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