900 MHz NoI Comments Mixed on Broadband Allocation, Band Realignment
Tuesday, October 10, 2017 | Comments

Comments for the FCC’s notice of inquiry (NoI) were mixed in response to a petition to realign the 900 MHz band for broadband operations, with most utilities opposing any realignment and other critical infrastructure industries (CII) entities saying it would benefit future networks and licensees.

Consistent with their petition for rulemaking in the proceeding, the Enterprise Wireless Alliance (EWA) and pdvWireless recommended a bifurcation and realignment of the band to create a 3-by-3 megahertz broadband allocation at 898 – 901/937 – 940 MHz, called the private enterprise broadband (PEBB) allocation while retaining a 2-by-2 megahertz allocation at 896 – 898/935 – 937 MHz for narrowband systems.

The PEBB allocation would be a combination of the spectrum held by PDV, primarily auctioned major trading area (MTA) authorizations, plus site-based licenses purchased from private enterprise (PE) and CII entities, and the 900 MHz band channels that are unused and being held in the FCC’s inventory. The PEBB licensee would be responsible for identifying replacement spectrum for any incumbent with channels above 898/937 MHz and for all costs associated with providing comparable facilities for their continued narrowband operations.

EWA/PDV said the rules they proposed initially remain valid, with some modest modifications intended to harmonize them with rule changes adopted by the commission for broadband systems generally. The technical viability of those rules and their ability to protect adjacent operations from harmful interference have been validated by independent analyses conducted on EWA/PDV’s behalf by Pericle Communications.

EWA/PDV said they examined the possibility of adopting a dynamic sharing arrangement in the 900 MHz band, but they determined that it would not be viable in an allocation of this size.

EWA/PDV proposed overlay auctions without mandatory relocation rights for most of the 2-by-2 megahertz narrowband allocation, albeit with a time-limited, 10-channel reservation for site-based licensing, should that continue to appeal to certain PE/CII entities. They recommended that such auctions be for wideband authorizations of varying bandwidths that could attract interest from incumbent or new entrants with other than narrowband needs and thereby put into productive use spectrum that has lain fallow in many areas for decades.

To accommodate future need for narrowband systems, EWA/PDV recommend reserving until 2025 10 narrowband 12.5-kilohertz channels, if available, in the event that an incumbent or new entrant has a need for narrowband capacity.

EWA also filed separate, individual comments in response to the NoI. EWA said that narrowband private LMR (PLMR) systems will continue to play a vital role in addressing the communications requirements of the PE community for the foreseeable future, and new digital equipment offers enhanced capabilities. For that reason, EWA recommended that the FCC conduct overlay auctions in markets where at least 80 channels remain available within the FCC’s inventory to licensees for both broadband and wideband systems.

“The opportunity to deploy wideband technologies may assist PE entities that have data requirements that cannot be met on narrowband channels,” EWA said. “This auction proposal for smaller blocks of unused spectrum supported by EWA does not propose the mandatory relocation of incumbents on spectrum available for wideband use. Incumbents would be free to continue operating narrowband systems unless they came to a voluntary agreement with the auction winner.”

EWA recommended a different approach than proposed in the EWA/PDV joint comments for the geographic size of the spectrum to be auctioned. EWA recommended using basic economic areas (BEAs), rather than retaining MTAs proposed in the joint comments. “Smaller geographic areas are better suited to the coverage requirements of PE entities than are large MTAs,” EWA said.

In addition, EWA suggested that all future rule changes and allocations associated with the Part 90 services pose minimal restrictions on eligibility.

The Utilities Technology Council (UTC) and most utilities that filed comments opposed expanding commercial use of existing business and industrial/land transportation (BI/LT) channels in the 900 MHz band. UTC said it is concerned that doing so will exacerbate the shortage of available channels for private internal communications and will encourage speculation by commercial entities.

“The commission should promote utility access to broadband to meet utilities’ increasing communications needs but ensure that any realignment of the 900 MHz band protects incumbent utility narrowband communications systems and enables them to access additional channels to increase capacity and coverage,” UTC said. “In that regard, the commission should reserve the 900 MHz band for utilities going forward. Finally, the commission should retain existing site-by-site licensing in the 900 MHz band and should not adopt geographic area licensing and auctions.”

The Critical Infrastructure Coalition (CIC) consists of a broad range of electric utilities, water authorities, trade associations and equipment manufacturers that use spectrum in the 896 – 901/935 – 940 MHz and adjacent bands for critical public-safety, nuclear power plant security, utility service restoration and maintenance, smart grid applications, and emergency communications.

CIC said realigning the 900 MHz band would disrupt critical communications during any migration period. “And forcing narrowband users into a compressed segment of the band adjacent to broadband users would increase the noise floor and result in increased operating costs to maintain the same level of service and coverage,” CIC said.

CIC, which includes seven utilities, the National Association of Water Companies (NAWC), Harris and Sensus, also said placing broadband operations in the 900 MHz band directly adjacent to narrowband operations in the compressed 900 MHz narrowband segment and the 901 – 902/940 – 941 MHz narrowband PCS (NPCS) band would result in harmful interference to critical communications in both adjacent bands. “Those interference concerns will be present whether the commission pursues realignment of the band as originally proposed in the Enterprise Wireless Association and Pacific DataVision petition, through voluntary realignment on a market-by-market basis, or by granting increased operational flexibility that would allow broadband operations in the 900 MHz band,” CIC said.

CIC said that because retaining incumbent narrowband users is important, any resulting broadband segment would be required to be relatively small, particularly after accounting for a proper guard band required to protect adjacent users. The costs of realigning the 900 MHz band or otherwise introducing broadband operations would outweigh the limited benefits, CIC said.

The Association of American Railroads (AAR) also noted the cost of realigning the band, saying it could total $100 million for railroad operations alone. AAR said a relocation would require revisiting the United States’ and Canada’s cross-border arrangement and establishing strict technical requirements to prevent interference between dissimilar narrowband/wideband operations and broadband operations that are close in spectral and geographic proximity.

AAR said railroads would benefit from the flexibility provided by allowing wider channels in this band; however, the FCC should consider the possibility of wideband channels that are 50- to 500-kilohertz wide for railroads and other mission-critical users that would benefit from having additional flexibility in supporting a number of applications that do not necessarily require broadband channels at this time.

Other utilities that opposed any realignment of the band included Duke Energy, Florida Power & Light, Lower Colorado River Authority (LCRA), Exelon and subsidiaries PECO Energy and Commonwealth Edison, Edison Electric Institute (EEI) and Westar Energy. Reasons for the opposition included disruption to critical communications, reduction of available spectrum for narrowband operations and increased possibility of interference.

Western Farmers Electric Cooperative (WFEC) said it has a need for broadband network connectivity in support of its power operations and supports the proposed reconfiguration of the band in question to provide broadband operations to critical infrastructure operators, especially utilities.

The National Association of Manufacturers (NAM) and MRFAC said converting the band to geographic area licensing would strand existing B/ILT systems at their existing capacity levels and service areas, and it should not be pursued.

A filing by the Ad Hoc Refiners Group, which includes Exxon Mobile, Phillips 66 and Marathon Petroleum, said the 900 MHz band is the “private land mobile band-of-last-resort.” The companies operate large 900 MHz band narrowband LMR systems to meet their essential wireless voice communications requirements at major refineries. There is no viable replacement spectrum for these systems, the group said.

Any reconfiguration of the 900 MHz band should continue to provide sufficient spectrum for narrowband voice systems, and in the event any reconfiguration entails the substitution in assigned 900 MHz band channels, the FCC should not depart from and continue to apply its “light touch” secondary markets policies, the group said.

Southern Company Services and Sensus operate advanced meter infrastructure (AMI) systems that use NPCS spectrum immediately adjacent to the 900 MHz band and are concerned about the potential for interference.

“Southern takes no position at this time as to whether the commission should create a broadband service in the 900 MHz band or, if so, which band plan should be used,” the company’s comments said. “At this point, Southern simply observes that a plan that places as much separation as possible between the 900 MHz band and the adjacent NPCS band would significantly mitigate the potential for interference to utility and CII systems in the NPCS band.”

The Telecommunications Subcommittee of the American Petroleum Institute (API) said it generally supports rule changes for the 900 MHz band to allow for wider bandwidth CII applications band. Vendors Puloli, Motorola Solutions, General Dynamics Mission Systems, Ericsson and Assured Wireless also filed comments supporting a 900 MHz broadband service.

“In so doing, the commission must remain mindful to preserve the rights of incumbent narrowband systems and enable such networks to operate without increased potential for interference,” Motorola said.

The Texas A&M University Internet2 Technology Evaluation Center (ITEC) said it strongly supports the recommendation to allow restructuring of the bandwidth to allow Long Term Evolution (LTE) use. ITEC said a change in the 900 MHz band to allow broadband would enable the efficient use of underused spectrum that could directly benefit industry, universities and enterprises in performance of mission-critical functions.

The ITEC staff is working with the Texas A&M University smart grid center in the integration of energy and communications. “To properly manage energy consumption requires the availability of a cost-effective, secure, reliable broadband network,” ITEC said in its comments. “The 900 MHz spectrum in question by this NoI could prove to be invaluable for private network buildout by the energy sector.”

Several other organizations engaged in modernization of the nation’s energy grid to implement smart grid, industrial internet of things (IIoT) and other emerging technologies support FCC rule changes rules to allow creation of a private carrier broadband network at 900 MHz.

In its comments, the United Parcel Service (UPS) said it generally supports the proposed PEBB realignment but urged the FCC to ensure that incumbent operations in the band are not unduly impacted as a consequence of any such realignment or other change to the rules.

Finally, M2M Spectrum Networks, which also filed a petition specific to the 900 MHz band, said that since filing its rulemaking petition, it has re-focused its business activities on use of the 800 MHz expansion and guard bands, expected to become available throughout the country and in major urban areas as a result of rebanding.

Nevertheless, M2M has continued to investigate the future of business enterprise communications requirements and concluded that a 900 MHz broadband allocation would be a valuable option for that user community. M2M believes there will be a need for both the IoT network it is deploying and broadband systems designed to address business and critical infrastructure rather than consumer service.

Access all the 900 MHz NoI filings here.

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