APCO Submits Comments to the FCC regarding the 4.9 GHz Band


On November 29, 2021 APCO filed comments on the FCC’s Eighth Further Notice of Proposed Rule Making for Docket 07-100 regarding the 4.9 GHz band. Highlights of APCO’s comments are:

  • Non-public safety use of the band only if it occurs without causing harmful interference to public safety.
  • Ensure the 4.9 GHz band is free from interference by requiring frequency coordination.
    • For base station/mobile use, use Part 90 contour-based coordination.
    • For Point to Point (P-P) or Point to Multi-Point (P-MP) using propagation modeling similar to that used to coordinate TDMA systems operating in the VHF band would be preferable to TIA-10 or Part 101 type coordination.
  • Maintain and enhance the FCC’s Universal Licensing System (ULS) for 4.9 GHz.
  • Increase flexibility for Public Safety licenses.
    • Permit channel aggregation up to 50 MHz.
    • Decline to specify a band plan and permit public safety frequency coordinators flexibility to assign channels in a way that maximizes spectrum efficiency.
    • Allow Unmanned Aerial System (UAS) use.
    • Modify power restrictions to increase spectral efficiency and broadband use.
    • All permanent fixed P-P and P-MP operations should be afforded primary status, not just those supporting broadband traffic.
  • Oppose a single nationwide band manager.
  • Open to a role for Regional Planning Committees (RPC) but notes that any continued or expanded role should take into account the funding and authority limitations creating challenges today.
  • Not opposed to a sharing approach provided that public safety is guaranteed priority and preemption over other users.

To view the full comments submitted by APCO go to the APCO Advocacy web page https://www.apcointl.org/advocacy/public-filings/ . For comments submitted by all other commenters go to the FCC Electronic Comment Filing System (ECFS) web page https://www.fcc.gov/ecfs/search/filings?proceedings_name=07-100&sort=date_disseminated,DESC