Subject: [NEXTEL-1] ITA On “Radio Frequency Spectrum”

From: [email-masked]
Date: Mon, 19 Apr 2004 02:16:47 -0400

Before the
DEPARTMENT OF COMMERCE
Washington, D.C. 20230

In the Matter of
United States Department of Commerce’s
National Telecommunications and Information
Administration Seeks Comments on Policy  Docket No. 040127027-4027-01
Reforms Relative to the Management of the
National Resource Known As “Radio Frequency  Spectrum”

Comments of Industrial Telecommunications Association, Inc.

 The Industrial Telecommunications Association, Inc. (ITA) hereby
respectfully submits its comments in response to the National
Telecommunications and Information Administration’s (NTIA) Notice of
Inquiry (NOI) in the above-referenced matter.   The NOI solicits
comments on policy recommendations that would facilitate the
implementation of a modernized, comprehensive, national spectrum policy
that would promote efficient spectrum use among public and private
spectrum inhabitants.   First, ITA would like to applaud NTIA’s efforts
to improve the nation’s spectrum management policies, but would like to
note the importance of maintaining adequate interference protection
criteria to incumbent operations.  Furthermore, ITA explains how Private
Land Mobile Radio (PLMR) licensees operate in a spectrally efficient
manner through frequency coordination and engineering practices.

I. Statement of Interest

ITA is a Commission-certified frequency advisory committee coordinating
in excess of 13,000 applications per year on behalf of applicants
seeking Commission authority to operate on a wide-variety of frequency
assignments allocated between 30-900 MHz.

 ITA enjoys the support of a membership including more than 2,100
licensed two-way land mobile radio communications users, private mobile
radio service (PMRS) oriented radio dealer organizations, and the
following trade associations:

  Alliance of Motion Picture and Television Producers
  Aeronautical Radio, Inc.
  National Propane Gas Association

In addition, ITA is affiliated with the following independent market
councils: the Council of Independent Communications Suppliers (CICS),
the Taxicab & Livery Communications Council (TLCC), the Telephone
Maintenance Frequency Advisory Committee (TELFAC), and USMSS, Inc.

ITA’s extensive involvement with the private land mobile industry
expands into many services including: application preparation for public
safety and first responders; coordination and engineering services for
industrial/business users, commercial licensees under Part 90 of the
Commission’s rules, and PMRS radio dealers; protection of petroleum
service users through a contractual agreement with the American
Petroleum Institute; an industry liaison for equipment manufacturers and
end users, as well as band managers and end users; the Commission’s
first line of post-licensing, interference resolution; and various other
services.

II. Background

 On May 29, 2003, the President signed an Executive Memorandum directing
the Department of Commerce to improve spectrum management by modernizing
spectrum policies and developing further incentives for efficient
spectrum use, among other policy objectives.   In an effort to address
these policy objectives, the NTIA released the instant NOI soliciting
comments on the state of America’s spectrum management policies.

III. Discussion

 ITA is encouraged by the steps being taken to develop more cohesive and
modern spectrum management policies; however, ITA stresses the
importance of protecting the rights of incumbents and recognizing the
efficient operations of PLMR licensees while promoting efficient
spectrum use and facilitating spectrum access through new and emerging
technologies.

A. Sound Spectrum Policy Would Protect Incumbent Licensees with
Specifically Defined Interference Protection Criteria

Mandating and enforcing adequate interference protection rules for
incumbent licensees and services will be vital to increasing efficient
spectrum-use and providing incentives for new and emerging technologies.
ITA believes that, through long-range planning with public
participation,  the NTIA and the Federal Communications Commission (FCC)
alike could develop necessary interference protection criteria of
Federal, public safety and private wireless licensees, among others.
Clearly defined spectrum-use rules could not only advance more efficient
use of the spectrum but also encourage further investment by incumbents
and new entrants to the spectrum-use market.  The FCC’s Spectrum Policy
Task Force noted in its November 2002 Report that spectrum rights and
responsibilities of licensees, including protection from harmful
interference, should be clearly defined by the Commission.

As a trade association representing an industry in need of additional
spectrum access, ITA supports the promotion of efficient spectrum use,
but such access should not come at the expense of harmful interference
to incumbent operations.  The NTIA and the FCC must remain cognizant of
the importance of interference-free operations in the private land
mobile industry, including public safety and mission-critical
communications.  Private radio systems are used in every aspect of the
American economy from overseeing the operations of an airport to
protecting the safety of employees at construction sites.  While
reevaluating and modernizing current spectrum management policies, these
critical licensees must have confidence that their current operations
will be protected from harmful interference.

Ironically, unacceptable levels of interference to many PLMR incumbents
would render those licensees’ operations unusable; thus, negating the
intended goals of increasing spectrum efficiency. The rewards gained
from more spectrally efficient operations could be lost in operating
environments overrun with unacceptable interfering devices if rules and
regulations are not clearly defined.  In light of the above, ITA
suggests that these agencies continue to solicit input in the form of
comments from industry to develop further interference-protection
criteria standards for incumbent licensees and services during spectrum
policy reforms.

B. PLMR Spectrum Use Remains Efficient with Spectrum Sharing Through
Frequency Coordination and Engineering Standards

Licensed services with shared licensees are an intrinsically efficient
way in which to operate on spectrum.  In this licensing method, unused
spectrum can be coordinated and used by an eligible entity by simply
applying for a license, through the FCC, to share spectrum with
geographic neighbors.  The vast majority of PLMR licensees utilize
conventional equipment on non-exclusive spectral assignments in a shared
environment.  The channels chosen for their operations are determined by
frequency coordinators based on the co-channel and adjacent channel
incumbents and their operations in the spectral and physical
environment.   Licensees with exclusivity in a shared PLMR service  are
using these authorizations for safety-of-life applications that require
redundant systems and excess capacity in the event of an emergency.
Efficiency in these cases must consider redundancy and excess capacity
as criteria worthy of evaluating the “efficiency” of a system. Thus,
whether shared or exclusive in shared service, PLMR operations by their
nature operate efficiently on the spectrum that has been allocated to
them.

IV. Conclusion

 ITA commends the efforts of the NTIA to seek the input of industry to
develop a complete record in facilitating the modernization of spectrum
management policies.   ITA supports the goal of increasing spectrum
efficiency and encouraging new technologies, but those goals must not be
achieved through the degregation of incumbent operations.  Moreover, ITA
would like to reiterate that the land mobile industry, through the use
of frequency coordination and engineering procedures has and continues
to operate in an efficient manner on shared radio spectrum.

Respectfully Submitted,

By:       /s/ Jeremy Denton

Jeremy Denton

Director, Government Affairs

/s/ Robin Landis

Robin Landis
Regulatory Affairs Assistant

March 18, 2004

http://spectrumreform.ntia.doc.gov/responses/documents/A17-ITA-Docket%20No.%20040127027402701%20ITA%20NOI%20comments.doc

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