L3HARRIS TECHNOLOGIES, INC Communication Systems 1680 University Avenue Rochester, NY USA 14610 Phone 1‐585‐244‐5830 Fax 1‐585‐242‐4755 l3harris.com February 28, 2020 Via Electronic Filing Federal Communications Commission Wireless Telecommunications Bureau 445 12TH Street SW Washington, DC 20554 Attn.: Marlene H. Dortch, Secretary RE: In the Matter of FCC WT Docket No. 17-200 FCC Public Notice DA 20-118 (Released February 3rd, 2020) LCRA Request for Extension of Time for Construction Dear Ms. Dortch: L3Harris Technologies, Inc. (L3Harris) provides this letter supporting the request of the Lower Colorado River Authority (LCRA) for an extension of time to complete LCRA’s implementation plan and construction using its 900 MHz frequencies. Background L3Harris has for nearly 25 years, supplied LCRA with radios and base stations supporting their more than 8,000 users on their 900 MHz communications network. LCRA purchased and constructed its original Enhanced Digital Access Communication System (EDACS™) from a predecessor of L3Harris in the mid 1990’s. In approximately 2005, L3Harris announced that EDACS™ was going into its End-of-Life stages. At that time, LCRA opted to transition to a highly efficient digital trunked radio system known as OpenSky™, obtained additional frequency licenses and has been rolling out its OpenSky™ system since then. In 2017, L3Harris informed LCRA that OpenSky™ system was approaching end of life due to equipment obsolescence but no firm date was established. In February 2020, L3Harris announced the End-of-Life of its 900 MHz OpenSky™ products and LCRA finds itself needing to plan its system migration to the P25 standard. Beyond Control of LCRA The decisions by L3Harris to suspend production and support of the EDACS™ and subsequent 900 MHz OpenSky™ radio system architecture were beyond the control of LCRA and were wholly determined by L3Harris. The 900 MHz OpenSky™ End-of-Life notice was officially released by L3Harris on February 7th, 2020 and is attached hereto as Appendix A. Page 1 or 4 L3Harris Technologies, Inc – LCRA Letter of Support In the Matter Regarding FCC WT Docket No. 17-200 FCC Public Notice DA 20-118 (Released February 3rd, 2020) LCRA Request for Extension of Time for Construction February 28, 2020 LCRA Next Steps L3Harris and LCRA agree that the immediate and highest priority next step is the development of a migration plan to address the transition of the LCRA system technology from OpenSky™ to P25. The migration plan is the priority as this plan will wholly dictate the order and pace of the deployment of the new P25 infrastructure and the methodology to implement dual OpenSky™ - P25 capability in order to minimize the system impact to the LCRA users. The additional and currently unused 900 MHz channels are definitely required by LCRA to deploy the new P25 architecture alongside the existing OpenSky™ system. The capacity challenges facing LCRA in transitioning from OpenSky™ to P25 Phase 2 technology offer no ability to relax the frequency count. For example, similar to P25 Phase 2, OpenSky™ technology affords two (2) simultaneous talk-paths on one RF channel; however, P25 Phase 2 also requires a separate RF channel to be the Control Channel. OpenSky™ technology avoids the Control Channel issue since it uses an embedded control schema. This means that for each OpenSky™ site, the channel count required at each site needs to increase by one (1) additional channel to act as the P25 Control Channel in order to maintain identical capacity for the OpenSky™ to P25 transition. L3Harris believes that the requested extension of time is required in order to successfully manage the Implementation Plan changes from OpenSky™ to P25. Denial of the extension of time and loss of the existing 900 MHz frequencies would result in a severe impact to the LCRA system users since, with the 900 MHz frequency band currently frozen to new applications, LCRA lacks the ability to secure additional spectrum. As a strategic partner to LCRA, L3Harris is in the process of developing equipment quotes and preparing contract deliverables and factory staging test procedures in order to deploy new system equipment as expeditiously as is reasonably achievable as soon as the migration plan has been fully revised and vetted. Without all of the channels currently held by LCRA, the development of a successful migration plan and launch of a smooth P25 deployment are at risk. Further, without all the current channels licensed to LCRA, the system Grade-of-Service will be negatively impacted. For all of the above reasons, L3Harris fully supports the LCRA request and requests the Commission GRANT the LCRA request for an Extended Implementation Plan. If you have any questions or need additional information, please do not hesitate to contact me by phone at 518.389.8876 or via E-Mail at [email protected] Sincerely, L3Harris Technologies, Inc. -- // ss // -- Robert H. Isby, Jr. Spectrum Engineering Unit Lead / RF Integrity Group Office Address: 434 West Sand Lake Road, Wynantskill, New York 12198 C: 518-389-8876 | E: [email protected] Page 2 or 4 APPENDIX A Page 3 or 4 APPENDIX A ‐ Continued Page 4 or 4 .