NATOA, NACo, NLC File Comments on FCC’s Proposed Rules for Reauction of D Block in 700 MHz Spectrum
NATOA, joined by NACo and NLC today filed Comments in response to the FCC’s Third Further Notice of Proposed Rulemaking with respect to the Re-Auction of the D Block in the 700 MHz Spectrum. The Comments include the following recommendations:- The Commission should apply its proposed changes to interim and final performance requirements only to new entrants to the wireless services industry who lack preexisting infrastructure and experience, but continue to impose the requirements set forward in the Second FNPRM to existing wireless carriers.
- Where the Public Safety Broadband Licensee (PSBL) will incorporate increased transparency and local government involvement, the Commission should allow the PSBL to facilitate a post-auction RFP process to distribute remaining licenses should the regional license option prevail. The Commission, potentially under its authority granted by the Communications Act, should create and administer an expedited appeals process to challenge a denial of priority access to D Block spectrum.
- Local government representation should be added to the composition of the PSBL to ensure local government has a voice in PSBL decisions.
- Any device and application approval process for use on the nationwide public safety broadband network should be designed to maximize the number of options available to public safety entities, and any network management practices considered for the network should be clearly defined and not restrictive on the number of devices and applications offered.
- The public safety network should be made available to infrastructure entities who play a recognized critical role in recovery immediately after an emergency.
- The Commission should not mandate a price for network access, but instead create a price cap that will allow for lower pricing agreements based on current market conditions.
- Finally, the network must be hardened and subject to regular reported testing to ensure operation in virtually all situations.