900 MHz Incumbents Ask for Interference Protection from Future Newcomers
Incumbent providers operating in the 900 MHz band urged the FCC to ensure “sufficient” protection for their systems from harmful interference if the Commission moves forward with a proposal to facilitate the band’s more flexible use. They want the agency to ensure that licensees don’t face interference such as that which required the remedies adopted in the 800 MHz interference proceeding. The incumbents, which are site-specific licensees, generally opposed the geographic market area licensing the FCC proposed. They said it would cause commercial systems to proliferate at the expense of continued licensing of critical infrastructure, industrial and land transportation systems.
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The FCC earlier this year proposed to amend Part 90 of its rules to facilitate more flexible use of 199 channels allocated to the Business & Industrial Land Transportation (B/ILT) pools in the 896-901 MHz and 935- 940 MHz bands (CD Feb 11 p7). It also proposed to license the remaining spectrum using a geographic area licensing scheme, not the site-based arrangement incumbents use.
The Commission’s proposal needs modifications, said the Assn. of American Railroads, American Petroleum Institute, MRFAC, National Assn. of Manufacturers and United Telecom Council in joint comments. The proposal “gives insufficient consideration to the spectrum needs of incumbent B/ILT users and is skewed in favor of commercial operations and spectrum auctions,” they said. The parties said the FCC should: (1) Retain existing site-based licensing policies for 99 B/ILT channel pairs to provide opportunities for incumbent and new private wireless entities to acquire more channels. (2) Amend its grandfathering proposals so incumbents have more flexibility to modify facilities provided an incumbent’s 22 dB V/m interference contour isn’t extended. That would be consistent with rules adopted for the 800 MHz band, they said.
The FCC should adopt the interference protection criteria it recently imposed in the 800 MHz band to mitigate likely interference between incumbent and commercial cellular networks, the joint parties said. “There is every reason to believe that incumbent 900 MHz receivers will be susceptible to this type of interference and should be protected by cellular licensees who deploy such systems despite knowing the risks posed to their spectrum neighbors,” they said.
PCIA recommended the Commission exempt 40 channels, or 20% of the 900 MHz B/ILT channels, from the auction. “This channel allocation would be the most efficient mix of spectrum licensing options to balance the competing interests of broad and rapid deployment of wireless services, and the critical need for a limited number of channels for the legitimate growth of private, internal business use systems,” it said. The FCC and industry also should “consider and agree” on required interference protections to 900 MHz licensees “as quickly as feasible,” PCIA said.
Electrocom, a 900 MHz and SMR service provider, said the Commission should require reciprocal notification of intentions by 900 MHz ESMR operators and incumbent licensees. It also should require use of Best Practices procedures to resolve interference ESMR systems may cause to 900 MHz incumbents, it said. Electrocom said the FCC should grant licenses on the basis of basic economic areas (BEAs), rather than major economic areas (MEAs), to provide new competitive opportunities to medium and small businesses. The Commission has expressed concern that some BEA licenses may remain unsold, but Electrocom said that could be avoided by setting upfront payments and minimum bids at levels likely to attract bidders.
Nextel said adopting a pro-competitive paradigm for initial licensing of 900 MHz “white spaces” would “greatly aid in facilitating band reconfiguration occurring at 800 MHz.” Under the Commission’s 800 MHz order, Nextel will retune its 800 MHz facilities twice as part of retuning other incumbent licensees and clearing the lower portion of the reconfigured 800 MHz band for NPSPAC licensees. The order said Nextel would need access to more 900 MHz spectrum to provide “green space” as it shifts its operations and retunes NPSPAC licensees. “By lifting the current restrictions on the initial licensing of 900 MHz white space and conducting an auction of this spectrum, the rule changes proposed in the NPRM will provide Nextel and all other interested parties the opportunity to acquire 900 MHz spectrum,” Nextel said. It urged the FCC to auction MEA licenses for existing 900 MHz white spaces as soon as possible.
Electrocom disagreed, saying there’s been “a substantial change of fact” calling into question the need for the proposed geographic area licensing scheme. It said if the Commission approves the proposed Nextel merger with Sprint, it should examine whether Sprint can use spectrum on its existing CMRS facilities to accommodate Nextel customers who may have to be moved to facilitate Nextel’s relocation within the 800 MHz band. If so, “there will be no need for a 900 MHz band geographic area licensing system to provide green space to Nextel,” Electrocom said.
The National Public Safety Telecom Council (NPSTC) urged the FCC to allocate channels within the B/ILT pool in the 900 MHz band to public safety for digital paging. That would let public safety use less costly off-the-shelf paging technology and prevent formatting of a niche market, it said. “Coupling the allocation with the timing of the 800 MHz band reconfiguration would provide an opportunity for public safety agencies to upgrade their paging technologies,” it said. NPSTC also agreed with the FCC that the proposed area licensing approach would be “the best regulatory framework for such a 900 MHZ allocation” and for “allocating frequencies to public safety for digital paging.”