For Private Enterprise, 4.9 GHz Spectrum Can Enable Reliable, Secure Broadband for Critical Systems

July 6, 2018
In comments filed in response to the Federal Communications Commission’s (FCC) Sixth Further Notice of Proposed Rulemaking (FNPRM) on the future allocation and use of the 4.9 GHz band, the Enterprise Wireless Alliance (EWA) argued that allowing private enterprise users primary access to a significant portion of the allocation will benefit both those users and public safety entities. EWA urged the FCC to broaden the eligibility criteria for this spectrum, but not open it for commercial use, and to adopt rules consistent with the efficient management of this allocation. Expanding eligibility to private business enterprise users will enable more intensive use of the allocation, increase development of equipment for the band, and yield more innovative uses of the spectrum. In addition, EWA used the opportunity of the FNPRM to comment on troubling trends in current FCC spectrum management. Below are highlights from that commentary.
 
  • EWA is concerned that the Commission’s seemingly single focus on consumer-based services may have obscured its view of the broader range of telecommunication requirements.  It is critical that the FCC recognize the vital importance of spectrum – narrowband, wideband, and broadband – for the businesses on which every consumer relies each and every day. No commercial network is capable of addressing all the needs of non-consumer based subscribers, and few are fully accessible during emergencies when they are most urgently needed.  
  • Supporters of opening the band for commercial operations describe the position as consistent with a movement away from central planning in favor of flexible spectrum use. In truth, however, commercial allocations are a form of FCC central planning and a choice with a highly predictable outcome. They inevitably result in spectrum either being awarded to a small number of commercial operators through the auction process, or being made available on an unlicensed basis, or a combination of the two. The spectrum invariably is used for consumer-oriented services, with a limited number of providers and vendors defining what offerings are provided to the consumer marketplace.   
  • The Commission too readily accepts claims from commercial carriers and their advocates that Business/Industrial Land Transporation requirements can be met by acquiring auctioned spectrum in the secondary marketplace through partitioning and/or disaggregation. The experience of more than two decades and almost one hundred auctions, does not support that assumption. In all but the rarest instances, it is not practical from a business development standpoint or economically worthwhile for a commercial operator to carve out a relatively small piece of its geographic authority to accommodate the unique coverage requirements of local private carrier competitors and business enterprises that are viewed as potential customers for the commercial network.   
  • While EWA would not object to a public safety licensee that has built and operated a 4.9 GHz system leasing some or all of its spectrum to another public safety entity, it would oppose extending the leasing option to commercial or even business enterprise users. Creating an arbitrage opportunity for public safety entities to acquire spectrum for the purpose of leasing it, rather than utilizing it for public safety operations, defeats the purpose of designating spectrum for public safety use in the first place.  

About EWA

The Enterprise Wireless Alliance is the leading national trade association and advocate for business enterprises, private carrier operators, equipment manufacturers, and service providers that support the private wireless industry. A frequency advisory committee certified by the Federal Communications Commission, EWA provides its members and clients with consulting services, frequency coordination, license preparation, spectrum management and associated business intelligence services. EWA is the market leader in Business/Industrial Land Transportation frequency coordination services and assists a significant percentage of public safety customers with their spectrum requirements. Learn more at www.enterprisewireless.org.

  • We use EWA for all of our FCC license applications. The staff at EWA provide outstanding customer service and do all they can to see that applications are granted. EWA does a super job of staying on top of situations that affect our ability to file license applications and serve customers. EWA’s Regulatory Call keeps us informed about what is happening with the FCC and their online systems.
    Brian S. Auker
    Triangle Security and Communications
  • The advocacy and regulatory issues are very important to our business, and, without EWA, we would have no voice. Nobody is speaking up for players like us in Washington except EWA.
    David Reeves
    P&R Communications
  • It’s not just about finding frequencies. It’s about finding the RIGHT frequencies for that customer, and EWA excels every time at that. We would not be moving forward without EWA.
    Craig Sikes
    Mobile Communications America
  • It’s remarkable what we’ve been able to do with EWA’s support. It’s a collaborative effort that has allowed Midland to deliver unparalleled support to our customers. No one else has the depth of understanding of FCC rules, which has resulted in more application grants. Midland Communications has a profound appreciation for EWA’s advocacy efforts. It has allowed us to have a voice before the FCC.
    Paul Moore
    Midland Communications
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    A Beep, LLC