NPSTC Files Comprehensive Comments to FCC on 4.9 GHz Band. In the Sixth Further Notice of Proposed Rule Making (FNPRM), the FCC sought comment on alternatives to stimulate expanded use of and investment in the 4.9 GHz band.

NPSTC's comments provided a more accurate picture of current and potential usage in the 4.9 GHz band. The Commission's stated calculation that no more than 3.5% of the potential licensees use the band has apparently created the misimpression that very little of the band's capacity is in use. NPSTC examined the 3.5% calculation and presented more relevant statistics and sample use cases on existing public safety operations in the band. Spectrum in the 4.9 GHz band is licensed by state and/or local entities in almost every state in the U.S. Just the states alone that hold licenses in the band cover a total population of 138 million, with additional population served by public safety in localities that hold licenses outside of those states.

There are two types of licensing: Site-specific licenses for permanent point-to-point operations and geographic licenses that cover a licensee's entire jurisdiction for the entire band. Fixed point-to-point sites have experienced a 31% increase over the past 3 years. As geographic licenses do not include site information, increases in the facilities used under those licenses could have increased as well, but it is impossible to determine that from the ULS database.

In addition to current uses, NPSTC addressed emerging technologies used in public safety for which 4.9 GHz would be beneficial. NPSTC demonstrated how this spectrum can be instrumental in supporting emerging technologies beneficial to public safety, including aeronautical, both manned and unmanned (UAS), robotics, and the public safety Internet of Things (PS IoT). NPSTC has provided additional information on each of these types of emerging uses and the additional need for the 4.9 GHz spectrum they bring.

NPSTC supported managed sharing of the band with Critical Industries Infrastructure (CII) entities and opposed reallocation and auction of the band for commercial use. Reallocation of the band would be very detrimental to public safety and likely would not be very productive for commercial carriers.

NPSTC has also addressed many of the technical and licensing improvement issues raised in the Sixth FNPRM. These include the need for more specific information in the database related to geographic licenses, as well as increased frequency coordination and provisions for Regional Planning Committee involvement.