NPSTC: Results of Spectrum Sharing Still Unclear, Protecting Incumbents Unresolved
Monday, September 17, 2018 | Comments

The National Public Safety Telecommunications Council (NPSTC) submitted comments specific to the Spectrum Pipeline Act, which requires the FCC to provide an opportunity for public comment before submitting a report to Congress that analyzes the results of the 2015 3.5 GHz rule changes and proposals to identify additional spectrum between 6 and 57 GHz.

NPSTC said the priority facilities that the Citizens Band Radio Service (CBRS) 3.5 GHz rules must protect are primarily U.S. Navy shipboard radars and ground-based radar sites at listed military installations.

The council said it is premature for the FCC to report to Congress that the results of the rules adopted for 3.5 GHz are either a success or a failure in managing the spectrum. Although some testing has been conducted, any significant operation of CBRS devices has yet to occur. Accordingly, it is not yet possible to accurately determine whether the real-world results of the 2015 rule changes relating to the frequencies between 3.55 and 3.65 GHz are positive or negative, NPSTC said.

Regarding the 6 – 57 GHz spectrum, the record is full of filings on both sides of the equation, some expressing significant concerns about the potential for interference to 6 GHz microwave networks and others claiming that sharing can be implemented with minimal interference, NPSTC said.

“Although there is no agreement on the potential for sharing, there is adequate information in the record to show that the 6 GHz band is extensively used,” the comments said. “For example, AT&T submitted [a] map of microwave links in the band and advised the 6 GHz band currently supports approximately 100,000 microwave links.”

AT&T is the contractor for the First Responder Network Authority (FirstNet) nationwide public-safety broadband network.

NPSTC said it is pleased to see the involvement of the FCC’s Office of Engineering and Technology (OET) as real spectrum management inherently involves engineering, not merely political direction and spectrum auctions.

NPSTC recommended that the commission be clear in its report to Congress that incumbent usage in the 6 GHz band is significant, and that protection of incumbents is a complex issue yet to be resolved. The congressional direction to find an additional 1 gigahertz of spectrum for sharing should not predetermine engineering that must be done by OET and users of the 6 GHz band to assess whether sharing can be implemented with no interference to critical microwave links in the band, the council said.

The full comments are here.

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