Enterprise Wireless Insider, Volume 14, Issue 9

T-Band Reconfiguration

On May 15, Federal Communications Commission Chairman Ajit Pai released a statement announcing that he has put a Notice of Proposed Rulemaking (NPRM) on circulation in light of the statutory directive to auction Public Safety (PS) spectrum in this band. Consistent with his earlier plea to Congress, the Chairman stated:

“An FCC auction of the T-band is a bad idea. But as of today, the law mandates that we do it.  It is unfortunate that Commission resources must be dedicated to laying the groundwork for an auction that will likely fail. This is especially true at a time when we are making every effort to keep Americans safe and connected, including allowing expanded temporary use of this very spectrum to help first responders save lives … Fortunately, there is bipartisan legislation in Congress to repeal this mandate ...”

The text of the NPRM will not be available until it has been voted on by all five Commissioners. The Enterprise Wireless Alliance (EWA) has confirmed that, as expected and contrary to the legislation that ignored Business/Industrial Land Transportation (B/ILT) use of the band, the NPRM recognizes that any auction of this spectrum must involve both PS and B/ILT channels.  

Mark Crosby, EWA President, stated in response to this news, “I agree with Chairman Pai that the ‘auction of the T-band is a bad idea’. It was a bad idea from the get-go. And now we are faced with the ever decreasing chance that Congress will repeal the mandate (see related article below).  I could be wrong, but if the FCC proceeds to competitive bidding as it must, incumbents will probably end up staying where they are as there will be insufficient funds generated to pay for relocation costs, and there is no suitable comparable spectrum to move business enterprises, private carriers and public safety. And wait until anybody who may be interested in this space gets wind of the heavy interference from repacked TV stations.” 

TV Repacking

EWA is compiling data about interference to T-Band systems and to certain UHF stations resulting from repacked television stations that now are operating on TV channels 14 – 20. FCC rules clearly state that TV CH 14 stations are responsible for protecting adjacent UHF Part 90 systems, a situation where aggressive filtering has proven effective in certain markets. T-Band systems are supposed to be protected from co-channel TV stations by a defined mileage separation, but that distance has not been sufficient in several markets. Unlike with CH 14 interference, FCC rules do not specify how interference is to be resolved and who is responsible when all systems involved operate in accordance with the rules and the terms of their authorizations.  EWA will present the data to the LMCC for a further response.

800 MHz 12.5 kHz Channels (Interstitials)

On May 11, the FCC adopted an Order on Reconsideration that sets the stage for licensing of the 318 new 800 MHz interstitial channels, spectrum originally requested by EWA in a 2009 Petition for Rulemaking. As expected, the FCC rejected the LMCC request to use an F(50,50) curve as the interference contour when coordinating these channels, rather than an F(50,10) curve. The FCC did adopt the LMCC’s revised derating matrix based on the F(50,10) curve although it denied the request that the matrix be posted on the LMCC website as opposed to being codified in the FCC rules to simplify the process for making changes in the future.

The FCC confirmed that applications for full and interstitial channels do not need to conduct a contour analysis if they are separated by the distance specified in the rules for co-channel 800 MHz systems. It also specified that the contour of a protected station must be calculated based on maximum permissible ERP while the proposed station’s contour is calculated based on the proposed ERP. The new rules will become effective 30 days after publication in the Federal Register and application will be accepted based on a Public Notice to be released by the FCC. Further application details will be circulated to EWA members and customers.

900 MHz Broadband

On May 13, the FCC voted unanimously to adopt a Report and Order in this proceeding. The few substantive changes from the draft Order released in April clarified aspects of the eligibility requirement for a broadband applicant. The FCC also confirmed that the freeze relaxation in the R&O did not supersede its earlier action relaxing the freeze for channels swaps that do not involve an expansion of the channel contour. The new rules will become effective 30 days after publication in the Federal Register and applications for broadband licenses will be accepted based on a Public Notice to be released by the FCC.

6 GHz Order Effective July 27

The FCC has adopted a Report and Order and Further Notice of Proposed Rulemaking authorizing standard-power and indoor low-power unlicensed operations in the 6 GHz band which will become effective on July 27. In a communication sent last week, EWA reminded its members that the license data as recorded in the ULS will be the data source for interference protection from the automated frequency coordination (AFC) systems that determine frequency availability. Operations outside of licensed parameters will not receive incumbent interference protection.  

The Further Notice of Proposed Rulemaking seeks comment on a proposal to permit very low power devices to operate across the 6 GHz band to support high data rate applications including high-performance, wearable, augmented-reality, and virtual-reality devices. The notice also seeks comment on increasing the power at which low-power indoor access points may operate. EWA anticipates participating in this phase of the proceeding. 

Meeting Construction Deadlines

The Wireless Telecommunications Bureau of the FCC has advised EWA that the FCC will not provide a further extension of build-out deadlines for site-based and mobile-only wireless systems with construction dates after May 15. Licensees that will not be able to meet their deadlines must file for waiver relief individually, consistent with the FCC’s standard waiver requirements. Affected licensees were most appreciative of the FCC’s original extension.

Citizens Broadband Radio Service

Some sources not from within the FCC, have posited the notion that the auction of priority access licenses (PALs) in the Citizens Broadband Radio Service (CBRS) may be delayed if the capital markets are reticent to fund auction opportunities during the nation’s present  economic issues. This has some credence given that successful, revenue generating auctions are just as important as making additional spectrum available for broadband applications. At present, the auction is set to begin on July 23. The “quiet period” for the auction began immediately following the May 5 filing deadline.