EWA Advocates 5-Year License Terms and Renewal Certifications

Acknowledging that there is little expectation that the Federal Communications Commission (FCC) will award additional allocations for site-based licensing, EWA recently filed comments supporting the FCC proposal to require applicants for site-based renewals to certify that the license represents their actual operating system. Inadvertently or intentionally, licensees renew licenses for systems that are not operating or overstate the scope of the system which unnecessarily removes frequencies from the available pool of spectrum that otherwise might be used by other deserving applicants.  

Although not proposed in the Notice of Proposed Rulemaking (NPRM), EWA also urged the Commission to revisit the 10-year license term for site-based Part 90 private land mobile radio (PLMR) licenses, having been convinced that they do more harm than good. When licensees do not proactively update or cancel licenses, incorrect license data remains in the FCC Universal Licensing Service (ULS), which prevents other entities from using available, often vacant spectrum. A 5-year renewal requirement would facilitate the removal of invalid ULS data at an accelerated pace.

Finally, EWA expressed its concerns associated with the FCC’s efforts to “harmonize” renewal showings for all geographic licensees. The proposed Renewal Showing in the NPRM is premised on the assumption that all geographic licensees can and should expand their operations beyond meeting their build-out requirements. While that may be a reasonable expectation for licensees that utilize 5, 10 or 20 MHz of spectrum to offer wireless services to the consumer marketplace over expansive amounts of geography, it is not realistic when a license is authorized only 20, 30, 50 or 125 kHz of bandwidth, typically for use within a single Basic Economic Area (“BEA”). EWA urged the FCC not to treat all geographic licenses as comparable, but to tailor renewal showings based on the specific spectrum and geographic limitations of the various services.

Category: EWA On Your Side