Unfortunately, it appears that the public safety coordinators aren’t particularly interested in responding with any degree of clarity to the B/ILT frequency advisory committees (FACs) suggestion that it is necessary to identify processes and standards that would trigger a public safety applicant’s ability to access B/ILT frequencies. Because we want to and will seek access to B/ILT spectrum whenever the mood strikes us on a case-by-case basis shouldn’t cut it anymore. More recently, the B/ILT FACs asked a number of questions, perhaps the most critical of which is how PS FACs determine that the assignment of a frequency would cause “interference” to an incumbent without a contour or other standard for defining permissible co-channel operations.  A non-answer was forthcoming that was clear as mud, specifically, “We believe that our obligation when requesting B/ILT channels is to satisfy the FCC requirement of the channel scarcity in the PS pool and the need to utilize B/ILT channels.”  Unfortunately, the PSCC’s description of the various bases on which PS coordinators conclude that there are no available public safety frequencies confirms that, in some instances, the determination is not based on FCC rules or on a technical analysis that is susceptible to review.  As a result, the B/ILT coordinators will soon be implementing procedures that will be applied when any B/ILT coordinator receives a public safety application seeking waiver concurrence to use B/ILT spectrum. These procedures will not be applied on a case-by-case basis, but every time.