Enterprise Wireless Insider, Volume 11, Issue 16

Opposition Shifting on PEBB

On November 1, 2017, the Enterprise Wireless (EWA) and pdvWireless (PDV) filed Joint Reply Comments that emphasized that the Private Enterprise Broadband (PEBB) proposal to reallocate the 900 MHz band was based on optionality. In the proposal, licensees with only narrowband requirements could continue operating in that mode while those with broadband needs would have an opportunity for a build-to-suit broadband service on cost-efficient spectrum below 1 GHz. 

Parties opposing the proposal offered no new technical analyses. In response to opposition, the EWA/PDV filing explained how potential broadband interference would be contained; why Federal Communications Commission (FCC) policies do not and should not guarantee users a perpetual right to a low noise floor that is the product of underutilized spectrum; why consolidated narrowband operations in a 2/2 MHz allocation is entirely consistent with current 900 MHz rules; and how opponents had mischaracterized the interference potential of fixed versus mobile broadband uses. The EWA/PDV Reply Comments noted that previous realignments of the most complex, mission-critical private land mobile radio (PLMR) systems had been accomplished successfully and without unscheduled downtime. Building on Comments filed by various parties, EWA/PDV described a path forward that responded to the concerns expressed and noted that band realignment would advance a number of FCC policy objectives, including an appropriately robust utilization of spectrum. 

While some entities continue to oppose the PEBB proposal, absent technical data to support their objections, an increasing number of supporting comments have been filed, including from entities such as Eversource, a utility that previously had rejected the proposal but that now favors a broadband option, and Martin Marietta.  (WT 17-200)

Grant of APSC Waiver

On November 15, the Wireless Telecommunications Bureau (WTB) of the FCC granted the Arizona Public Service Company (APSC) waiver request for early access to 800 MHz Sprint-vacated spectrum to be used in APSC’s system, which is required in order to replace one that is no longer vendor-supported. The Commission accepted APSC’s explanation that it needed to deploy its new system before it could decommission the old one; that there were no alternative frequencies at the sites it needed in Arizona; and that APSC would surrender some of its current channels once the cut-over was completed. The WTB also noted that the system is shared by public safety entities and is used for emergency plans involving the Palo Verde Nuclear Generating Station, the nation’s largest nuclear-generating facility. EWA had supported this waiver request and opposition by the Association of Public-Safety Communications Officials International (APCO) was relatively muted. (DA 17-1114)

EWA Expects to Support TAC Spectrum Policy Recommendations

On December 1, The FCC Office of Engineering and Technology (OET) released a Public Notice (PN) requesting comment on spectrum policy recommendations from its Technological Advisory Council (TAC). If adopted, the recommendations could have far-reaching impact on wireless systems. They propose defining “interference” more precisely; establishing “Interference Limits”; regarding interference as a two-directional issue; and taking into account receiver performance and the design of the “victim” system as well as the operation of the alleged “interferer.” In addition, OET and its TAC recommend “that operators should expect and plan for occasional service degradation or interruption, and the Commission should not base its rules on exceptional events.” The TAC recommendations are likely to generate lively debate in an increasingly spectrum-congested environment. EWA plans to participate in the discussion and will note the importance of equipment quality in considering causes of interference, among other comments. Comments are due January 31 and Reply Comments February 15. (DA 17-1165)

EWA to Notify Verizon that B/ILT in 800 MHz Too

Recently, EWA learned that Verizon has notified Chicago-based public safety (PS) entities operating systems in the 800 MHz band regarding tests they plan in the cellular portion of the band. This notice is a requirement of the carriers pursuant to the FCC rules, but those same rules do not mandate that Verizon alert Business/Industrial Land Transportation (B/ILT) or Specialized Mobile Radio providers (SMRs) that are also operating in the band in the Chicago area. EWA plans to alert the potentially impacted B/ILT and SMR licensees as well as Verizon regarding the presence of B/ILT licensee incumbents that may also be impacted by their cellular operations.

EWA to Support Members on CMRS Presumption

EWA expects the FCC will approve a Report and Order (R&O) to harmonize FCC rules by eliminating the commercial mobile radio service (CMRS) presumption and allowing licensees to self-identify their service as common carrier, non-common carrier, and/or private internal communications. The selection must be based on the intended use and reflect the current CMRS and PMRS definitions. This action will eliminate the need for private internal applicants to request a waiver when acquiring either from the FCC or by assignment what has been considered commercial spectrum. It also should allow 800/900 MHz SMR licensees to identify their service as non-common carrier/PMRS, as long as the system is not interconnected, an action not permitted today. 

The draft R&O also adopts EWA’s recommendation that FCC forms retain all three regulatory categories rather than having all systems identified as CMRS or PMRS. EWA explained that it can be helpful to distinguish non-interconnected commercial systems from private internal systems, a distinction that would be lost if both types were identified as PMRS. EWA will provide guidance with member SMR licensees in compliance with the new rules.  (WT 16-240)

EWA Questions Merits of 460-470 MHz Proposal

In Comments filed November 9, EWA joined the LMCC and the National Public Safety Telecommunications Council (NPSTC) in expressing concern about FCC and U.S. support for the World Radiocommunication 2019 Conference (WRC-19) proposal to upgrade satellite overlay operations in the 460-470 MHz band from secondary to co-primary status with respect to terrestrial land-based operations. 

On behalf of “the more than 125,000 land mobile systems operating in the 460-470 MHz band,” EWA expressed concern that the power flux density (pdf) limits might not be conservative enough to offer adequate protection. Specifically, EWA worries that the WRC-19 “has not urged adoption of the more stringent pdf level of 
-157.8 dBW/m2/4kHz” although elsewhere WRC-19 admits that preliminary “testing by the relevant United States government agencies has shown that, at satellite angles of arrival below 25 degrees, the -152 dBW/m2/4kHz is not adequate to protect terrestrial operations.”

In light of the critical communications conducted within the band, EWA concurred with recommendations made by the LMCC and NPSTC that representatives of these users be involved in testing “to demonstrate that terrestrial operations will be adequately protected before an upgrade” is approved.

FCC December Meeting to Include Twilight Towers, CMRS Presumption

At its December 14 meeting, the FCC plans to address a number of items, including a Public Notice on Twilight Towers seeking input on the historic preservation review requirements for collocating wireless communications facilities on certain towers and, a Report and Order to harmonize FCC rules by eliminating the commercial mobile radio service (CMRS) presumption (See story above). The meeting, which is set to begin at 10:30 a.m., is open and will be streamed live at www.fcc.gov/live. 

FCC Adopts Dividing Line for SMRs in 800 MHz CBR

On November 17, the PSHSB announced the Enhanced Specialized Mobile Radio (ESMR) dividing line in the 800 MHz band for Canada Border Regions (CBR) 1 through 6. The 800 MHz Report and Order directs the 800 MHz Transition Administrator (TA) to assign post-reconfiguration channels to licensees operating in the CBR. Specifically, “the Bureau instructed the TA to separate ESMR systems from non-ESMR systems in the CBRS by assigning non-ESMR licensees to replacement channels in the lower segment of the 800 MHz band while maintaining the upper portion of the band for licensees operating ESMR systems.” In response, Sprint requested that the TA consider an alternative dividing line in CBR 2, based on NPSPAC region. The TA adopted the request, seeing no adverse effect on band reconfiguration. The FCC has accepted the TA’s recommendation.

A First Step in Wireless Siting Rule Changes

As expected, at its November meeting the FCC adopted an Order that eliminates historic preservation review when a pole is replaced with a substantially identical pole. The replacement pole must meet certain conditions including that the original pole is not on historic property; that it does not cause new ground disturbance; and that it is consistent with various other size, location, and appearance restrictions detailed in the rule. EWA expects this initial step will be followed by more substantive changes in the wireless siting rules. (WT 17-79; FCC 17-38)

Could Spell Relief in Asian Radio Matter…