(Mclean, VA)    The Land Mobile Communications Council (LMCC) has submitted a letter to the FCC suggesting that, during the FCC’s review of requests from entities seeking to be certified as frequency advisory committees, that one of the fundamental requirements for receiving FCC-certification is that the entity must be “representative” of the applicants and licensees that it serves. This has been interpreted consistently by FACs to mean that they are to be overseen by and responsible to licensees for whom frequency coordination services are provided. This requires, in the opinion of the LMCC, that an FAC “… have a representative governance structure that directly oversees the development and implementation of all FAC-related policies and procedures.”

The LMCC suggested further that those “serving in that capacity should be appointed or elected by their peers, and not chosen by the very FAC staff whose activities they are to oversee. Whether those activities are performed entirely by FAC employees or contracted to others, the FAC governing body must be accountable for ensuring that the Commission’s standards for representativeness, non-discrimination, technical expertise, and nationwide coordination capability are fully satisfied. FCC certification of any entity that does not have an independent governance structure would undermine the credibility of the entire frequency coordination process upon which the Part 90 spectrum is made available.”

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