The Wireless Communications Assn. (WCA) filed with the FCC a cons...

of revising its 40-year-old rules governing how the spectrum is used. WCA and 2 education groups already asked the FCC to make some key changes to the July order earlier this year (CD Jan 12 p4). The latest petition is “really the last written major part of the process” that builds on the record in the proceeding, WCA Pres. Andrew Kreig told us. The FCC will now decide whether to change parts of its July order, and Kreig said WCA was “hoping that they would make some of these very important adjustments in their original order that will enable the service to achieve what is intended.” WCA said several petitions filed in the record included proposals that weren’t advanced by WCA but made “eminently good sense.” It said in addition to the rule changes suggested in WCA’s earlier petition, the FCC should adopt a number of other proposals, including: (1) Amend Sec. 27.1221(a) to clarify that the height benchmarking rules are applicable to EBS facilities. (2) Revise Sec. 27.53(1) to clarify that where 2 or more contiguous channels are used as part of the same system, all out-of-band emissions limitations should be measured at the outermost edges of those contiguous channels. WCA said it opposed several of the suggestions filed by other parties in their petitions for reconsideration, including: (1) Use of any geographic area for governing transition other than basic trading areas (BTAs). It also said it believed the deadline for filing initiation plans should be extended until 30 months after the effective date of the elimination of the major economic area (MEA), but the Commission shouldn’t extend it any further. (2) The imposition of any ban on 2-way deployments prior to transition. (3) The proposal to require some, but not all, licensees to reimburse transition costs immediately following the transition. (4) Adoption of the proposed expanded MVPD opt-put or alternative band plan for rural areas. (5) The proposal for reinstatement of the former 15-year limit on the maximum term of an EBS excess capacity lease. (6) The ITFS/2.5 GHz Mobile Wireless Engineering & Development Alliance proposals for Commission micro-management of the 2.5 GHz band. WCA also said the rules adopted in the order to govern the licensing and operation of the J- and K-band guard channels shouldn’t be modified on reconsideration. “Those bands are primarily designed to serve as guardbands between low-power, cellular operation in the LBS/UBS and high-power, high-site operation in the MBS, and the proposed revisions to the governing rules would undermine that purpose,” it said.