Public Safety Advocates for 4.9 GHz, CII Requests Access
Monday, July 09, 2018 | Comments

Public safety came out in strong support of the 4.9 GHz band, again suggesting critical-infrastructure industries (CII) be given access to the band but strongly opposing further unlicensed or licensed access. Only a few entities filed comments requesting the band be opened to commercial services.

The National Public Safety Telecommunications Council (NPSTC) questioned the FCC’s calculation that no more than 3.5 percent of the potential licensees use the band, calling the percentage “suspect.”

NPSTC reviewed the FCC’s 4.9 GHz licensing records from the Universal Licensing System (ULS) and determined there are 18 states that hold licenses at 4.9 GHz, comprising a population of 138 million people that public safety is serving.

NPSTC said there is a need to maintain the 4.9 GHz spectrum to support emerging technological advances that enable public-safety operations. NPSTC highlighted airborne operations including manned aircraft and unmanned aerial systems (UAS), robotics and the public-safety internet of things (IoT). “All of these new technologies require spectrum support that the 4.9 GHz band can help provide,” NPSTC said.

The Association of Public-Safety Communications Officials (APCO) International said public safety’s dedicated access to the 4.9 GHz band must be preserved. “Public safety is using the 4.9 GHz band to support localized, bandwidth-intensive applications for mission-critical use cases,” APCO said.

Several public-safety agencies and other 4.9 GHz users around the country filed comments highlighting their reliance on the 4.9 GHz band. These agencies included New York City, the state of Maryland, the Denver Regional Transit District (RTD) and the National Academy of Sciences, among others. They all opposed sharing the band, citing interference concerns.

APCO said the FCC can take immediate steps to help public safety take greater advantage of the 4.9 GHz band. The FCC should require frequency coordination limited to certified public-safety pool coordinators. “Rather than adopt a band plan, the commission should permit public-safety frequency coordinators flexibility, both in terms of channel assignment and power limits, to maximize efficient use of the spectrum,” APCO said.

APCO didn’t rule out future sharing. “APCO is open to exploring a sharing framework for this band that would allow use for nonpublic-safety purposes, provided a proven sharing mechanism is in place that ensures priority and pre-emption for public-safety users,” the filing said. “Public-safety agencies should not be put in a position to lease or otherwise put a price on their use of the 4.9 GHz band.”

Four utility associations, including the Utilities Technology Council (UTC), said the 4.9 GHz band should be expanded to include utilities and other critical infrastructure industries (CII). “As it pertains to utilities, we believe our members would make quite effective use of the band as the demand for smart-grid, grid modernization, and Utility 2.0 applications increases over the next several years,” the comments said.

If the FCC expands availability to CII, utilities would likely invest in deploying communications networks in the 4.9 GHz band immediately over the next five years to support utility applications with high capacity and high duty cycle requirements, the comments said.

UTC said in a member survey, it found that all the utilities that responded planned to use the band for fixed operations, and half reported that they planned to use the band for mobile operations. About one-third of the utilities reported that they planned to deploy more than 1,000 units (transceivers) using the 4.9 GHz band.

The American Petroleum Institute (API) and the Energy Telecommunications and Electrical Association (ENTELEC) filed joint comments that agreed with NPSTC’s additional aerial, drone and robotics (ADR) use cases but said the FCC should allocate 20 megahertz instead of the suggested 5-megahertz allocation.

“…We feel NPSTC underestimates the growth of drone and robotic use cases and the technical challenges of RF interference, especially with the drone and aerial use case in large open areas,” API and ENTELEC said. “Interference can be mitigated more easily with a larger channel pool. Thus, we believe that 20 megahertz should be considered the ADR use cases and termed the ‘ADR band.’ The remaining 30 megahertz of the 4.9 GHz band that remains for other use cases, would be termed the ‘remaining band.’ ”

The two groups suggested numerous additional technical changes. API and ENTELEC do not support a leasing model with public safety serving as “spectrum landlords.”

“We believe that the commission best performs that function as the primary issuer of spectrum, even if it is on a secondary basis,” the filing said.

In its comments, the Enterprise Wireless Alliance (EWA) argued that allowing private enterprise users primary access to a significant portion of the allocation would benefit both those users and public-safety entities. EWA urged the FCC to broaden the eligibility criteria for the spectrum, but not open it for commercial use, and to adopt rules consistent with the efficient management of the allocation.

Nokia filed comments agreeing that the FCC should extend primary access to the 4.9 GHz band to CII. “Nokia differs with NPSTC, however, in that we believe that CII should gain immediate co-primary access to 20 megahertz of spectrum (not 10 megahertz as proposed by NPSTC),” the comments said. “… We envision the 20 megahertz being partitioned into multiple, exclusive 5- to 10-megzhertz blocks that could be used by different CII segments.

Nokia further supported API’s and ENTELEC’s request that CIIs be permitted to use the band for any purpose, not just in support of public safety. “By eliminating the requirement that the band be used for public-safety services by CII users, the commission will facilitate increased use of the band, lowering equipment costs, encouraging wider spread deployment and facilitating the other benefits of CII access to the band,” Nokia said. “The need for reliable, secure, dedicated spectrum for CII extends to all communications that lead to safe operation of the CII entity’s tasks, and thus communications should not be restricted to public-safety uses for such entities.”

Nokia said the FCC should also allow public-safety licensees to lease 4.9 GHz spectrum capacity to CII. The vendor also said the FCC should consider harmonizing the rules with Third Generation Partnership Project (3GPP) standards developed for 5G New Radio (NR) covering the 4.4 – 5.0 GHz range, referred to as 3GPP band N79. “This would allow public safety and CII to access 5G technologies, since harmonization would help to achieve economies of scale, enable global roaming, reduce equipment design complexity and improve spectrum efficiency,” Nokia said.

Federated Wireless, a spectrum software supplier, urged the FCC to implement dynamic spectrum sharing in the band.

The Wi-Fi Alliance said the 4.9 GHz band is less appropriate for unlicensed use and the FCC should proceed with the consideration of unlicensed use in the 6 GHz band. Several mission-critical communications groups oppose 6 GHz unlicensed use.

In fact, UTC and the three other utility groups opposed this in their 4.9 GHz comments. “The 6 GHz band must be preserved to ensure communications reliability for utilities and other CII, as well as public safety and other important incumbent operations in the band,” UTC said. “Therefore, the 4.9 GHz is not and should not be considered by the commission as a substitute for continued interference-free access to the 6 GHz band by utilities and other incumbent critical infrastructure microwave operations.”

All the comments are here.

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