CREATING WIRELESS POSSIBILITIES 2016 ANNUAL REPORT
OUR MISSION To assist enterprise business users, wireless sales/service providers, technology vendors and manufacturers in the deployment of wireless communications solutions that promotes corporate productivity in the enterprise wireless space.
ON THE COVER
The map of the United States illustrates a few major projects of the nearly 10,000 transactions for which EWA provided spectrum engineering, consulting or frequency coordination during 2016. Below is a summary of the projects depicted on the map.
700 MHz spectrum acquisition brokered through SEI, Inc. See story on page 7.
Sale of 220 MHz spectrum by SEI, Inc., a wholly owned subsidiary of EWA.
Secured Special Temporary Authority (STA) for a UHF system for a weekend concert festival.
Frequency coordination and licensing services for the Multiple Address Systems (MAS) band for an energy logistics company.
Spectrum engineering, frequency coordination and licensing services for a 470-512 MHz (T-Band) trunked system for a private carrier.
Secured STAs and permanent authority for UHF spectrum for a manufacturing and electronics company.
Spectrum engineering, frequency coordination and licensing services for a 470-512 MHz (T-Band) trunked system for a private carrier.
Relocation, license consolidation and contour studies for 800/900 MHz Expansion Band frequencies for a multinational courier delivery services company.
Relocated and modified existing as well as added new 800/900 MHz frequencies for a non-profit hospital.
Frequency coordination services for 173 MHz channels for an energy company. 900 MHz spectrum leasing and consulting for a small town on the Cape.
Performed spectrum engineering and frequency coordination services for 800 MHz spectrum for a large statewide 700/800 MHz system shared by an energy company and public safety entity. See story on page 9.
Secured four exclusive-use UHF channels for a resort development company.
Frequency coordination and licensing services for a UHF centralized trunked system for a private carrier.
Spectrum engineering, consulting and licensing services for a 470-512 MHz (T-Band) trunked system for a public safety entity. See story on page 11.
Consulting, licensing and FCC liaison for a project involving involving adding sites to Part 22 UHF geographic area licenses for a private carrier. See story on page 10.
Frequency coordination and advocacy for an energy company serving an 11-state area. Supported companyâ€™s waiver for early access to Sprint-vacated 800 MHz spectrum. See story on page 9.
Frequency coordination and licensing services for the MAS band for an energy company.
Relocated 800/900 MHz sites authorized to an energy company by securing a waiver due to the FCC freeze on sites within the Mexican border region.
Frequency coordination services for new 800/900 MHz spectrum and existing license modification for an energy company.
Consulting, licensing and FCC liaison for a project involving adding sites to Part 22 UHF geographic area licenses for a private carrier. See story on page 10.
Frequency coordination for a VHF trunked system for an electric cooperative. Frequency coordination and licensing for a VHF SCADA system for a town.
Sale of 220 MHz spectrum by SEI, Inc. Secured low-power, exclusive-use UHF channels for a private carrier.
Frequency coordination services for a common carrier railroad, multi-site, using 161 MHz spectrum.
Frequency coordination services for new 800/900 MHz spectrum and existing license modification for an energy company.
ABOUT THE ENTERPRISE WIRELESS ALLIANCE The Enterprise Wireless Alliance is the leading national association for business enterprise wireless users and the manufacturers, resellers and communication sales and service providers that serve the land mobile radio industry. An FCC-certified frequency advisory committee, EWA provides consulting services, frequency coordination, license preparation, spectrum management and associated services to the business/industrial and public safety communities. EWA’s advocacy transforms public policy, and its services support business productivity by providing reliable guidance regarding spectrum and wireless technology access decisions. Members and clients trust EWA to coordinate more applications per year than any other frequency advisory committee serving the business/industrial community. EWA is the creator of Cevo®, a powerful online
frequency coordination portal, which simplifies the FCC license application process and allows users to select their own frequencies. More information about EWA membership and services is available at www.EnterpriseWireless.org.
TABLE OF CONTENTS FROM THE PRESIDENT AND CHAIR. . . . . . . . . . . . 2 BOARD OF DIRECTORS. . . . . . . . . . . . . . . . . . . . . . 4 SPECTRUM SOLUTIONS. . . . . . . . . . . . . . . . . . . . . . 6 PROJECTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ADVOCACY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 CONFRONTING SPECULATORS. . . . . . . . . . . . . . 16 PRODUCTS AND SERVICES. . . . . . . . . . . . . . . . . . 18 RESOLVING INTERFERENCE. . . . . . . . . . . . . . . . . 20 MEMBERSHIP. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 OUTREACH. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 FINANCES AND OPERATIONS . . . . . . . . . . . . . . . 28 LEADERSHIP AND STAFF. . . . . . . . . . . . . . . . . . . . 29
Enterprise Wireless Alliance | 1
FROM THE PRESIDENT It is a pleasure to present you with the enclosed
Enterprise Wireless Alliance 2016 Annual Report. Its
theme, “Creating Wireless Possibilities,” emphasizes
the success of business enterprises in deploying land
mobile radio systems with EWA’s assistance, as well as
summarizing EWA’s efforts to maximize the use of the limited spectrum allocated to serve for critical private land mobile communication requirements.
Mark Crosby President and CEO of the Enterprise Wireless Alliance
In 2017, EWA will continue to actively represent business enterprise wireless interests before the Federal Communications Commission (FCC) and increase its efforts to provide the highest level of spectrum access and related services available in the industry. This year may well be a year of significant activity with a change of leadership at the FCC coupled with no less than a dozen major pending advocacy initiatives that will affect the future of the private land mobile industry. Stay informed of these developments and more, through EWA’s “Member Only” regulatory teleconferences, the Enterprise Wireless Insider, and by following EWA on LinkedIn and Twitter. Of course, our members know that they need only call or email EWA’s professional staff for information and guidance. On behalf of the Board of Directors and staff, we wish you continued success and sincerely appreciate your support of EWA.
President and CEO
Crosby Named a Most Influential Thought Leader of 2016 The readers of MissionCritical Communications honored Mark Crosby by naming him a “Most Influential Thought Leader” for business and industrial enterprises in the MCC 2016 Industry Awards.
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FROM THE CHAIR OF THE BOARD As my term comes to a close, I want to say what a
privilege and honor it has been to serve as Chair of the Board of Directors of the Enterprise Wireless Alliance. How the time has passed!
This past year has been exciting to witness the continued trend of industry consolidation and the merging of RF and IT sectors. Though it gives us more opportunity, it also presents some obstacles to find the qualified personnel to take on these new responsibilities and retool our shops.
Catherine Leonard Chair of the Board of the Enterprise Wireless Alliance
To embrace these challenges as opportunities, we must be open to change and have a strong network. The Alliance offers the counsel, tools and information to help navigate the industry and its changes. The Regulatory Call keeps me aware of changes in Federal Communications Commission (FCC) rules that can help offer new solutions to clients and learn how EWA is working to protect our interests. Most important to me is the opportunity to engage with peers during the Wireless Leadership Summit. The executives gathered there share more than best practices; we share success. In the past year, our business has become more consultative, as it has for many industry colleagues. By diversifying product offerings, we strengthen our businesses and our position with clients. We help clients make technology decisions and solve communications needs. Itâ€™s a new role, and EWA is facilitating the transition. As we enter 2017, membership in EWA is vital. We face issues that require us to unite behind a strong advocate that understands our regulatory system and our industry. The approaching T-Band take back, the movement of cellular carriers into the traditional two-way radio space, and the Private Enterprise Broadband initiative are all things that continue to make EWA so relevant and our industry so exciting! I am truly grateful to be surrounded by such a passionate group of people all committed to furthering our industry and being the unrelenting guardians of our allocated enterprise spectrum. Join with us to work together for the success of our industry.
Chair of the Board Enterprise Wireless Alliance | 3
Executive Committee 2016-2017 [L-R] David Reeves, Catherine Leonard, Mark Crosby, Mike Fordinal, Paul Lauttamus and Bart Fisher. [NP] Gordon Day and Bill Landis.
BOARD OF DIRECTORS OFFICERS & EXECUTIVE COMMITTEE 2016-2017 Catherine Leonard
Chair of the Board
Vice Chair of the Board
COMMITTEES 2016–2017 AUDIT & FINANCE
Responsible for ensuring that the Alliance’s accounts are correct, for preparing the annual budget, contingency planning and reserve investment policies. CHAIR Gordon Day
Develop and coordinate activities for a successful Wireless Leadership Summit. CHAIR Kim Bozman
EWA-JOSEPH B. VESTAL ENDOWED SCHOLARSHIP
Supports endowed scholarship at Old Dominion University by promoting industry contributions and by providing input on the selection of scholarship recipients. CHAIR Mark Crosby
INFORMATION TECHNOLOGY Ensures that EWA’s technology strategy supports member needs. CHAIR David Reeves
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Identifies member candidates for the Board of Directors and the Executive Committee. CHAIR Rocky Eramo
MEMBERSHIP & SERVICES DEVELOPMENT
Provides guidance on member recruitment and member service programs. CHAIR David MacDonald
BOARD OF DIRECTORS 2016-2017 Mark Abrams
Owner Mobile Relay Associates Paramount, CA
Manager, Radio Engineering & Support Delta Air Lines Atlanta, GA
General Manager Unication USA Arlington, TX
Carlos Fernandez Alonso Vice President, Business Development PowerTrunk Jersey City, NJ
Frank Anderson Owner A Beep, Inc. Joliet, IL
Business Manager Teltronic, Inc. Beltsville, MD
President & CEO Enterprise Wireless Alliance Herndon, VA
President EMCO Technologies Baton Rouge, LA
President Day Wireless Systems Milwaukie, OR
CEO BearCom Wireless Worldwide Costa Mesa, CA
Roger Dickinson President RFC Wireless Fremont, CA
Laguna Hills, CA
Executive Director Technology Resource Network International Troy, NY
Vice President Wireless Communications, Inc. Baltimore, MD
President John Eramo & Sons Hilliard, OH
President Fisher Wireless Services, Inc. Blythe, CA
President DFW Communications, Inc. Arlington, TX
Owner Signal Communications Coconut Creek, FL
Supervisor, Open Source Software & IT Contracts Manager Ford Motor Company Allen Park, MI
Vice President Motorola Solutions, Inc. Schaumburg, IL
Executive Vice President & General Manager JVC Kenwood USA Corporation Suwanee, GA
CEO TuWay Communications Bethlehem, PA
Owner Lauttamus Communications Weirton, WV
President Comtronics Corporation Quincy, MA
Chief Operations Officer Lockard & White College Station, TX
David MacDonald President Radio One Orlando, FL
President & CEO RACOM Corporation Marshalltown, IA
Systems Engineering Manager Southern Company Services Atlanta, GA
Owner The Cambridge Group Plano, TX
President & CEO Aviation Spectrum Resources Annapolis, MD
President ComSource, Inc. Rochester Hills, MI
Vice President Icom America, Inc. Kirkland, WA
President & CEO pdvWireless Paterson, NJ
President P & R Communications Dayton, OH
Owner New York Communications Company Poughkeepsie, NY
Michael Saia, Sr.
Owner Saia Communications, Inc. Buffalo, NY
Senior Vice President, Chief Marketing & Strategy Officer NRTC Herndon, VA
Wireless Architect United Parcel Service Louisville, KY
Salt Lake City, UT
President Creative Communications Sales & Rentals, Inc. Phoenix, AZ
Owner Communications Electronics of Virginia Fairfax, VA
James Silke, Jr.
President Hytera America, Inc. Miramar, FL
F. H. Smith
President Silke Communications Eugene, OR
IT Infrastructure Architect Chevron Bakersfield, CA
Vice President, General Manager & Principal ESP Wireless Technology Group, Inc. Warrenville, IL
Lukas, LaFuria, Gutierrez & Sachs, LLP. Tysons, VA
President Triangle Communications, Inc. New Holland, PA
Vice President, Spectrum Management Sprint Reston, VA
Owner Tomba Communications and Electronics, Inc. Metairie, LA
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EWA Executive Vice President, Spectrum Operations, Ila Dudley (right) discusses issues affecting frequency coordination and licensing during a session at IWCE 2016. Also pictured is Michelle Fink, National Frequency Coordinator, IMSA/IAFC/FCCA.
SPECTRUM SOLUTIONS EWA continues to be the frequency advisory committee trusted by more
wireless sales and service providers and business enterprises than any other. EWA offers spectrum engineering, consulting, frequency selection and coordination as well as FCC application processing services for both Industrial/Business (I/B) and Public Safety (PS) in the 30 to 900 MHz bands. EWA performs licensing and consulting services in many other spectrum bands, including Part 22 UHF/VHF, Aviation, Marine, and Multiple Address Systems (MAS).
Trusted for Frequency Coordination In 2016, EWA remained the market leader, despite an industrywide decrease in the number of applications filed.
MOST TRUSTED FOR FREQUENCY COORDINATION AAA AAR EWA FIT MRFAC WIA UTC
16,000 12,000 8,000 4,000 0
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SPECTRUM SOLUTIONS BY THE NUMBERS
In March, EWA began accepting and processing Business/Industrial Land Transportation (B/ILT) and public safety applications for Vehicular Repeater Systems (VRS) on six 173 MHz channels that were previously available only for data telemetry systems. Before the FCC began accepting applications, EWA conducted a webinar on strategies for accessing VRS frequencies.
Total volume of applications — licensing, renewals, and coordination combined
Additional Spectrum for Vehicular Repeater Systems
Supported California High-Speed Rail 700 MHz Spectrum Acquisition Through its subsidiary Spectrum Equity, Inc. and in collaboration with Access Spectrum, EWA played an instrumental role in facilitating California High-Speed Rail Authority’s acquisition of exclusive rights to radio spectrum critical for the development of secure and reliable train communication systems. These systems include features like Positive Train Control, a state-ofthe-art collision avoidance technology.
Average number of applications per day
Speed of service on average for applications that do not require spectrum engineering or a Request for Waiver
EWA & AFTRCC Executed Concurrence Process Agreement EWA and the Aerospace and Flight Test Radio Coordinating Council, Inc.® (AFTRCC®) executed a Concurrence Process Agreement that will govern coordination protocols between the parties for the registration and coordination of Medical Body Area Networks (MBAN) operating in the 2360-2390 MHz band. These networks will be used for wireless patient monitoring in hospitals and health-care facilities and will share this band with Aeronautical Mobile Telemetry (AMT) operations.
Exclusive-Use Channel Validation Protects Licensees EWA now verifies the accuracy of all business/industrial applications that certify exclusive-use channels in the bands below 470 MHz through its “Exclusive-Use Channel Validation” program. EWA has undertaken this program to protect the exclusive service areas of licensees that hold channels designated as FB8s. Any application that appears to have violated FCC Rule Section 90.187 will be identified and reviewed for compliance. If an FB8 certification was not issued in accordance with the FCC rules, parties responsible for the application will be notified by EWA and requested to amend that application. Enterprise Wireless Alliance | 7
Members of the Roanoke Police Department (Texas) participate in a panel on improving customer experience through collaboration with vendors.
PROJECTS EWA’s expertise covers the entire “life cycle” of spectrum, including, as
necessary, spectrum research, acquisition guidance, licensing and spectrum license management.
EWA’s spectrum advisors are undaunted by any challenge to satisfy customer requirements. Whether seeking exclusive-use channels, preparing waivers, or securing Canadian approval for systems located North of Line A, our spectrum advisors work until “no” becomes “yes.”
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Utility & Public Safety Collaboration EWA provided consultative and frequency coordination services for a large, 54-site, statewide system to be deployed at 800 MHz throughout the state of Michigan, a collaborative effort between a utility and public safety entity. The private land mobile radio industry is beginning to see an increase in these joint efforts between critical infrastructure and public safety. The equipment manufacturer brought this project to EWA’s attention due to its high level of expertise with complex spectrum solutions for B/ILT and Public Safety (PS) licensees. Engaging discussions take place at the Wireless Leadership Summit.
EWA’s review of the availability of 800 MHz spectrum at the 54 sites was challenging because a portion of the sites are located within the Canadian border region, which diminishes the number of frequencies available for licensing. EWA conducted spectrum engineering and coordinated 800 MHz frequencies at all but two sites and will monitor availability at the two locations in the future.
Fighting for Access EWA coordinated an application for American Electric Power (AEP), which required a Request for Waiver to use 800 MHz Sprintvacated frequencies that normally would not be available to Critical Infrastructure Industry (CII) entities until after February 10, 2018. AEP noted in its request that no public safety entity had applied for the Sprint-vacated spectrum in the required coverage area. The Association of Public-Safety Communications Officials International, Inc. (APCO) filed Reply Comments on this matter, stating that AEP had not met the standard for waiver relief because it failed to provide compelling circumstances. AEP/EWA filed a joint response describing AEP’s responsibilities in providing safe, reliable electric service to millions of customers throughout an 11-state area, including the rural area at issue. The reply described the specific functionalities that AEP is adding to its system that require additional capacity. They further demonstrated that the proposed site is entirely within the contour of existing AEP facilities for two of the seven channels, making the channels unavailable to a public safety applicant. Existing contours on three additional channels substantially overlap the contour of the proposed site, effectively limiting the opportunity for reuse by a PS applicant. Finally, EWA and AEP identified sixteen interleaved PS channels available at this rural site, and noted that there were additional Sprint-vacated channels as well, which may explain why no PS applicant had filed for the channels in question.
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The Wireless Leadership Summit draws new faces each year.
Up for The Challenge — Part 22 Licenses North of Line A Central Vermont Communications Inc. (CVC) requested assistance from EWA on a licensing project involving Part 22 UHF geographic area licenses. Following its successful participation in Auction 48, CVC was authorized for several Part 22 UHF channel block licenses in Economic Area BEA004. CVC wanted to deploy fixed/mobile operations using time division multiple access (TDMA) technology. EWA worked with CVC on applications with different transmitter locations within BEA004, specifically in Northern New York and Vermont, which required coordination and approvals from Canada. Initially, Innovation, Science and Economic Development Canada (ISED Canada), Canada’s version of the FCC, rejected one application because of concern over the location of the proposed base station with their standard response of “Harmful Interference Anticipated.” To protect the incumbent Canadian user, EWA recommended use of a directional antenna and provided predicted propagation contours generated through a Longley-Rice contour evaluation. ISED Canada consented, and the FCC granted the application. After this experience, Central Vermont’s Steve Suker said, “With the help of EWA, Central Vermont Communications has licensed successfully UHF Part 22 auction channels at several locations above Line A in Vermont. EWA was instrumental in helping us accomplish this, and we look forward to working with them in the future.” 10 | Creating Wireless Possibilities : 2016 Annual Report
Taber Alderman, Patti Ryg and EWA Board member Kim Bozman lead the discussion during the Women of Wireless session.
Thawing the Frozen T-Band Mercer County, New Jersey, requested EWA’s assistance in securing access to T-Band frequencies. A waiver was necessary to secure an exemption from the T-Band application “freeze” imposed by the FCC in preparation for the repurposing of this band for general broadband purposes. Mercer County was receiving interference created from radio frequency ducting, the source of which was a Channel 20 (T-Band) TV station broadcasting in western Connecticut. Because both licensees were operating in compliance with the rules, efforts to address the interference had not been successful. Mercer needed to separate itself from the interference. T-Band capacity was available on Channel 19, but a T-Band waiver would be necessary. EWA assisted in developing a plan for an equal exchange of TV Channel 19 frequency capacity that would enable Mercer County to remove itself from the TV Channel 20 interference and comply with FCC policy requirements in that neither Mercer County’s spectrum capacity nor geographic coverage would expand. In conjunction with Mercer County officials, EWA prepared the waiver and processed the necessary applications and attachments through Public Safety Coordination Associates (PSCA), a collaboration between the International Municipal Signal Association/International Association of Fire Chiefs (IMSA/ IAFC) and the Forestry Conservation Communications Association (FCCA), with which EWA has a formal relationship. “We were honored to have Mercer County trust EWA to secure a spectrum solution needed to serve its citizens. We always appreciate the challenge,” said EWA President Mark Crosby. Working with PSCA, the application was expeditiously filed, and the FCC granted the waiver. Enterprise Wireless Alliance | 11
Leading EWAâ€™s regulatory efforts is President and CEO Mark Crosby whose deep understanding of spectrum policy and issues facing business and industrial enterprises make him a strong advocate for EWA members and the private land mobile industry.
ADVOCACY The Enterprise Wireless Alliance represents business enterprise users,
wireless sales/service providers, technology vendors and manufacturers united by their reliance on spectrum in multiple bands to meet their
communications needs. On behalf of this broad alliance, EWA pursues
regulatory issues affecting the availability and efficient use of spectrum and seeks new spectrum access opportunities.
EWA is an active member of the Land Mobile Communications Council (LMCC), a nonprofit association of organizations that represent the wireless communications interests of public safety, critical infrastructure, business, industrial, transportation, private and common carriers, and manufacturers of wireless communications equipment. Through LMCC, EWA engages with these organizations on matters concerning the future of spectrum and frequency coordination in the United States. Mark Crosby serves as the LMCCâ€™s Secretary/Treasurer.
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2016 ADVOCACY AT A GLANCE
Filings by EWA
Filings by LMCC
EWA Member Regulatory Teleconferences ADVOCACY AGENDA FOR 2017 In 2017, The Enterprise Wireless Alliance will focus on the following priorities, among other regulatory initiatives: T-Band Repurposing Combating Speculation 900 MHz Private Enterprise Broadband Revisiting the Sprint-vacated Reservations Potential New Opportunities in 800 MHz
HIGHLIGHTS Maximizing Opportunities for 800 MHz Incumbents EWA remains a vocal advocate for 800 MHz incumbent licensees in response to a Notice of Proposed Rulemaking (NPRM) that contains, among other topics, the LMCC proposal to allow 800 MHz incumbents time-limited priority access to 800 MHz Expansion Band (EB) and Guard Band (GB) spectrum before opening it up to new entrants. The LMCC recommended that the FCC adopt a six-month, time-limited priority access opportunity; that all 800 MHz incumbents be permitted access to all available channels in both the EB and GB; and that the FCC lift the freeze on inter-category sharing during this period. In comments supporting the LMCC position, EWA reminded the FCC that no non-public safety Private Land Mobile Radio (PLMR) spectrum has been made available since 1986 and recommended that Industrial/Business T-Band and 900 MHz incumbents be eligible for priority access. EWA asked the FCC to require licensees to deploy digital systems that use 12.5 kHz bandwidth technology or technology with 12.5 kHz spectral efficiency or better. EWA also suggested that licensees should verify construction six months following grant, complete with site-owner verification.
Championed Expansion of Conditional Licensing The FCC proposed to extend conditional licensing authority to 800/900 MHz spectrum and requested comment on the merits of extending conditional authority to narrowband 700 MHz public safety spectrum, but excluded commercial service providers and declined to include T-Band spectrum because of legislation that affects the future of this band. EWA and the LMCC recommended that conditional licensing be extended to 470-512 MHz, Specialized Mobile Radio (SMR), and 700 MHz public safety narrowband applicants. They also urged the FCC to strictly enforce the 180-day limit on a conditional license unless an applicant justifies a waiver of that rule.
Securing Access to Exclusive Guard Band Channels The FCC proposed to add certain UHF channels that fall between PLMR and Broadcast Auxiliary Service (BAS) spectrum and PLMR and General Mobile Radio Service (GMRS) spectrum to the Part 90 Industrial/Business (I/B) frequency table, but rejected the inclusion of others because of potential interference or other issues. EWA recommended that all the channels identified, including those not approved by the FCC in recent Orders responding to waiver requests, be added to the I/B allocation table, subject to generally accepted frequency coordination protocols.
Promoting Private Enterprise Broadband EWA continues to recommend that the FCC move forward with the EWA/pdvWireless (PDV) proposal to bifurcate the 900 MHz band into broadband and narrowband allocations. Most recently, EWA sought the release of a suspected Notice of Inquiry (NOI) that would seek information regarding the EWA/PDV proposal; the M2M proposal to allow commercial entities immediate access to B/ILT spectrum to serve B/ILT eligible entities; and, potentially, other substantial changes to the 900 MHz rules.
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Part 90-Related Advocacy Filings by I/B Coordinators, 2016
Fighting for Your Spectrum — More than Any Other EWA is more focused on Part 90 issues than any other association serving the private wireless sector. In 2016, EWA contributed 70% of the 2016 filings by I/B coordinators.
PART 90-RELATED ADVOCACY FILINGS BY I/B COORDINATORS, 2016 20
Supported Eliminating CMRS Presumption EWA urged the Commission to eliminate FCC Rule Section 20.9 and make related rule changes to clarify which wireless services are classified as Commercial Mobile Radio Service (CMRS). In addition, EWA sought a declaratory ruling clarifying that 800 MHz and 900 MHz Specialized Mobile Radio (SMR) systems that are not interconnected with the public switched network cannot be classified as CMRS or regulated as common carriers — or as telecommunications carriers — in accordance with Section 332(c) of the Communications Act.
PENDING ADVOCACY ISSUES T-Band Repurposing The FCC has yet to issue an NPRM that would introduce rules necessary to implement Congressional mandates to reallocate and auction the PS channels in the 470-512 MHz band for commercial purposes. One difficult issue, before the band is to be auctioned in 2021, is the identification of sufficient comparable replacement spectrum for PS and B/ILT incumbent licensees.
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License Renewal Proceeding The FCC may resurrect an NPRM adopted in May of 2010 proposing more detailed renewal showings for both site-based and geographic licenses. Given the opportunity, EWA would propose to return to five-year license terms for PLMR authorizations and recommend verification processes to minimize spectrum warehousing.
Tribal Nation Tower Review Process The FCC has not taken action on the filing by PTA-FLA, Inc., a wireless carrier, proposing measures to lessen the challenges from the tribal review process faced by entities seeking to construct new towers or collocate on existing facilities. EWA filed comments in support, urging the FCC to strike a “balance between the entirely legitimate interests of Tribal Nations in protecting locations of meaningful historic significance … and the public interest in facilitating deployment of antenna facilities that are used in delivering public safety, public service, broadband and other wireless communications.”
800 MHz Interstitial Channels The FCC is working on a Report and Order adopting final rules to introduce new, full power, interstitial 12.5 kHz “offset” channels in the 809-817/854-862 MHz band (800 MHz Mid-Band), subject to certain protections designed to safeguard 800 MHz licensees from interference. The Order will create the opportunity for 319 additional voice-grade channels for use by Public Safety, Industrial/Business, General Category, and high-site SMR licensees and will address the proposed LMCC reciprocal interfering contours for these channels. EWA filed the Petition proposing these channels.
EWA Proposal for New Interstitial Channels EWA has proposed to add 319 12.5 kHz channels to the 800 MHz Mid-Band.
CHANNEL B 25 kHz
CHANNEL C 25 kHz
Regularly assignable 25 kHz bandwidth channels spaced every 25 kHz
CHANNEL D 25 kHz
Interstitial 12.5 kHz bandwidth channels proposed by EWA
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Certain 800 MHz SMR licensees invested in authorizations with the expectation that their spectrum would be purchased by a cellular carrier â€” even though cellularized systems are prohibited from operating on these channels. These licenseesâ€™ interest in providing the service for which they are licensed and their capability of providing it is highly questionable. An EWA member documented that there are no PLMRS 800 MHz antennas at this site despite the fact that multiple licensees have certified construction at the location. Photo by Linda Peters of ProComm Alaska.
CONFRONTING SPECULATORS Spectrum is a finite resource. It is imperative that EWA members and
other active users of private land mobile radio spectrum have access to this limited resource when needed. Spectrum is a tool to be used for communications and not a commodity for investment. Yet, the PLMR
community has been confronting speculators, who seek to profit from this public resource, for decades.
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Spectrum Warehousing — EWA Seeks to Close Loopholes EWA requested guidance from the FCC regarding channel justification requirements for 900 MHz not-for-profit systems and rental radio businesses. Such applications tend to create the potential for spectrum warehousing.
“We do not have the luxury of permitting applicants to secure more spectrum than perhaps they will ever need, as it is near impossible at the moment to have licensees on their own return excess spectrum,” EWA President Mark Crosby noted. Avoiding a Spectrum Tragedy An NPRM addressing several outstanding requests from the PLMR community includes the LMCC proposal that would allow 800 MHz incumbents time-limited priority access to 800 MHz Expansion Band and Guard Band spectrum before making it available to new entrants. The proposal intends to ensure that those who have invested in wireless systems for legitimate purposes can expand their systems. The FCC proposal limits priority access to incumbents from the B/ILT pool that seek B/ILT spectrum in the Expansion Band, severely undercutting the relief offered by the LMCC proposal and effectively opening this new allocation of spectrum to speculative investors.
“This is it, this is the last sliver of spectrum the private land mobile industry will have access to in order to accommodate internal communication requirements, perhaps ever. The FCC’s proposal doesn’t go far enough. Let’s first take care of those who have invested millions in wireless systems for legitimate purposes before new applicants are allowed access, many of whom will have only the misguided intention of profiting on spectrum transactions. We need to absolutely limit the opportunity for such a spectrum disaster,” said Mark Crosby.
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EWA Executive Director of Marketing & Membership Sarah Beerbower (right) discusses EWA’s diverse product and service offerings with Brent McGraw of Day Wireless.
PRODUCTS AND SERVICES More members and clients are recognizing the value that EWA’s products
and services deliver to their businesses. From spectrum engineering and filing
assistance to license management and custom market reports, EWA continues to diversify its product and service offerings to deliver complete support. EWA’s License Management program has grown to more than 19,000 licenses.
LICENSE MANAGEMENT GROWTH
Managing More Licenses Each Year
20,000 15,000 10,000 5,000 0
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HIGHLIGHTS Launched MBAN Registration Capability Pursuant to its Memorandum of Agreement (MOA) with the FCC, the Enterprise Wireless Alliance launched a website that allows health-care facilities to register for the deployment of Medical Body Area Networks (MBAN) in the 2360-2390 MHz band. MBAN will be used for wireless patient monitoring in hospitals and health-care facilities to transmit patient health data over a short range at a very low power level. The devices are range-restricted to indoor use at health-care facilities. EWA’s MBAN registration site is available at www.MBANregistration.org.
Cevo Usage Increases Since its launch in 2015, Cevo, EWA’s online frequency coordination portal, continues to make submitting FCC license applications easier. No other licensing software collects into one solution all of the tools required for calculating parameters like latitude/longitude, Height Above Average Terrain, Effective Radiated Power and more. No other resource provides users with as many options and features for managing licensing requirements. No other licensing service provider offers clients an online tool with the breadth and depth of Cevo, which now accounts for 40% of EWA’s total application volume.
Deployed Enhanced Wireless Solutions Center To support EWA members in growing their businesses, EWA enhanced and relaunched its online Wireless Solutions Center. This updated buyer’s guide makes it easier for those planning private wireless projects to find the solutions that suit their needs. Site enhancements include an improved search function and navigation.
Financial Model Supports Sales Discussion EWA released an interactive tool to help service providers and decision makers determine the most cost-effective wireless system, based on specific project requirements, and to ensure that prospective buyers understand the cost components that figure into a comparison of two-way radio and cellular systems. The Wireless System Investment Model calculates and compares annual and cumulative expenses for a commercial cellular, versus private carrier, versus private WSIM internal network over a ten-year period. The Wireless System Investment Model calculates and compares investment costs for three network types over a 10-year period.
10-YEAR NETWORK INVESTMENT COSTS Commercial
$1,000,000 $800,000 $600,000 $400,000 $200,000 $0
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EWA Board member Terry Zaccarino points out to EWA staff the various antenna types atop the Garfield House in downtown Washington, D.C. EWA provided spectrum engineering, coordination and licensing services for private wireless systems located there.
RESOLVING INTERFERENCE The Enterprise Wireless Alliance assists in the preliminary investigation of
reports of radio signal interference in the Industrial/Business radio bands
under a Memorandum of Understanding (MOU) with the FCC, signed in
1998. Since that time, EWA has worked to resolve more than 2,275 cases of interference — an average of 119 cases per year.
FCC rules require that private land mobile radio licensees take steps to avoid causing harmful interference, which the Telecommunications Act defines as “any emission, radiation or induction that endangers the functioning of a radio navigation service or of other safety services or seriously degrades, obstructs or repeatedly interrupts a radio communications service operating” as licensed. In accordance with FCC rules, land mobile frequencies are assigned on a shared basis, unless specifically indicated otherwise. Applicants and licensees must cooperate to reduce interference and make the most effective use of the authorized facilities.
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INTERFERENCE RESOLUTION BY THE NUMBERS
Year EWA signed MOU with FCC
Number of cases logged since 1998
Average number of cases per year
EWA works with licensees to understand the issue and reach cooperative resolutions, particularly in cases of co-channel interference. In some cases, EWA conducts mediation to reach an agreement and will refer cases to the FCC Enforcement Bureau as needed. The Federal Communications Commission is the only agency that has authority to take enforcement action against any entity causing harmful interference. The following are a few of the more complex cases EWA addressed in 2016.
The Reality of Shared VHF Channels In a deviation from standard protocols, EWA received notice from the FCC Enforcement Bureau’s Chicago office of a complaint registered by a licensee operating a VHF trunked system in Ohio who stated that they were receiving interference from a co-channel licensee that was coordinated on the same frequency by EWA. Apparently, the FCC was unaware that EWA had attempted to resolve the nuisance interference three years earlier, and that the complaining licensee had unilaterally ceased communicating after it was suggested by EWA that the fair approach towards resolution would be for the parties to share the costs of a channel change for one or the other. There was no evidence of harmful interference, all parties were operating their systems in compliance with the rules, and simply hearing another user on a shared-use channel does not normally justify detailed investigative research on the part of the FCC. The Enforcement Bureau agent investigating the complaint questioned EWA’s frequency selection processes to which EWA responded that: • Licensees operating conventional or trunked systems on shared channel assignments are not guaranteed that there will be no additional users added to their shared channel; •
he VHF band is not a paired band, which creates greater interference issues for T duplex system operations;
• Both analog and digital systems are permitted to operate and share spectrum within overlapping areas of operation; and •
iven that both licensees are monitoring the channel prior to transmitting in G accordance with the rules, there is no evidence of purposeful, harmful interference.
EWA will continue to provide recommendations in this matter towards an equitable resolution for both licensees.
Secondary v. Primary Use Channels Located in the suburbs of Chicago, a licensee contacted EWA stating that they were experiencing interference to their Supervisory Control and Data Acquisition (SCADA) system. SCADA systems gather data in real time from remote locations to control equipment and conditions, and are often deployed in power plants, refineries, and water and waste control systems. During a review of the license, EWA noticed that the licensee was assigned “secondary use” channels which, in accordance with FCC rules, may “not cause interference to operations authorized on a primary basis and which are not protected from interference from those Enterprise Wireless Alliance | 21
primary operations.” Apparently, the licensee was unaware of this distinction, and in collaboration with EWA, decided to pursue alternative “primary use” channels that would place their system on an equal basis with other co-channel systems.
Self-Inflicted Interference A management firm that operates an annual state fair notified EWA that it had recently begun experiencing interference to its communications system that operated on shared 450 MHz channels. EWA’s spectrum review revealed no co-channel licensees that might be the source of the interference, but noted that the management firm was operating multiple repeaters at different locations. Further discussions revealed that the firm had modified its system by relocating one transmitter within closer proximity to other transmitters, the consequence of which was that they were inadvertently interfering with themselves. EWA also learned that the license was not amended to represent the new repeater locations as required by the FCC. To immediately mitigate the interference, EWA recommended returning the transmitters to their licensed locations, to seek technical advice from a professional wireless sales and service organization and, when new transmitter locations are identified, to amend the FCC license to reflect actual operational information. The management firm contacted an EWA wireless service provider member who reconfigured Keepingthe the firm’s Peace Since 1998 radio system to operate at peak performance and, facilitated through EWA’s offices, appropriate license amendments. Within six years of offering interference resolution through its MOU with the FCC, EWA had addressed a long-standing need within the private land mobile radio community and now receives, on average, 119 cases of interference per year.
KEEPING THE PEACE SINCE 1998 400 350 300 250 200 150 100 50 0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
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ENFORCEMENT BUREAU’S TOP TEN FCC rules require that the private land mobile radio licensees take steps to avoid causing harmful interference, including monitoring the transmitting frequency for communications in progress. The FCC Enforcement Bureau shared its “Top 10” issues that cause interference problems within the shared Part 90 bands.
10 Non-Compliant Wideband Systems in the 150-470 MHz Band
The narrowband deadline was over three years ago, but non-compliant systems still operate wideband technologies. Adjacent channel users suffer the consequences.
9 Poor System Engineering and Maintenance
oor system designs, installations and maintenance create all kinds of P harmonics and intermodulation products that are harmful to unsuspecting systems.
Invalid Licensed Entities
icensees are obligated to ensure that licenses reflect proper business L names and that administrative information is accurate.
An absolute killer to spectrum management objectives, licensees who fail to
renew their authorizations or entities that purchase wireless equipment off the Internet and do not pursue valid FCC licenses corrupt the airwaves and cause untold interference havoc.
Non-Compliant Itinerant Operations at Special Events
Failure to Monitor Before Transmitting on Shared Channels
Failure to Provide Station Identification
hile some providers have proper licenses that permit the leasing of mobile W and other wireless solutions at special events on approved channels, many others simply rent radios without regard for local incumbent operations.
ntities cannot effectively share channels if they disregard their co-channel E neighbors. Bad behavior on shared channels begets bad behavior.
Nothing annoys the FCC’s Enforcement Bureau more during an interference
investigation than encountering licenses that do not report their call signs. It’s easy to comply with this FCC rule requirement. Most digital systems can be programmed to automatically provide station identification. If an analog system is in use, train employees to get into the habit of providing the system’s call sign.
3 Artificial Spectrum Shortages — Spectrum Warehousing
he FCC will not tolerate the practice of padding licenses in an attempt T to reduce the risk of having new users sharing channels. Such practices include licensing excessive power, claiming more mobiles than will ever be realistically deployed and/or securing access to more channels than will ever be needed to satisfy operational system expectations.
2 Control Channel Use in Trunked Systems on Shared Channels
The control channel is perhaps the most critical piece of spectrum management within a centralized, hybrid or non-centralized trunked radio system. Ideally, the control channel operates on an exclusive channel basis within fully-centralized or hybrid systems. When the channels within a trunked system are shared, recognized when no channels have the coveted FB8 code, serious interference to co-channel licensees sharing the control channel results, as no monitoring is taking place.
Monopolizing Shared Channels — Duty Cycles Greater than 95% If #2 above wasn’t a big enough issue in shared-channel environments, excessive polling by a control channel on a shared channel is bad news. The FCC has and will continue to issue fines for this practice.
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Membership in EWA provides private wireless industry leaders with opportunities to share best practices and experience.
MEMBERSHIP In wireless, your business is impacted by changes in spectrum access,
regulatory updates, shifting license requirements and an ever-increasing
pace in technological advancements. Keeping up with all of these changes is a job all its own, requiring you to monitor industry trends, numerous
regulatory shifts from the FCC and other government agencies and laws enacted by Congress.
Membership in EWA means that you gain access to the experience, knowledge, and influence of experts in matters of wireless spectrum and technology. EWA prides itself on being the representative voice for the wireless industry, taking actions that protect your current wireless investments as well as secure your rights to operate profitably in the future. Members engage with EWA by joining our bi-weekly regulatory call, reading the Enterprise Wireless Insider newsletter, enjoying members-only discounts and benefits, and the ability to consult EWA staff for compliance assistance. 24 | Creating Wireless Possibilities : 2016 Annual Report
2016 MEMBERSHIP AT A GLANCE 71% Wireless Sales & Service Providers 26% Licensees 3%
HIGHLIGHTS Strategic Partnerships
MOTOROLA SOLUTIONS BRAND MARKS COLORS FOR HORIZONTAL LOGO
Theusing emsigniamanufacturer disk color should be selected the Motorolato Solutions color palette for EWA members continue to enjoy the benefits of co-opfrom programs As a general rule, a minimum 20% value difference is recommended between the backgro reimburse for membership programs and services. youcolor. to the following companies for and theThank emsignia disk their support of EWA and the dealer network:
New Service for Members Only — Custom Reporting In 2016, EWA launched a new custom reporting service, using data from the FCC’s Universal Licensing System. Reports include parameters designated by the customer, such as data on recently licensed private land mobile radio systems; new licenses granted in a specific geographic area; or all PLMR licenses expiring within a given date range. Access to custom reporting is a benefit allowed only to EWA members.
New Benefit — D3M Subscription Discount
Through a strategic partnership announced in 2016, EWA and D3M launched a new benefit for EWA members — a 20% discount for the first-year’s subscription to D3M services.
EWA enhances the value of membership by creating partnerships with service providers, such as D3M, that benefit EWA members.
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OUTREACH Representing business enterprise users, wireless sales/service providers, technology vendors and manufacturers, EWA is an alliance.
The industry and EWA thrive when all aspects of the private land mobile radio industry come together â€” in defense against shared threats and for mutual benefit.
26 | Creating Wireless Possibilities : 2016 Annual Report
HIGHLIGHTS Provided Networking Opportunities to Industry Leaders
During IWCE 2016, EWA members and clients sought advice on a variety of spectrum projects.
Business owners and private wireless industry leaders gathered in Dallas, Texas for the 2016 Wireless Leadership Summit, an annual conference hosted by the Enterprise Wireless Alliance and Technology Resource Network (TRN), that provided sessions on business trends, best practices, regulatory issues and the latest in technology developments. Topics included product diversification, transitioning businesses and collaborating for success on large wireless projects.
Raised $3,400 for the EWA-Joseph B. Vestal Endowed Scholarship Fund Members of the private wireless industry contributed over $3,400 to the EWA-Joseph B. Vestal Endowed Scholarship fund at Old Dominion University (ODU), which supports students working toward degrees in fields of study related to the wireless industry. Funds were raised through individual donations and a silent auction held during the Wireless Leadership Summit. EWA Spectrum Advisor Andrew Burkholder delivers instruction in the essentials of spectrum to NYCOMCO employees.
Delivered Educational Opportunities This industry evolves constantly — as FCC regulations change or as new technology becomes available. To help owners and executives navigate these changes and support their customers, EWA offered webinars on such topics as strategies for selecting frequencies for Vehicular Repeater Systems; locating exclusive-use channels; and deciding between private land mobile radio or push-to-talk over cellular. In addition to executive-level sessions, EWA continues to deliver training focused on spectrum essentials and how to use Cevo, EWA’s online application submittal and frequency coordination portal.
Enhanced Engagement with Social Media EWA sought new ways to connect with members and others in the industry by reaching out using social media networks, such as LinkedIn and Twitter. During the Wireless Leadership Summit, EWA and TRN used the Twitter hashtag #WLS2016 to promote the Summit and communicate “just-in-time” information.
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FINANCES AND OPERATIONS
SOURCES OF REVENUE 48% Spectrum Solutions 16% Application Data Verification and License Preparation 5% Education and Management Services 12% Membership and Membership Services 19% Spectrum Equity, Inc.
USE OF REVENUE 51% Staff and Benefits 41% Operations 8% Reserves
The Enterprise Wireless Alliance engages the accounting firm of Tate & Tryon, Washington, D.C. to conduct an annual audit of EWAâ€™s financial activities. Audited financial results for the calendar year 2016 may be requested by contacting EWAâ€™s Accounting Department by phone at 800-482-8282 or by email at firstname.lastname@example.org.
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President and CEO
Ila R. Dudley
Executive Vice President, Spectrum Operations
Senior Vice President, Corporate Operations
Kristen Scott Membership and Events Coordinator
Mel Wingate-Bey Manager, IT & Web
Executive Director, Marketing & Membership
Executive Director, Regulatory Affairs & Spectrum Strategies
STAFF Andrew Burkholder Spectrum Advisor
Karen Fouchie Accounting Manager
Karen Holmes Spectrum Advisor
Andrea Cumpston Communications Director
Ron Franklin Customer Service Manager
Cheri Horvath Director, Accounting
Cyndi DeVecchis Spectrum Advisor
Cecilia Hayes Executive Director, Spectrum Solutions
Denisse Ibarra Director, Spectrum Solutions
Adrienne Shaffer Spectrum Advisor Judy Wilson Manager, Membership Services
Enterprise Wireless Alliance | 29
Herndon Office 2121 Cooperative Way Suite 225 Herndon, VA 20171
CONNECT EnterpriseWireless.org 800-482-8282 @EWA4Spectrum
Emmitsburg Office 17750 Creamery Way Suite B-10 Emmitsburg, MD 21727
Enterprise Wireless Alliance
Enterprise Wireless Alliance Annual Report 2016