Expand Eligibility and Spectrum Management of 4.9 GHz
On August 6, 2018, the Enterprise Wireless Alliance (EWA) filed Reply Comments in the 4.9 GHz proceeding concerned with user eligibility and spectrum management requirements. In its filing, EWA reminded the Federal Communications Commission (FCC) that it has been a strong proponent of critical infrastructure industry (CII) access to the 4.9 GHz band as consistent with the need to make appropriately intensive use of all spectrum resources and continued to oppose commercial access. Public safety’s utilization of this band over the past decade and a half appears to be more robust than recognized by the FCC, and its plans may be ambitious, but this 50 MHz allocation can and should support additional primary uses. EWA has recommended not only that a somewhat expanded definition of CII have co-equal eligibility but also that the assignment of spectrum within this allocation be managed by entities that have demonstrated to the FCC the technical and financial capability of carrying out that function.
EWA focused on this last issue given public safety’s unanimous suggestion that only public safety frequency coordinators have the expertise and in-depth knowledge to manage the band in the future. We countered that the policies governing the current Part 90 frequency coordination process have been in place since 1958 and were formalized in 1986. The capabilities that caused the FCC to deem an organization qualified to perform coordination functions in 1969 and even in 1986 bear little resemblance to today’s requirements and offer no assurance that an organization is prepared to handle what the public safety community itself expects to be exceedingly complex technical analyses at 4.9 GHz. The fact that some, or even perhaps all, users will be public safety entities does not mean that only a public safety FAC can conduct effective frequency coordination. For that reason, EWA strongly supports the Commission’s proposal to require entities that wish to coordinate applications in this band to submit their qualiCategory: EWA On Your Side