EWA Opposes KMRZ Request for CH 20 in Los Angeles

The Enterprise Wireless Alliance (EWA) has filed an opposition to the application of KMRZ-LD to relocate its low-power television (LPTV) station operations from channel 26 to channel 20 in the Los Angeles market. The application is based on an almost unfathomable misunderstanding of the use of channel 20 for private land mobile radio (PLMR) entities in the Los Angeles area and must be denied. KRMZ correctly notes that Section 74.709(a) of Federal Communications Commission (FCC) rules require LPTV stations to protect land mobile radio services (LMRS) on channel 20 within 130 kilometers (km) of the Los Angeles reference point. Inexplicably, KMRZ asserts that "there are no operating LMRS services on channel 20 within this radius. Therefore, this application is immediately grantable.” However, the FCC Universal Licensing System database identifies hundreds of PLMR facilities authorized to operate on channel 20 frequencies within 130 km of the Los Angeles reference point as well as several pending applications for channel 20 frequencies. EWA attached to the opposition a list of LMRS licensees within 130 km including the City of Los Angeles;  Los Angeles MTA; Port of Los Angeles; Orange County Transportation Authority; South Bay Regional Communications Authority; Los Angeles County Department of Public Works; the Cities of Claremont, Long Beach, Pasadena, Santa Monica, and Torrance; Northrop Grumman Systems Corporation; and numerous commercial dispatch providers, including Fisher Wireless, whose customers include critical infrastructure, medical, educational, transportation and other businesses serving the needs of the public in this area.