EWA Files Petition Seeking Designation of 800 MHz Guard Band as "Green Space"

04/18/2019
The Enterprise Wireless Alliance (EWA) has filed a Petition for Rulemaking (Petition) requesting that the Federal Communications Commission (FCC) designate the 800 MHz Guard Band spectrum as “green space” for incumbent Business/Industrial and Land Transportation (B/ILT) licensees who may be required to vacate T-Band spectrum; and for certain 900 MHz incumbents whose narrowband systems may need to be moved to replacement frequencies as part of a transition to create a 900 MHz broadband opportunity. As stated in the Petition, “[s]tatutory and regulatory mandates. . . may require incumbents in these bands to be relocated to comparable facilities.” Through this Petition, EWA seeks to provide meaningful and realistic spectrum solutions that will allow licensees to be relocated to comparable spectrum. The Petition specifically notes that:
 
  • T-Band spectrum has been used extensively by private land mobile radio entities since the early 1970s, and in many of the cities affected by the Act, no comparable spectrum exists to which these operations could be relocated.
  • It is unlikely that providing T-Band B/ILT incumbents priority access to 800 MHz interstitial channels will provide meaningful relief since 800 MHz interstitial channels are least likely to be available for use in the major urban areas where T-Band systems are located. 
  • A more robust ecosystem of equipment and applications exist in the 800 MHz band that could prove attractive to certain 900 MHz incumbents as they consider how best to position their operations for future growth and system technology requirements.  
On the filing of the Petition for Rulemaking, EWA President Mark Crosby made the following statement: 
 
“B/ILT T-Band incumbents deserve recognition of their plight. For whatever reason, the Middle-Class Tax Relief and Job Creation Act did not even recognize their presence in the band, which places their wireless investments and operations at future peril.  B/ILT licensees do not deserve to be an afterthought. Compressing B/ILT licensees within the T-Band after public safety departs maroons them and fails to appreciate the economic contributions provided by B/ILT systems. Establishing the 800 MHz Guard Band as green space, while likely not a total answer, offers these licensees the possibility of a future home and shows that the industry and regulators are paying much-needed attention to their situation. 
 
Regarding the pending 900 MHz NPRM proposing the introduction of broadband capabilities for use by B/ILT entities, the spectrum transition in certain geographic areas may be facilitated by having access to the 800 MHz Guard Band as green space. While it is expected that most 900 MHz incumbents will elect to replace their channels with other channels in that band, some licensees might prefer to integrate 800 MHz channels into their 900 MHz system since technology advances make dual-band 800/900 MHz system capabilities available, or to relocate entirely to 800 MHz spectrum. Lots of flexibility is beneficial.”

About EWA

The Enterprise Wireless Alliance is an FCC-certified frequency advisory committee and leading advocate for business enterprises that rely on wireless communications systems. EWA has been meeting member needs for more than 65 years and offers members and clients consulting services, frequency coordination, license preparation, spectrum management and associated services. Membership in EWA is open to users of wireless communications systems, vendors, system operators and service organizations. EWA is the developer of Cevo®, a powerful online frequency coordination solution, which simplifies the FCC-license application process and allows users to select their own frequencies, and is the creator of Cevo Go™, a mobile app and online capability that delivers certified frequencies in hours, not days. More information about membership and services is available at www.enterprisewireless.org.