The Enterprise Wireless Alliance (EWA) submitted comments in support of a pending 800 MHz waiver request filed by Arizona Public Service Company (APSC). APSC, a current 800 MHz licensee, has requested waivers of the long-standing 800 MHz freeze in the Mexican border regions and for early access to Expansion Band spectrum (860 MHz) for use in a new, statewide, 57-site, digital Project 25 system. As described in APSC’s waiver request, their current system had reached its end of life and is no longer supported by its vendor. APSC requests two new 800 MHz Business/Industrial Land Transportation (B/ILT) channels at each location, some of which are Expansion Band channels, in addition to reusing current 800 MHz channels throughout the system. APSC has committed to surrendering channels not needed once the cutover to the new system is completed and successful, which will be made available to other licensees.
EWA supports the waiver request, as APSC has no reasonable alternative to its spectrum requirements. EWA strongly supports time-limited incumbent priority access to B/ILT Expansion Band channels; the APSC waiver request exemplifies the need for this access.