In an ex parte letter filed July 21, 2017, the Land Mobile Communications Council (LMCC) urged the FCC to include Public Safety in its category of licensees subject to the proposed rules on license renewal and discontinuance of operations. As written, the Second Report and Order (Order) excludes Public Safety licensees from the rule’s obligations, holding this license pool to a different standard, and does not take into consideration a recommendation the LMCC made in 2010 that Public Safety be included in whatever obligations are applicable to similarly situated non-Public Safety licensees. Additionally, the Order never explains why the LMCC recommendation was rejected. Pursuant the LMCC protocols, the letter recognized APCO’s objection to the original LMCC position as well as the ex parte letter filed by the LMCC on July 21.

In its letter, the LMCC argued that including “Public Safety licensees in these provisions would be consistent with the current rules governing license renewal and discontinuance of operation, none of which exempt Public Safety entities. Public Safety users are well aware of the critical importance of spectrum in their operations and in the operations of other wireless entities. They are prepared to share equally in the obligation to be careful stewards of the spectrum they are awarded and to provide whatever information the FCC deems appropriate to demonstrate that they have met that obligation.”

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