Important Message to AeroMACS Ecosystem – FCC Requests Comments on AeroMACS Petition

24-Jul-2017

Dear AeroMACS friends,

The United States Federal Communications Commission (FCC) has issued a Public Notice (PN) in response to the WiMAX Forum’s AeroMACS Petition for Rulemaking. I am writing to ask you to submit supportive comments to the FCC. Initial Comments are due August 18, and responses are due to the FCC no later than SEPTEMBER 5, 2017. I have provided filing instructions at the bottom of this email. As you know, this is a very high priority for the AeroMACS community.

The PN highlights a few issues for comment, which we have addressed in our Petition. I take the liberty of addressing them briefly here again:

1. Channel Manager. The WiMAX Forum has proposed that non-Federal eligible users share available channels under the auspices of a single FCC-appointed nationwide Channel Manager as the most efficient way of optimizing the available spectrum. The Channel Manager would establish a Memorandum of Agreement with the National Telecommunications and Information Administration for Federal Users’ access to spectrum and would allocate channels to non-Federal users upon application to the Channel Manager. We believe that a Channel Manager, with oversight from industry participants such as the airport and airline communities (for example), is best placed to allocate spectrum fairly on a non-discriminatory basis. We strongly believe that the Channel Manager should be independent, non-profit, and deeply knowledgeable of the AeroMACS industry, ecosystem, regulatory framework, international movement and application development. We have further outlined in our Petition our rationale for such an approach and we ask that you support this approach directly in comments to the Commission.
2. License by Rule. Related to the above, the WiMAX Forum has proposed that non-Federal eligible users be “licensed by rule” under Part 95 and be able to register sites and secure AeroMACS channels by applying to the Channel Manager as described above. We strongly believe that if point 1 above is accepted as the best approach, then this licensing approach is the simplest, fairest and most economical way to actually assign AeroMACS channels. We ask that you specifically support this approach in any comments you submit to the Commission. Licensing by rule increases flexibility and reduces the possibility that an entity “warehouses” spectrum it does not need at a particular airport.
3. Technical Rules. The WiMAX Forum has included in its Petition the internationally adopted standards and technical rules for equipment certified to operate in the band. The technical rules for AeroMACS are derived from ICAO-adopted Standards and Recommended Practices (SARPS) and RTCA and EuroCAE published documents.
4. Eligible Users. The Commission seeks comment on what non-Federal users should be considered “eligible users.” We have outlined in our Petition the various classes of users which in our view should be eligible users – and this non-exhaustive list includes broadly any entity which utilizes the spectrum in furtherance of the Safety and Regularity of Flight mandate for which the Spectrum was originally allocated. Airports, airlines, ANSPs and ANCPs are included in this list. We ask that you specifically support the group of eligible users described in the Petition.

Finally – we ask you to URGE THE COMMISSION TO TAKE ACTION QUICKLY. The WiMAX Forum has spent the better part of a year and a half discussing the elements of this Petition with interested stakeholders, and we salute the Commission for highlighting the key areas for consideration and comment. In your comments to the Commission, we ask you specifically to urge the FCC to adopt a Notice of Proposed Rulemaking with proposed service rules. The AeroMACS spectrum has been available for some time now and many equipment manufacturers have commercial kits available for deployment. Our labs are currently certifying two manufacturers’ equipment for compliance to AeroMACS standards. More equipment manufacturers are lining up to certify and deliver to the market innovative products and services dependent on AeroMACS spectrum being available. Many airports are waiting on the FCC Rulemaking to commence their own pilots and deployments. We believe there is broad consensus on the value of this spectrum to our ecosystem, and we urge you to ask the Commission to move quickly.

I thank you in advance for your consideration. This has been a long road, but one which has a clear and positive end in sight. With your help, we believe 2018 will be a very strong year for AeroMACS deployments in the USA. I remain completely at your disposition should you have any questions, comments or concerns.

Filing Instructions: Comments may be filed electronically with the FCC at the following link: http://fjallfoss.fcc.gov/ecfs2. Please make sure to enter RM-11793 in the field for “Specific Proceeding.” I have taken the liberty of preparing a template letter of support which some may find helpful. To access and use our template please click at the following: AeroMACS Template. If you use this template, I encourage you to personalize your letter.

I would be delighted to speak with any of you should you care to discuss this personally. You may contact me at info@WiMAXForum.org.

Please accept the assurances of our highest regards,

Declan Byrne
President
WiMAX Forum

About the WiMAX Forum
The WiMAX Forum is an industry-led, not-for-profit organization that certifies and promotes the compatibility and interoperability of broadband wireless products based upon IEEE Standard 802.16. The WiMAX Forum’s primary goal is to accelerate the adoption, deployment and expansion of WiMAX, AeroMACS, and WiGRID technologies across the globe while facilitating roaming agreements, sharing best practices within our membership and certifying products. WiMAX Forum and WiGRID Certified^® products are interoperable and support broadband fixed, nomadic, portable, and mobile services. The WiMAX Forum works closely with service providers and regulators to ensure that WiMAX Forum Certified systems meet customer and government requirements. For more information, visit www.wimaxforum.org.