Greetings. Just now, after approval from the Executive Committee and following helpful edits from Dave Sumner, I filed the attached Petition to Deny 68 pending applications for Part 90 licenses in the Public Safety service. These license applications were filed for the sole purpose of authorizing operation of the ReconRobotics device in the 433-445 MHz band. There were several flaws in these applications (stemming from flaws in the grant in April of certification for the ReconRobotics device by FCC's OET). While we are not optimistic that the applications will ultimately be denied, we have most certainly slowed them down a good bit pending FCC action on our Petition for Reconsideration in the ReconRobotics docket (08-63), whatever that turns out to be. We can be certain that the devices are already in the hands of the 68 public safety entities that applied for them. The applications were prepared and filed by the frequency coordinator, APCO, and probably were arranged and paid for by ReconRobotics, so we will likely hear back from ReconRobotics directly.The major problems with these applications are that they: (1) specify a 100 kHz emission designator, when the necessary bandwidth of these channelized devices is 6 MHz; and (2) they specify a narrower frequency range (433-445 MHz) than is specified in the ReconRobotics waiver (430-448 MHz). The waiver order specified operation on three channels in that latter range, in a specific order of priority. The first unit sold to an eligible entity has to operate in the 436-442 MHz range. So the frequency range specified in each of the subject applications (each of which specifies only one device) makes no sense at all. Again, however, the applications reflect what showed up in the grant of equipment authorization. But in any case, there are good, technical reasons to ask that these applications be dismissed.73, Chris W3KD
Christopher D. Imlay
Booth, Freret, Imlay & Tepper. P.C.
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
W3KD@ARRL.ORG