RSSNumerous group submitted reply comments to the FCC’s request for comments on the future of the 4.9 GHz band, spectrum that is currently exclusive to public safety.
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In its reply comments, the National Public Safety Telecommunications Council (NPSTC) and other public-safety licensees said reviewing the FCC’s Universal Licensing System (ULS) database does not provide an accurate count of 4.9 GHz licensees and said existing licensees should provide more specific information about their operations for the licensing information.
“NPSTC believes this proposed requirement is an essential first step, regardless of any other policy or technical decisions made in this proceeding,” the council said.
NPSTC also said any freeze in the band should not begin until the FCC receives Office of Management and Budget (OMB) approvals and the ULS is ready to receive the additional information.
Los Angeles County said that because the ULS mixes different types of licenses, geography and bandwidth, it is difficult to discern actual 4.9 GHz usage. The county also said the First Responder Network Authority (FirstNet) is not a substitute for use of the 4.9 GHz band.
“As one of the early adopters of band 14 usage, Los Angeles can attest to the fact that the LA-RICS (Los Angeles – Regional Interoperable Communications System) is not a substitute for the county’s use of the 4.9 GHz band,” the Los Angeles County filing said. “Combined with the loss of the T-band, loss of the 4.9 GHz band would be devastating to the county. Spectrum is not fungible.”
The county provided examples of its 4.9 GHz use. Los Angeles County Sheriff Department uses the 4.9 GHz spectrum to provide a communications downlink between air support units and dispatch. Los Angeles County Fire Department uses the spectrum to create a mesh communications link between Life Guard Tower units and dispatch. Los Angeles County Internal Services Department uses the 4.9 GHz spectrum to create a WiMAX mesh data communications link to provide critical data links during wired infrastructure outages.
The city and county of Denver; San Bernardino County, California; and the Government Wireless Technology and Communications Association (GWTCA) filed joint comments outlining public-safety uses of the band and agreeing with NPSTC that the ULS isn’t a clear picture of the spectrum’s use. The filing recommended expanded use with frequency coordination in the band.
NPSTC also reiterated that 4.9 GHz spectrum is not appropriate for commercial use, unlicensed use or dynamic spectrum sharing but endorsed a mechanism for public safety to share the 4.9 GHz band with critical infrastructure industries (CII) through coordination conducted by public-safety coordinators.
Regional Planning Committee (RPC) Region 20 said the 4.9 GHz band should continue to support public-safety communications as a primary spectrum resource. Region 20 supports the creation of a model national plan that establishes a template for the uniform creation of 4.9 GHz plans that can be amended to meet the unique characteristics found in an individual RPC. The national plan should be established through the various public-safety associations, the region said.
The Association of American Railroads (AAR) agreed with NPSTC’s concerns that opening the band to commercial use creates an unacceptably high risk to “critically important security, reliability and availability features.” AAR recommended that CII entities be granted immediate co-primary status on all channels. The association said CII eligibility should not be conditioned on providing “public safety services” as defined in Section 337(f)(1)(A). AAR agreed with commenters that raised concerns about the difficulties that would arise from limiting CII use of the 4.9 GHz band to public safety services.
AAR also said higher power limits and wider channels will benefit public safety and CII use of the band. Higher power operations will support longer links and wider channels, improving coverage and adding capacity. AAR agrees with the commission’s proposed maximum effective isotropic radiated power (EIRP) levels of 65.15 dBm for point to point and 55.15 dBm for point to multipoint.
The Utilities Technology Council (UTC), the Edison Electric Institute (EEI), National Rural Electric Cooperative Association (NRECA) and GridWise Alliance (GridWise) said comments on the record support wider channels and higher power limits to promote greater capacity and reliability for increasing communications requirements.
The Alarm Industry Communications Committee (AICC) also agreed that expansion of eligibility to use the 4.9 GHz bands, for a limited number of entities that provide safety-related services, can be accomplished without compromising public-safety use of this spectrum. The group proposed several possible safeguards for private sector use including alarm operations of the 4.9 GHz band to be considered by the FCC.
pdvWireless weighed in to support CII use of the 4.9 GHz band, while touting realignment of the 900 MHz band for broadband use.
The San Francisco Bay Area Rapid Transit District (BART) opposed a suggestion of American Petroleum Institute (API) and the Energy Telecommunications and Electrical Association (ENTELEC) that a 20-megahertz “ADR band” be created for manned aerial systems, unmanned aerial systems and robotic systems, leaving only 30 megahertz for “other use cases.”
BART’s comments supported the FCC’s proposal that an existing user should not be required to frequency coordinate for current uses. BART also proposed that BART retain a specific geographic footprint for its public-safety train control uses, so that other potential users will be on notice that BART has actual and planned critical public-safety uses throughout its operating area. BART agreed that the ULS database may need additional fields of information and good coordination.
The Enterprise Wireless Alliance (EWA) continued to support primary CII access to the band and said the FCC should adopt a 4.9 GHz band plan rather than having public safety coordinate the band. “Whatever eligibility, band plan and other rules the FCC adopts for 4.9 GHz, EWA questions the wisdom of awarding that responsibility to the five public-safety FACs (frequency advisory committees) without evaluating their qualifications for performing that task,” the EWA filing said.
A few groups, including the Wireless Internet Service Providers Association (WISPA) and GeoLinks, continued to push for secondary commercial use of the band.
“The record developed … shows that the two-tiered sharing approach is the best alternative for moving forward and achieving the commission’s goals for the 4.9 GHz band,” WISPA said.
All the comments are available here.
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