Comments on Motorola's petition for a clarification or waiver of the licensing procedures pertaining to low-power operations under Part 90 of the Federal Communication Commission's rules are due April 19, 2010.

The Federal Communications Commission (FCC) has requested comment on a petition filed by Motorola asking for a clarification or waiver of the licensing procedures pertaining to low-power operations permitted under Part 90 of the FCC's rules in the 450–470 MHz band (450 MHz band). Comments are due April 19, 2010, with reply comments due May 4, 2010.

Under Section 90.173(i) of the FCC's rules, frequencies in the 450 MHz band are ordinarily assigned in pairs, with the mobile transmit frequency 5 MHz above the paired base station transmit frequency. Section 90.267 of the FCC's rules provides that certain frequencies in the 450 MHz band are designated for low-power use, subject to varying coordination and operating conditions or restrictions.

In July 2009, Motorola sought a declaratory ruling that low-power systems authorized pursuant to Section 90.267 are not subject to the requirement in Section 90.173(i) of a standard 5 MHz separation between paired 450 MHz band base and mobile transmit frequencies. Motorola asserts that the standard separation applies only to the primary frequencies in the band spaced 25 kHz apart and not to offset frequencies between them, including the low-power frequencies set forth in Section 90.267.

Most recently, Motorola supplemented its petition by alternatively requesting a blanket waiver of the separation standard with respect to all applications for low-power operations in the 450 MHz band that are submitted pursuant to Section 90.267. Motorola argues that a waiver would serve the public interest by promoting more effective utilization of spectrum, because it would facilitate the deployment of low-power repeaters with non-standard separation to avoid the occurrence of intermodulation interference when multiple repeaters are used within close proximity.

Motorola states that the 5 MHz separation requirement creates intermodulation problems when multiple repeater cells are used within close proximity. Motorola claims that there is significant demand for low-power repeaters or mobile relay devices to provide more reliable on-site coverage to multiple end users. Motorola asserts that because of the intermodulation issue, enterprise users with a large number of low-power radios using multiple channels for unit-to-unit communications cannot now deploy multiple on-site repeaters if additional coverage is needed. Motorola states that where service areas are confined, the operating environment may be quite hostile with obstructions that unit-to-unit communications solutions cannot overcome. By permitting non-standard pairing of the low-power channels subject to frequency coordination under Section 90.267, Motorola argues that enterprise users will be able to save costs while minimizing the potential for interference.

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