The FCC has released an NPRM seeking comment on its proposals to revise Part 20 of its rules governing commercial mobile radio services (CMRS). The FCC proposes to streamline and harmonize requirements for wireless licensees and applicants and eliminate the presumption that all Part 20 applicants intend to license their facilities as CMRS operations. The FCC notes that there has been an in increase in the use of wireless services for internal and private mobile radio service operations, such as state and local governments using paging frequencies to support public safety operations, licensees providing service to only specific entities such as a hospital or school, or by commercial businesses using spectrum for internal operations. The FCC states that the proposed revisions are intended to eliminate the burden on applicants and licensees that desire to operate on a non-CMRS basis of having to overcome the presumption that their service offerings are CMRS. This proceeding is part of the FCC’s process reform initiative to update and modernize Part 20 and related rules. Comments will be due 60 days after publication of a notice in the Federal Register, and replies will be due 30 days later.