Unlicensed v. Licensed Debated in Offshore Comments to FCC

Critical infrastructure providers, including windfarms and offshore oil and gas platforms, need better access to spectrum, the Utilities Technology Council said. “Providing access to spectrum for clean energy facilities will substantially advance the Biden Administration’s overarching energy policy goals to reduce carbon emissions by using more renewable energy resources,” the group said. But UTC doesn’t support unlicensed use of the 6 GHz band for offshore communications and “strenuously opposes proposals to change the 6 GHz rules, which will increase the potential that unlicensed operations will cause harmful interference to licensed operations, including utility and … mission critical microwave systems.”

“Adopt a spectrum management strategy for offshore spectrum use that incorporates hybrid- and shared-use models,” NCTA urged: “Given the limited availability of greenfield spectrum, hybrid- and shared-use models promote efficient spectrum management.” The FCC should complete work on the unlicensed 5.9 and 6 GHz bands to make them more available for use offshore, NCTA said.

“There is currently unmet demand for spectrum to support a wide variety of offshore use cases, including [augmented-and virtual-reality] for oil rig maintenance, wind farm ‘IoT’ device measurements, near real-time safety communications, vessel-to-vessel communications, broadband-intensive applications such as video conferencing and telehealth, and tracking of marine wildlife and weather, among others,” said Federated Wireless. A “common theme” in the comments has been “the need for access to spectrum on a reliable, interference-free basis without having to purchase large license areas through an auction,” Federated said.

“While many wind farms are not actively operating, this sector needs spectrum on an immediate basis due to the crucial role mobile communications play in the ongoing construction and development of such systems,” said Tampnet, which operates an offshore mobile network in the Gulf of Mexico. “Act promptly to ensure that energy production is not unduly stifled as a result of limited spectrum availability in these markets by initiating a proceeding to make more spectrum available offshore,” the company said.

Dominion Energy said the record shows agreement on the “significant and growing demand” for licensed spectrum for windfarms. “It is difficult to imagine any spectrum-rights model that can match the availability and resilience offered by licensed spectrum,” Dominion said. Terrestrial Trunked Radio (TETRA) equipment “is familiar to the large wind farm developers because of the use in other parts of the world,” the company said: “Technicians and installers are best served to be allowed to use familiar equipment. They are best served by the 400 MHz and 800 MHz bands.” Windfarm operators also need access to 700 MHz for LTE, Dominion said.

“Commenters agree that the commission should make available as much offshore spectrum as possible,” T-Mobile said. The carrier wants a “unified approach” and FCC confirmation “that all terrestrial licensees in coastal areas may extend their operations as far out to sea as permissible under U.S. law.” T-Mobile opposed setting aside spectrum for private networks. “T-Mobile appreciates the needs of private networks,” the filing said: “But the suggested approaches are anachronistic and should be dismissed. … Private users can better have their needs met by partnering with wireless carriers to provide service in the geographic areas where they are required. … Carriers can engage in leasing, partitioning, and/or disaggregating their spectrum to third parties for their private network.”

Satellite Industry Concerns

Garmin noted comments by NTIA on the need to protect GPS and other operations (see 2208010042). “Garmin’s other business segments, especially aviation, help provide critical safety-of-life data and services to mariners and offshore operations,” the company said: “Garmin therefore urges the Commission to consider carefully the potential for interference both to GPS, as well as to other critical safety services that serve the offshore marine community as it contemplates any changes to its policies or rules.”

Satellite advocates stressed the role satellite communications have always played offshore. “Given the historic, undisputed, and vital use of satellite communications to serve offshore platforms, the Commission should affirm the importance of satellite networks when acting on the information provided in response to the NOI, and consider inclusive options to protect these networks and facilitate new deployments,” Inmarsat said. The FCC should “affirm the importance of offshore satellite networks, as well as consider technologically inclusive options to protect and facilitate deployment of these networks,” the Satellite Industry Association said.