In my capacity of President of ENTELEC, I went to Washington, D.C. in mid-May to meet with FCC staff.
There were two primary purposes to the meeting:
Education. On behalf of ENTELEC’s Regulatory and Technology Committee, we wanted to educate FCC staff about the oil and gas industry. In particular, we discussed how ENTELEC member companies rely on internal networks to run our businesses in a safe, efficient, and productive way. We also talked about decisions the FCC has made in the past have both positively and negatively impacted members of ENTELEC’s community;
Advocacy. We also discussed a few active FCC proceedings that involve spectrum allocations, including the 6 GHz and 2.5 GHz bands. We explained how we use existing 6 GHz networks and urged the FCC to protect those existing uses. We also discussed how the FCC’s rules for auctioning spectrum disadvantage ENTELEC member companies who financially cannot compete with commercial telelcom carriers when it comes to purchasing spectrum in major metropolitan areas. With this background, we encouraged the FCC to consider revised rules to repurpose the 2.5 GHz band for critical infrastructure use.
Further details of the meeting are discussed below. But if you’re really interested in the substantive meeting discussion – or participating in future dialogue about these issues – you should join ENTELEC’s Regulatory and Technology Committee.
We will provide much more information about the FCC meeting during the next R&T Committee meeting next month. It’s an important time to get involved with the R&T Committee because the FCC asked us some questions that relate to the future of the 6 GHz band. We want to solicit member feedback and provide this valuable information to the FCC in the next few weeks. We’ll discuss this further on the next R&T Call, so if you’d like to participate in this process and support the R&T Committee please register for the call online.
6 GHz Band. In August 2017, the FCC issued a Notice of Inquiry asking if it could introduce unlicensed operations into the 6 GHz band. Last year, the FCC issued proposed rules that – if adopted – would make this possible. The bulk of my meeting with the FCC was discussing the future of the 6 GHz band.
I explained how ENTELEC member companies currently use 6 GHz fixed links to support mission critical operations. I also reminded the Commission that many of these companies migrated to the 6 GHz band at great expense after the FCC repurposed the 2.1 GHz band. Introducing unlicensed use in the 6 GHz band could compromise the reliability of that band. This, coupled with the fact that migration out of the 6 GHz band is impossible with the existing infrastructure ENTELEC members have in the field, make it a bad idea for the FCC to permit unlicensed devices to operate in the 6 GHz band.
The Commission understood these arguments and asked what rules and protections they should adopt to protect incumbent fixed microwave licensees in the 6 GHz band if the agency eventually permits unlicensed use of the band. We want to discuss your ideas at the next R&T Committee meeting so we can provide additional feedback to the FCC.
2.5 GHz Band. The FCC is currently looking to repurpose all or some of the Educational Broadband Service (“EBS”) band at 2.5 GHz. The band is 114 MHz of contiguous spectrum, the largest such block of contiguous spectrum below 3 GHz. Auctioning the spectrum to commercial entities is one of the proposals the FCC is considering.
I explained how the FCC’s auction process disadvantages ENTELEC members because we do not monetize our use of the spectrum, but we rely on spectrum to support federally mandated secure and redundant communications networks. I discussed how different ENTELEC members could be impacted by the FCC’s decision. For instance, smaller licensed areas around refineries could help some ENTELEC members, but it is nearly impossible for a company to acquire spectrum that covers pipeline operations that cover hundreds of miles and traverse many states.
I hope the FCC considers ENTELEC members as it continues to explore expanded use of the 2.5 GHz band.
Other Items. Though these were the two big items, I also touched on some other issues. For instance, I explained how the FCC’s streamlined environmental review process for towers has helped ENTELEC member companies deploy infrastructure in a more efficient manner. But there is still more the FCC could do in this space. I reiterated the industry’s need for spectrum and the perils of relying on unlicensed or lightly licensed spectrum when mission critical operations are at stake.
It was a productive meeting. But I’m hoping it’s the first of many where ENTELEC members ensure their voice is being heard in Washington. And I encourage you to participate in the R&T Committee if you want your voice – like mine – to be heard.
Jerry “O” Roberts
2019-2020 ENTELEC President