900 MHz Licensees Outline Continued Concerns with PDV/EWA Realignment Proposal
Wednesday, July 01, 2015 | Comments

By Sandra Wendelken
Sixteen entities filed comments about the Pacific DataVision (PDV) and Enterprise Wireless Alliance (EWA) proposed rules for realigning the 900 MHz band to allow broadband technology. Only one commenter — Motorola Solutions — said the FCC should move forward with a notice of proposed rulemaking (NPRM) on the matter.

The other 15 commenters opposed the proposed rules that suggest realigning the 900 MHz band to create a broadband allocation for a licensee that would offer a broadband service to critical infrastructure industries (CII) entities. Many said the additional details outlined in a May supplement do not address interference and other concerns.

PDV’s and EWA’s May filing suggested specific technical rules for operation in the broadband segment, such as emission mask and antenna height and power limits. The proposed rules also prescribed a relocation process similar to the procedure the FCC adopted in the 800 MHz proceeding. Other proposed rules discussed the conditions under which the private enterprise broadband block (PEBB) licensee would offer broadband arrangements to requesting entities, and the interference protection that the PEBB licensee must provide to systems operating in the 901 – 902/940 – 941 MHz band.

The Utilities Telecom Council (UTC) and two utilities, Duke Energy and Salt River Project (SRP), said the process for the proposed realignment of the band should provide licensees with sufficient notice and an opportunity to negotiate to participate in the PEBB or to relocate into the narrowband allocation. Similarly, there should be more than one “realignment manager” to ensure fairness, the entities said.

Interference protection and compensation should be available to incumbent licensees who operate anywhere in the 900 MHz band, not just those incumbent licensees that relocate from the PEBB allocation to the narrowband allocation, the utility groups said. “The interference threshold should be set at a lower level than -88 dBm; and there needs to be a guard band to protect narrowband operations below 937 and above 940 MHz,” UTC and in its filing.

Incumbents who are relocated below 937 MHz need to be provided comparable facilities in terms of cost, quality, reliability and resiliency — and costs need to account for all additional ongoing operational and capital expenses with no limit on the time period, the groups said. Finally, a cost-benefit analysis of the proposed realignment that includes the estimated cost of relocating incumbents and of constructing, operating and maintaining the PEBB in each major trading area (MTA) based on a proposed set of standards for coverage, reliability and resiliency should be developed at the outset.

The Ad Hoc Refiners Group, composed of Exxon Mobil, Marathon Petroleum and Phillips 66, said the proposed rules should permit spectrum aggregation solely through voluntary negotiations. And any proposed rules should be limited to defining the technical parameters of PEBB operations so that broadband operations in the PEBB sub-band don’t interfere with existing 900 MHz narrowband systems, preferably with a guard band. The group also said the proposed rules’ specific output powers are well below the output powers of portables and mobiles operating on the 900 MHz narrowband systems deployed at their refineries.

Several of the oil companies also acquired 900 MHz channels through voluntary negotiations to meet narrowband wireless needs at the refineries. “The commission should not change the rules under which PDV and the companies acquired their 900 MHz band assignments to either’s advantage or disadvantage,” the filing said. “CII entities’ narrowband communications requirements are no less critical than the proposed PEBB service that remains very much a work in progress.”

“The idea of a mandatory migration modeled after 800 MHz rebanding rules is very difficult for people to stomach,” said Douglas Jarrett, partner at Keller and Heckman, which filed comments for the Ad Hoc Refiners Group. “And then you have the interference question on top of that and the level of disruption.”

Other CII firms that filed comments stating that their concerns had not been adequately addressed or that the proposed rules failed to resolve interference concerns included Sensus, M2M Spectrum, Sensus Partners & Advisors Network (SPAN), Lower Colorado River Authority (LCRA), Southern Co., Eversource Energy, PECO Energy and NextEra Energy.

The American Petroleum Institute (API) filed comments with concerns on several areas of the rules, including the proposed power and antenna height limits, proposed licensing rules, realignment agreements between the PEBB licensee and incumbents, retuning cost reimbursements, priority access requirements for the proposed broadband service and interference protection rights.

“Due to the sensitivity and importance of current uses of the 900 MHz band, API urges the commission to conduct an extremely diligent review of petitioners’ proposals to ensure protection of current and future narrowband operations before initiating a rulemaking proceeding to adopt them,” API said.

The Association of American Railroads (AAR) comments had a similar theme. “AAR is not inclined to support the proposal because of its continued concerns regarding the potential interference from the proposed PEBB service to adjacent-band operations, particularly those operations of AAR member railroads,” AAR’s filing said.

While Harris filed comments opposing the PDV/EWA petition, Motorola Solutions said it believes the proposal would preserve incumbent spectrum rights.

However, Motorola also discussed the proposed interference protection standards. “Motorola Solutions therefore urges the commission to consider whether protection standards below -88/-85 dBm are warranted,” the company’s filing said. “While the standards adopted for 800 MHz public-safety systems may not be directly applicable here due to differing receive performance levels, additional protection is warranted to prevent interference well within the expected service areas of incumbent systems.”

Reply comments in the proceeding, No. RM-11738, are due July 14.

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