The Eighth Report and Order and subsequent public notice require existing geographic licensees to provide site-specific usage information by June 9, 2025. Thus, unless the FCC’s decision in the Eighth Report and Order is overturned, this document provides recommendations which can be used by geographic licensees to meet the FCC’s requirements.
As discussed previously, existing licensees are limited to their existing operations during the pendency of the FCC’s freeze, and if the FCC’s order remains in place as current written, those limitations will remain in place. However, informal inquiries with the FCC staff indicate that it is not the FCC’s desire to stop existing licensees that were in the process of constructing transmitter sites (a process which can take several years) from completing their work. Because the FCC has not issued a document identifying any limitations on continued construction, and because this document is not designed to provide legal advice, it is suggested that impacted licensees and users individually contact the FCC’s Public Safety and Homeland Security Bureau to determine whether the particular ongoing work for that system may be completed without violating the FCC’s ongoing freeze in the band.