On The Record: Anterix's Bid to Reconfigure the 900 MHz Band (NPRM 24-99)

Utilities champion the 5/5 MHz future, but face opposition from railroads. Here’s a summary of what's "On The Record" in WT Docket 24-99

This article presents two summaries of WT Docket 24-99: an Executive Summary, followed by a Detailed Summary.

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Executive Summary of Docket 24-99

I. Introduction

On January 16, 2024, the FCC’s Wireless Telecommunications Bureau released a Notice of Proposed Rulemaking (NPRM) in WT Docket No. 24-99. The NPRM proposes a framework to expand private broadband opportunities in the 900 MHz band by enabling a 5/5 megahertz (MHz) channel configuration, building upon the 3/3 MHz segment established by the Commission in its 2020 Report and Order.¹ The proposal outlines a voluntary, negotiation-based transition mechanism where a qualifying entity could obtain a 5/5 MHz license on a county-by-county basis. To qualify, an applicant must hold licenses for over 50% of the 900 MHz spectrum in a county and demonstrate it has cleared or will protect 100% of incumbent narrowband licensees in the target segments through private agreements. This executive summary analyzes the comments, replies, and ex parte filings to outline the key arguments from proponents and opponents. It provides a high-level overview of the debate, with a more comprehensive summary provided in the Detailed Summary that follows.

II. ARGUMENTS IN SUPPORT OF THE 5/5 MHZ FRAMEWORK

Proponents, led by the utility sector and Anterix, argue that the expansion from a 3/3 MHz to a 5/5 MHz channel is a necessary and logical evolution of the band to support the increasing data demands of modern critical infrastructure.

Utilities and their trade associations argue that while the 3/3 MHz channel is sufficient for current needs, it will not support future high-bandwidth and low-latency applications, which are essential for grid modernization, security, and reliability. Filers identified numerous use cases that require expanded capacity, including the integration of Distributed Energy Resource Management Systems (DERMS), Advanced Metering Infrastructure (AMI) 2.0, high-resolution video surveillance for physical security, and Uncrewed Aircraft System (UAS) inspections.² Southern Linc, drawing from its operational experience, noted that a fully loaded Cat-M channel for smart meters can consume up to 60% of a 3/3 MHz channel's capacity, an issue that a 5/5 MHz channel would mitigate. The Utility Broadband Alliance (UBBA) and others also emphasized the need for wider channels to support low-latency applications, such as Direct Transfer Trip (DTT), for grid protection.³

Technology vendors and ecosystem partners argue that a 5/5 MHz configuration better aligns with global 3GPP standards for LTE and 5G. This harmonization is expected to foster a broader and more cost-effective equipment ecosystem by leveraging economies of scale from the commercial wireless industry, thereby accelerating the deployment of private 5G networks for critical infrastructure.⁴ Supporters universally endorsed the NPRM's voluntary, negotiation-based framework, with Ameren Services Company and the Lower Colorado River Authority (LCRA) citing the success of the 3/3 MHz transition as proof that the model works effectively with minimal FCC intervention.⁵

III. ARGUMENTS IN OPPOSITION OR URGING CAUTION

Opposition to the NPRM is led by the railroad industry, which operates a nationwide, safety-of-life communications network in the band. The Association of American Railroads (AAR) described the proposal "inappropriate and premature," highlighting that the 3/3 MHz transition is still ongoing and that its members are on schedule to meet the September 2025 deadline to vacate six channels at an expected cost exceeding $110 million.⁶ AAR stated it has no plans to relocate again and that a piecemeal, county-by-county transition is "incompatible" with its national Advanced Train Control System (ATCS). It also cited studies showing a significant risk of co-channel broadband interference to its safety systems. Before considering any voluntary agreement, AAR listed several non-negotiable conditions: equivalent replacement spectrum (a nationwide ribbon license of at least ten 25 kHz channels), full recovery of both sunk and future relocation costs, and a 20-year quiet period secured by financial guarantees.⁷

Rail technology developers Ondas Networks (Ondas) and Siemens Mobility Rail Infrastructure (Siemens) argued the NPRM creates an "abrupt policy reversal" that would undermine the regulatory certainty of the 2020 Order, jeopardizing significant investments made in reliance on that stability to develop next-generation rail technologies.⁸ Motorola Solutions, Inc. (MSI) also deemed the proposal "premature," noting that 3/3 MHz broadband deployment remains "nascent." MSI insisted that any transition must be strictly voluntary and fully compensated, and raised concerns about out-of-band emissions (OOBE) interference into remaining narrowband systems now that the guard bands would be eliminated.⁹

Adjacent-band operators also voiced interference concerns. Gogo Business Aviation LLC (Gogo) warned of a significant risk that 5/5 MHz uplinks could interfere with its air-to-ground (ATG) uplinks and proposed mandatory coordination procedures or stricter OOBE limits.¹⁰ Space Data Corporation proposed a broader band reorganization, suggesting the 5/5 MHz block be shifted into the adjacent NPCS spectrum to avoid conflict with the AAR.¹¹

IV. DEBATE OVER SPECIFIC RULES AND TRANSITION MECHANISMS

Filings reveal significant debate over the specific mechanics of the proposed 5/5 MHz framework, with parties proposing modifications to the NPRM.

• Relocation Mechanism: While most filers supported a purely voluntary process, San Diego Gas & Electric Company (SDG&E) argued the Commission should extend a mandatory relocation mechanism to the narrowband segments to prevent incumbent holdouts from thwarting the transition.¹² This position was opposed by incumbent operators like the National Rural Electric Cooperative Association (NRECA), which conditioned its support on a strictly market-based process.¹³

• Complex System Exemption: Operators of large, integrated "complex systems," such as NextEra Energy, Inc. (NextEra) and Eversource Energy Service Company (Eversource), conditioned their support on the express retention of their exemption from mandatory relocation. They argued against any revision to the definition and urged the FCC to codify the May 13, 2020, date for determining system status to provide regulatory certainty.¹⁴

• Interference Protection: Anterix, supported by LCRA and SDG&E in reply comments, proposed modifying the incumbent protection rule from a 70-mile radius to a 40-mile radius, arguing the latter is more realistic for modern private LTE systems.¹⁵ AAR strongly defended retaining the 70-mile zone.¹⁶

• Application Freeze: Parties were divided on the ongoing freeze on 900 MHz applications. Multiple utility filers and MSI urged the Commission to lift the freeze on incumbent licensees' licenses to allow for system maintenance and expansion.¹⁷ Anterix and others supported a more limited modification to allow certain narrowband-to-narrowband exchanges while opposing a full lift to prevent speculation.¹⁸

• Technical Rules: A key point of contention is the OOBE limit. Gogo and MSI argued for stricter limits to protect adjacent-band and remaining narrowband operations.¹⁹ In contrast, Anterix, Nokia, and Ericsson asserted that the existing rules are sufficient and would allow for cost-efficient network expansion.²⁰ In reply comments, Anterix submitted a technical analysis disputing Gogo's interference model and concluding the risk was minimal.²¹

• Anti-Windfall Provisions: Anterix and SDG&E argued for modifications to the anti-windfall rules. Anterix proposed that applicants receive credit for spectrum surrendered in a prior 3/3 MHz transaction. Meanwhile, SDG&E argued that entities that have already deployed networks should not be subject to further measures, citing the potential chilling effect on investment.²²

V. Conclusion

The record in WT Docket No. 24-99 demonstrates a broad consensus among the utility sector, technology vendors, and other critical infrastructure entities that expanding the 900 MHz broadband segment to 5/5 MHz is a vital step to meet future operational and security needs. Proponents frame the proposal as a market-based, voluntary evolution that will unlock significant public interest benefits. However, the proceeding also reveals deep-seated and consequential opposition from the railroad industry, which views the proposal as a premature and direct threat to its nationwide, safety-of-life communications network. The viability of the Commission's proposed framework hinges on whether a voluntary, negotiated agreement can be reached with AAR, whose relocation preconditions are substantial. The Commission's path forward will require balancing the clear demand for additional private broadband capacity against the protection of entrenched, safety-critical incumbent operations and the investment stability of the entire band.

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Detailed Summary

FCC Proposes Framework to Expand 900 MHz Broadband to 5/5 MHz

The FCC initiated a rulemaking to consider expanding broadband opportunities in the 896-901/935-940 MHz band. A Notice of Proposed Rulemaking released by the Wireless Bureau on January 16 established the framework for a proceeding, WT Docket No. 24-99, that seeks comment on rules to enable a 5/5 megahertz broadband segment in the band, building upon the existing 3/3 megahertz framework.²³ This set the stage for a public record with comments from utilities, private network operators, and other stakeholders.

The proposal aims to unlock the full ten megahertz of the band for broadband use through a voluntary, negotiation-based transition mechanism. In its 2020 Report and Order, the Commission realigned the band to create a six megahertz broadband segment and reserved four megahertz for incumbent narrowband operations. The current NPRM proposes a framework where licensees could opt for a 5/5 MHz broadband configuration on a county-by-county basis, provided they reach private agreements with all incumbent narrowband users in those segments.

To facilitate this expansion, the FCC proposed specific eligibility requirements for a 5/5 MHz broadband license. An applicant would need to hold licenses for more than 50% of the total licensed 900 MHz spectrum in a given county. The applicant would also have to demonstrate that it has cleared, or will protect, at least 90% of the incumbents in the existing 3/3 MHz broadband segment, consistent with current rules. Crucially, the proposal requires an applicant to clear 100% of incumbents from the narrowband segments through purely voluntary agreements, as the mandatory relocation rights afforded for the 3/3 MHz segment would not extend to the narrowband portions of the band.

The progress of incumbent relocation under the 2020 order remains a relevant factor in the new proceeding. In an ex parte filing, the Association of American Railroads (ARR) addressed what it termed "unwarranted speculation" regarding its ability to meet the September 2025 deadline to vacate six paired channels under its nationwide license. The AAR asserted that its members "remain on schedule to meet the transition deadline" for moving to their new narrowband spectrum allotment.²⁴ In a subsequent meeting with FCC Chairman Carr’s office, AAR further detailed its position, noting that total industry costs for this transition are expected to exceed $110 million, up from the initial $70 million estimate. The railroad association highlighted the function of its 900 MHz Advanced Train Control System (ATCS). It argued that recent railroad studies confirmed a significant risk of interference from co-channel broadband operations to ATCS communications, framing the NPRM as a challenge to its critical safety network.²⁵

In another filing, AAR reiterated its opposition, calling the NPRM "inappropriate and premature" while the 3/3 MHz transition is still underway and its members have no plans to relocate again.²⁶ AAR stated it has no alternative spectrum for its nationwide safety-of-life operations, arguing that the 220 MHz band is not a viable option without significant re-banding of its "picket fence" channels. AAR asserted that before it could agree to vacate the band, any voluntary agreement must provide assurances including: equivalent replacement spectrum (a minimum of ten 25 kHz channels configured as a single nationwide ribbon license); full cost recovery for both sunk costs from the 3/3 MHz transition and future relocation expenses; and a reasonable transition timeline that includes a 20-year protection period against further transitions, secured by letters of credit or similar financial guarantees. The association argued that piecemeal, county-by-county relocation is "incompatible" with its national network and that the current 70-mile interference protection zone must be retained. The Utility Broadband Alliance, in reply comments, noted that AAR, despite these conditions, stated it remained "open to working with the Commission and broadband proponents to support a further transition."

In reply comments joined by the American Short Line and Regional Railroad Association, AAR reiterated its opposition, calling the 5/5 MHz proposal "unwarranted" and premature.²⁷ The railroad associations argued the record shows significant opposition, citing comments from Motorola, Ondas, and Siemens on the risks to safety operations and the disruption to investments made in reliance on the 2020 Order. They strongly defended the existing 70-mile interference protection zone, asserting Anterix and SDG&E had provided no engineering studies to justify reducing it. AAR reaffirmed its pre-conditions for any voluntary agreement, including full cost recovery, a 20-year quiet period, and equivalent replacement spectrum, suggesting the aggregation and reconfiguration of 220 MHz "picket fence" licenses into a single nationwide ribbon license. The filing also noted that AAR met with Anterix to discuss these assurances but had received no subsequent updates.

Ondas Networks, a technology developer for the rail industry, opposed the NPRM as premature and disruptive, arguing it would undermine the regulatory certainty established in the 2020 R&O.²⁸ Ondas stated that the stability afforded by the 2020 order was the basis for significant investment in its IEEE 802.16t-based platform for critical rail applications in the A-Block spectrum. The company argued that initiating another transition would disrupt the ongoing 3/3 MHz clearing process and create uncertainty that would jeopardize investment in next-generation rail technologies.

Rail technology supplier Siemens Mobility Rail Infrastructure echoed these concerns, supporting the comments filed by Ondas.²⁹ Siemens, which has a strategic partnership with Ondas to develop an IEEE 802.16t-compliant platform for the rail industry's A-Block spectrum, argued the NPRM represents an "abrupt policy reversal." The company stated the 2020 Order provided the regulatory certainty that spurred R&D investment and that the proposed rule changes would compromise rail safety and discourage future innovation in wireless technologies. In reply comments, Anterix characterized these interference concerns as a "misreading of the NPRM," asserting that AAR’s facilities would be protected under the proposed rules.

Motorola Solutions, Inc. (MSI) also urged caution, calling the 5/5 MHz proposal “premature” given that the 3/3 MHz transition is still “nascent,” with broadband deployed in less than seven percent of U.S. counties.³⁰ Should the Commission proceed, MSI stated any transition must be based on a strictly voluntary, negotiation-based process with no exceptions for holdouts, and must ensure full compensation for relocating narrowband incumbents. In reply comments, MSI maintained the transition is premature given the "slow and uneven" deployment of 3/3 MHz broadband, and pointed to record support for lifting the application freeze to allow narrowband incumbents to maintain and expand their critical systems.³¹ If the FCC moves forward, MSI reiterated that the transition must be entirely voluntary and fully compensated, and that narrowband operations must be protected from OOBE interference, proposing a limit no greater than -23 dBm/MHz and noting Ondas shares similar interference concerns.

As an original petitioner for the 5/5 MHz option, the Enterprise Wireless Alliance supported the NPRM, stating that it closely tracks the petition and that the record should enable a prompt Report and Order.³² EWA argued the need for private broadband extends beyond utilities to financial, transportation, and manufacturing industries seeking secure networks. The alliance endorsed the entirely voluntary exchange process for clearing incumbents but opposed proposals to impose new deployment obligations on incumbents that decline relocation, viewing them as inappropriate retroactive requirements. EWA suggested, however, that the FCC has authority to enforce existing discontinuance rules under Section 1.953 to ensure that inactive licenses do not obstruct the transition.

The Edison Electric Institute, representing U.S. investor-owned electric companies, supported the 5/5 MHz proposal, asserting the expanded capacity is needed for high-bandwidth applications like mobile video and high-density sensor deployments.³³ EEI underscored that while the expanded segment would support meaningful advancements, any incumbent relocation must be entirely voluntary. The trade association also strongly advocated for retaining the complex system exemption.

The utility sector also voiced support. Dominion Energy endorsed the 5/5 MHz framework, arguing it is necessary to support grid modernization efforts like integrating distributed energy resources, enhancing physical security, and enabling real-time system monitoring.³⁴ The company detailed numerous critical applications, including VoLTE, advanced drone communications, wildfire mitigation, and black-start solutions for grid recovery. Building on this, Dominion urged the Commission to expand the geographic scope of 900 MHz broadband licenses in coastal counties to integrate offshore wind farm operations with land-based networks, a position it noted was supported by Anterix and consistent with EEI's call for a broader spectrum pipeline for critical infrastructure.

Southern California Edison (SCE) also wrote in support of the 5/5 MHz option, arguing the expanded broadband capabilities are needed to modernize communication systems for improved grid resilience, reliability, and efficiency.³⁵ SCE stated that a 5/5 MHz segment is more aligned with global 3GPP standards, which would improve the cost-effectiveness of network deployments and foster a broader equipment ecosystem.

Drawing from its experience operating its CriticalLinc 4G LTE Advanced network, Southern Linc echoed support for the 5/5 MHz framework, contending that the expanded bandwidth is necessary to meet the future demands of utilities and other Critical Infrastructure Industry (CII) entities.³⁶ Southern Linc argued that private networks are essential for cybersecurity, allowing operational data to be segmented from the internet and enabling utilities to "island" their networks during a wide-scale attack. The company stated that while a 3/3 MHz channel is sufficient for some applications, it is constrained by certain technologies; for instance, a fully loaded Cat-M channel can consume up to 60% of a 3/3 MHz channel’s capacity, an issue that a 5/5 MHz channel mitigates. Southern Linc also asserted that the wider channel is needed to support low-latency applications like Direct Transfer Trip (DTT) and high-bandwidth uses such as video surveillance and Phasor Measurement Units (PMUs). Furthermore, it argued that a 5/5 MHz configuration better harmonizes with 3GPP standards for LTE and 5G, which would promote economies of scale for equipment and aid the evolution to private 5G networks.

The Utility Broadband Alliance, a coalition of utilities and technology vendors, also urged the Commission to adopt the 5/5 MHz framework, calling the expansion "not just necessary, but essential."³⁷ UBBA stated that while the 3/3 MHz segment was a success, it cannot support future use cases including Direct Transfer Trip (DTT), video surveillance of critical assets, transmission synchrophasors, and uncrewed aircraft system (UAS) inspections. The alliance argued that a 5/5 MHz channel would better harmonize with 3GPP standards for LTE Band 106 and 5G band n106, promoting a wider ecosystem, greater innovation, and economies of scale for all 900 MHz broadband operations.

The Utilities Technology Council also filed in support of the NPRM, describing the 5/5 MHz framework as an important step building upon the 2020 R&O.³⁸ UTC asserted that while narrowband systems remain relevant, broadband spectrum is increasingly necessary for smart grid applications and security functions like video surveillance. The council endorsed the voluntary, negotiation-based transition framework and the proposed eligibility and application requirements, stating that the public interest benefits of the additional bandwidth outweigh potential costs. In reply comments, UTC pointed to what it called "resounding support" on the record, echoing arguments from other utilities regarding the need for more bandwidth to handle Cat-M metering devices, improve public safety, and support low-latency applications like DTT.³⁹

The National Rural Electric Cooperative Association (NRECA), representing 832 distribution cooperatives, supported the 5/5 MHz option in reply comments as a meaningful opportunity to address the acute shortage of broadband spectrum for electric operations in rural America.⁴⁰ NRECA conditioned its support on the Commission’s adherence to a strictly voluntary, market-based process, emphasizing that several of its members operate mission-critical incumbent systems and that it does not support mandatory relocation. The association urged the Commission to move expeditiously to adopt the proposal.

Select Spectrum, a secondary market advisory firm, supported a wholly voluntary transition framework, arguing the market landscape had fundamentally changed since 2020.⁴¹ The firm noted that a growing menu of widely available licensed broadband spectrum alternatives for utilities lessens any public safety or national security imperative for a mandatory 5/5 MHz transition. While acknowledging an agreement with AAR is a significant obstacle, Select Spectrum opposed any mandatory relocation, arguing alternative bands could support a voluntary, negotiated solution. The firm also urged the Commission to provide long-term regulatory stability—suggesting a 10-year quiet period—to allow licensees and equipment manufacturers to recoup investments.

In reply comments, the Utility Broadband Alliance argued the record shows overwhelming support for the 5/5 MHz framework, which it called essential to meet the expanding needs of CII entities.⁴² UBBA reiterated arguments from initial comments that the 3/3 MHz channel cannot sufficiently support future low-latency or high-capacity use cases such as DERMS, AMI 2.0, and DTT. It highlighted Southern Linc's experience showing a 5/5 MHz channel mitigates capacity constraints posed by Cat-M metering technologies on a 3/3 MHz system. UBBA also argued that expanding to 5/5 MHz would better align with 3GPP standards, promoting a broader equipment ecosystem and supporting the evolution to private 5G.

Portland General Electric, also an original petitioner for the rulemaking, supported the NPRM, noting that while the current 3/3 MHz channel is sufficient for present requirements, it will not meet future needs driven by evolving smart grid technologies.⁴³ PGE highlighted that the voluntary framework proposed in the NPRM was a key component of its original petition. It pointed to comments from the Edison Electric Institute as evidence of overwhelming industry support, arguing that the creation of a 5/5 MHz option would more effectively meet the Commission's public interest goals, as it would support a greater number of utility applications than the existing 3/3 MHz channel.

Ameren Services Company, another original petitioner and the first utility to secure 900 MHz broadband spectrum rights in 2020, strongly supported the NPRM.⁴⁴ Ameren argued that the expanded capacity is necessary for future applications like distributed energy resource management systems (DERMS), advanced metering infrastructure (AMI) 2.0, and artificial intelligence. The company described the voluntary, negotiation-based framework as a "win-win-win outcome," stating that the successful 3/3 MHz transition is evidence the model works and that any technical issues are manageable with existing mitigation tools.

The Lower Colorado River Authority, one of the largest incumbent 900 MHz complex narrowband systems and an original petitioner, also supported the NPRM, describing the 5/5 MHz option as the "next logical step" in the band's evolution.⁴⁵ LCRA, which is deploying a 3/3 MHz pLTE network, argued that future requirements will necessitate capacity beyond what the 3/3 MHz allocation can provide, particularly to support 5G technologies. From its position as a complex system incumbent undergoing voluntary relocation, LCRA attested to the success of the transition framework, arguing the voluntary nature of the 5/5 MHz proposal would not hinder narrowband operations. The authority supported the proposed eligibility rules and opposed stricter requirements, stating a 5/5 MHz applicant should not first be required to obtain a 3/3 MHz license. In reply comments, LCRA reiterated its support, arguing there is an "almost unanimous" consensus among CII organizations for the proposal.⁴⁶

San Diego Gas & Electric Company, a 3/3 MHz broadband licensee, supported the expansion, arguing it is essential for integrating emerging technologies like smart grid systems and IoT devices and for enhancing public safety communications.⁴⁷ Diverging from the NPRM's voluntary-only proposal for the narrowband segment, SDG&E argued the Commission should extend a mandatory relocation mechanism to the 5/5 MHz transition to disincentivize incumbent holdouts and ensure an efficient realignment. SDG&E supported using license cancellation to demonstrate incumbent clearing and asked the FCC to reevaluate the 70-mile clearing rule in light of modern interference mitigation technologies.

NextEra Energy, Inc., parent of Florida Power & Light, remained neutral on the 5/5 MHz proposal, conditioning its position on the express reaffirmation of protections for incumbent “complex systems.”⁴⁸ FPL, which qualifies as a complex system with over 45 functionally integrated 900 MHz sites, requires certainty that its network will be protected from interference and disruption. NextEra asserted that the exemption from mandatory relocation and the requirement that a broadband applicant must reach an agreement with a complex system licensee within a county or a 70-mile radius must be preserved. The company opposed any revision to the current definition of a complex system in the 5/5 MHz context. Instead, NextEra supported clarifying the rule to codify the May 13, 2020, date for determining system status and to ensure that licensees do not lose complex system status if network adjustments later reduce their site count below 45. The Edison Electric Institute and the Utilities Technology Council echoed this position, with EEI also supporting the call to codify the May 13, 2020, date into the rule to provide regulatory certainty for long-term investments. UTC opposed any limitations on the complex system exemption.

Eversource Energy Service Company, another complex system operator, likewise conditioned its support on the Commission’s adherence to a 100% voluntary market-based process and the retention of the complex system exemption.⁴⁹ Eversource operates a Digital Supervisory Control and Data Acquisition (DSCADA) network across Connecticut and Massachusetts that it classifies as a complex system. The utility argued against any mandatory relocation scheme for the narrowband segment, but stated that if one were adopted, the Commission must not eliminate or narrow the scope of the complex system exemption. Eversource asserted that networks of this size require simultaneous relocation of all sites to maintain functionality, making incremental clearing unfeasible.

Network equipment vendor Ericsson expressed support for the Commission's proposal, stating that a 5/5 MHz channel is a "critical and timely step" to meet growing demand from utilities and enterprises for private broadband.⁵⁰ The company noted it has already deployed multiple private LTE networks on 3/3 MHz spectrum for utilities and that while this capacity is sufficient for current SCADA and mission-critical push-to-talk applications, it will be insufficient for future data-intensive requirements like video surveillance and large-scale smart meter deployments. Ericsson added that incorporating a 5 MHz channel into the existing 3GPP Band 106 standard is expected to be "straightforward," which would help accelerate the adoption of utility-grade private networks by leveraging economies of scale from the commercial wireless ecosystem.

Fellow equipment vendor Nokia also supported the expansion to 5/5 MHz, arguing digital transformation among utilities and enterprises is driving demand for more capacity for high-throughput, low-latency applications like AMI, DTT, and CCTV.⁵¹ The company highlighted the cost-effectiveness of the 900 MHz band, noting its propagation characteristics allow for the reuse of existing network infrastructure. To facilitate this, Nokia urged the Commission to maintain the current power spectral density and OOBE limits, arguing this would protect adjacent services and allow utilities to expand existing 3/3 MHz deployments in a cost-efficient manner.

A coalition of technology companies and solution providers calling itself the Anterix Active Ecosystem (AAE) also filed in support of the NPRM.⁵² The group, which includes over 125 companies such as GE, Hitachi Energy, and Palo Alto Networks, argued that establishing a 5/5 MHz option would be a "catalyst for the development and implementation of even more innovative applications, devices, sensors, and use cases." The AAE stated that the expanded capacity is necessary to support the growing demand for secure, private networks and to advance U.S. technology leadership in critical infrastructure.

Anterix, the primary petitioner and the main entity clearing the band, urged the FCC to adopt the rules expeditiously, framing the 5/5 MHz option as a "natural and necessary next step."⁵³ Anterix touted the success of the 3/3 MHz market-driven transition, noting that over 75% of incumbents have been relocated with minimal FCC involvement and that more than 360 broadband license applications have been filed without challenge. It argued the wider channel is needed for low-latency use cases like Falling Conductor Protection and Direct Transfer Trip, and like EWA, suggested the FCC should use its authority to address licensees whose operations have been permanently discontinued but who refuse to negotiate. Anterix recommended a minor modification to the incumbent protection rule, proposing a 40-mile distance parameter as more realistic for pLTE systems than the current 70 miles. LCRA, citing its own operational experience in replies, concurred with the 40-mile proposal, and SDG&E affirmed its support in reply comments, arguing the 70-mile rule is outdated given modern low-power network capabilities.⁵⁴

In reply comments, Anterix argued the record confirms that adopting the 5/5 MHz option will require only minor modifications to the existing rules while providing utilities a necessary tool for grid modernization and cybersecurity.⁵⁵ Anterix framed prompt adoption as a national security imperative, connecting the need for a resilient grid to U.S. leadership in AI and the FCC’s efforts to counter foreign adversaries. The company reiterated its support for allowing license cancellation as a clearing mechanism and modifying the 70-mile incumbent protection rule. Anterix also disputed Gogo’s claim that they had “jointly develop[ed]” an interference model, submitting its own analysis from Pericle Communications Company that it argued shows the probability of harmful interference to Gogo’s ATG operations is “almost non-existent.”

The NPRM proposes that the licensing and operating rules for the 5/5 MHz segment would largely mirror the existing Part 27 rules for 3/3 MHz licenses. This includes county-based license areas, a 15-year initial license term with 10-year renewals, and similar population- or geography-based performance requirements. Anterix and LCRA both argued that an applicant should not be required to first obtain a 3/3 MHz license before applying for a 5/5 MHz authorization, viewing it as an unnecessary step that would create delays. In replies, LCRA also supported Anterix's proposals for post-grant cancellation of 3/3 MHz licenses to ensure continuous operation and clarification of the performance metric to reflect private network use. LCRA recommended that a licensee expanding from 3/3 to 5/5 MHz operate under a single, consolidated performance deadline based on the 5/5 MHz grant date, arguing separate deadlines would be "overly complicated." LCRA, Anterix, and SDG&E also supported an alternative performance metric based on a licensee's use of the network to further its private business needs, similar to a "substantial service" standard. In its replies, SDG&E argued this approach would allow operators to scale and adapt their networks to evolving operational needs, directly enhancing critical infrastructure.⁵⁶ The Commission also proposed that the anti-windfall provisions adopted in 2020 would apply to the 5/5 MHz transition, requiring licensees to surrender up to ten megahertz of spectrum or make a commensurate payment to the U.S. Treasury. Anterix supported maintaining the provision but recommended that applicants receive credit for "excess" spectrum surrendered during a prior 3/3 MHz transaction. SDG&E went further, arguing that broadband licensees who have already deployed 3/3 MHz spectrum should not be subject to further anti-windfall measures, citing the potential chilling effect of significant capital outlays on private networks. In its reply comments, SDG&E supported Anterix’s proposal for spectrum credits and reiterated its call for the Commission to consider other factors, including prior investments and use of the spectrum for public safety functions.⁵⁷ In reply comments, LCRA supported SDG&E’s position, arguing the Commission should consider factors like prior investment and spectrum returns.

On technical matters, the Commission sought comment on whether existing rules for power limits, OOBE, and interference protection are sufficient for a 5/5 MHz configuration, which would eliminate the current guard bands between broadband and adjacent-band services. Gogo Business Aviation, an adjacent-band operator of air-to-ground (ATG) services in the 894-896 MHz band, argued that eliminating the guard band creates a significant risk of OOBE from new 5/5 MHz broadband uplinks interfering with its ATG uplinks.⁵⁸ Gogo stated its ATG ground stations are uniquely susceptible to the "near-far problem" and cited a joint interference model developed with Anterix showing potential for harmful interference from 900 MHz user equipment located within 9 kilometers of a Gogo site. To mitigate this, Gogo proposed several procedural safeguards, including mandatory coordination, licensee-funded testing, and a duty to remediate interference. UBBA countered in reply comments that the Commission rejected similar proposals from Gogo in its 2020 order and that Gogo had not provided new evidence that existing mitigation tools were insufficient. Anterix likewise disputed that it had “jointly developed” the model and submitted its own technical analysis concluding the risk of harmful interference was minimal. If such procedures are not adopted, Gogo argued the Commission must impose a stricter OOBE limit.

Space Data Corporation, a licensee in the adjacent Narrowband Personal Communications Service (NPCS) band, did not take a position on the 5/5 MHz framework but demanded its operations be protected from harmful interference, stating 900 MHz broadband licensees should be required to resolve any interference in good faith.⁵⁹ As a potential solution to both interference risk and the conflict with AAR's nationwide license, Space Data proposed a broader reorganization of the 900 MHz band. It argued that instead of attempting to clear the AAR's safety-critical network, the 5/5 MHz broadband block could be shifted upband to occupy a portion of the adjacent NPCS spectrum. Space Data asserted this would provide greater flexibility, avoid conflict with the railroad incumbent, and better align the band with the global 3GPP Band 8 ecosystem. In reply comments, UBBA dismissed the proposal as "well outside the scope" of the proceeding and argued it should not be allowed to delay the rulemaking.

In contrast, Ericsson, Nokia, and Anterix argued the existing OOBE limit should remain unchanged. Ericsson stated that adherence to the current limit provides a consistent regulatory environment, while Anterix argued the existing OOBE rules will provide appropriate protection and that mandatory coordination should not be imposed absent documented showings of harmful interference risk. LCRA strongly agreed in its reply comments, urging the Commission to follow the recommendations of the equipment vendors. MSI shared the concern of adjacent-band operators for remaining narrowband incumbents, arguing the elimination of guard bands creates a significant interference risk from OOBE. MSI reiterated its call for an OOBE limit no greater than -23 dBm/MHz in the adjacent spectrum and urged the Commission to study if the interference protection criteria need to be changed. UBBA countered this position in replies, noting the Commission had previously found the -23 dBm/MHz limit "overly conservative" and that no guard band exists between the current 3/3 MHz segment and some incumbent operations.

The NPRM also solicited input on the status of the ongoing freeze on most new 900 MHz applications, questioning whether it should be modified or terminated. EWA proposed a modification that would permit Industrial/Business Pool incumbents to apply for channels in the narrowband segments for expansion into adjacent counties, but only after the 3/3 MHz clearing process is completed in those counties. Similarly, LCRA supported lifting the freeze for narrowband-to-narrowband frequency exchanges. In reply comments, Anterix opposed fully lifting the freeze to avoid speculation but supported EWA's proposal as a reasonable balance and endorsed refinements to facilitate narrowband exchanges. LCRA reaffirmed its support for this limited modification while opposing a broader lifting of the freeze, aligning with Anterix and SDG&E. Anterix supported maintaining the freeze to preserve a stable landscape but endorsed refinements. In contrast, SDG&E opposed any modification to the freeze unless it directly supports the transition to expanded broadband use. Multiple filers, including EEI, Motorola Solutions, and Eversource, urged the Commission to lift the freeze. EEI specifically recommended lifting it for incumbent licensees, at a minimum in counties where a complex system is licensed, to allow for network maintenance and expansion. The Utilities Technology Council, in reply comments, urged the Commission to partially lift the freeze to allow incumbents to modify existing sites and add new ones for capacity and coverage, arguing the freeze had served its purpose of stabilizing the band for transition and was now imposing significant limitations.⁶⁰ UTC argued a partial lift for incumbents would provide relief without enabling speculation from new entrants and agreed with Eversource that some areas may never transition to broadband, making a continued freeze on all modifications unnecessary. In an accompanying Order, the Commission delegated authority to the Wireless Telecommunications Bureau to modify or terminate the freeze if it finds doing so is in the public interest.

Note: Ondas Networks' comment was unintentionally excluded. ⁶¹

1. [Notice Of Proposed Rulemaking, Wireless Telecommunications Bureau, https://docs.fcc.gov/public/attachments/FCC-25-8A1.pdf]

2. [Comment, Edison Electric Institute, https://www.fcc.gov/ecfs/document/105162685110351/1; Comment, Utility Broadband Alliance, https://www.fcc.gov/ecfs/document/10516952312419/1; Comment, Dominion Energy, Inc., https://www.fcc.gov/ecfs/document/10516125855699/1]

3. [Comment, Southern Communications Services, Inc. d/b/a Southern Linc, https://www.fcc.gov/ecfs/document/10516062225888/1; Reply To Comments, Utility Broadband Alliance, https://www.fcc.gov/ecfs/document/10616123716351/1]

4. [Comment, Ericsson, https://www.fcc.gov/ecfs/document/10516275898930/1; Comment, Nokia, https://www.fcc.gov/ecfs/document/105162681826469/1; Reply To Comments, Advantech Corporation, et al., https://www.fcc.gov/ecfs/document/10616378727989/1]

5. [Comment, Anterix, Inc., https://www.fcc.gov/ecfs/document/10516973500908/1; Comment, Ameren Services Company, https://www.fcc.gov/ecfs/document/1051643391463/1; Comment, Lower Colorado River Authority, https://www.fcc.gov/ecfs/document/1051605471845/1]

6. [Comment, Association of American Railroads, https://www.fcc.gov/ecfs/document/10516569829840/1; Notice Of Exparte, Association of American Railroads, https://www.fcc.gov/ecfs/document/10403916727916/1]

7. [Comment, Association of American Railroads, https://www.fcc.gov/ecfs/document/10516569829840/1]

8. [Comment, Ondas Networks, https://www.fcc.gov/ecfs/document/10516345322890/1; Comment, Siemens Mobility Rail Infrastructure, https://www.fcc.gov/ecfs/document/10516167918304/1]

9. [Comment, Motorola Solutions, Inc., https://www.fcc.gov/ecfs/document/1051611016710/1; Reply To Comments, Motorola Solutions, Inc., https://www.fcc.gov/ecfs/document/10616625006557/1]

10. [Comment, Gogo Business Aviation LLC, https://www.fcc.gov/ecfs/document/10516016110865/1]

11. [Comment, Space Data Corporation, https://www.fcc.gov/ecfs/document/1051619105015/1]

12. [Comment, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/1051619009079/1]

13. [Reply To Comments, National Rural Electric Cooperative Association (NRECA), https://www.fcc.gov/ecfs/document/1061632218073/1]

14. [Comment, NextEra Energy, Inc., https://www.fcc.gov/ecfs/document/10516149734367/1; Comment, Eversource Energy Service Company, https://www.fcc.gov/ecfs/document/105160878812834/1]

15. [Comment, Anterix, Inc., https://www.fcc.gov/ecfs/document/10516973500908/1; Reply To Comments, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/10616934912900/1]

16. [Reply To Comments, Association of American Railroads, https://www.fcc.gov/ecfs/document/10616158666269/1]

17. [Reply To Comments, Utilities Technology Council, https://www.fcc.gov/ecfs/document/10617700817864/1; Reply To Comments, Motorola Solutions, Inc., https://www.fcc.gov/ecfs/document/10616625006557/1]

18. [Reply To Comments, Anterix, Inc., https://www.fcc.gov/ecfs/document/106161927203728/1]

19. [Comment, Gogo Business Aviation LLC, https://www.fcc.gov/ecfs/document/10516016110865/1]

20. [Comment, Nokia, https://www.fcc.gov/ecfs/document/105162681826469/1]

21. [Reply To Comments, Anterix, Inc., https://www.fcc.gov/ecfs/document/106161927203728/1]

22. [Comment, Anterix, Inc., https://www.fcc.gov/ecfs/document/10516973500908/1; Reply To Comments, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/10616934912900/1]

23. [Notice Of Proposed Rulemaking, Wireless Telecommunications Bureau, https://docs.fcc.gov/public/attachments/FCC-25-8A1.pdf]

24. [Notice Of Exparte, Association of American Railroads, https://www.fcc.gov/ecfs/document/1020582373462/1]

25. [Notice Of Exparte, Association of American Railroads, https://www.fcc.gov/ecfs/document/10403916727916/1]

26. [Comment, Association of American Railroads, https://www.fcc.gov/ecfs/document/10516569829840/1]

27. [Reply To Comments, Association of American Railroads, https://www.fcc.gov/ecfs/document/10616158666269/1]

28. [Comment, Ondas Networks, https://www.fcc.gov/ecfs/document/10516345322890/1]

29. [Comment, Siemens Mobility Rail Infrastructure, https://www.fcc.gov/ecfs/document/10516167918304/1]

30. [Comment, Motorola Solutions, Inc., https://www.fcc.gov/ecfs/document/1051611016710/1]

31. [Reply To Comments, Motorola Solutions, Inc., https://www.fcc.gov/ecfs/document/10616625006557/1]

32. [Comment, Enterprise Wireless Alliance, https://www.fcc.gov/ecfs/document/105161740813550/1]

33. [Comment, Edison Electric Institute, https://www.fcc.gov/ecfs/document/105162685110351/1]

34. [Comment, Dominion Energy, Inc., https://www.fcc.gov/ecfs/document/10516125855699/1]

35. [Letter, Southern California Edison, https://www.fcc.gov/ecfs/document/1061866048364/1]

36. [Comment, Southern Communications Services, Inc. d/b/a Southern Linc, https://www.fcc.gov/ecfs/document/10516062225888/1]

37. [Comment, Utility Broadband Alliance, https://www.fcc.gov/ecfs/document/10516952312419/1]

38. [Comment, Utilities Technology Council, https://www.fcc.gov/ecfs/document/1051741458913/1]

39. [Reply To Comments, Utilities Technology Council, https://www.fcc.gov/ecfs/document/10617700817864/1]

40. [Reply To Comments, National Rural Electric Cooperative Association (NRECA), https://www.fcc.gov/ecfs/document/1061632218073/1]

41. [Reply To Comments, Select Spectrum LLC, https://www.fcc.gov/ecfs/document/1061698086232/1]

42. [Reply To Comments, Utility Broadband Alliance, https://www.fcc.gov/ecfs/document/10616123716351/1]

43. [Comment, Portland General Electric, https://www.fcc.gov/ecfs/document/1051688656487/1]

44. [Comment, Ameren Services Company, https://www.fcc.gov/ecfs/document/1051643391463/1]

45. [Comment, Lower Colorado River Authority, https://www.fcc.gov/ecfs/document/1051605471845/1]

46. [Reply To Comments, Lower Colorado River Authority, https://www.fcc.gov/ecfs/document/10616225726643/1]

47. [Comment, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/1051619009079/1]

48. [Comment, NextEra Energy, Inc., https://www.fcc.gov/ecfs/document/10516149734367/1]

49. [Comment, Eversource Energy Service Company, https://www.fcc.gov/ecfs/document/105160878812834/1]

50. [Comment, Ericsson, https://www.fcc.gov/ecfs/document/10516275898930/1]

51. [Comment, Nokia, https://www.fcc.gov/ecfs/document/105162681826469/1]

52. [Reply To Comments, Advantech Corporation, Altairis Technology Partners, LLC, BEC Technologies, Inc., CMG Consulting LLC, Digi International Inc., GE, Hitachi Energy, Multi-Tech Systems, Inc., Palo Alto Networks, Sentient Energy, Inc., SNC, Streamwide, The Antenna Company US, Inc., Telit Cinterion, Ubicquia, Utilidata, Viventum Inc., https://www.fcc.gov/ecfs/document/10616378727989/1]

53. [Comment, Anterix, Inc., https://www.fcc.gov/ecfs/document/10516973500908/1]

54. [Reply To Comments, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/10616934912900/1]

55. [Reply To Comments, Anterix, Inc., https://www.fcc.gov/ecfs/document/106161927203728/1]

56. [Reply To Comments, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/10616934912900/1]

57. [Reply To Comments, San Diego Gas & Electric Company, https://www.fcc.gov/ecfs/document/10616934912900/1]

58. [Comment, Gogo Business Aviation LLC, https://www.fcc.gov/ecfs/document/10516016110865/1]

59. [Comment, Space Data Corporation, https://www.fcc.gov/ecfs/document/1051619105015/1]

60. [Reply To Comments, Utilities Technology Council, https://www.fcc.gov/ecfs/document/10617700817864/1]

61. https://www.fcc.gov/ecfs/document/10516345322890/1