Enterprise Wireless Insider, Volume 13, Issue 11

EWA Urges FCC to Condition T-Band License Renewals

In a letter filed July 16, the Enterprise Wireless Alliance (EWA) acknowledged that the licensing staffs of the Public Safety and Homeland Security Bureau and the Wireless Telecommunications Bureau have been directed not to process applications for renewal of Part 90 licenses operating on spectrum in the 470-512 MHz band (T-Band) and instead, to hold the applications in a pending status. This decision was certainly made in anticipation of the Federal Communications Commission (FCC) eventually taking action in response to Section 6103 of the Middle Class Tax Relief and Job Creation Act of 2012 (Act), which directs the Commission to reallocate T-Band spectrum being used by public safety eligible entities and, begin an auction of that spectrum in 2021. However, EWA recommended that a far better approach for the benefit of licensees would be to grant T-Band renewals conditioned on the outcome of the T-Band proceeding, or any successor rulemaking in which the directives of the Act are implemented by the FCC.

EWA reminded the FCC that it used the identical approach during the pendency of the FCC’s license renewal proceeding (WT Docket No. 10-112), and that its application in this instance would avoid situations where a licensee needs to demonstrate that it has operating authority from the FCC, but must explain that what appears on its face and in the ULS database to be an expired license, actually remains valid because a timely renewal application was filed. EWA also stated that it was “unfortunate that the Bureaus did not consult the industry” before deciding to hold T-Band renewal applications in abeyance or, notify the industry that the decision not to process had been made.

EWA Files Reply Comments on 900 MHz Realignment

On July 2, 2019, EWA filed Reply Comments in response to industry commentary on the Federal Communications Commission’s (FCC’s) Notice of Proposed Rulemaking (NPRM) that proposes to realign the 900 MHz band. In its Reply Comments, EWA made the following points:

• Industrial users other than utilities and other critical infrastructure industries (CII) have a need for private broadband networks. EWA urges the FCC to adopt the definition of CII used by the Department of Homeland Security (DHS).
•  The FCC should limit future eligibility for narrowband channels to B/ILT entities with the right to convert to commercial after a holding period, perhaps a year;
• Start with a 3/3 MHz broadband segment and allow 5/5 on a case-by-case basis;
• Relocation should begin with voluntary negotiations, but any FCC rulemaking should address a way to clear holdouts whose systems are demonstrably able to be retuned; and
• All incumbents, including those retuned on a mandatory basis, are entitled to comparable facilities and payment of all reasonable costs.

In addition, EWA clarified the record regarding its position on application license freezes, specifically noting that they are a necessary evil to deal with speculators but should always be incumbent-friendly.

In other comments, some incumbents, primarily large utilities that would be exempt from mandatory relocation, continue to oppose any band realignment while other parties, including utilities, agree that a 900 MHz private broadband option would address a growing wireless need. The record in this proceeding is now complete; however, when the FCC will take the next step is unknown. (WT 17-200; FCC 19-18)

EWA Welcomes Jennifer Garry as Membership Director

The Enterprise Wireless Alliance (EWA), a private wireless spectrum solutions and advocacy leader for the business enterprise private wireless industry, is pleased to announce that Jennifer Garry has become EWA’s Membership Director. In this role, she will oversee EWA’s membership sales and service strategies. Read more...

TMA Pushes CSA App Acceptance Date to July 26

Due to issues during the testing of the electronic application submissions process for applications requesting Central Station Alarm channels, The Monitoring Association (TMA) has changed the date on which it will begin accepting applications to July 26 at 10:30 a.m. Eastern.

In other matters, EWA requested clarification of TMA’s proposed concurrence and related fee requirements to process requests for these channels. Negotiations are ongoing.

Concerns Raised Over AT&T CBRS Antenna Proposal

On July 12, jointly with FedEx Corporation, General Electric Company, Union Pacific, among others, EWA filed a letter expressing concerns about AT&T’s proposal to deploy a new “Category C” antenna for use in the Citizens Broadband Radio Service (CBRS). The parties noted that the higher proposed power risks creating in-band interference, especially to the extent that networks will be TDD systems; will increase the size of DPAs; add complexity to the SAS/ESC/DPA system; undermine use cases; harm investments, and limit innovation even beyond the impact already implicated by moving Priority Access Licenses from census tract to county size. An even more strongly worded letter on this issue had been filed previously jointly by API, NCTA and WISPA and others. (WT 17-258)

Learn New Competitive and Hiring Strategies at 2019 Wireless Leadership Summit

Are you hiring the right talent? Do you suspect your competition might be “twinning” your company to win business? Is your company winning bids for in-building wireless projects? If your company is scrambling to keep up with changes in the wireless industry, make plans now to attend the 2019 Wireless Leadership Summit in Kansas City, Missouri, October 23-24 at the InterContinental Kansas City at the Plaza.

Programming for this year’s Wireless Leadership Summit is clearly focused on new ways to compete successfully in our challenging – and rapidly changing – environment. Nationally recognized experts on competition and recruitment will present a special afternoon workshop and our keynote. You’ll also learn about mission critical IoT, shifts in the regulatory environment that will affect you and gain insights into the future of land mobile radio and more.

EWA Seeks Confirmation of Wide-Area Licensing Policies

Earlier this week, EWA filed a letter with the FCC’s Wireless Telecommunications Bureau (WTB) requesting confirmation of WTB processing policies for B/ILT applicants requesting wide areas of operation, specifically those exceeding 80 km. Essentially, it seems that the FCC will no longer routinely grant, amend or renew licenses that seek wide areas of operation unless they specify itinerant use channels.

Further, non-itinerant channels are no longer permitted to report a “Nationwide area of operation south of Line A”. Applications seeking the use of non-itinerant channels for wide area operations will be required to establish unique, 80 km site-based (center coordinates) service areas and, will receive primary protection only within the 80 km service area. However, for applicants who will be operating temporary operational fixed stations (FXOTs), wide area operations may be licensed, but all operations will be on non-itinerant channels and licensed only on a secondary, non-interference basis. This licensing tactic if often used by firms who conduct surveying operations.

Anterix Seeks Relaxation of 900 MHz Freeze

In a recent filing, pdvWireless, Inc. d/b/a Anterix requested that the Wireless Telecommunications Bureau modify the temporary freeze of the 900 MHz band it announced in September of 2018. Anterix has based its request upon the possible adoption of the Federal Communications Commission’s Notice of Proposed Rulemaking to realign the 900 MHz band to create broadband and narrowband segments. The company contends that modifying the freeze provides greater flexibility to permit incumbents to exchange frequencies in the broadband segment voluntarily for frequencies in the narrowband segment while also accelerating the relocation process without compromising the outcome of the proceeding.

Utilities Cite Reliability Concerns While Big Tech Claims No Interference at 6 GHz

The American Public Power Association, the National Rural Electric Cooperative Association and four other organizations representing America’s energy utilities have asked the Department of Energy to hold a meeting on the FCC proposal to open the 6 GHz band to unlicensed use. Citing significant reliability issues for the energy and water sectors, the organizations assert the plan to open the band could adversely affect the mission-critical services energy and water utilities provide across the country.

In other news, last week, representatives from Google, Facebook, Apple, Intel, Hewlett Packard Enterprise, Marvell Semiconductor and others met with staff of the Federal Communications Commission Office of Engineering and Technology to present an engineering study that shows that incumbents will be protected from interference from 6 GHz radio local area network operations. The study was prepared by RKF Engineering, the same firm that produced the much-questioned analysis last year.