LMCC Comments on Creation of Interstitial 12.5 kHz Channels in 800 MHz Band

The Land Mobile Communications Council (“LMCC”), in accordance with Section 1.45 of the Federal Communications Commission (“FCC” or “Commission”) rules, respectfully submits its comments in response to the Notice of Proposed Rulemaking regarding the creation of new, full power, interstitial 12.5 kHz channels in the 809-817/854-862 MHz band (“800 MHz Mid-Band”).1 The NPRM represents an important opportunity for the private land mobile radio (“PLMR”) user community to derive more intensive use of its limited spectrum options.