900 MHz Incumbents, Vendors Weigh in on Broadband Realignment Proposal
Monday, June 10, 2019 | Comments

Industry feedback on the FCC’s proposal to realign the 900 MHz band to allow for broadband services was varied, with large incumbent utilities opposing the proposal and others supporting the realignment only with tight interference protections and voluntary incumbent relocation.

The LMR vendors are split as well, with Tait Communications supporting the FCC’s 900 MHz proposal released earlier this year, which generally follows recommendations in a 2014 pdvWireless and Enterprise Wireless Alliance (EWA) petition for rulemaking, and JVCKENWOOD and Harris opposing the proposal. Motorola Solutions supported the changes with several recommendations and caveats.

Duke Energy, the Lower Colorado River Authority (LCRA), Southern California Edison (SCE), the Critical Infrastructure Coalition (CIC) and First Energy all opposed the suggested realignment.

Following a notice of inquiry (NOI), the FCC in March proposed a 3-by-3-megahertz broadband segment to allow for Long Term Evolution (LTE) services in the band. The commission anticipates that paired 1.5- and 0.5-megahertz blocks could provide enough spectrum for 900 MHz narrowband operations.

“LCRA’s existing narrowband system would not fit within the proposed 2/2 megahertz narrowband allocation and would suffer harmful interference if forced to relocate to the compressed narrowband segments,” the utility said. “LCRA would incur significant costs to relocate to the new, smaller narrowband segments and to respond to instances of harmful interference that would occur post-relocation.”

NextEra, a utility with operations in Florida, said complex systems with 25 or more 900 MHz sites should not be forced to move, and LCRA agreed in its comments. The FCC’s March proposal defined complex systems as systems with 65 or more sites.

The FCC proposed that a new 900 MHz broadband license applicant must hold licenses covering the entire county for all 20 geographically licensed SMR blocks; reach an agreement to clear from the broadband segment, or demonstrate how it will protect all covered incumbent licensees; and agree to return all 900 MHz licenses for the relevant county, including any site-based B/ILT or SMR licenses, to the commission.

pdvWireless holds 20 geographic SMR licenses in a significant number of counties throughout the United States.

SCE said any 900 MHz incumbent should be able to apply for a broadband license in the band, and the American Petroleum Institute (API) and the Energy Telecommunications and Electrical Association (ENTELEC) agreed and said business/industry land transportation (B/ILT) and critical infrastructure industries (CII) should be able to license the 3-by-3-megahertz broadband spectrum in areas where they otherwise meet the eligibility requirements. Hawaiian Electric Companies agreed any public utility should be eligible to apply for the broadband license.

API and ENTELEC also laid out numerous recommendations and cautions — such as the high cost to replace radios and ensure coverage is maintained and interference is minimized — if the FCC moves forward with its proposal.

Although the Utilities Technology Council (UTC) generally supported the 3-by-3-megahertz broadband allocation, the council “recognizes that there are areas where it may not be appropriate to deploy a 3/3 megahertz broadband system due to the presence of large and complex narrowband systems.”

The notice of proposed rulemaking (NPRM) proposed designating 897.5 – 900.5 MHz/936.5 – 939.5 MHz as the broadband segment. The arrangement provides 1.5 megahertz of separation between the broadband segment and the 894 – 896 MHz air-ground radiotelephone service/932 – 935 MHz fixed microwave systems spectrum, and 500 kilohertz of separation between the broadband segment and the 901 – 902/940 – 941 MHz Narrowband Personal Communications Service (NPCS).

Interference was a large concern for the majority of commenters with current 900 MHz systems. UTC recommended providing 500 kilohertz of frequency separation between the broadband segment and the narrowband segment within the 900 MHz band. Currently, the commission’s proposal does not provide any separation between the narrowband and broadband segments, UTC said.

For its part, Motorola Solutions recommended that the power flux density (PFD) around broadband base stations not exceed a PFD of 1,000 microwatts per square meter across at least 98% of the area within 1 kilometers of the base or repeater station antenna, at 1.6 meters above ground level regardless of transmission bandwidth. Similarly, Motorola Solutions proposed that the conducted broadband transmitter out-of- band emissions (OOBE) limits be no greater than -23 dBm per megahertz in the band immediately adjacent to the broadband allocation.

“This level will reduce the impact of broadband splatter into the adjacent narrowband channels,” Motorola said. “This level should be kept low since there is essentially very little guard band between the broadband and narrowband allocations.”

UTC, CIC and NextEra said the 800 MHz band realignment interference parameters of -104 dBm at a mobile unit and -101 dBm at portable station should be adopted.

FirstEnergy, with operations in New Jersey, recommended an alternative band plan that it said mitigates possible interference. The plan allocates the fixed broadband transmit to the 896 – 901 MHz portion of the band and broadband subscribers to the 935 – 940 MHz portion.

“FirstEnergy’s alternative band plan mitigates possible interference to subscriber receivers and moves that possible interference to fixed receivers on both the LMR and broadband segments,” the comments said. “At fixed locations, it is possible to remedy interference through the use of receiver filtering, an option not possible in mobile subscriber receivers. The revised band plan benefits both LMR and broadband operations by moving interference possibility from numerous mobile subscriber units to a lesser number of fixed receivers where it is technically feasible to install filtering that can selectively pass or notch the offending frequency.”

Most commenters supported voluntary negotiations between narrowband and broadband licensees versus mandatory relocation and/or auctions.

UPS, a 900 MHz narrowband incumbent, said the voluntary process should be fostered for up to one year, and if a mandatory relocation or an auction process becomes necessary, the process must provide for coverage of all incumbent costs to relocate to comparable facilities, which will include far more than retuning radios.

“Further, the commission must allow sufficient time for any mandatory relocation — at least 30 months — because of the extensive planning and engineering activities necessary,” the UPS comments said. “Many B/ILT narrowband licensees may have cyclical down times that need to be respected during which relocation work is not possible. UPS, for example, has a ‘peak freeze’ window during the holiday months when the company strictly limits changes to its technology systems.”

EWA said the transition should include both an initial voluntary period and thereafter a means of addressing holdouts to avoid giving individual licensees effectively a veto power over broadband in their area. In all instances, incumbents must be provided with comparable facilities and their retuning costs must be paid by the broadband licensee.

EWA and most other commenters did not support the use of an incentive auction either as a backstop to prevent holdouts or as an initial method of band clearing.

Many entities, including CIC, suggested the FCC not impose mandatory relocation. “CIC opposes any mandatory relocation mechanism that would both interfere with the free market and potentially jeopardize critical infrastructure communications,” said the coalition, which includes the city of Los Angeles Department of Water and Power (LADWP), LCRA, NextEra, the South Carolina Public Service Authority and Harris. “These licensees should not be forced to relocate into new spectrum or deploy new systems that may be less resilient or more costly to operate, especially when the benefits of the realignment inure to a single party that to date has not put its spectrum to robust use.”

pdvWireless supports mandatory relocation for holdouts that do not participate in voluntary negotiations.

LADWP estimated its relocation costs would be at least $13 million solely in capital costs and the value of existing contracts, not including the costs to be incurred in locating and deploying alternative communications means. Last year, NextEra said its 900 MHz relocation costs would be $98 million.

Last month, pdvWireless CEO Morgan O’Brien told potential investors the company needs an additional $100 million to $150 million to carry out its 900 MHz realignment plan and offer broadband services in the spectrum. The company had $77 million cash on hand March 31.

Manufacturers that supported the 900 MHz realignment for broadband services included Multi-Tech Systems, Ericsson, Council Rock, Azetti Networks, Encore Networks, Sonim Technologies and Virtual Network Communications. Sensus USA and Critical Response also supported the realignment if they can continue offering narrowband data equipment in the band.

All the 900 MHz comments are here.

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