Enterprise Wireless Insider, Volume 12, Issue 9

Chatter on 900 MHz Private Wireless Broadband

Unless it’s the discovery of yet another pirate radio station which receives quick justice from the Federal Communications Commission’s (FCC’s) Enforcement Bureau, spectrum policy and management decisions take a while to come to fruition, a couple of years minimum in any event. You can imagine our interest, then, when both FCC Chairman Pai and Julius Knapp, Chief of the Office of Engineering & Technology publicly mentioned during the same week no less that broadband opportunities may be available at 900 MHz. It’s progress, slow progress perhaps, but progress nevertheless. Maybe a Notice of Proposed Rule Making (NPRM) is in the offing. We don’t want to jinx any FCC efforts; however, so we will not characterize the pending timeline as imminent. But we remain optimistic that the FCC will now move this item forward. RCR Wireless News featured a story on pdvWireless and its strategies for 900 MHz, which you can access online. (WT 17-200)

T-Band - A Current Assessment

Introduced this past February, H.R. 5085 (“Don’t Break Up the T-Band Act”) proposes to rescind the repurposing of the 470-512 MHz band that would eliminate all kinds of spectrum planning threats and hassles for both Public Safety and Business/Industrial Land Transportation (B/ILT) incumbents. This legislation currently has 19 cosponsors, but 219 would be better, and having a companion bill introduced in the Senate remains a crucial requirement. There’s white noise on the subject, specifically rumors about identifying alternative spectrum other than T-Band that could be auctioned, unfortunately, a necessary exercise to pay for the spectrum reallocations and funding that led to the formation of FirstNet - a mere $15,000,000,000 or so obligatory nut from which the Feds are reluctant to walk. 

But to add salt to the proverbial wound: while we all seek a reasonable solution out of the T-Band morass, the FCC Wireless Telecommunication and Public Safety and Homeland Security Bureaus seem paralyzed to respond to the industry’s request to relax the now six-year-old T-Band application freeze, a request that wouldn’t seem to materially affect the potential yield from a future T-Band auction. In exchange for the sleeves on its vest, the FCC would generate considerable industry goodwill. These and other related topics were informally discussed among Enterprise Wireless Alliance (EWA) members who gathered last week via teleconference to review T-Band developments. (PS 13-42) 

Applying the Spectrum Sharing Template at 3.7-4.2 GHz

As an outcome of the FCC’s “Mid-Band” (3.7-24 GHz) Notice of Inquiry (NOI), the FCC on July 12 adopted an NPRM to consider various proposals for more intensive use (“Intensive use = 5G/Broadband) of the 3.7–4.2 GHz band, while providing appropriate protection for incumbent fixed microwave links and Satellite Service earth stations. The NPRM proposes to add a mobile allocation to the entire 500 MHz of spectrum and, considers allowing further point-to-multipoint fixed use in some portion of the band. Comments and Replies will be due 60 and 90 days after Federal Register publication. (GN 18-122)

Watershed Decisions Abundant at 4.9 GHz

In Comments filed earlier this month, EWA maintained its support for co-equal eligibility of and frequency coordination options for Public Safety and B/ILT entities in this band, while opposing commercial access. EWA also took the opportunity to suggest that with its focus on consumer-oriented offerings, the FCC appears to have lost sight of the important operations conducted on private land mobile radio (PLMR) systems that support America’s way of life and the economy in general. 

EWA challenged the FCC’s theory that auctioning spectrum for flexible commercial use was not “central planning” since the outcome of such allocations is entirely predictable, both in terms of the auction winners and the users and applications to which their service is oriented. It also disagreed with the notion advanced by national carrier advocates that secondary market transactions were effective in making spectrum available for PLMR uses since, commercial entities rarely are motivated to carve out spectrum for those purposes.  

For their part, a few public safety organizations disagreed with the FCC’s finding that the spectrum is underutilized and described both current and future applications. While NPSTC has maintained its prior proposal that sharing some spectrum with CII eligibles on a co-primary basis is a good approach, APCO would only allow CII sharing on a secondary, preemptible basis. (WP 07-100)  

Tell Me Again How Interference Will Be Avoided?

The Fixed Wireless Communications Coalition (FWCC) continues to lobby the Federal Communications Commission (FCC), challenging the use of unlicensed devices in the 6 GHz microwave band as proposed by Apple, Google et al coalition, without further evidence that interference can be avoided. 

The unlicensed-use proponents have received support from a group representing hospitals and other medical facilities which says they need additional WiFi capability as well as the Dynamic Spectrum Alliance (DSA), which, not coincidentally, has a membership roster that includes several members of the RLAN Group (the major proponent of unlicensed use). (GN 17-183) (GN 18-122).

3.5 GHz Negotiations – Or Lack Thereof

It is not particularly accurate to state that there has been a successful negotiation between the national carriers and their primary advocate versus those parties including EWA who suggested that just a few Priority Access Licenses (PALs) based on census tracts would promote greater spectrum access. After all, it makes no sense for smaller communication providers and business enterprises to acquire huge swaths of geography better suited for national carriers during a 3.5 GHz auction. But maybe that was the plan all along – the bigger the areas auctioned, the fewer number of interested entities will show up.  Proponents of smaller geographic areas have been forced to fall back to the position that their needs may have to be accommodated within the unlicensed General Access Authorization (GAA) spectrum. This approach will not please proponents of unlicensed use at 3.5 GHz but will serve the interests of the large national carriers who lobbied exclusively only for large geographic areas to be auctioned. 

Although the national carriers have left the negotiation table, the Wireless ISP Association (WISPA) asked the FCC to ensure that census tracts remain available as bidding units for Priority Access Licenses, as census tracts are “the only way that small businesses will be able to participate in the CBRS band auction”. (GN 17-258)

Public Safety T-Band Waiver Denied

In an Order released July 24, the FCC denied an application and request for waiver from the County of Union, New Jersey. The County had sought a waiver to operate in the TV Channel 19 band at a location further than 80 kilometers from the center of Philadelphia, Pennsylvania. Union sought this added capacity because it plans to control dispatch operations of call sign WPIG291, assigned to the Borough of Roselle, New Jersey. In addition, Union sought to add mobile units to an existing license and sought a waiver of the T-Band freeze in order to acquire a new license in that band. The FCC denied the waiver for a number of reasons, including that Union cited incorrect rule sections in its request and that Roselle has not given concurrence to the proposed control station arrangement.  

Globalstar’s 5G Petition

Globalstar recently filed a Petition asking the FCC to initiate a proceeding that would re-evaluate spectrum sharing between licensed Mobile Satellite Services (MSS) and outdoor Unlicensed National Information Infrastructure (U-NII) devices operating in the 5150-5250 MHz band. Those opposing the petition claim that it lacks crucial evidence and that Globalstar is raising new views expressed when the FCC first evaluated the band, which lead to the 2014 5 GHz Order, leading one filer to call it “little more than an untimely Petition for Reconsideration” (Open Technology Institute at New America and Dynamic Spectrum Alliance).