Utilities, Manufacturing Groups Weigh in on 900 MHz Realignment
Friday, December 27, 2019 | Comments

More critical infrastructure industries (CII) and private wireless entities are lobbying the FCC on both sides of the 900 MHz realignment proposal.

The National Association of Manufacturers (NAM) and MARFAC, which represents large manufacturing firms, said 900 MHz narrowband spectrum is essential for manufacturing operations.

Given the shortage of such channels in many areas, the NAM/MRFAC representatives urged the FCC to limit any broadband allocation to 3-by-3 megahertz and use county allocations, rather than nationwide. The groups said the cost of relocating incumbent systems may be significantly higher than the FCC anticipates.

The NAM/MRFAC representatives also said relocation should not be mandatory. Rather, the comparable facilities standard developed for the 800 MHz reconfiguration process should be sufficient.

The Lower Colorado River Authority (LCRA) agreed that any 900 MHz realignment should be truly voluntary, and complex systems should be excluded from any mandatory relocation obligation. LCRA also said the FCC should define a complex system as any LMR network with 25 or more sites but it is willing to accept a definition based on 45 or more sites.

The utility also said the FCC should adopt interference protection threshold levels similar to those afforded to 800 MHz systems. LCRA urged the commission to ensure that incumbent 900 MHz narrowband incumbents are fully reimbursed for any and costs they incur as part of any relocation plan, including future operating and maintenance costs incurred post relocation.

Florida-based utility NextEra also opposed mandatory reconfiguration, saying it could lead to a complicated, years-long process similar to 800 MHz reconfiguration, which is ongoing after 14 years.

“If the FCC requires mandatory reconfiguration, the FCC necessarily will need to adopt procedures and dedicates resources for years to come to manage a mandatory reconfiguration process,” NextEra said. “Implementing a strictly voluntary, market-by-market approach also would avoid the contentious issues discussed below because the parties will have reached negotiated agreements.”

Those contentious issues included whether there is a need for a guard band and whether to exempt complex systems from mandatory reconfiguration.

For its part, Anterix, which originally petitioned the FCC for the realignment, joined the Enterprise Wireless Alliance (EWA) in opposing a request filed by Southern California Edison (SCE) that would provide CII entities priority access for one year to 900 MHz broadband licenses.

“At its core, SCE is requesting free, exclusive access to broadband spectrum because it is a utility,” said Anterix, which plans to offer broadband service to utilities if the FCC’s realignment proposal, which would create a broadband segment to allow for Long Term Evolution (LTE) services in the band, moves forward.

Incumbents in the band said they should be able to access broadband licenses at 900 MHz following any realignment, along with Anterix.

The NAM/MRFAC ex parte letter is here. LRCA’s letter is here. The NextEra filing is here.

The Anterix filing is here.

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