timely.

The James Kay's, Nextels and spectrum manglers... whoops 'managers'...
would love to hijack those those channels and warehouse them for months
or years, hoping poor, taxed based agencies will eventually pay ransom
to get them back.

This would be a good sub-topic for your Radio Club talk at the APCO
National.
Tell that audience they don't deserve any extra consideration even if
they are public safety, speculators need these channels. We all know it
more important now days to provide maximum protection to for-profit
spectrum uses, can't auction public safety channels..........yet. 

(big grin)

I have signed up for the Radio Club breakfast but I have to leave early
for a must-do association meeting, so I hope you get on stage fast.
Break a leg.

Jack Daniel
====================================================

[email-masked] wrote:
> 
> Depends on circumstances.  If it's a shared channel, it's usually not
> a problem.  If a new licensee has exclusive use of the channel, but
> not yet on the air, maybe.  If a new licensee is operating and the old
> will interference, odds against.  But then, there's that public safety
> trump card..........
> 
> Alan Tilles
> 

> 
>      From:   RF-ENT <listmember2@r...>
>         Date:  Sat Jul 26, 2003  1:58 pm
>         Subject:  STA for expired license?
> 
> 
> 
>         Q: To allow him to continue to operate while a new
>      license
>         application/coordination is processed, will the FCC grant
> 
>         an STA to the operator of a 450 MHz trunked radio system
>      if
>         through his own negligence he didn't file for renewal of
>         his license?

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Free shipping on all inkjet cartridge & refill kit orders to US & Canada. Low prices up to 80% off. We have your brand: HP, Epson, Lexmark & more.
http://www.c1tracking.com/l.asp?cid=5510
http://us.click.yahoo.com/GHXcIA/n.WGAA/ySSFAA/61FxlB/TM
---------------------------------------------------------------------~->

Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/

---

From: [email-masked]
Date: Mon, 28 Jul 2003 12:31:21 -0400

-------- Original Message --------
   From: [email-masked]
Subject: Re: STA for expired license?

With all due respect, Jack (and you are due much respect), I actually disagree in
many areas, see below:

In a message dated 7/27/2003 11:37:32 PM Eastern Daylight Time,
[email-masked] writes:

> Alan,
>
> Since you do public safety licensing, you know you just can't compare
> the differences in administration of anything , including license
> renewals, between these a private company and governmental agencies.

Actually, I can compare them.  My experience with larger, non-carrier corporations
and public safety agencies is that it is often handled exactly the same way.

>
> Private users often use their licenses for profit and the person in
> control of the licenses lasts for many years.

Not true, at all.  Many of the big corporations that I've worked with over the
years have a revolving door for this responsibility, not by design, but rather
because people move on to other jobs, and licensing is not a full time job for
most (but not all) non-carrier corporations.  That's why we try to bring their
licensing in house, both for corporations and public safety licensees, so that
they don't have to worry with constant training of personnel on this.

>
> In governmental agencies the person who understands the license renewal
> and it's importance has often either left that position when the renewal
> comes due or those who DO know the importance must go through a maze of
> approvals that delays the process.

Often for corps., too.

>
> I agree everyone has the same responsibility under the rules.
> It's the public necessity for undisrupted service that makes public
> safety and critical infrastructure wireless system different.
>
> We can't let thousands of citizens lose protection or have to pay
> millions just because of an administrative error. The guy who dropped
> the ball should be held responsible, not the whole city of state.

But, you haven't addressed how you weigh the competing interests of one public
safety licensee vs. another public safety licensee.  Don't they BOTH have the same
needs?  And, this PS vs. PS issue is what comes up most often (not always) in
these expired license cases.  It RARELY has anything to do with a non-PS licensee.

>
> But I'm talking about common sense and not law, and we all know those
> are often two different things.

I disagree.  I try to teach my kids respect for the law.  If the law isn't a top
priority for Joe Chief of Police, why should it be for my kid?  You're over
simplifying it, making it sound like it's ALWAYS some lowly bureaucrat who is not
an officer who messed up.  Actually, it's often (not always) an officer.  Plus,
the FCC has made it ABUNDANTLY clear that PS agencies get no special treatment on
this issue.  We have publicized this up the wazoo (as has APCO, IMSA, IAFC, etc.
etc.), and most are fine, but others chose to ignore.

>
> I know cities (using OUR money) often have to pay billions in damages
> and legal fees because of the stupid act of one employee so who wins
> when the public suffers needlessly for a harmless error.

HARMLESS?  Don't get me started on THAT one!  That you see this as such a no big
deal thing greatly disturbs me, and quite possibly explains the attitude that some
PS agencies have on their licenses.  Let me ask the PS agencies on the other side
of these disputes if THEY think it was harmless.

>
> I think we may need some additional special consideration for public
> safety and critical infrastructure licensees (primary utilities, urban
> transportation, etc.) to deter the insatiable profit motivated spectrum
> warehousing by for-profit corporations.

This is a HUGE issue that I have with you, Jack, and UTC.  What this does is value
one company's license higher than another's.  At first blush, that might seem
fine, but look at the impact.  Take Racom's SMR System.  It consists of over
10,000 mobile units, 60% of which are public safety (guns and hoses) users, and
20% are utilities.  Aren't THEIR licenses as critical to PS communications as the
County of Blah-Blah?  The same could be said about the SMR systems run by Neal
Ragan, New York Communications, and others which have up to 80% of the users on
the system being public safety (guns and hoses) users.  How about the John Deere
factory in Iowa?  Their Motorola radio system supports an internal fire and rescue
service.  Or Intel, where the internal radio system supports a HazMat crew.  How
about ARINC's system, wh ich is used for air safety.  Aren't THEIR systems worthy
of "special consideration"?  Valuing one license above another, in this context,
is wrong.

OK, so now what we've determined is that EVERYONE is public safety, EVERYONE is
"critical", and EVERYONE deserves special consideration.  So, people need to stop
the "common sense vs. law" talk, and get down to the VERY VERY simple task of
putting a tickler on your calendar reminding you to renew your license, and always
have someone responsibile for responding to governmental correspondence.

>
> But I may be wrong..........
> Jack Daniel

In this case, I believe so.  Now, let's go back to the bar at the Paris Hotel and
develop a system to ensure maximum compliance..........

Alan T.

---

From: [email-masked]
Date: Mon, 28 Jul 2003 12:32:55 -0400

------- Original Message --------
   From: "Todd Ellis" <[email-masked]>
Subject: RE:  STA for expired license?

I have dealt with clients that were several years in arrears on their licensing
efforts.  Some were really bad, but I feel that the Commission is far more
interested in hearing that the licensees (or lack thereof) are REALLY interested
in getting legally licensed rather than throwing them to the enforcement group.
The Commission IS very tired of the paper mills and folks that take your money
FIFTEEN MONTHS in advance and don't even wind up renewing the license.  For those
who have screwed up and lost channels, there's not a lot that can be done aside
from learning from the experience.

One interesting note is that several clients that had expired licenses (and didn't
realize it for a plethora of reasons we'll skip for now) had continued to operate
their equipment.  It's fairly good news if they learn about the licensing problem
from persons OTHER than FCC enforcement or the newly licensed entity who swooped
in and applied for their lost channels.

Occasionally we will see an odd arrangement where we applied for a license and
someone else lost it, and pleaded for the client to get another channel.  This
happened recently for an entity building a statewide network, and miraculously,
through the tireless efforts of Ron Franklin at ITA, we were able to locate two
FB8 replacement channels for the client.  (Yeah, I said FB8 channels.  You CAN get
them).

I know my friends in Gettysburg realize what a pain it is for licenses to lapse
for everyone, but what they really want to hear is how everyone can work together
to solve the problem.  Usually that's the biggest hurdle, and everything else is
downhill…assuming you enjoy spending a few hours, in some cases, playing on the
ULS system…

Todd Ellis