Subject: [NEXTEL-1] General Category Coordination: Love Or Money?

From: NEXTEL-1
Date: Fri, 11 Jun 2004 02:18:49 -0400

General Category Coordination: Love Or Money?

Jun 02, 2004

Earlier this year, the Federal Communications Commission released an
instant notice of proposed rulemaking (NPRM) that sought comments on
ways to "streamline and harmonize" specific rule parts (regarding Parts
1, 22, 24, 27 and 90) that are "no longer necessary in the public
interest as a result of meaningful economic competition." The commission
does this from time to time when it is in housekeeping mode or when the
regulatory environment changes.

According to the Industrial Telecommunications Association Inc. (ITA),
which has been representing business-radio and specialized mobile radio
users for decades, some of the proposed rule changes contained in WT
Docket No. 03-264 could worsen the already contentious 800 MHz-band
congestion problem, especially for public-safety users.

ITA's concern centers on the FCC's maintenance of a rule requiring
General Category licensees to undergo frequency coordination before
filing an application for authorization. According to the group, the
Cellular Telecommunications & Internet Association (CTIA) had asked the
commission to dump this long-standing requirement because, according to
CTIA, "General Category channels are subject to competitive bidding and
are authorized by exclusive geographic areas."

General Category channels are home to three different kinds of
business-radio users: SMR operators and customers, conventional trunked
services, and trunked public-safety and industrial/business licensees.
ITA points out that, two years ago, during the last biennial review of
old rules, commission staffers believed "the possible conversion of
existing site-by-site licensed general category frequencies to a
different mode of operation (e.g., from conventional to trunked use),
and the potential shared use environment of the frequencies, makes
[wholesale] elimination of the coordination requirement a concern." What
has changed in those two years, ITA wonders?

Many of the rule changes proposed in this NPRM were the result of ideas
forwarded to the commission at least two years ago, and money appears to
be the reason why some of CTIA's constituents want to see General
Category frequency coordination go the way of all things. The two
biggest business-radio players, Nextel [NXTL] and Southern [SO], would
like to save the cash they now must spend to coordinate in this band.

There is no doubt frequency coordination contributes a lot of money to
ITA's bottom line. The group says it coordinates more than 13,000
applications each year on behalf of applicants that want to be
authorized to operate in the frequency bands spanning 30 MHz to 900 MHz.
However, it apparently isn't the money that's pushing ITA and other
wireless associations that also are FCC-certified coordinators, to ask
that General Category coordination rules remain in place.

ITA agrees that General Category channels are auctionable, but it points
out they are "used extensively by underlying public safety and
industrial/business licensees. These incumbent licensees provide
safety-of-life applications, whether for the public, the radio operator
or employees in a business or industrial setting." The growth of new
services around these channels, which will happen after an auction,
could cause even more interference, ITA says. As such, frequency
coordination continues to be needed, due to what PCIA - The Wireless
Infrastructure Association (PCIA) said in its own comments to the FCC:

"Interference in the 800 MHz band has increased as the result of the
proliferation of 'low site' systems...The elimination of a frequency
coordination requirement for General Category licensees may exacerbate
this problem."

To mitigate what could be the inevitable increase of interference to
public-safety officials using these channels, ITA suggests the
commission "[maintain] the frequency coordination requirement for
site-specific licensees in the 800 MHz General Category pool" for
"shared, site-by-site incumbent licensees." And if the FCC chooses to
throw out its frequency-coordination requirement, ITA asks it to be
"clear that exclusive-use licensees are exempted from frequency
coordination only when such an action does not expand its 22 dBu
contour, as expanding the footprint of its existing operation into a
site-specific incumbent's authorization would run counter to the
commission's rules and intentions for the 800 MHz band."

Of course, if the FCC accepts Nextel's Consensus Plan, all of this will
be moot.

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