T-Mobile Concerned About Part of Wireless Radio Service Overhaul
T-Mobile raised questions about FCC wireless radio service overhaul proposals. Draft Section 1.949(d)(2) of the rules could be interpreted to require commercial service geographic licensees “may never fall below a final performance requirement in order to take advantage of the…
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safe harbor renewal certification,” the carrier said. T-Mobile said it has a record of exceeding performance requirements after it starts to offer service. “Nevertheless, like all carriers, T-Mobile’s coverage, when considered on a license-by-license basis, may be interrupted in limited areas from time-to-time because of, for example, natural disasters,” the filing said. “Coverage levels for a particular license may temporarily drop below the level necessary to establish compliance with a final performance requirement even though coverage remains strong in the remainder of the market.” T-Mobile also objected to proposed rules that could prohibit licensees from providing the required certification and require submission of “an explanation of the circumstances preventing such a certification and why renewal of the subject license is in the public interest.” The Wireless Bureau launched the record refresh in May (see 1705020064). The filing in docket 10-112 reflects the carrier's discussions with Wireless Bureau staff. The Land Mobile Communications Council, meanwhile, sent a letter urging the FCC to include public safety in its category of licensees subject to the proposed rules on license renewal and discontinuance of operations.