AT&T said proponents of uncontrolled devices in the 6 GHz band “bear the burden of proving that the introduction of such uses would not cause harmful interference to incumbent licensed operations.” AT&T representatives spoke with FCC Office of General Counsel staff, said a filing posted Tuesday in docket 18-295. “Not only have … proponents failed to meet their burden of proving the absence of harmful interference, the occurrence of harmful interference would be a statistical certainty,” AT&T said. Commissioners vote April 23 (see 2004060062).

Environmental Systems Research Institute representatives spoke with FCC Public Safety Bureau staff on the capabilities of 3D software and data relative to better vertical location accuracy of wireless calls to 911. Software can do geocoding and 3D data extrusion, ESRI said. “Creation of a 3D base map by a federal entity at a national level would result in cost-savings from both lidar and parcel based vendors, and would ease in standardization and adoption.” The filing was posted Monday in docket 11-117.

AT&T raised concerns about the C-band transition, in calls with FCC staff, said a filing posted Monday in docket 18-122. “Unaccounted for earth stations could result from the inability of space station operators to identify all of the earth stations that receive a signal from their satellite." AT&T cited Section 27.1412(a) of FCC rules. “Unaccounted for earth stations could result from the inability of space station operators to identify all of the earth stations that receive a signal from their satellite and, hence, are associated with them," the telco said: "As a result, some incumbent earth stations may 'fall through the cracks' and not appear in the Transition Plan of an eligible space station operator.” AT&T said “there appears to be some ambiguity as to which entity/entities are responsible for the migration of earth stations that are solely associated with space station operators not electing accelerated relocation, if accelerated clearing is triggered.” Executives spoke with staff from the Wireless and International bureaus and Office of Economics and Analytics.

The National Spectrum Managers Association asked the FCC to revise a December RF safety order (see 1912040036). “The 2-year timetable for implementation of site by site RF exposure evaluation is not realistically practical,” the group said in a filing docket 19-222 posted Monday. The evaluation calls for “aggregation of radiation from multiple highly directive fixed antennas that do not, by design and as operated, radiate in the same direction so as to present a risk to nearby humans,” it said.

CTIA questioned part of a draft 6 GHz order slated for an April 23 vote (see 2004020066) allowing sharing of the entire band by low-power devices indoors, in a filing posted Monday in docket 18-295. “There is no reasonable basis to conclude” such use “will comply with the fundamental tenet of FCC unlicensed policy -- namely, that unlicensed operations are unequivocally barred from causing harmful interference to authorized stations like 6 GHz fixed service licensees,” CTIA said: There are almost 100,000 U.S. FS links.

Comments are due May 15, replies June 15 in docket 19-226 on a December NPRM (see 1912040036) on the range of frequencies for which RF exposure limits should apply, says Monday's Federal Register. The agency subsequently issued a correction, with the dates that are now in this Notebook. The FCC approved the NPRM 5-0, with Commissioner Jessica Rosenworcel's concurrence. "This NPRM focuses on developing a record encompassing RF exposure limits and compliance issues raised by recent developments in technology that have changed the way wireless devices are used, frequency bands of operation, how supporting wireless infrastructure is deployed, and how RF sources are assessed for compliance with the Commission’s existing RF exposure limits,” the notice says.

The Multicultural Media, Telecom and Internet Council asked the FCC to act on a proposal to open the 6 GHz band for sharing with Wi-Fi and other unlicensed use (see 2004020066). “The COVID-19 pandemic has shined a harsh light on the impact that disparity in access has on lower-income and minority groups who are on the wrong side of the digital divide,” the group said in a filing posted Friday in docket 18-295. “The perils of those on the wrong side of the digital divide can no longer be ignored.” The FCC is focused on protecting incumbents as it opens the band, Chairman Ajit Pai told Sen. Brian Schatz, D-Hawaii. “The Commission's technical experts in our Office of Engineering and Technology have spent considerable time reviewing the substantial record that has been compiled in this proceeding and meeting with interested stakeholders,” Pai said in a letter posted Friday. Commissioners vote April 23 on opening the band to Wi-Fi. Tech companies reported on calls with aides to the commissioners, except Pai. Apple, Broadcom, Cisco, Google, Hewlett Packard Enterprise and Microsoft discussed “the importance of authorizing unlicensed use … for standard-power, low-power indoor, and very-low-power devices, at power levels that will successfully enable key use cases and applications.”

CTIA asked for additional help as industry addresses COVID-19. One change would be a streamlined process for spectrum loans, said a Friday letter to be posted by the FCC. “The Communications Act and the Commission’s rules allow the agency to receive and process requests outside of established formal procedures in the event of national emergencies,” the group said: “The Commission could allow licensees to complete temporary license swaps upon written notice to the Commission, either by informal letter or email, rather than prior Commission approval.” The FCC could “accelerate approval of all applications for license assignments and transfers of control, particularly where: any applicable public notice period has elapsed and the application is unopposed,” CTIA said: Allow all paper filings electronically and expedite access to high-band spectrum.

Executives spoke with the FCC Public Safety Bureau staff about NextNav building a “highly accurate vertical location network,” said a filing posted Thursday in docket 07-114: “NextNav is deploying its infrastructure in more than one hundred cellular market areas." The company said the FCC should reject any effort by carriers to revise rules requiring they provide height above ellipsoid data from wireless calls to 911, within 3 meters accuracy for 80 percent of calls, starting in the largest markets in April 2021 (see 2003230059): “Most wireless handsets (and nearly all smartphones) that include barometric pressure sensors, Wi-Fi and Bluetooth capabilities are already z-axis capable.”

The National Public Safety Telecommunications Council opposes Boulder Regional Emergency Telephone Service Authority’s pursuit of a declaratory ruling or rulemaking on FirstNet interoperability (see 1910150038), said a filing posted Wednesday in docket 19-254. “It could actually reduce interoperability,” NPSTC said: “Requiring that the Public Safety Broadband Network (NPSBN) be interoperable at the network level with other commercial networks in essence would transition the NPSBN architecture from one nationwide broadband network to a broadband network of networks across which public safety users would roam."