EWA, Motorola Solutions Support Streamlining Part 20 Rules
The Enterprise Wireless Alliance urged the FCC to streamline Part 20 rules, via a July NPRM. CTIA also supported the change, which would end the presumption that all applicants and licensees in the services identified in the section intend to…
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operate as commercial mobile radio service (CMRS) providers (see 1610170056). EWA also said the FCC should issue a declaratory ruling clarifying that 800 MHz and 900 MHz specialized mobile radio systems that aren't interconnected with the public switched network can't be classified as CMRS or fall under common-carrier rules. “The Commission is correct that Rule Section 20.9 serves no useful regulatory or public interest purpose,” EWA said in docket 16-240. “The presumptions embodied in it have proven inaccurate as entities other than CMRS operators have made substantial, productive use of certain categories of spectrum identified in that rule. The FCC routinely grants waivers of the presumption upon proper showings, allowing non-CMRS entities to utilize that spectrum, but the waiver process imposes burdens both on the Commission and applicants for no useful purpose.” Motorola Solutions agreed. “As the Commission correctly notes, the services identified in Section 20.9 have evolved significantly over time,” the company commented. Motorola warned the FCC of what it sees as the potential for unintended consequences: “The Commission also should make clear that elimination of Sections 20.7 and 20.9 (as well as adoption of the other technical corrections outlined in the NPRM) will not alter the regulatory classification of or modify the regulatory obligations applicable to current licensees.”