Citing reliability concerns, groups urge DOE to hold meeting on FCC plan

Saying that a Federal Communications Commission proposal to open the 6 GHz band to unlicensed use would likely lead to significant reliability concerns for the U.S. energy and water sectors, the American Public Power Association and several other groups are urging the Department of Energy to hold a meeting on the FCC proposal.

In October 2018, the FCC proposed opening the 6 GHz band to unlicensed use, which would allow any commercial entity access to the band. In most bands, unlicensed spectrum is less expensive and comes with requirements that the entities not interfere with incumbent license holders.

However, most bands are not used for the kinds of mission-critical purposes that 6 GHz is well-suited to provide. Furthermore, the 6 GHz band is already heavily used; the entrance of new players into the band would threaten to interfere with these critical networks, the groups noted in their July 16 letter to Secretary of Energy Rick Perry.

“While the FCC knows the band is already crowded, it is moving forward nonetheless because it believes it can protect our systems from disruption through an automated protection system called Automated Frequency Coordination (AFC). Unfortunately, the FCC’s AFC system is unproven and untested, and even those who support the concept cannot guarantee it will prevent harmful interference consistently and reliably,” the groups said.

They said that interference to these mission-critical communications networks could impair an electric utility’s ability to protect its infrastructure from faults on the grid. If a line is experiencing a problem or fault, teleprotection systems take action to prevent the problem from escalating and possibly damaging other elements on the system or causing power outages, the letter pointed out.

“Teleprotection systems must operate in milliseconds to execute their functions properly. Interference to these communications could cause delayed or degraded communication signals within these systems, which may present adverse operational and safety impacts.”

Energy, water industries critical to nation’s critical-infrastructure industries

Every single federal agency, including and especially the DOE, has acknowledged the energy and water industries as among the most critical of all the nation’s critical-infrastructure industries (CII).

Electric utilities, for example, remain the only industry in the country subject to mandatory reliability and cybersecurity standards to ensure that the U.S. has highly reliable electricity service. “In addition, each of our sectors participate in its respective sector-coordinating councils to ensure close collaboration with our federal partners in the event of natural or manmade disasters,” the letter noted.

“Despite this recognition from DOE, the White House, Department of Defense, and Department of Homeland Security, the FCC is proposing a rule which, if adopted as currently drafted, would likely cause significant reliability concerns along the energy and water infrastructure in the U.S.”

In order to avoid adverse impacts to customers, “many of our individual members could be forced to rebuild parts of their infrastructure over a multi-year process because of the risk and uncertainty brought about by this rulemaking.”

The letter to Perry was signed by Sue Kelly, President and CEO of the American Public Power Association, as well as Jim Matheson, CEO of the National Rural Electric Cooperative Association, Maria Korsnick, President and CEO of the Nuclear Energy Institute, G. Tracy Mehan, Executive Director, Government Affairs, at the American Water Works Association, Tom Kuhn, President of the Edison Electric Institute, and Joy Ditto, President and CEO of the Utilities Technologies Council.

“The CII we represent own and operate infrastructure to deliver life-sustaining services to all aspects of our economy, including to the technology and telecommunications sectors,” the groups told Perry.

This infrastructure consists of power plants, interstate and intrastate electricity lines, interstate and intrastate water and gas pipelines, control centers, and substations, among others.

“Because the generation of electricity must be instantly matched with the delivery of power to customers, balancing the supply and demand of electricity requires intense planning, careful coordination, and robust and redundant infrastructure. Additionally, oil and gas and water pipelines must be constantly monitored for safety and reliability.”

Networks provide critical situational awareness, underpin safety functions 

In order to support the reliable delivery of these services on a real-time basis, the collective membership of the trade groups deploys a sophisticated array of private communications networks throughout their service territories.

“Often overlooked, these networks provide critical situational awareness, underpin safety functions, and enable crews to safely repair and restore services after storms. In addition, these communications networks support the greater deployment of distributed energy resources, smart meters and other technologies to enable the more flexible grids associated with the transition to the utility of the future.”

The energy and water utilities’ communications networks of the trade groups’ members consist of wireline and wireless technologies.

While wireline services can often provide faster and more reliable communications, they can be cost-prohibitive or unfeasible to deploy in some locations. “Therefore, our collective members must rely on wireless networks for numerous mission-critical communications needs,” the groups said.

According to a recent survey published by the Utilities Technology Council, the most popular, reliable, and cost-effective wireless transmissions are done via microwave networks.

Electric utilities use microwave communications for outage management, energy management, teleprotection (the communication between and among power relays), and smart metering, among other functions.

The membership of the trade groups uses the 6 GHz band for many of these mission-critical communications. Currently, the band is reserved for licensed use. “Licensed spectrum offers our members the reliability and protection from interference that these networks require. Due to the criticality of these networks, electric utilities cannot tolerate even the slightest risk that these communications systems could be degraded, as diminished situational awareness can result in degraded electricity reliability. Having continued interference-free access to this licensed spectrum ensures greater reliability and resilience.”

Groups call for DOE public conference on FCC proposal

“Given the negative impacts this proposal could have on our nation’s energy and water systems, we believe the FCC must hear from other agencies that regulate this infrastructure,” the trade groups told Perry.

While the members of the trade groups recognize the importance of using spectrum more efficiently to meet the country’s growing wireless needs, the 6 GHz band “is home to the communications systems that support the very devices and services the FCC wishes to expand.”

The groups acknowledged that the FCC is an independent agency. But its decisions have a clear and present impact on the nation’s energy and water sectors, they noted.

“It is therefore in DOE’s interest to hold a public conference or, at the very least, encourage the FCC to ensure that its final rule contains adequate, tested, and proven measures to protect the CII industries which power our ways of life.”

A copy of the letter was sent to members of the Federal Energy Regulatory Commission.

Comments on House hearing with wireless groups

On July 16, the House Energy and Commerce Committee Subcommittee on Communications and Technology held a hearing, Our Wireless Future: Building a Comprehensive Approach to Spectrum Policy, which included panelists from the FCC and groups representing the telecommunications industry.

The Association joined the same set of groups that sent the letter to DOE in submitting a statement for the record related to the hearing. In the statement, the groups urged the House to consider a holistic approach to spectrum and wireless policies and recognize the impact of FCC’s policies on other CII. The statement notes that the shared goal of 'winning the race to 5G' will only happen “if the spectrum policies adopted by the FCC support CII, which in turn support the wireless telecommunications providers looking to roll out 5G technologies.”

The statement requests the Subcommittee recommend that the FCC discuss with FERC the potential impacts opening the 6 GHz band will have on CII. 

Read the full statement on UTC’s website.