June 1, 2017 (Herndon, VA) – The current 10-year license term is not in the best interest of business enterprises says the Enterprise Wireless Alliance (EWA) in comments filed today. Most business enterprises using wireless technologies do so for operational communications, to support cost-effective, competitive business practices. These companies, which range in size from international manufacturing companies to small retail organizations, routinely adopt new, more efficient communications technologies or make other changes that may affect their spectrum needs.
To increase the amount of available spectrum and to keep the Federal Communications Commission (FCC) database more accurate than it is today, EWA recommended adopting five-year license terms for Part 90 licenses. The comments were filed in response to a 2010 FCC initiated Notice of Proposed Rulemaking that had as its objective the articulation of “clear, consistent requirements for license renewals and consistent consequences for discontinuance of operation.” In its comments, EWA reaffirmed positions taken in early filings, including its support of the position of the Land Mobile Communications Council (LMCC), but has taken the opportunity of a new filing to refresh the record considering the wide adoption of digital technology by Part 90 licensees. Additional comments include:
- Harmonization of rules for like services is a worthy objective, but a “one-size-fits-all” approach is not in the public interest.
- Site-based licensees must be encouraged to request license renewals for spectrum that is actually in use. The migration to digital technology means that fewer channels are needed to support operations, thereby freeing channels for use by other entities.
- The FCC should not require a Regulatory Compliance Demonstration for site-based private licensees.
- The discontinuance period for wireless, site-based systems, including trunked Specialized Mobile Radio (SMR), should be 180 days, while other Part 90 licenses should remain at 1 year.
- Not all geographic licenses are alike, and they should not be subject to identical rules. The limited bandwidths afforded Part 22 auction licenses makes it exceedingly difficult for licensees to meet post-buildout coverage requirements that are designed for the renewal of a 5, 10, or 20 MHz wide licenses.