FCC Proposes Sweeping 900 MHz Band Changes, Including Voluntary Broadband Exchange
Tuesday, March 19, 2019 | Comments
The FCC proposed sweeping changes to the 900 MHz band, suggesting a realignment to create broadband licenses and moving incumbent narrowband licensees to other spectrum within the band. The proposal is a win for pdvWireless CEO Morgan O’Brien, who has been advocating for 900 MHz broadband for more than four years.

“We believe that realigning the 900 MHz band will create opportunities for robust broadband networks that fully support critical communication systems and that ensure the low latency and ultra-high reliability required by electric and other utilities, as well as other B/ILT (business/industry land transportation) and SMR spectrum users,” said the notice of proposed rulemaking (NPRM) released March 14. “Accordingly, we propose to realign the 900 MHz band to enable broadband deployment, and we seek comment on how to realign the band, how to conduct a transition, and the technical rules needed to make the realignment a reality.”

In 2014, pdvWireless and the Enterprise Wireless Alliance (EWA) filed a petition asking the FCC to realign the 900 MHz band to allow Long Term Evolution (LTE) operations.

Following a notice of inquiry (NOI), the FCC proposed a 3-by-3 megahertz broadband segment in the band. The commission anticipates that paired 1.5- and 0.5-megahertz blocks could provide enough spectrum for 900 MHz narrowband operations.

The NPRM proposed designating 897.5 – 900.5 MHz/936.5 – 939.5 MHz as the broadband segment. The arrangement provides 1.5 megahertz of separation between the broadband segment and the 894 – 896 MHz air-ground radiotelephone service/932 – 935 MHz fixed microwave systems spectrum, and 500 kilohertz of separation between the broadband segment and the 901 – 902/940 – 941 MHz Narrowband Personal Communications Service (NPCS).

The proposal does not split any of the geographic SMR license blocks between the broadband segment and narrowband spectrum, which would potentially complicate band realignment. Moreover, separate narrowband segments, rather than a single 2/2-megahertz segment, would allow greater flexibility in frequency selection for narrowband licensees to provide adequate space between co-located channels, the FCC said.

The NPRM proposes replacing the land mobile service allocation in the 900 MHz band with a mobile except aeronautical mobile service allocation on a co-primary basis with the fixed service, consistent with the allocations in the 890 – 902 MHz and 928 – 942 MHz bands in region 2 of the International Table of Frequency Allocations.

The narrowband channels would no longer have a distinction between B/ILT and SMR blocks, but instead, they would be designated as the narrowband segment available for site-based operations. The FCC said designating the narrowband segment in this way would make it easier for existing operations of both B/ILT and SMR site-based licensees to be relocated from the broadband segment to achieve band realignment.

As an alternative, some commenters in the NOI suggested realigning the entire band to create a 5/5-megahertz broadband channel. The FCC is seeking comment on both alternatives with specific questions on each.

The FCC proposed licensing the broadband segment on a geographic area basis and for 15-year terms. “Geographic area licensing promotes spectrum efficiency and expedites deployment of flexible use services,” the NPRM said. “It also provides licensees with flexibility to adjust and coordinate spectrum usage quickly, based on changing market conditions.”

The FCC plans to designate the 900 MHz broadband service as a miscellaneous wireless communications service governed by Part 27 rules. The commission asked commenters to address whether 900 MHz broadband licenses should be regulated under Part 90 rules so that broadband licensees and narrowband incumbents in the 900 MHz band would be operating under a single set of rules. Commenters favoring this approach should identify the Part 90 rules that would need to be amended and suggest specific rule language.

Voluntary Exchange or Auctions?
The commission also proposed a “market-driven, voluntary exchange process” that would allow existing licensees to come together and mutually agree to a plan for relocating site-based incumbents and transitioning the band for broadband use. “We recognize, however, that a voluntary process may not be successful in all markets, particularly those with a substantial number of incumbents,” the NPRM said.

Therefore, to facilitate a nationwide realignment for broadband uses, the commission may need to consider alternatives to be used in combination with a voluntary exchange process and is seeking comment on alternatives, including an auction of overlay licenses and an incentive auction.

Site-based incumbents would have the opportunity to relocate on a voluntary basis and allow an eligible party to acquire a broadband license on a county-by-county basis in the cleared spectrum. Under the proposal, the FCC would require the prospective broadband licensee to hold the licenses for all 20 geographically licensed blocks of 900 MHz SMR spectrum in the relevant county. The prospective broadband licensee could then negotiate with site-based incumbents to move narrowband operations out of the broadband segment and agree to clear the spectrum to enable use of 3/3-megahertz of contiguous spectrum. The new broadband licensee could then apply for a license to operate on a primary basis in the 3/3-megahertz broadband segment in each county it successfully clears.

The FCC said a new 900 MHz broadband license applicant must hold licenses covering the entire county for all 20 geographically licensed SMR blocks; reach an agreement to clear from the broadband segment, or demonstrate how it will protect all covered incumbent licensees; and agree to return all 900 MHz licenses for the relevant county, including any site-based B/ILT or SMR licenses, to the commission.

In a statement, O'Brien said pdvWireless holds 20 geographic SMR licenses in a significant number of counties throughout the United States. "If the FCC allows the broadband applicant to include geographic SMR-allocated channel blocks held in the FCC's inventory, a possibility raised in the NPRM, PDV is optimistic that it can satisfy the first eligibility criterion in additional counties following successful negotiations with the limited number of other geographic licensees around the country, some of which are already in discussion with PDV," he said.

The FCC also questioned how to mitigate a windfall that might thereby be attributed to such an applicant. pdvWireless said it will need to address this issue, both in this context and in the context of exchanging narrowband for broadband spectrum. "PDV believes it has identified powerful public interest arguments to justify such an action by the FCC, arguments the FCC itself has advanced recently," O'Brien said.

Buildout and Interference
The commission is also seeking comment on requiring a 900 MHz broadband licensee to provide reliable signal coverage and to offer service to at least 45 percent of the population in each of its license areas within six years of the license issuance date (first performance benchmark), and to at least 80 percent of the population in each of its license areas within 12 years from the license issue date (second performance benchmark).

In recent proceedings, the FCC has applied the power spectral density (PSD) concept when adopting transmission power limits because a PSD model allows greater broadband coverage than non-PSD limits, the NPRM said. “We propose to permit an effective radiated power for base and repeater stations in the broadband segment not to exceed 400 watts/megahertz in non-rural areas and 800 watts/megahertz in rural areas, with the maximum permissible power decreasing as the HAAT (height above average terrain) rises above 304 meters,” the NPRM said. “For operations in the Canada/Mexico border region, licensees are subject to international agreements between Canada and Mexico.”

The FCC also proposed establishing a median field strength limit of 40 dBµV/m at any given point along the geographic license area boundary in the broadband segment unless the affected licensee agrees to a higher field strength limit. This limit corresponds to the current field strength limit at the border between co-channel 900 MHz SMR licensees.

"The in-band interference analyses prepared by Pericle Communications and Ericsson confirmed that broadband and narrowband facilities could co-exist within the 900 MHz band, as long as the broadband system adhered to the technical criteria proposed by PDV/EWA (Enterprise Wireless Alliance)," O'Brien said in the pdvWireless statement.

Broadband licensees would be responsible for preventing harmful interference to narrowband operations and for resolving any interference in the shortest time practicable, the FCC proposed. The FCC is seeking comment on technical rules designed to prevent interference between users of the band, as well as users of adjacent bands.

“Additionally, we propose to establish an out-of-band emission limit outside a licensee’s frequency band of operation to be attenuated by at least 43 + 10 log (P) dB for uplink operations in the 897.5 – 900.5 MHz band and by at least 50 + 10 log (p) dB for downlink operations in the 936.5 – 939.5 MHz band,” the NPRM said.

“Narrowband operations continue to be critical to certain users of PLMR (private LMR) bands, and we recently took action to promote greater capacity and efficient use of PLMR spectrum for narrowband operations in the 800 MHz band,” the FCC said. “In light of the continuing evolution of technology and the marketplace, and consistent with the commission’s recent efforts to increase access to flexible-use spectrum, we propose to reconfigure the 900 MHz band to facilitate the development of broadband technologies and services as well, including for critical infrastructure.”

Comments will be due 60 days following publication in the Federal Register. The full NPRM is available here.

The statement from pdvWireless' O'Brien is here

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