CII Entities Tell FCC to Hold Off on 900 MHz Rulemaking
Monday, November 05, 2018 | Comments

Critical Infrastructure Coalition members met with the FCC to discuss the cost and technical challenges with reconfiguring the 900 MHz band. They said the commission should wait on a 900 MHz rulemaking until after interference testing takes place.

The FCC froze the band in September following a notice of inquiry into options for the 900 MHz spectrum.

Coalition members with representatives attending the meetings were NextEra Energy, the Lower Colorado River Authority (LCRA), Oncor Electric Delivery and Harris. Coalition members that could not attend the meeting but support the coalition positions were Duke Energy, Exelon, Alliant Energy, Salt River Project, Jackson Electric Membership Corp. (EMC) and South Carolina Public Service Authority.

Harris discussed the technical challenges of reconfiguring the 896 – 901/935 – 940 MHz band to include a 3- by 3-megahertz segment broadband segment as proposed by Enterprise Wireless Alliance (EWA) and pdvWireless. These challenges include compacting incumbent licensee networks, now spread across the 5- by 5-megahertz band, into a compressed 1.85- by 1.85-megahertz band, as no analysis exists to show that the residual bandwidth available would allow existing narrowband licensees to replicate their operations without interference. In addition, the lack of a guard band between broadband Long Term Evolution (LTE) and narrowband 900 MHz operations could be a challenge. Harris said new technical rules EWA/PDV proposed do not follow the precedent in the 700 and 800 MHz bands.

Coalition members said the Utilities Technology Council (UTC) is leading an effort to conduct testing among 900 MHz stakeholders, including representatives of PDV, to determine the potential interference impacts between narrowband and broadband systems at 900 MHz. The coalition suggested that the FCC await the findings of this testing — anticipated by the end of the second quarter of 2019 — before taking further action on the EWA/PDV proposal.

Coalition members discussed and distributed hard copies of the cost-benefit analysis and the two technical reports that NextEra submitted into the docket in September, including a technical report prepared by Harris.

NextEra, LCRA and Oncor each described how their respective organizations use 900 MHz narrowband for mission-critical communications, including emergency communications and disaster recovery.

NextEra said its Florida Power & Light (FPL) subsidiary is estimated to restore electrical service following catastrophic events such as Hurricane Irma one to two days faster because of its hardened 900 MHz voice dispatch system. Should the 900 MHz transition not work as planned, then additional costs would be borne by the residents and businesses of Florida and the nation, between $506 million and $1 billion in FPL’s areas of operation.

“… If the intent of this proceeding is to support the broadband needs of utilities and other users of the 900 MHz band, the FCC should ensure that incumbents in the band have a fair opportunity and a realistic timeframe to become the broadband licensee and acquire broadband spectrum in their respective markets, as well as greater control over how to migrate their operations,” the ex parte filing said. “The EWA/PDV proposal only gives incumbents 12 months to attempt to acquire spectrum to become a broadband licensee before it goes to auction, which is an unrealistic timeframe given the reality of how utilities and other incumbents operate.”

Last month, the UTC said the FCC’s 900 MHz freeze imposes substantial hardship to utilities and does not serve the public interest in a petition for reconsideration or clarification. The UTC asked the FCC to clarify that the 900 MHz freeze would apply only to applications by entities that are not affiliated incumbents.

The latest Critical Infrastructure Coalition ex parte filing is here.

Would you like to comment on this story? Find our comments system below.



 
 
Post a comment
Name: *
Email: *
Title: *
Comment: *
 

Comments

No Comments Submitted Yet

Be the first by using the form above to submit a comment!

Site Navigation

Close