A Proposal for the 4.9 GHz Band
By Mark Crosby
Tuesday, October 04, 2022 | Comments
First and foremost, we understand that the 4.9 GHz was, is now and will remain primarily a band allocated for use by public-safety entities. That fact is not in dispute by the industry trade associations that represent private wireless interests, for sure public-safety advocacy groups, and those institutions whose members also serve the public welfare but fall short of the mission critical description.

But for whatever reason, the FCC just does not seem to be pleased with the state of the 4.9 GHz band. Maybe it is because it firmly believes the band is underutilized. Maybe the commission is looking for the opportunity to allow unlicensed devices into this important “mid-band” space. Maybe because maintaining the status quo after 15 years actually stunts technological advancement and greater spectrum utilization which is anathema to today’s telecommunications policy. More than likely, it is a combination of these issues.

So, where are we? The FCC’s proposal a couple of years ago to hand responsibility of the 4.9 GHz band over to the states who would then determine who would be eligible to access the band and under what economic terms seems like an act of desperation today. From the Enterprise Wireless Alliance’s (EWA) perspective, it was an innovative proposal, but went over like a lead zeppelin in public-safety circles. But it also signaled that the FCC might benefit from another option given that the other scenarios presently on the table are either liked or disliked equally. So, the authors of a joint ex parte filing came to the mutual conclusion that the FCC would benefit from a new innovative, but not a particularly controversial proposal. If the commission was willing to have the states manage the nation’s 4.9 GHz spectrum assets, why wouldn’t they take the significantly reduced risk of endorsing an organization that represents all potential 4.9 GHz users? And the added benefit? Participation from FCC-certified frequency advisory committees (FACs) that have decades of experience, spectrum management infrastructure already in place, and whose expertise may be applied towards accommodating user needs and spectrum access processes immediately.

On August 25, EWA, the American Petroleum Institute (API), the Forestry Conservation Communications Association, the International Municipal Signal Association (IMSA), and the Utility Technology Council (UTC) proposed the creation of a single band manager to serve as the organizing body for the 4.9 GHz band. While the name of the entity is not critical at this point, under the FCC’s review and approval, it would be responsible for the development of a 4.9 GHz band plan that would include, among other requirements, spectrum channelization, permitted technologies, eligibility requirements, application processes, construction responsibilities, spectrum management policies, coordination protocols, fee schedules, database development and maintenance, and inter-frequency advisory committee data sharing. This proposal is fully responsive to the FCC’s suggestion that “assigning spectrum management responsibility to a single nationwide entity might simplify the task of developing a national framework for the band.”

The devil is always in the details of course, and there will be a lot of them, but a few of the more general strategic recommendations that would be thoroughly vetted before implementation are provided below.

The fundamental objectives of the 4.9 GHz band manager (or whatever label the FCC assigns to the entity) would be to establish, following FCC approval of a national 4.9 GHz band plan, the maintenance of a national 4.9 GHz frequency advisory system and authorization capability that promotes spectrum utilization and efficiency while minimizing interference among users, and to represent the needs of 4.9 GHz users before the FCC on all regulatory and technical matters.

The entity would be established as a non-profit organization, governed by a board of directors composed of representatives from public safety, business/industrial national trade associations, and FCC-certified frequency advisory committees. Participating representatives would be volunteers and would receive no compensation for their participation.

The entity would seek designation from the FCC as the national 4.9 GHz “band manager,” and under operating guidelines agreed to by participating frequency advisory committees, would facilitate and process applications for the 4.9 GHz band in a manner virtually identical to the processes that are in place for the 800 MHz band today. Applicants would be free to utilize the services of any participating frequency advisory committee to determine spectrum availability.

The entity would maintain a database of 4.9 GHz systems, including information such as spectrum used, emission designators, output power, equipment deployed, system locations, coverage, administrative information, priority access levels, and grant, construction, and expiration dates.

The entity would also confirm the operational status of all previously registered 4.9 GHz public-safety operations to ensure database integrity. One suggestion has been that incumbents would be required to confirm their operations within a specific period of time not to exceed six months from the FCC’s appointment of the entity as the national 4.9 GHz band manager.

There are, of course, many tactical elements to this proposal that would receive a thorough analysis before implementation by the entity’s governing board. But EWA, at least, has no doubt that given the skill sets of the participating representatives, appropriate solutions would be identified.

Mark Crosby is the chief strategy officer for the Enterprise Wireless Alliance (EWA).

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