Enterprise Wireless Alliance filed Comments on June 3, 2019, in response to the FCC’s Notice of Proposed Rulemaking on 900 MHz. Major points included in EWA’s comments were:
- While the electric utilities have much to gain from a broadband option at 900 MHz, there are many business enterprises involved in transportation, manufacturing and agriculture, among other industries, that will also benefit from this opportunity;
- Eventually, there may be advantages of a 5/5 MHz broadband allocation, but the FCC should start with a 3/3 MHz service and evaluate its progress before considering realignment of the entire band;
- Consideration should be given to EWA’s Petition for Rulemaking which proposes that 800 MHz Guard Band spectrum be reserved as “green space” for relocating incumbents from 900 MHz and for Business/Industrial/Land Transportation incumbents displaced from T-Band;
- The transition process should include both an initial voluntary period and thereafter a means of addressing holdouts to avoid giving individual licensees effectively a veto power over broadband in their area;
- In all instances, incumbents must be provided with comparable facilities and their retuning costs must be paid by the broadband licensee; and
- EWA does not support the use of an incentive auction either as a backstop to prevent holdouts or as an initial method of band clearing.
Reply Comments are due on July 2. (WT 17-200; FCC 19-18)