More Groups Ask FCC to Stay New 6 GHz Rules Amid Interference Concerns
Tuesday, June 16, 2020 | Comments

Several more groups stepped up support for the Association of Public-Safety Communications Officials (APCO) International petition for reconsideration and petition for stay of the FCC’s 6 GHz report and order to allow unlicensed operations in the spectrum. The National Public Safety Telecommunications Council (NPSTC), Government Wireless Technology & Communications Association (GWTCA) and several local jurisdictions submitted filings supporting the APCO petitions.

The new rules are scheduled to go into effect July 27.

NPSTC said it opposes rules that do not fully take into account preventing harmful interference to critical public-safety and other essential operations in the 6 GHz band.

“Deployment of numerous unlicensed devices as addressed by the commission and the unlicensed proponents would affect the noise floor at 6 GHz, raising the risk of interference and reducing the reliability of critical public-safety microwave links,” NPSTC said. “The commission should not cite the potential to accommodate millions of unlicensed devices when addressing the perceived need for unlicensed spectrum and at the same time essentially ignore the same millions of unlicensed devices when characterizing the interference potential to public safety.”

Specifically, the FCC’s decision allows unlicensed devices intended for indoor use to operate without the requirement of automatic frequency coordination (AFC). The rules also fail to take all practical steps to ensure that unlicensed operations that do cause harmful interference with public-safety operations can be shut down expeditiously, NPSTC said.

AFC is a technical mechanism designed to help prevent unlicensed operations from transmitting on frequencies used by licensed operations in the same proximity at the same time. The commission relies on the requirement of AFC for outdoor unlicensed devices to help minimize interference to operations in the 6 GHz band. However, for unlicensed devices that are intended for indoor use, AFC is not a requirement in the 6 GHz rules adopted. There is little assurance with the rules that an “indoor” device cannot be used outdoors, NPSTC’s filing said.

The commission’s own records of enforcement cases that involve 5 GHz band unlicensed devices show that the occurrence of interference is a fact, not merely an opinion. Review of the enforcement cases also show that resolving the interference and addressing the violations, some repeated despite earlier warnings, can take months, the group said.

“Public-safety entities do not have the time or resources to track down sources of interference, and the commission’s own field enforcement resources have been reduced over the past several years,” NPSTC said. “Accordingly, prior to allowing unlicensed devices to be deployed at 6 GHz, the commission’s rules need to provide a mechanism to identify and shut down unlicensed devices expeditiously that cause harmful interference to public-safety and other critical services in band.”

Given the difficulty of recalling unlicensed devices once they are in the market and operational, NPSTC said a stay of the July 27 effective date of the FCC’s report and order is necessary and reasonable until the commission can impose such “stop buzzer” requirements as APCO requested.

In a separate filing, the city and county of Denver; the city of Kansas City, Missouri; Ozaukee County, Wisconsin; San Bernardino and Orange counties, California; and GWTCA said they have microwave interests in the 6 GHz band and are concerned about the potential of interference to these operations.

The entities said the order is devoid of any meaningful recognition of efforts, costs and consequences of interference to public-safety operations. The groups agreed with APCO’s concern about the lack of required field testing prior to equipment deployment.

The report and order is in contrast to the FCC’s action in permitting cellular carriers to move to the use of power spectral density (PSD) metrics, where the FCC took specific steps to address the potential for increased interference to public safety and where there was field testing prior to final implementation.

“It is quite stunning that the commission has now taken such a cavalier approach to the protection of public-safety services,” said GWTCA and the jurisdictions in the filing. “This is not a situation where the commission has been forced to choose between services, nor is there an urgency to make a decision. More importantly, the absolute absence of commission-mandated meaningful protections regarding public-safety services is a complete abdication of the commission’s responsibilities.”

Earlier this month, the Fixed Wireless Communications Coalition (FWCC) submitted a pleading in support of the APCO petition for stay. On June 17, the FCC denied the request of the Ultra-Wide Band Alliance (UWB Alliance) to extend the deadline for filing 6 GHz comments and replies.

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On 6/17/20, Ken Isom said:
As a first responder and an amateur radio operator, I support any existing frequencies or bands that are currently being used for amateur radio to continue to be assigned to hams as many are already deploying mesh networks that support emergency communications operations.


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