4.9 GHz Reply Comments Show Divide Over Different Band Management Proposals
Tuesday, January 25, 2022 | Comments

The reply comments in the FCC’s continuing 4.9 GHz proceeding showed a divide over whether the band should be managed on a national level or on a local level.

The 4.9 GHz band is currently dedicated to public-safety use, but over a number of years, the FCC has been looking at ways to increase use of what it describes as an underused band. In 2020, the FCC adopted rules that would have allowed stats to license portions of the band to non-public-safety entities.

After that proposal met with opposition from public safety, the FCC vacated those rules and released a further notice of proposed rulemaking (FNPRM) seeking ways to optimize use of the band while protecting public-safety use of the band.

In its reply comments, the Public Safety Spectrum Alliance (PSSA) said that the band should be preserved, enhanced and prioritized for public-safety use. The alliance reiterated its earlier comments that the most effective way to utilize the band would be to have a nationwide license for the band.

“The PSSA agrees with the recommendation of the International Association of Chiefs of Police (IACP), which suggests ‘an option using all 50 megahertz of 4.9 GHz as a single band nationwide license’ in order to enhance public-safety broadband usage of the 4.9 GHz band,” the PSSA’s filing said. “Furthermore, the 4.9 GHz nationwide licensee should have the authority to appoint a nationwide band manager in order to coordinate usage of the band, ensure interoperability and protect public safety operations from interference.”

The PSSA said that it also agrees with the IACP and the National Public Safety Telecommunications Council (NPSTC) that the band is well suited for 5G use.

“5G technology must be deployed in a way needed to serve the public-safety community with the requisite capacity, reliability, real coverage, backup power provisions, operational features, rugged devices and specialized applications required,” NPSTC’s filing said. “The most effective way to accelerate the deployment of the 5G technologies is in the 4.9 GHz band is through a nationwide licensee (and the appointment of a band manager by such licensee) to develop a spectrum plan for the use of 5G across the band, which would facilitate widespread deployment and interoperability, and lower equipment costs.”

PSSA and other public safety organizations also argued that if the commission institutes spectrum sharing similar to that used in the Citizens Broadband Radio Service (CBRS) as advocated by several commercial companies, that sharing must absolutely protect public safety’s priority use of the band.

The PSSA has advocated for the FCC to give the spectrum to the First Responder Network Authority (FirstNet Authority) to become part of the national public-safety broadband network (NPSBN) and be used for 5G for public-safety.

More than 40 public-safety professionals filed comments saying that they agreed with the PSSA’s filing and think the FCC should give the spectrum to the FirstNet Authority.

Like the PSSA, industry consultant Andrew Seybold said that he thinks the best action would be for the FCC to appoint a single band manager for spectrum and adopt the same spectrum sharing plan being using for the FirstNet Authority’s band 14 spectrum.

“I have also read and discussed other methods of frequency management with a number of individuals who have reviewed and understand both automatic frequency control (AFC) and spectrum access system (SAS),” Seybold wrote. “Neither of these forms of spectrum management can provide access equal to how spectrum management is handled within public-safety Band 14 spectrum when it is needed by public safety. The flexibility provided over the past five years by Band 14 has served the public-safety community well.”

Neil Horden, another industry consultant, said that a nationwide strategy to the band could help ensure that the spectrum meets the needs of public safety.

“This coordination will properly protect the interests of the existing public safety licensees and their systems, while creating a large enough unified market to drive costs down and thereby increase value for all the band users, especially public safety,” Horden’s filing said.

He noted that such a strategy wouldn’t necessarily limit the band to just public-safety agencies as long as those additional users are selected carefully and thoughtfully.

“The caveat is that the additional users are selected properly,” Horden’s filing said. “Complementary uses such as Critical Infrastructure could be managed by an appropriate process that assures effective priority and preemption for public safety.”

Horden also noted that many public-safety agencies do not have the staff or technical expertise to properly deploy and support a 5G network without additional assistance.

“Starting with a national strategy could provide the guidance needed for some public safety to deploy systems in a coordinated manner and provide the structure to allow others to leverage this spectrum utilizing systems deployed on a state, regional, or national basis,” he said.

While many commenters expressed support of a national plan for the 4.9 GHz band, many commenters also pushed for a more local approach to the band.

The Enterprise Wireless Alliance (EWA) noted that the initial comments in the proceeding showed a consensus on many issues, which could provide the basis for a framework.

The EWA also said that the FCC should allow non-public-safety access to the spectrum but that such access should be achieved without jeopardizing future or existing public-safety operations. However, the organization disagreed with the idea that the spectrum be given to the FirstNet Authority.

“Like the great majority of public-safety commenters, EWA opposes the recommendation of the Public Safety Spectrum Alliance that FirstNet take over control of the 4.9 GHz band,” the EWA said. “As the FCC itself has noted, that proposal raises significant legal and policy issues. Not least of those are the extent to which AT&T would assume significant control of this spectrum without the oversight normally applicable to FCC licensees and the fact that the spectrum would no longer be subject to the FCC’s jurisdiction except in the most limited sense.”

Verizon also argued that the band should not be given to the FirstNet Authority in order to promote competition in the band.

“Competition in the delivery of public-safety communications services and local determination of public-safety use of the 4940 – 4990 MHz band,” Verizon’s filing said. “Contrary to the suggestions of some commentors, a top-down regulatory approach for the 4.9 GHz band, with a single nationwide licensee or a national band manager role for FirstNet and its contractual partner AT&T, would not. Instead, competition and choice in the public-safety communications space best serves state and local first responders and emergency management agencies by unlocking innovation and optimizing their budgets.”

Verizon said it supports an approach that would “promote local determination” to give local authorities the ability to develop communications that best meet the unique needs of each community and region.

Verizon argued that such an approach was backed by a variety of public-safety organizations including the National Sheriffs’ Association (NSA) and the Association of Public-Safety Communications Officials (APCO).

T-Mobile also advocated for allowing public-safety to make decisions on how to use the spectrum at a local level.

“One key way to make the spectrum more useful is to ensure that public safety entities have the flexibility to make individualized decisions about how to employ the spectrum, including by leasing the spectrum to commercial service providers or other third parties to support both public and non- public safety use,” T-Mobile’s filing said. “That is why the Commission should not establish a nationwide framework with a single entity designated as a nationwide band manager or licensee for the 4.9 GHz band. Such an approach would frustrate the localized needs of public safety users and the services that the spectrum supports.

EWA also argued that the FCC should reject shared access models, such as the spectrum access system (SAS) used in the CBRS band.

“These models involve shared use of the same spectrum in the same geographic area, with access controlled by a central source that relies on data collected from license information to determine who is permitted to transmit on the spectrum at any moment in time,” the EWA’s filing said. “While those models may hold promise for protecting the operations of incumbent fixed facilities, experience with them remains limited and they are not without issue. Overlaying them in a dynamic spectrum environment that includes both mobile and fixed operations carries far too great a risk that interference will result, however inadvertently.”

The EWA said that it instead supports the leasing of excess capacity by licensees with exclusive spectrum rights, which is an option available to public-safety licensees operating in other bands.

“These voluntary arrangements are defined by contractual rights and allow a licensee to determine under what conditions it will permit another entity access to its spectrum,” the filing said. “Priority and preemption are not an issue since the parties determine those rights as part of the lease arrangement.”

AT&T, which is building and operating the FirstNet Network, said that it supports the commission’s goal of adopting a framework that will help address public safety’s critical need for mid-band spectrum for 5G while maximizing public-safety use of the band.

AT&T asked the FCC to:
• Create a nationwide framework that protects existing and future public-safety uses of the band;
• Adopt 5G friendly service and technical rules;
• Reject unlicensed use and any dynamic spectrum sharing model akin to the Citizens Broadband Radio Service (CBRS); and
• Not pursue an incentive auction of 4.9 GHz licenses.

Despite the objections from public-safety organizations, several other companies and organizations continued to advocate for sharing of the band.

“The record in this proceeding demonstrates that a framework for the 4.9 GHz band that leverages the scalability, reliability and adaptability of dynamic spectrum sharing technologies, such as the Citizens Broadband Radio Service (CBRS) spectrum access system (SAS) and the 6 GHz automated frequency coordination (AFC) system, would best support the commission’s goal to ensure ‘public safety enjoys maximum access to emerging broadband technologies’ while also increasing overall use of the band through a single, nationwide framework that protects and fosters the growth of, and innovation in, critical operations,’ ” said a filing from Federated Wireless, which provides SAS services for the CBRS band.

The Dynamic Spectrum Alliance (DSA) also said that it believes an automated dynamic shared access system would be the best way of achieving the FCC’s twin goals of expanding use of the 4.9 GHz band while protecting the priority of public-safety communications in the band.

“With over 185,000 commercial CBRS base stations deployed across the country and zero reports of interference to protected incumbents, including the U.S. Department of Defense, the success of the CBRS sharing model is undeniable,” the DSA’s filing said. “This success is the result of the public/private partnership that was instrumental to the development of the SAS and the rules that have been effective at protecting incumbents, and to the vibrant ecosystem of commercial devices and applications that are currently operating in the CBRS band.”

Meanwhile, critical infrastructure industry (CII) entities such as Florida Power and Light continued to advocate for allowing critical infrastructure to access the band.

“The commission has repeatedly recognized that the 4.9 GHz band is underutilized,” Florida Power and Light’s filing said. “To address the issue, commenters, including public-safety organizations, overwhelmingly support permitting CII organizations to use the 4.9 GHz band. The additional use of the band by CII users on a secondary basis will promote the band’s development with increased funding from CII entities for necessary infrastructure, which will benefit public safety organizations, CII entities, and the public alike.”

Florida Power and Light referenced NPSTC, which argued in filings that the “natural alignment between CII and public safety in preparation and response to certain natural and man-made disasters” make it so CII entities should be the only one sharing the spectrum.

“Permitting CII organizations to operate on a secondary basis would safely expand use of the 4.9 GHz band without jeopardizing public-safety operations,” Florida Power and Light said. As the American Association of State Highway and Transportation Officials (AASHTO) made clear, the commission has adopted a similar primary/secondary approach for travel information stations, so adopting that approach in the 4.9 GHz band is feasible.”

The Utilities Technology Council (UTC) also pushed the FCC to allow CII to use the band. It noted for example that CII entities are already working with public safety to use the 4.9 GHz band to support unmanned aerial systems (UAS).

“The commission should provide electric companies and other critical infrastructure industries (CII) with access to the 4.9 GHz band as such access to the 4.9 GHz band would advance the commission’s goals of making more effective use of this spectrum, because electric companies and other CII would use it to support their increasing communications needs to deliver a reliable supply of electricity that is a necessity and which our economy as well as our way of life depends on,” the UTC’s reply comments said. “Moreover, such access is compatible with public safety because electric companies and other CII design, build and operate their communications systems for similar missions.”

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