Appreciation

 

Sept. 9, 2019

Many of you already know that the Department of Energy (DOE) Assistant Secretary of the Office of Electricity Bruce Walker recently sent letters to Federal Communications Commission (FCC) Chairman Ajit Pai, National Telecommunications and Information Administration (NTIA) Acting Administrator Diane Rinaldo, and NTIA Deputy Associate Administrator of the Office of Spectrum Management Peter Tenhula regarding the 6 GHz spectrum band. Letters were also sent to several trade association CEOs, including me, who wrote to the Department of Energy in July asking for help on this important matter. I could not be more appreciative of DOE’s support for protecting and promoting utility communications!

I’ll go into the specifics of the DOE letter in a bit. First, as a reminder, the issue at hand deals with the FCC’s proposed rulemaking to open up the 6 GHz spectrum band — currently a licensed band — to unlicensed operations. Adding unlicensed use into this band in particular changes the dynamics and utility use case for it. Right now, as a licensed-only band, utilities and other users are able to coordinate with each other to prevent against interference, because all of the users in the band have licenses and are therefore known to each other. Even though there is occasional interference in the band, users are able to work with each other to resolve it going forward.

But by allowing unlicensed users, the FCC is adding a new level of risk to the critical-infrastructure industries (CII), including utilities, already in the band. Even though unlicensed users are not supposed to cause harmful interference, utility license holders are concerned because in the event that an unlicensed user causes interference, it will be too late to correct if it leads to a failure of critical communications. For example, a utility won’t know who is causing interference if it is coming from an unlicensed user, and by the time it is remedied, it will be too late. So the FCC’s proposed mitigation measure—called Automated Frequency Coordination (AFC)—must prevent interference from occurring in the first place, rather than fixing it after the fact. That’s why UTC and others who oppose this concept want the FCC to test the mitigation measure to ensure it will work.

Electric, water and gas utilities of all ownership types, railroads, public safety, and oil pipelines, among others, rely on the 6 GHz band for critical communications – mostly “point-to-point” microwave wireless networks that use towers to repeat a signal sent along a distinct path. These networks are often owned and operated by critical-infrastructure providers themselves. Electric utilities use the 6 GHz band, in some cases, to enable Supervisory Control and Data Acquisition (SCADA) and teleprotection, two reliability tools that govern modern electric utilities’ operations. In other cases, utilities use fiber lines/networks to enable such industrial control systems. The rub is that in some geographic areas, laying fiber is either unrealistic (on federal lands, for example), very expensive, or both. That’s why these wireless networks housed in the 6 GHz band were developed in the first place.

So, why the push to open this band? Some “Big Tech” companies have asked the FCC to open it up for 5G wireless activities. While we at UTC are supportive of 5G conceptually, we believe that these companies have ample opportunity and available spectrum in other bands to rollout 5G wireless networks without putting critical-infrastructure use of this vital band in jeopardy. DOE makes these points in its letters to the FCC and NTIA. DOE also cites the failure of a similar technology to AFC, called Dynamic Frequency Selection (DFS), that was used to prevent interference to Terminal Doppler Weather Radar systems in the 5.8 GHz band. DOE states; “…our understanding is that DFS had numerous issues and failed to work correctly, to the point where the National Telecommunications and Information Administration (NTIA) found that the DFS system did not properly address interference in that band.” DOE then offers the National Labs’ help to field test the AFC to ensure it works properly before being put into use in the 6 GHz band, an offer UTC wholeheartedly supports.

The DOE letter urges the FCC to look at other bands for 5G. And here’s where things get intriguing: If the FCC does not consider other bands for 5G usage, DOE suggests that the FCC establish a dedicated spectrum band for energy and water use, with appropriate funding to relocate these entities from 6 GHz to such a band. As those involved in the spectrum debates for much longer than I have been will understand, dedicated spectrum for critical-infrastructure use was hotly debated for many years but rejected by the FCC and other policymakers. U.S. spectrum policy has therefore shifted in favor of spectrum sharing and auctions, rather than allocating spectrum on a dedicated basis specific service or for certain entities to use for free.

I would suggest, however, that the DOE question about dedicated spectrum does not have to be viewed through these “old” lenses. UTC and its members have long recognized the synergies between federal-government spectrum users and CII such as energy and water utilities. We have been in discussions with our federal government brethren about spectrum sharing in some of those bands—a potential win-win solution that would not only ensure government and CII access and use to dedicated spectrum but also enable more efficient use of these bands. Regardless of the details, DOE has correctly and forcefully identified that the FCC, must recognize the highly reliable communications needs of energy and water utilities.

The bottom line – thank you again to DOE for taking on this important issue that has long-term implications. UTC will continue to push for the positive actions urged by DOE. Until we meet again…