EWA, Public Safety, Say FCC Should Move Forward on 800 MHz Rule Change

“As all currently allocated spectrum except [the] 800 MHz Mid-Band already has 12.5 kHz bandwidth limits, this is the only spectrum that has the potential for more intensive use through the allocation of interstitial channels,” EWA said. The spectrum will see its main use outside urban areas, the alliance said. The proposed rule change “will provide important opportunities for deployment of the more advanced technologies” being developed for public land mobile radio (PLMR), EWA said. An updated matrix that addresses the many technology choices now available to PLMR users is under development, EWA said. “Over time, EWA anticipates that incumbent licensees on 25 kHz channels may migrate to more feature-rich and efficient technologies that occupy less bandwidth. This will make an 800 MHz Mid-Band interstitial allocation even more useful.”

The Land Mobile Communications Council supported the proposal. “Through careful coordination of interstitial system deployment, the LMCC is confident that additional, spectrally efficient systems can be implemented without adversely impacting incumbent systems operating on adjacent 25 kHz bandwidth channels,” the council said. LMCC said need for the rule change has only increased since EWA sought the change six years ago. “An industry that had utilized analog systems almost exclusively for decades now has available to it a wide variety of feature-rich analog and digital technologies,” the group said. “The benefits of these technologies in meeting the needs of public safety, critical infrastructure, business enterprise, and commercial licensees are obvious. The challenge is identifying PLMR spectrum on which those benefits can be realized most fully.”

But the Utilities Telecom Council said the FCC should hold off making the change. Utilities, pipelines and other critical infrastructure companies use the spectrum in which the FCC proposes to introduce the 12.5 kHz high power offset interstitial channels, UTC said. “Utilities and other critical infrastructure industries have invested millions of dollars in these systems; and, moreover, these systems are used to protect the safety of utility personnel and the public at large. Any interference to them risks lives.”

The National Public Safety Telecommunications Council said it supports the plan as long as “sufficient protection” is provided for the public through the frequency coordination process. “The addition of the interstitial channels will add up to 319 land mobile channels for potential use, consistent with the protection criteria ultimately decided upon in this proceeding,” the group said. “NPSTC believes these channels are sorely needed for public safety and other categories of land mobile users and supports the interstitial approach for more effective and efficient use of the current spectrum.”

APCO filed similar comments. “While limited in scope, such additional capacity could help alleviate significant spectrum congestion that exists in much of the nation,” APCO said. “The danger, however, is that adding new channels without appropriate protections could interfere with existing operations, including critical public safety communications, and result in a net loss of useable spectrum.”

Boeing supported the rule change, provided protections are offered for incumbents, especially from “new and potentially non-compatible users,” such as terrestrial trunked radio systems. “As an intensive user of business/industrial wireless licenses in the 800 MHz Mid-Band, Boeing concurs with the numerous comments in the record that this proposal may improve spectral efficiency in a heavily-used frequency band,” Boeing said.