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Major Critical-Infrastructure Industry Organizations Push Back Against FCC Spectrum Proposal

Major Critical-Infrastructure Industry Organizations Push Back Against FCC Spectrum Proposal

Six major industry organizations representing critical electric, oil, natural gas, and water utilities are united in opposition to a federal proposal that would open up a critical wireless communications band, potentially disrupting crucial communications systems underpinning the safe and reliable delivery of these lifesaving and sustaining services.

In a significant show of force, the critical industry organizations said the proposal could cause these entities to re-engineer and rebuild their communications networks–a costly process that could take individual companies 10 years or more—rather than face even the threat that their networks could fail.

The entities signing the comments are the American Petroleum Institute, the American Public Power Association, the American Water Works Association, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the Utilities Technology Council.

“These networks are used to provide mission-critical command-and-control applications to manage the grid, including SCADA and teleprotection,” the entities state. “These highly complex systems collect data from devices on the grid and process that information for operators to control operations from remote locations or for the devices themselves to automatically respond to faults on the grid that can cause outages as well as accidents.”

At issue is the Federal Communications Commission’s proceeding into whether to open the heavily used 6 GHz spectrum band to unlicensed, commercial use. Spectrum is a finite commodity and is necessary for any kind of wireless communication system, including baby monitors, smart phones, Wi-Fi, and industrial control systems.

Nearly all electric, water, and natural gas utilities/companies deploy their own communications systems to monitor and underpin their infrastructure. These networks are almost all privately owned and operated, and therefore do not rely on commercial communications companies for service. Like any communications network, those owned and operated by members of these organizations consist of wireline and wireless features.

Critical infrastructure industries such as those represented in this coalition build their networks to monitor and maintain their infrastructure and ensure it is operating safely and reliably. Many entities use the 6 GHz spectrum band for certain functions. Electric utilities, for example, use 6 GHz to run their supervisory and control data acquisition (SCADA) and teleprotection systems, both essential to the reliable operation of electricity. Because of the importance of the information being transmitted in the band, to date the FCC has limited use of the band to license holders. Licensed spectrum offers a high-level of protection against radiofrequency interference and provides users the ability to resolve potential interference from other licensees, if any occurs.

However, in late October 2018, the FCC initiated a proceeding into whether it should open the 6 GHz to unlicensed, commercial users. It also sought comment into whether a proposed “automated frequency coordination system” (AFC) could be used to prevent interference with licensed users. Proponents of opening the band argue that doing so will provide more access to Wi-Fi devices, among other things.

In their comments, the critical infrastructure organizations urge the FCC to reconsider its proposal, as there remains no proven way to reduce interference and there are other bands which could be used for other commercial uses.

“The 6 GHz band uniquely provides favorable propagation characteristics for reasonable path distances, lower rain fade, and better reliability than other spectrum bands, such as the 8 GHz or 11 GHz bands,” the entities state. “Electric companies and CII could not simply migrate their operations to these other spectrum bands; it would require significant reengineering of their microwave links or adding more link segments to make up for shorter propagation distances.”

The AFC system proposed in the FCC proceeding remains untested and based on faulty assumptions, the entities said. It does not account for the nature of the existing critical services in the band and “disregards” concerns over critical-infrastructure interference.

“The Commission’s proposal to mitigate interference through automated frequency coordination (‘AFC’) is unsupported by the record evidence or experience,” the entities state. “The Commission’s proposal would also likely require lengthy periods of time and substantial sums of money to implement. Spectrum sharing technologies like those in the Citizen’s Broadband Radio Service (‘CBRS’) are nascent and AFC has not even been tested to determine its performance capabilities.”

Comments are the FCC proposal were due Feb. 15. Reply comments are due March 18. It is unclear when or whether the Commission will take final action.


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