The FCC has requested comments on four petitions for reconsideration of the August 3, 2017 Second Report and Order adopting unified construction, renewal, and service continuity rules for Wireless Radio Services (WRS). The petitions were submitted by American Messaging Services, LLC, Critical Messaging Association (CMA), Enterprise Wireless Alliance, and Sensus USA Inc. and Sensus Spectrum LLC. (Sensus). The Petitioners request reconsideration and clarification of a number of issues relating to renewal showings under the new rules. Such requests include clarification that the evaluation of case-by-case renewal showings is not a license for the staff to ratchet up the standard during the implementation process or make it indistinguishable from the safe harbor standard itself. Petitioners also request that the FCC modify or clarify the safe harbor rule to reflect the mix of geographic and site-based licenses used by the messaging industry, and that a site-by-site licensee may employ the safe harbor certification when the renewal application is filed if the license is providing an accurate snapshot of its operations at the time the renewal certification is made. Oppositions to the petitions must be filed within 15 days of the publication of the Public Notice in the Federal Register, and replies to an opposition 10 days following that date.
