April 6, 2020

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UTC to Continue Engaging with FCC as Agency Tees Up Final 6 GHz Order

UTC is committed to continue engaging with the Federal Communications Commission (FCC, the Commission) over the next two weeks as the agency prepares to vote on its draft order allowing unlicensed operations in the 6 GHz band.

The FCC last week released its draft order; it plans to vote on the proposal at its April 23 open meeting.

According to the FCC, the final rule will:

  • Permit two types of unlicensed operations which they claim will protect incumbent services that operate in distinct parts of the 6 GHz band:
    • Across the entire 1,200 megahertz of the 6 GHz band, unlicensed access points would be permitted to operate at lower power restricted to indoor use, without an automated frequency control (AFC) system.
    • In the 5.925-6.425 GHz and 6.525-6.875 GHz sub-bands, unlicensed access points would be permitted to transmit both indoors and outdoors under the control of an AFC system at standard power levels that are currently permitted in the 5 GHz band.
  • Permit client devices to operate across the 6 GHz band only under the control of either a standard power (indoors or outdoors) or low power indoor access point.

The FCC is also proposing to issue a further notice of proposed rulemaking that proposes to permit unlicensed devices to operate both indoors and outdoors across the entire 6 GHz band at very low power, which they claim will prevent harmful interference.

In addition, the agency also seeks comment on increasing the transmit power of indoor access points that operate without an AFC.

While UTC is still reviewing the draft order, a summary of the order is available here: https://utc.org/wp-content/uploads/2020/04/IB-on-6-GHz-_FINAL.pdf.

In response to several press inquiries, UTC Senior Vice President of Government and External Affairs Sharla Artz issued the following statement:

“We have and will continue to provide the FCC with technical detail demonstrating the very real interference potential from unlicensed use across all parts of the band and the need for thoroughly tested automated frequency coordination (AFC) to protect incumbent users. While we appreciate the FCC proposing to require AFC for the standard-power access points, these measures must also be applied to all unlicensed devices in the band to prevent interference to mission-critical utility communications systems. We are also concerned that the FCC is planning to allow low-power indoor unlicensed operations across the entire 1200 MHz of the band. In addition, we are concerned that the draft would allow unlicensed devices to operate at power levels that would cause unacceptable levels of interference to vital utility communications systems. We have and will continue to engage with the FCC and interested stakeholders to develop technical requirements that adequately protect critical infrastructure incumbents and allow unlicensed operations to use in the band.”

In related news, UTC and allied trade associations the Edison Electric Institute, American Gas Association, American Public Power Association, American Water Works Association, the National Rural Electric Cooperative Association, and the Nuclear Energy Institute held a meeting on March 26 with members of the FCC’s Office of Engineering and Technology (OET).

The meeting was an opportunity to review our responses to criticisms of the study we submitted in January which demonstrated that the 6 GHz rule, as proposed, would likely result in interference to nearly all incumbent microwave systems in the Houston area.

Predictably, proponents of opening the band to unlicensed users have criticized the January study. In our rebuttal filing, UTC and the trade associations stated that even using the data submitted by the proponents into the Roberson analysis still results in the significant likelihood of interference.

Please contact the UTC Public Policy Team with any questions.

ESCC Seeks ‘Targeted’ COVID-19 Testing Approach to Protect Essential Utility Employees

The Electric Subsector Coordinating Council (ESCC) is seeking a “targeted” coronavirus testing program to ensure the utility industry can protect its workers who are essential for maintaining power reliability.

In a notice late last month, the ESCC noted that while it understands the current limitations surrounding the availability of coronavirus tests, the utility industry must be part of a strategic testing approach in order to keep its workforce healthy.

According to the ESCC, the following factors must be considered in a targeted testing approach for the industry:

  • Workers’ functional connections to maintaining reliability;
  • The amount of lead time required to train these personnel;
  • The limited pool of people with these qualifications;
  • The risks to regional reliability if this workforce is severely impacted.

The ESCC notice also details steps the industry is taking to ensure employees critical to grid reliability, particularly control-room operators and response crews, are sequestered and even living onsite to ensure their health and safety.

Meanwhile, the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) listed utility workers as among the essential workers critical to protecting the nation’s safety and security.

The CISA notice, posted online and updated regularly, highlighted utility control-room operators, IT and OT operators, black-start facility crews, and many others as critical.

“This list is intended to help State, local, tribal and territorial officials as they work to protect their communities, while ensuring continuity of functions critical to public health and safety, as well as economic and national security,” CISA said. “Decisions informed by this list should also take into consideration additional public health considerations based on the specific COVID-19-related concerns of particular jurisdictions.”

Please contact the UTC Public Policy Team with any questions.

GridEx V Report Recommends Emergency Response Plan Reviews, Enhanced Cross-Sector Coordination

Utilities and reliability coordinators should review their emergency response plans to account for the complex collaboration with all levels of government in North America that would be required should a grid security event occur, NERC recommended in its GridEx V after-action report.

This report focuses on lessons learned and recommendations highlighted throughout the two-day exercise. NERC held the grid security exercise, which had 7,000 participants from across North America — including industry and U.S. and Canadian government partners — in November 2019. The GridEx V Lessons Learned Report focuses on participant observations and recommendations from the cyber and physical security exercise’s distributed play and complementary executive tabletop.

The recommendations target actions for the Electricity Information Sharing and Analysis Center (E-ISAC), electricity industry and cross-sector and government partners in North America to improve future GridEx events and enhance the security posture. “Each GridEx is an important milestone in the ongoing cyber and physical security training of industry members and government partners,” said Manny Cancel, NERC senior vice president and E-ISAC chief executive officer. “This report notes the success of GridEx V and starts the planning process in earnest for GridEx VI as an enhancement to its predecessor.”

GridEx V achieved six of its seven objectives, the report finds. The objectives achieved were exercise incident response plans; expand local and regional response; engage critical interdependencies; improve communication; engage senior leadership; and gather lessons learned. Based on participant feedback, the report lists the “increase supply chain participation” objective as being partially achieved and having significant room for improvement in GridEx VI.

UTC, NRECA Reiterate Support for RDOF Auction, Seek Clarification

UTC and the National Rural Electric Cooperative Association (NRECA) late last month reiterated support for the Federal Communications Commission’s (FCC, the Commission) $20.4 billion Rural Digital Opportunity Fund (RDOF) but asked the agency to clarify that certain new, risky businesses are not eligible for the funding.

In joint comments, UTC and NRECA that they support most of the agency’s bidding rules, particularly the rules that ensure that projects offering the highest quality service—i.e., the best speeds—will be in the best position to win the funding.

However, the groups urged the Commission against allowing satellite companies to participate in the bidding because it is counter to the public interest.

“Commission staff should not be obligated to entertain technical proposals in short-form applications that lack meaningful operational history upon which reasonable expectations of performance can be based,” the parties said. “The same logic applies in considering whether to even allow operators of Low Earth Orbit satellite (LEOs) networks to participate in the auction. LEOs have scant, if any, operational history. That the projected latency for LEOs may be better than geostationary orbits is obvious, but LEOs is not a mature technology suitable for USF support at this time.”

Reply comments are due April 10.

The FCC approved the RDOF program in late January 2020. About a month later, the agency sought comments on its bidding rules and auction procedures (Industry Intelligence, March 9, 2020).

UTC CALENDAR OF EVENTS

Calendar of UTC committee/division conference calls

  • RESCHEDULED! Aug. 31-Sept. 4, 2020: Telecom & Technology Annual Meeting, Providence, RI
  • RESCHEDULED! Oct. 12-14: Region 6 Meeting, Double Tree by Hilton Kansas City-Overland Park
  • RESCHEDULED! Aug. 4-6: Broadband Workshop, Fairfield Inn and Suites, Charlotte

Webinars

  • April 7: Broadband Backhaul, Sponsored by Aviat
  • April 21: Small Cell Pole Attachment Best Practices
  • April 28: How Utilities Empower Broadband Deployment
  • May 12: UTC Training Webinar: Utility Backup & DC Power Systems – Part 1
  • May 14: UTC Training Webinar: Utility Backup & DC Power Systems – Part 2

Committee/Division calls

  • April 14: UtiliSite Committee Call—For more information, contact Bob Lockhart at bob.lockhart@utc.org
  • April 15: IT/OT Committee Call—For more information, contact Bob Lockhart
  • April 16: Telecom Committee Call—For more information, contact Brett Kilbourne
  • April 16: Public Policy Division Call—For more information, contact Rob Thormeyer
  • April 17: Security, Risk, and Compliance Committee Call—For more information, contact Bob Lockhart
  • April 21: Utilities Broadband Committee Call—For more information, contact Brett Kilbourne