CII Entities Continue to Push Back Against FCC’s 6 GHz Unlicensed Proposal
Tuesday, July 23, 2019 | Comments

The push by critical infrastructure industries (CII) entities to convince the FCC to rethink allowing unlicensed devices to share the 6 GHz spectrum continued with several CII associations asking the secretary of the Department of Energy (DOE) to intervene. In addition, a new report outlines the negative impact of unlicensed devices to a 6 GHz network in the Gulf of Mexico.

A letter from several associations urged Secretary of Energy Rick Perry to hold a DOE public conference on the FCC’s 6 GHz proposal or encourage the commission to fully protect CII networks in its final rules.

“We write to urge you to consider holding a public meeting on an ongoing proceeding at the FCC which could have a profoundly negative impact on our industries’ collective ability to provide safe, reliable and efficient life-sustaining energy and water services across the country,” said the letter from American Public Power Association, American Water Works Association, Edison Electric Institute, National Rural Electric Cooperative Association, Nuclear Energy Institute and Utilities Technology Council (UTC).

The letter said nearly every federal agency has acknowledged the energy and water industries as among the most critical of all the nation’s CII. The groups said the “FCC is proposing a rule which, if adopted as currently drafted, would likely cause significant reliability concerns along the energy and water infrastructure in the U.S. To avoid adverse impacts to customers, many of our individual members could be forced to rebuild parts of their infrastructure over a multiyear process because of the risk and uncertainty brought about by this rulemaking.”

In October 2018, the FCC proposed opening the 6 GHz band to unlicensed use, which would allow any commercial entity access to the band. “In most bands, unlicensed spectrum is less expensive and comes with requirements that the entities not interfere with incumbent license holders,” the associations said. “However, most bands are not used for the kinds of mission-critical purposes that 6 GHz is well suited to provide. Furthermore, the 6 GHz band is already heavily used; the entrance of new players into the band would threaten to interfere with these critical networks.”

The letter said that although the FCC knows the band is already crowded, it is moving forward because it believes it can protect mission-critical systems from disruption through an automated protection system called automated frequency coordination (AFC). “Unfortunately, the FCC’s AFC system is unproven and untested, and even those who support the concept cannot guarantee it will prevent harmful interference consistently and reliably,” the letter said.

Senate Energy and Natural Resources Committee Chairman Lisa Murkowski, in a June 14 letter to FCC Chairman Ajit Pai, specifically asked whether and how the FCC was planning on consulting the Federal Energy Regulatory Commission (FERC) and other energy stakeholders in developing the proposal.

“Although the FCC is an independent agency, its decisions have a clear and present impact on the nation’s energy and water sectors,” the letter said. “It is therefore in DOE’s interest to hold a public conference or, at the very least, encourage the FCC to ensure that its final rule contains adequate, tested and proven measures to protect the CII industries which power our ways of life.”

The full letter is here.

Separately, RigNet, which operates a 6 GHz network in the Gulf Coast, presented a report from Roberson and Associates outlining the impact of unlicensed devices to its network to the FCC.

“Unlicensed operation of small numbers of indoor devices in U-NII-5 in the vicinity of these six locations would cause extremely high levels of interference, levels sufficient to raise the interference (I/N) ratio by 25 dB and 42 dB (300 to 15,000 times),” the report said. “In order to achieve the high levels of availability and low outage levels required, interference levels into point-to-point links are recommended to meet an interference (I/N) specification of -12 dB. The expected interference caused by indoor unlicensed devices in the vicinity of these point-to-point receivers would cause the interference to exceed the specification by 37 dB to 54 dB (5000 to 250,000 times).

“These interference levels would render the point-to-point backbone links inoperable and sever the RTM (real-time monitoring) service for oil and gas production platforms in the Gulf. The disruption would also render 9-1-1 and other emergency responses inoperable.”

The full report is here. More information on the RigNet network is here.

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