The Enterprise Wireless Alliance (EWA) has filed comments urging the Commission to adopt rules in response to the Eighth Further Notice of Proposed Rulemaking (FNPRM) that will enable the 4.9 GHz band to reach its full potential. The FCC’s FNPRM confirmed that this band must continue to maximize its use by public safety entities, but also explored various models for shared spectrum use. In its comments, EWA recommended the FCC adopt the National Public Safety Telecommunications Council (NPSTC) plan recommended in 2013, which NPSTC has continued to endorse over the past eight years. That plan, a consensus proposal from the public safety community, recommended that the 4.9 GHz band be shared with Critical Infrastructure Industry (CII) entities. EWA represents a number of CII entities and other large business enterprise companies eager to invest in private broadband networks. The Alliance generally supports the NPSTC Plan but recommends expanding the CII category to track the definition developed by the Department of Homeland Security, which includes — in addition to governmental and emergency services — energy, healthcare and public health, water and wastewater systems, information technology, food and agriculture, critical manufacturing, and transportation systems. This more inclusive list will promote robust enterprise activity, activity that will significantly expand investment in the band with the expected concomitant reduction in equipment cost and expansion of technology options that will benefit public safety entities as well.
Public safety and business enterprise entities have demonstrated an ability to share exclusive spectrum rights in other bands, such as 800 MHz, through a frequency coordination process that has been tested over many decades. They have a desire to do so at 4.9 GHz, a band in which commercial service providers and unlicensed spectrum proponents have expressed little or no interest. The record supports the sharing arrangements endorsed by public safety and business enterprise representatives. Adopting the NPTSC plan with an expanded definition of CII will support the FCC’s goals of protecting the operations of incumbents, while promoting new entrants that will maximize investment in and utilization of this spectrum.