API Members Say Anterix Not Addressing 900 MHz Interference Concerns
Wednesday, March 25, 2020 | Comments

American Petroleum Institute (API) members called out Anterix for not providing enough information on how it plans to remedy interference concerns in the 900 MHz band and said refineries can’t give up critical spectrum until the issues are addressed.

Last year, the FCC proposed sweeping changes to the 900 MHz band, suggesting a realignment to create broadband licenses and moving incumbent narrowband licensees to other spectrum within the band. The proposal is a win for Anterix, which has been advocating for 900 MHz broadband for more than four years.

API and its members, such as ExxonMobil and Phillips 66, said the FCC should refrain from approving any type of order in the 900 MHz proceeding until Anterix has undertaken the necessary work and conversations to understand the impact of its proposals on the critical narrowband communications of API members in the band. The amount of spectrum at stake is small but critical to API members’ narrowband communications and to safety inside and outside of their facilities, the filing said.

“Unfortunately, Anterix has not, to date, produced interference studies, detailed transition plans or remediation plans that alleviate the substantial concerns raised by API and its members in the docket,” API said in an ex parte filing. “It is not acceptable to knowingly move forward with a new band plan that could cause interference to the safety communications of refineries and petrochemical facilities or to rely on remedies after the fact. Moreover, the commission and Anterix need to be clear that a 3x3 megahertz LTE (Long Term Evolution) channel has neither the speeds nor the bandwidth to support the ‘refinery of the future’ and is of no value to API’s members.”

API outlined several items Anterix should be required to do before action is taken in this proceeding. Anterix needs to provide studies demonstrating that the new band plan will not result in broadband interference to critical narrowband communications systems, which can be evaluated and verified by the FCC and industry. For incumbents that voluntarily transition to the new band plan, Anterix needs to study the co-channel and adjacent channel interference to impacted narrowband 900 MHz licensees that are using the spectrum for safety and emergency communications and propose mitigations that will ensure protection of those licensees.

Anterix also must demonstrate that the existing rules, generally establishing 70-mile separation distances between co-channel 900 MHz licensees and that were designed to separate co- channel narrowband operations, will be sufficient to prevent both co-channel and adjacent channel broadband interference to incumbents.

In certain areas with high narrowband use, including Houston/Gulf Coast and Los Angeles, the math of the proposed Anterix transition simply does not work. Anterix needs to present an actionable transition plan that demonstrates how current and future narrowband operations will be satisfied in these markets, with a smaller amount of spectrum, the filing said.

API said Anterix recently contacted the institute for meetings with API and its members, and the institute is working to set up a joint meeting. The FCC should allow time for those conversations and the necessary evaluations to take place and allow time for consultation with the Commission, before any action is taken in the proceeding.

If API and Anterix reach a positive understanding that supports moving to the new 900 MHz band plan, the FCC must ensure that incumbent users have access to enough channels in the future to satisfy expected growth. At least 20 additional narrowband channels must be reserved in the Houston major trading area (MTA), for example, with similar reserves in the New York, San Francisco, Los Angeles and New Orleans MTAs.

API said the commission also must decline to require a mandatory transition process. The proposed 3-by-3 megahertz broadband channels cannot be used by all narrowband incumbents, and there are no viable spectrum alternatives for narrowband communications. Maintaining and protecting use of the 900 MHz band for API members is essential for safety and emergency communications.

“The commission cannot leave disruption of these critical industry players to chance,” the filing said. “API and its members, the purported beneficiaries of Anterix’s proposal, do not see a positive cost/benefit analysis in the Anterix plan. The cost to critical industries, such as our nation’s refineries and petrochemical facilities, is too high, when weighed against the absence of ‘benefits’ from a 3x3 megahertz broadband channel. The risks associated with the Anterix proposal for the 900 MHz band, with no apparent benefits for API members, suggests that there is no reason for positive commission action at this time.”

Earlier this year, the Ad Hoc Refiners Group met with FCC officials and discussed similar concerns, including challenges in securing narrowband 900 MHz channels in high-density markets for refineries.

The full API filing is here.

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