EWA: Nothing Against TETRA, It’s the FCC
November 30, 2011
Photo courtesy Motorola
Mark Crosby, president and CEO of the Enterprise Wireless Alliance (EWA), said his association’s three filings with the FCC requesting clarification on items related to the commission’s orders on TETRA technology don’t translate to problems with the technology itself.
“All we’re trying to do is to get the FCC to recognize that there are critical frequency coordination and licensing requirements,” Crosby said. “If necessary, EWA is prepared to go back to the commission on clarifications 11 times if it must.”
In its recent clarification order on TETRA’s use in UHF spectrum, the FCC said that frequency coordination is not required for TETRA modification applications if the only proposed change to the station’s technical parameters is the emission bandwidth.
Crosby contends that when a licensee moves to TETRA technology, the emission designator isn’t the only change to the license. The channel bandwidth generally changes as well, which should require frequency coordination. EWA is an FCC-certified frequency advisory committee.
In a narrowbanding order this year, the FCC clarified that if a licensee is changing only the emission designator and nothing else on the license the change didn’t require frequency coordination, and the licensee could make the change itself in the FCC’s Universal Licensing System (ULS) database. But if anything else changes — moving from analog to digital, for instance — the change requires coordination.
“Of course, the emission designator needs to change if a licensee elects to migrate to TETRA technology,” Crosby said. “But a migration to TETRA in the majority of instances will require license changes beyond simple changes to the emission designator. It’s highly unlikely that an incumbent already has an entire system authorized for digital comprised of all-exclusive 25-kilohertz channels operating digital at 25 kilohertz that would permit the incumbent to invest in TETRA and just amend the emission designator.”
In addition to the coordination clarification request, in its latest filing with the FCC Nov. 14, EWA urged the FCC to affirmatively state that applications involving TETRA technology are subject to all applicable Part 90 frequency coordination requirements and that TETRA must be deployed in systems that are using exclusive-use channel designations.
In a Nov. 17 FCC filing, Harris agreed with EWA that the FCC should clarify that applications involving TETRA technology are subject to all applicable Part 90 frequency coordination requirements, including the narrowbanding exemption, and that the FCC should clarify that TETRA can be deployed only in systems exempt from the normal Part 90 monitoring requirements.
In September, the FCC clarified four points
of its original April order on TETRA, which allows the technology to operate in the United States for business, industrial and transport sectors. The technology is not approved for use in the U.S. public-safety spectrum bands.
“It appears EWA is attempting to impose a shared channel constraint on a part of the spectrum in which such a constraint is not required and not justified,” said a TETRA Association response.
Crosby said EWA never intended the TETRA + Critical Communications Association (TCCA) — the group changed its name earlier this month from the previous TETRA Association — to view EWA as an adversary. “In fact, we’re trying to clear this issue up so TETRA customers won’t be in a world of hurt,” he said. “If incumbents attempt to operate TETRA systems in a shared spectrum environment, it’s going to be an interference mess.”
Crosby said licensees with large networks and investment capital for communications system upgrades will consider TETRA as an option. “Large enterprises will certainly review all technology options available to them,” he said. “They always do.”
Because TETRA is a digital technology that promotes efficient use of spectrum, it could be good for the market. “The industry needs spectrum efficient technologies, and TETRA may prove to be a significant contributor to that objective,” Crosby said. “We just need to make sure it’s licensed properly to achieve any success in the marketplace.”
“We remain fully engaged with the FCC’s processes and will comply with the requirements of their waiver order and subsequent clarification,” said Phil Kidner, TCCA CEO. “We would like to remind EWA that TETRA more than meets the FCC’s need to improve spectrum efficiency by providing four channels in 25 kilohertz. As has been well documented in the various submissions to the FCC, TETRA’s adjacent channel performance is better than many technologies already approved for use in the United States. We are confident that experience will demonstrate how well TETRA will perform in a U.S. regulatory environment.”
The National Public Safety Telecommunications Council (NPSTC) opposes TETRA on public-safety channels and asked the FCC to include that prohibition in its Part 90 rules.