900 MHz Incumbents Want Access to Broadband Licenses in the Band
Monday, July 08, 2019 | Comments
Several common themes stood out in reply comments filed in the FCC’s 900 MHz realignment proceeding, which proposes a 3-by-3-megahertz broadband segment to allow for Long Term Evolution (LTE) services in the band.

First, incumbent utilities said they should be allowed to become broadband licensees in the 900 MHz spectrum. In its proposed rules released in March, the FCC would require a prospective broadband licensee to hold the licenses for all 20 geographically licensed blocks of 900 MHz SMR spectrum in the relevant county.

“That criterion would limit the eligibility to a single party – not surprisingly, PDV (now called Anterix),” said Southern California Edison (SCE) in reply comments. “Those parties who expressed a view on the subject were universally opposed to that approach. Apart from the obvious appearance of highly preferential treatment to one company, several commenters, including SCE, objected to directing the broadband license to a non-utility whose only incentive would be to monetize the sale or lease of the spectrum without adding any value of its own to the process.”

SCE reiterated its position that eligibility for a 900 MHz broadband license should be expanded to include all 900 MHz incumbents. The Utilities Technology Council (UTC) agreed that incumbent critical infrastructure industries (CII) licensees should be eligible for 900 MHz broadband licenses.

“Specifically, utility networks like LCRA’s (Lower Colorado River Authority) are heavily encumbered, and SMR networks are underused,” UTC said. “Thus, in certain areas, large site-based incumbents may actually be better positioned to effectuate the relocation to broadband operations.”

UTC also suggested adopting a 3-by-3-megahertz broadband allocation but allowing licensees to adopt a 1.4-by-1.4-megahertz configuration within the 3-by-3 segment to avoid interference with narrowband systems. UTC and other commenters urged the FCC to protect against adjacent channel interference to narrowband PCS (NPCS) channels by using at least 500 kilohertz of frequency separation.

The Ad Hoc Refiners Group said the proposal to add broadband services in the band will adversely affect the narrowband systems operated by the refiners. The group said there are areas of the country in which a 3-by-3-megahertz broadband allocation is not appropriate because of the presence of large or complex 900 MHz narrowband systems.

“In many of these areas, a 1.4-by-1.4-megahertz LTE-compliant band could be authorized, providing a critical guard band between the narrowband and broadband segments and allow expansion of the critical 900 MHz narrowband systems. This flexible approach is particularly important for the refiners. … In their core areas, expansion of 900 MHz narrowband systems are the only option.”

Most reply comments argued for voluntary relocation and said any mandatory relocation should exclude complex systems.

“EWA (Enterprise Wireless Alliance) agrees with the proposal in the NPRM (notice of proposed rulemaking) to exclude from any mandatory relocation arrangement systems defined by the FCC as particularly complex because of their large number of inter-related sites,” the EWA said in reply comments.

Incumbent licensees and the groups that represent them consistently said there should be no mandatory relocation of “complex systems,” and the definition of a complex system should be a network of 25 sites or more, not the 65 sites proposed by the FCC.

Anterix also endorsed the recommendation that complex systems be exempt from any mandatory relocation provisions. In its reply comments and in a June 26 ex parte filing, Anterix, formerly pdvWireless, representatives expressed their support for the “success threshold” solution to the holdout problem following voluntary relocation.

Under this approach, once a prospective broadband licensee is able to present a transition plan that documents its right to clear a defined percentage of channels in the broadband segment, it would be able to require the cooperation of any remaining incumbent in the retuning of its system. Anterix said the success threshold has “solid economic support and will do much to alleviate the holdout problem and permit the socially valuable repurposing of spectrum to occur.”

Others disagreed. “The mandatory success threshold proposal is at best a solution in search of a problem and at worst a goad that will be used by broadband operators to force below-market terms on incumbents,” Alliant Energy said in its reply comments. “The commission should reject that proposal and trust in the integrity of a completely voluntary exchange process to deliver true market-driven results.”

All incumbents reiterated their calls for comparable facilities and strong interference protection through a guard band if realignment moves forward. Several reply commenters warned the commission that it is underestimating relocation costs.

“AAR calculated that its relocation costs could total $70 million if all six channels were relocated and roughly $35 million if only three channels were relocated,” the Association of American Railroads (AAR) said in its reply comments.

Other incumbent licensees pegged their relocation costs between $10 million and $20 million. Incumbent Caesars Entertainment Group in Las Vegas said costs would extend beyond retuning equipment to include purchasing equipment, renting equipment during the retuning process, and planning and implementing the change in frequencies. The activities would necessarily increase business expenses and labor costs.

“The cost of retuning increases significantly when thousands of radios are involved. Each radio and associated equipment, such as transmitters, must be individually retuned,” Caesars reply comments said.

Anterix CEO Morgan O’Brien told potential investors May 21 the company needs an additional $100 million to $150 million to carry out its 900 MHz realignment plan and offer broadband services in the spectrum. The company had $77 million cash on hand March 31.

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