pdvWireless Revises 900 MHz Spectrum Realignment Proposal
Wednesday, May 02, 2018 | Comments

pdvWireless revised its spectrum proposal to the FCC, which asks the commission to realign the 900 MHz band for broadband operations. The comments, filed jointly with partner Enterprise Wireless Alliance (EWA) supplemented previous filings in an FCC notice of inquiry (NOI) considering possible rule changes for spectrum in the 896 – 901/935 – 940 MHz band.

The PDV/EWA revised proposal proactively addresses issues raised by parties who supported and opposed the original proposal. The revised plan provides an opportunity for critical infrastructure and other business entities to obtain 900 MHz broadband licenses potentially years before other spectrum options become available, pdvWireless said in a statement.

The revised proposal also shifts the broadband allocation down 400 kilohertz to 897.6 – 900.6/936.6 – 939.6. This will move the broadband allocation away from adjacent 901/940 MHz narrowband PCS (NPCS) systems operated by customers of Sensus America. This shift will also create an upper and lower PLMR narrowband segment, thereby allowing greater separation between collocated frequencies in narrowband systems.

The shift of the broadband allocation spectrum is dependent on accommodating the Association of American Railroads (AAR) requirements by modifying its license, WPSF894, to channels lower in the 900 MHz band. “PDV is engaged in very constructive discussions with AAR on this subject and believes an arrangement will be reached,” the filing said.

The revision also adopts an asymmetrical emission mask by adjusting the uplink (897.6 – 900.6 MHz) mask to the standard limit of 43 + 10 log (P) dB while retaining the 50 + 10 log (P) dB mask for downlink (936.6 – 939.6 MHz) spectrum. A more stringent uplink mask was proposed to address the Sensus concern about interference to adjacent NPCS operations. This will allow critical infrastructure broadband users to access Long Term Evolution (LTE) band class 8 subscriber devices available in the global market.

The changes also rely on traditional frequency coordination processes to create broadband licenses.

"We have listened to the comments on the record and studied very minutely the radio environment of 900 MHz," said Morgan O'Brien, CEO of pdvWireless. "Today we are proposing substantive changes to our 2014 proposal, all of which are designed to ameliorate the effects of introducing a new 6-megahertz broadband allocation into an existing 10-megahertz band. What emerges is a very simple plan for creating highly valued broadband spectrum dedicated for the use of the nation's critical infrastructure industries. We respectfully urge the FCC to propose new rules incorporating the revised plan."

PDV asserted in 2014 and re-asserted in its revised plan that spectrum in the 900 MHz band is optimally positioned to enable secure, reliable private wireless networks that meet mission-critical communications needs. The FCC has an opportunity to create a broadband service on spectrum that has been allocated for more than 30 years, much of which remains entirely unused, without compromising the operations of entities that wish to continue using narrowband technology, the company's filing states.

"The FCC is charged with addressing urgent issues of national significance, and few issues should have higher priority than arming our country's critical infrastructure sectors with private, secure broadband networks that can communicate at machine speed," said Jack Markell, former governor of the state of Delaware and adviser to pdvWireless. "As a former governor, I know the dangers of letting regulatory complexity get in the way of necessary change. I also know that attacks against our nation's utility grids are increasing and that improving the security, reliability and resilience of critical infrastructure operations is in everyone's best interest."

The full pdvWireless and EWA filing is here.

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