I was very encouraged last week after reading a blog by Roger Sherman, Chief of the FCC’s Wireless Bureau, on the Commission’s draft report and order to modernize and streamline the rules for cellular licenses in the 800 MHz band.

During the year that the FCC set aside spectrum for the first cellular licenses, Ronald Reagan was President, Lady Diana Spencer married Prince Charles, MTV was launched and video killed the radio star.  A lot can change in 30 years.

When these cellular licenses were first granted, the rules required a great deal of information on each cell site that the licensee used to provide service.  Almost any time the licensee made a change to a cell site, or the equipment on it, new filings had to be prepared by the licensee and processed by the Commission.  Changes like antenna model number, antenna center height, or structure height. And although the Commission later required filings for boundary sites only, the vast majority of these filings made little, if any, change to the service the consumer was receiving.  The paperwork merely reflected changes that are necessary to keep the network running and meeting customer demand.

Since networks are constantly responding to changes in environment (like trees leafing out or the construction of new buildings), as well as customer needs, these filings occurred frequently.  As a side note, the FCC, the FAA and local authorities already have other rules and requirements that apply to tower siting, so some of the tower-specific information that’s filed with cellular changes already exists in other systems.  The current rules are indeed burdensome and can stall progress, especially when the licensee must wait for Commission approval before changes can be made to provide service.

Other commercial wireless services, like PCS, AWS and 700 MHz (which are used to provide similar services that are in the 800 MHz band) were licensed not on a site-by-site basis but on a geographic area basis.  Under the geographic area-based licensing system, the licensee is authorized to construct anywhere within a particular geographic-licensed area, subject to certain technical rules and having the proper tower filings and authorizations.  This system provides licensees the flexibility necessary to respond to the needs of its customers without prior agency approval and further lessens the paperwork burden on licensees as well as the Commission.

We’re pleased that the proposal currently before the Commission will streamline the 800 MHz rules and make the transition from site-by-site to geographic area licensing.  And while some vestiges of site-by-site licensing may still remain in the proposal, those are to be expected when moving from such a complex, 30-year-old licensing regime.

The Commission also has before it a companion item – a proposal to allow for the use of power spectral density (PSD) to measure power in the cellular band.  AT&T filed a petition asking for this change to allow us to deploy long term evolution (LTE) in the cellular band.  This rule change was already made in the PCS, AWS and 700 MHz bands and is urgently needed as carriers are deploying LTE now.

We commend the Commission for taking steps to remove outdated, burdensome rules that hinder the deployment of wireless infrastructure and we look forward to learning more about the Commission’s report and order and further notice.

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