Commenters Nearly Unanimous on Positive Train Control Waiver, PTC-220 Says
NRTC objected, in earlier comments, saying many of its members hold licenses in the 220-222 MHz band, acquired on the secondary market, located close to PTC-220 operations. “NRTC supports the deployment of Positive Train Control technology but is concerned that a unilateral grant of PTC-220’s Waiver Request will unfairly undercut NRTC’s license rights and degrade its ability to expand its system in the future,” it said (http://bit.ly/17ikQxc).
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"NRTC’s concern that it will suffer harmful interference if the Waiver Request is granted is unfounded,” PTC-220 said (http://bit.ly/11CeXsw). “NRTC’s technical analysis relies on a simplistic path loss model and grossly pessimistic assumptions to arrive at unrealistic conclusions about the impact of the Waiver Request. Using the Chicago area as an example, PTC-220 demonstrates that the use of more realistic path loss modeling and noise floor assumptions will result in only about 0.2 percent of the area being subject to coordinations between PTC-220 and other 220 MHz licensees wishing to deploy new stations."
PTC-220 asked the FCC to move forward on the waiver request. “The public interest justifications strongly favor a grant of the Waiver Request. Without such a grant, up to half of PTC-220’s spectrum will remain fallow and it will have to acquire more spectrum on the secondary market,” the group said. “This will mean less spectrum available for short line and commuter railroads. In some areas PTC-220 may be able to build additional sites to increase network capacity, but there are practical limits to such an approach; capacity may still not be sufficient to accommodate non-member railroads; and state, local and tribal governments will be burdened with processing many more tower site approvals."
Only one other group, the Joint Council On Transit Wireless Communication, filed reply comments, and it supported the PTC-220 request. The council is a recently formed organization that represents the transit industry on wireless issues (http://bit.ly/12I8hdw). “While this waiver is intended to benefit the Freight railroads directly as they seek to comply with the FRA regulations regarding implementation of PTC on their freight lines, the commission should be aware that in most urban markets where freight lines travel through and where commuter passenger lines operate, it is common for freight and commuter passenger operators to share tracks,” the council said (http://bit.ly/ZqVNaw). “Freight lines can run on commuter operator dispatched territory, or commuter operators can run on Freight dispatched territory depending on the area and section of track.”