Wireless Spectrum Changes Bring New Opportunities in 2015

By Mark Crosby, President/CEO of the Enterprise Wireless Alliance

Maybe it’s always about spectrum at the FCC, but not too often about spectrum for Business/Industrial and Land Transportation (B/ILT) entities. If B/ILT interests are want to improve their spectrum lot, we must do it on our own. 

Despite grumbling from a few sectors, the industry survived the requirement to reduce channel bandwidths at 150-470 MHz which everyone knew was coming for ten years. Eventually, as the deadline approached, the majority of licensees jumped on board, retuned their systems, and knowingly or unknowingly, made the affected spectrum a better place in the long run.

Okay, everyone knew that narrowbanding was never a 2 for 1 proposition at the outset given the level of congestion (at least in the B/ILT space), but coupled with the acceptance of multiple varieties of skinny channel digital technologies, spectrum efficiency gains in the 150-450 MHz space should be applauded by all who participated.  We also know that further efficiencies will be achieved as the scales tip towards a digital majority. Yes, there are still channel sharing issues experienced by analog users from more robust digital systems, but these growing pains should recede over time. 

We need the FCC’s help on how to best handle those nincompoops whose licenses still report non-compliant wideband emission designators. The FCC’s approach is to simply catch these authorizations at time of renewal as enforcement dollars have higher priorities. This is not an optimum solution since these licenses gum up frequency selection processes today, and treating them as if they are compliant with the rules is incredibly unfair to those who obeyed the rules of engagement, especially after all of the dire Commission warnings of fines and admonishments for failure to act.

We will suggest a more progressive solution on how to handle these detrimental licenses in 2015. After all, we are on our own.

A couple of years back, actually almost six years ago, EWA filed a Petition suggesting that it would be a good idea to initiate a proceeding to provide for the assignment of new, full-power interstitial 12.5 kHz frequencies between currently authorized 25 kHz bandwidth channels at 854-861/809-816 MHz (we would include the 861-862 MHz band today). It still seems like a good idea and an example of how we may help ourselves. What gave us the idea was the development and growing market acceptance of digital technologies that didn’t require 25 kHz channel bandwidths. A favorable outcome would promote spectrum efficiency, encourage the development of new applications critical to incumbent licensees that require innovative wireless solutions to accommodate expanding business requirements, and provide the potential for a viable spectrum alternative for new B/ILT (and Public Safety) entrants whose requirements can be met without compromising incumbent operations.  The LMCC provided suggested frequency coordination analyses in April 2010, and those may have to be amended to adapt to today’s potential 800 MHz technologies, but we’re still ready to go at EWA. The good news is that we believe the FCC may soon be initiating a proceeding in response to this spectrum opportunity. That would be great news in 2015.

And speaking of creating opportunities, how long would B/ILT interests (and Critical Infrastructure Industry interests) have to wait for a block of spectrum dedicated to their unique requirements as opposed to using unpredictable unlicensed spectrum, perhaps playing second fiddle within bands dedicated primarily to mission critical operations, or relying on commercial networks serving the general public first and foremost? A long time – a very long time.  

So it shouldn’t be a surprise that EWA has partnered with Pacific Datavision LLC (who purchased Sprint’s 900 MHz licenses), in a joint Petition for Rulemaking to realign the 900 MHz band to accommodate a “build-to-suit” 3/3 MHz broadband opportunity while retaining a 2/2 MHz allocation for narrowband B/ILT and SMR voice and data systems. The broadband segment of this initiative will be dedicated to Private Enterprises (B/ILT) interests with a requirement to provide priority access to CII entities.

More recently, the FCC has issued a Public Notice requesting comment on the merits of the Petition and also requesting comment on (i) the uses to which private entities would put this broadband spectrum; (ii) what changes to the technical rules would be needed; (iii) the estimated relocation costs; and (iv) whether a broadband opportunity could be accomplished without band realignment. Legitimate questions for sure, but new spectrum allocations will not simply fall into the laps of the B/ILT or CII industries. We must pursue rule amendments and policies that will result in the better use of the spectrum currently available to B/ILT licensees. 

The 800 MHz and 900 MHz bands are critical to B/ILT and CII’s future, and 2015 potentially looks promising. We did the work to create these opportunities on our own and we can now all look forward to the results.