Current-and-Future-Spectrum-Use-by-the-Energy-Water-and-Railroad-Industries.pdf

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News & Politics
 
CURRENT AND FUTURE SPECTRUM
USE BY THE
ENERGY, WATER, AND RAILROAD INDUSTRIES
Response to Title II of the Departments of Commerce,
Justice, and State, the Judiciary,
and Related Agencies Appropriations Act, 2001
Public Law 106-553
U.S. DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
NTIA SPECIAL PUBLICATION 01-49
CURRENT AND FUTURE SPECTRUM
USE BY THE
ENERGY, WATER, AND RAILROAD INDUSTRIES
Response to Title II of the Departments of Commerce,
Justice, and State, the Judiciary,
and Related Agencies Appropriations Act, 2001
Public Law 106-553
Marshall W. Ross
Jeng F. Mao
U.S. DEPARTMENT OF COMMERCE
Donald L. Evans, Secretary
Nancy J. Victory, Assistant Secretary
for Communications and Information, and
Administrator, National Telecommunications
and Information Administration
January 2002
Project Management
Office of Spectrum Management
William T. Hatch
Associate Administrator
Office of Spectrum Management
Fredrick R. Wentland
Director, Spectrum Plans and Policies
William D. Speights
Manager, Public Safety Program
Report Authors
Marshall W. Ross
Jeng F. Mao
ACKNOWLEDGMENTS
The authors wish to thank the federal agency representatives on the Interdepartment
Radio Advisory Committee for reviewing and providing vital comments and information used in
this report.  We also wish to thank Derrick Owens, Richard Orsulak, Gary Patrick, and Edward
Drocella for providing quality suggestions and comments on the earlier versions of this report and
Robert Wilson for preparing the graphs and tables.
A special thanks to NTIA staff, Gloria Mitchell, Carolyn Washington, and Joyce Henry for
providing secretarial support; Joseph Camacho and Steve Litts for their publication assistance;
and Kathy Smith for her invaluable comments and suggestions on earlier and final drafts of this
report.
ix
TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvii
1     INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
1-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
 1-1
Objective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
1-2
Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1-2
Letter Soliciting Responses from Federal Agencies . . . . . . . . . . . . . . . . . . . . . . 1-3
Request for Comments from the Public . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-4
Report Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
1-4
2     CERTIFIED FREQUENCY COORDINATORS
       AND FEDERAL REGULATORY AGENCIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2-1
Certified Frequency Coordinators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-1
The Energy Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-3
The Water Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-5
The Railroad Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-5
Federal Regulatory Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
The Energy Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-6
The Water Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-6
The Railroad Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
2-7
3     THE ENERGY INDUSTRY
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
3-1
Industry Growth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-4
Consumer Demand and Industry Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-4
Deregulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
3-5
Wireless Communications Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7
Voice Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8
Data Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-9
Wire-Based and Commercial Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12
Fiber Optic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-12
Power Line Carrier. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-14
Commercial Telephone Lines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-15
Commercial Wireless Telephones. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15
Cellular Digital Packet Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-17
Summary of Spectrum and Systems Currently Used . . . . . . . . . . . . . . . . . . . . . . . . . . .3-17
Technical Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
3-18
Technology Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
3-21
x
Trunked Radio Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-21
Wideband Data Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21
Wireless LAN/WAN Connectivity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22
Geographic Position and Automatic Location Data . . . . . . . . . . . . . . . . . . . . .3-22
Summary of Non-Spectrum Dependent Alternatives
and Commercial Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-23
Possible Future Spectrum Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24
Possible Future Alternative Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-25
4     THE WATER INDUSTRY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
4-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4-1
Industry Growth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
4-2
Wireless Communications Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3
Voice Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-4
Data Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4-4
Wire-Based and Commercial Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
Summary of Spectrum and Systems Currently Used. . . . . . . . . . . . . . . . . . . . . . . . . . . .4-5
Technical Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
4-6
Technology Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-7
Summary of Non-Spectrum Dependent Alternatives
and Commercial Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-8
Possible Future Spectrum Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-9
5     THE RAILROAD INDUSTRY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
5-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5-1
Industry Growth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5-3
Wireless Communications Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
Voice Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-4
Data Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5-5
Wire-Based and Commercial Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-6
Summary of Spectrum and Systems Currently Used. . . . . . . . . . . . . . . . . . . . . . . . . . . .5-7
Technical Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
5-8
Technology Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
5-9
Summary of Non-Spectrum Dependent Alternatives
and Commercial Services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5-10
Possible Future Spectrum Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10
6     SUMMARY OF CURRENT SPECTRUM USE
       AND FUTURE REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6-1
Current Spectrum Used. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
6-1
Future Spectrum Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
Availability of 700 MHz Guard Band Spectrum. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3
xi
7     SUMMARY/CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
7-1
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3
APPENDICES
A   PL 106-553; Departments of Commerce, Justice, and State, the Judiciary,
      and Related Agencies Appropriations Act, 2001. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .A-1
B   NTIA Request for Comments Published in the Federal Register . . . . . . . . . . . . . . . . . . . . . B-1
C   Copy of Letter Sent to Federal Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
C-1
D   Public Comment and Federal Agency Respondents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .D-1
E   Railroad Base Station Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
E-1
F   Executive Summary of the USAT Final Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .F-1
xiii
ACRONYMS AND ABBREVIATIONS
AAR
Association of American Railroads
ACE
Atlantic City Electric Company
AEI
Automatic Equipment Identification
AMR
Automatic Meter Reader
APCO
Association of Public-Safety Communications Officials
API
American Petroleum Institute
ATCS
Advanced Train Control System
AWWA
American Water Works Association
BG&E
Baltimore Gas & Electric
BPA
Bonneville Power Administration
CAD
Computer Aided Design
CDPD
Cellular Digital Packet Data
CFR
Code of Federal Regulations
CICC
Critical Infrastructure Communications Coalition
Cinergy
Cinergy Corporation
Cinergy Supp.
Cinergy Corporation’s supplemental comments
CMP
Central Maine Power Company
DFS
Data Flow Systems, Inc. 
DOD
Department of Defense
DOE
Department of Energy
DOE/CIO
DOE, Chief Information Officer
DOE/IRAC
DOE, Interdepartment Radio Advisory Committee
DOI
Department of Interior
Dominion
Dominion Resources Services, Inc.
DOT
Department of Transportation
DPL 
Delmarva Power & Light Company
DTE
The Detroit Edison Company
EBMUD
East Bay Municipal Utility District
EMR
Electronic Meter Reading
EPA
Environmental Protection Agency 
EOT
End-of-Train Device
FCC
Federal Communications Commission
FERC
Federal Energy Regulatory Commission
FM
Frequency Modulation
FPL
Florida Power & Light Company 
FRA
Federal Railroad Administration
GHz
GigaHertz
GIS
Geographic Information Systems
GPU
GPU Energy, Inc. 
HR
House of Representatives
IRAC
Interdepartment Radio Advisory Committee
xiv
Itron
Itron, Inc.
kHz
KiloHertz
LAN
Local Area Network
LMCC
Land Mobile Communications Council
LMCS
Land Mobile Communications Service 
LMR
Land Mobile Radio
LMS
Location and Monitor Service
MAS
Multiple Address System
Mb/s
Mega bits per second
MB/S
Mega bytes per second
MDD
Mobile Data Dispatch
MHz
MegaHertz
ms
Millisecond
NAES
North Atlantic Energy Service Corporation
NMP
Niagara Mohawk Power Corporation
NRTC
National Rural Telecommunications Cooperative
NTIA
National Telecommunications and Information Administration
OPPD
Omaha Public Power District
OPS
Office of Pipeline Safety
PCS
Personal Communication Service
PL
Public Law
PLC
Power Line Carrier
PLMR
Private Land Mobile Radio
PLMRS
Private Land Mobile Radio Service
PLTF
Power Line Telecommunications Forum
PMA
Power Market Administration
PNR
Pittsburgh Naval Reactors
POFS
Private Operational-Fixed Microwave Service
PSTN
Public Switched Telephone Network
PSWN
Public Safety Wireless Network
PTC
Positive Train Control
PSP
Public Safety Program
RF
Radio Frequency
RFC
Request for Comment
RSPA
Research and Special Programs Administration
SCADA
Supervisory Control And Data Acquisition
SCANA
SCANA Corporation
SMR
Special Mobilized Radio
SRS
Savannah River Site
UHF
Ultra High Frequency
U.S.
United States
USACE
U.S. Army Corps of Engineers
USAT
Utilities Spectrum Assessment Taskforce
xv
USATFR
Utilities Spectrum Assessment Taskforce Final Report
USC
United States Code
USEPA
U.S. Environmental Protection Agency
UTC
United Telecomm Council
VHF
Very High Frequency
WAN
Wide Area Network
Western
Western Area Power Administration
WGP
Williams Gas Pipeline
xvii
EXECUTIVE SUMMARY
BACKGROUND
Public Law 106-553, The Departments of Commerce, Justice, and State, the Judiciary,
and Related Agencies Appropriations Act, requires the National Telecommunications and
Information Administration (NTIA) to consult with other federal agencies and departments
responsible for regulating the core operations of entities engaged in the provision of energy,
water, and railroad services and to report to Congress no later than one year after the Act’s
enactment on the current and future use of spectrum by these entities to protect and maintain the
Nation’s critical infrastructure.
NTIA employed the following methodology to facilitate and expedite the information
gathering process from the energy, water, and railroad industries; representative trade
organizations; and federal agencies with regulatory oversight of these industries:
•
A Request for Comments, with a 60-day comment period, was published in the
Federal Register on April 9, 2001.  NTIA received a total of 19 responses from
members of the utilities industry and various trade organizations.  The membership
of these trade organizations represents major segments of the energy, water, and
railroad industries.  This report contains a compilation of the responses received to
the Request for Comments.
•
A letter was sent to Executive Branch agencies that exercise oversight of these
industries containing specific questions pertaining to the current and future
spectrum requirements of providers of energy, water, and railroad services.
NTIA reviewed the information collected through comments, reports, and other sources
of information.  NTIA presents its findings in this report based upon such data.  NTIA found that
providers of energy, water and railroad services submitting comments for this report had concerns
regarding their current and future spectrum requirements.  In addition, federal agencies who
regulate the core operations of these industries (or some aspect of those operations) generally
concur with comments by the industry and its representative trade organizations.  Specifically,
these comments disclosed the following key issues regarding spectrum usage by these industries.
•
Continued use of spectrum is essential to the current and future operations of these
industries, taking into account industry trends and advances in wireless
telecommunications technology.  Providers of energy, water and railroad services
are vital components of the nation’s critical infrastructure.
xviii
•
Problems of interference caused by congestion in the land mobile portion of the
spectrum currently utilized was the issue mentioned most frequently by
commenters.  The issue of exclusivity (e.g., spectrum that is allocated for specific
services) was a key thread throughout the comments.
•
According to industry, reliance on commercial services for mission critical
functions is hampered by insufficient coverage, reliability, redundancy, and
robustness.  Additionally, the high cost of commercial wireless services and
wireline technologies affect reliance on these technologies.
•
Almost all commenters mentioned general frequency bands (e.g., 2.4 GHz and 5
GHz bands) currently used, instead of identifying specific frequencies.
•
Many commenters were not specific as to whether spectrum-efficient technology
such as trunked systems and narrowbanding are used on currently assigned
frequency bands or channels.  However, there were notable exceptions, such as the
American Association of Railroads’ decision to implement the Association of
Public Safety Communications Officials’ Project 25 protocols to develop a
rechannelization plan for its 160 MHz radios.
CURRENT SPECTRUM USE
Currently, the energy, water, and railroad industries use spectrum between 20 megahertz
(MHz) and 25 gigahertz (GHz).  Although they use numerous frequencies in a variety of bands,
all three industries agreed and informed NTIA that spectrum currently used is either congested or
quickly approaching critical mass, thus leading to problems of interference.
The technologies and applications used in these bands are vital to the core operations of
these industries.  Furthermore, in 1996 (by Executive Order No. 13010), President Clinton
recognized the railroad, water and energy industries as part of the Nation’s critical infrastructure. 
These entities provide commodities and services that are essential to daily life.  Table 1 illustrates
the three industries and the spectrum and applications currently used by each.
POSSIBLE FUTURE SPECTRUM REQUIREMENTS
The energy, water, and railroad industries submitted to NTIA suggestions to alleviate their
claim of congestion and lack of new spectrum.  There is no consensus among the commenters as
to where new spectrum can be reallocated or obtained.  However, there is consensus that
additional spectrum is needed due to what they perceive as current congestion and lack of
additional spectrum available for their respective industries.  Table 2, on page xx in this section,
summarizes the spectrum bands where the energy, water, and railroad industries believe their
frequency requirements need to be addressed.
xix
Table 1
Spectrum and Applications Currently Used as Indicated by Commenters
Energy Industry
Water Industry
Railroad Industry
20 MHz
 25-50 MHz:  PLMRS                                                       
40 MHz
 48-50 MHz:  Voice Dispatch, Alarms From Remote
50 MHz
 50 MHz Band:  PLMRS, MAS
100 MHz
 150-170 MHz:  Voice Dispatch, Load Management Control
 150-175 MHz:  Alarms From Remote Substations, PLMRS
160.215-161.565 MHz:
FM Equipment
200 MHz
 220 MHz:  SCADA
400 MHz
 450-470 MHz:  Voice Dispatch, Mobile Data, PLMRS
450-460 MHz:
End of Train Devices
 470-512 MHz:  PLMRS
800 MHz
 800 MHz Band:  Voice Dispatch, Mobile Data Terminals,
 Trunked PLMRS
 806-821 MHz:  PLMRS; 821-824 MHz:  PLMRS
 851-866 MHz:  PLMRS; 866-896 MHz:  PLMRS
 896-901 MHz:  PLMRS
896 MHz:  ATCS/PTC
900 MHz
 900 MHz Band:  MAS
900 MHz Band:  MAS, SCADA
 902-928 MHz:  SCADA
902-928 MHz:  LMS
 928-929 MHz:  POFS
928 MHz:  MAS
928 MHz:  MAS
 928/932/941 MHz:  MAS;  952/956/959 MHz:  MAS
952 MHz:  MAS
936 MHz:  ATCS/PTC
 928-952 MHz:  SCADA; 929-930 MHz:  PLMRS, 932-935 MHz,
956 MHz:  MAS
 932-941 MHz, SCADA, 935-940 MHz, PLMRS, 941-944 MHz,
 952-960 MHz, POFS, 956 MHz, Mobile Meter Reading
952 MHz, 956 MHz, MAS
1 GHz
 1.427-1.432 GHz, AMR, 1.85-1.99 GHz, POFS
2 GHz
 2 GHz Band, PLMRS, POFS, MAS, SCADA, Point-to-Point
2 GHz Band,1
2 GHz Band,2
 2.4 GHz Band, Point-to-Point Microwave
Water Operations Network
Point-to-Point Microwave
5 GHz
 5 GHz Band, Spread Spectrum
 5.8 GHz, 5.9-6.4 GHz, Point-to-Point Microwave
6 GHz
 6 GHz Band, Point-to-Point Microwave
6 GHz Band,3
6 GHz Band,4
 6.5-6.8 GHz, Point-to-Point Microwave
Water Operations Network
Point-to-Point Microwave
 6.525-6.875 GHz, POFS
11 GHz
 11 GHz Band,5 Point-to-Point Microwave
11 GHz Band,6
Point-to-Point Microwave
18 GHz
 18-19 GHz, Point-to-Point Microwave
18 GHz Band,7
Point-to-Point Microwave
21 GHz
 21.2-23.6 GHz, POFS
23 GHz
23 GHz Band,8
Water Operations Network
24 GHz
 24.25-25.25 GHz, POFS
1) 2.11-2.2 GHz, 2.45-2.5 GHz and 2.65-2.69 GHz.  47 CFR § 101.147(a).
2) Id.
3) 5.925-6.875 GHz.  47 CFR § 101.147(a).
4) Id.
5) 10.7-12.2 GHz.  47 CFR § 101.147(a).
6) Id.
7) 18-19 GHz.  47 CFR § 101.147(a).
8) 23-23.6 GHz.  47 CFR § 101.147(a).
xx
Table 2
Summary of Frequency Bands That Could Be Used as Indicated by Commenters
Energy Industry
Water Industry
Railroad Industry
220 MHz Band
216-220 MHz Band
700 MHz Band1
450 MHz Band
6 GHz Band
1.4 GHz Band
800 MHz Band
11 GHz Band
900 MHz Band
23 GHz Band
1427-1432 MHz Band
1-12 GHz Band
1) Although the AAR mentioned the 700 MHz Guard Band, this spectrum will also be available to the energy and water industries by leasing spectrum from the
“Guard Band Managers.”  More information on the 700 MHz band can be found on page 6-3.
The Energy Industry
The United Telecom Council, in its joint comments, recommends that exclusive spectrum
for utilities be allocated in the 450 MHz, 800 MHz, and 900 MHz bands for voice and data
communications.  DTE Energy states that unused television channels should be allocated to
utilities on a low powered non-interfering basis for voice and data communications and
recommends access to bands between 1 GHz and 12 GHz for fixed narrow and medium-wide data
channels as other preferred spectrum.  
Itron, Inc., suggests that the 1427-1432 MHz band should be licensed for utility telemetry
services such as Automatic Meter Reader and Supervisory Control and Data Acquisition.  The
National Rural Telecommunications Council states that access to the 220 MHz band for
Supervisory Control and Data Aquisition applications allows rural electric and telephone
cooperatives to transmit telemetry data over wide distances at reduced costs when compared to
land line or high frequency wireless alternatives.
The Water Industry
The American Water Works Association believes the United Telecom Council’s Utilities
Spectrum Assessment Taskforce Final Report (1998) underestimated spectrum requirements for
the utilities industries based on industry trends and the pace of telecommunications technology
development.  Table 3 is a summary of the Utilities Spectrum Assessment Taskforce (USAT)
report spectrum prediction, which was included as an attachment to American Water Works
Association’s comments and derived from projections of future wireless applications and growth. 
xxi
Table 3
USAT Final Report Spectrum Requirements
Year
2000
2004
2010
Additional Bandwidth
Required
1.0 MHz
1.9 MHz
6.3 MHz
Another commenter, Data Flow Systems, specifically recommends that the 216-220 MHz band be
dedicated to water utility telemetry uses nationwide.
The Railroad Industry
The Association of American Railroads suggests that the 700 MHz “guard band,” recently
auctioned by the FCC, be considered as a source of additional spectrum and that it be divided into
geographic sectors, each with a separate band manager.  The Association of American Railroads
notes that one impediment to this suggestion is that the 700 MHz band is currently occupied by
broadcast television stations. 
The Association of American Railroads also suggests the 1.4 GHz band as a source for the
proposed Land Mobile Communications Service for itself and other members of the Land Mobile
Communications Council.  The Association of American Railroads and other members of the
Land Mobile Communications Council have previously asked the Federal Communications
Commission for spectrum in the 1.4 GHz band (specifically, the 1390-1395 MHz/1427-1429
MHz/1432-1435 MHz bands), and to limit auctions in the 1392-1395 MHz and 1432-1435 MHz
bands to band managers.
SUMMARY/CONCLUSIONS
In its investigation into the use of spectrum by these industries, NTIA recognizes the vital
roles the railroad, water, and energy industries play in the Nation’s critical infrastructure.  The
events of September 11, 2001, have underlined the importance of these industries and the role
they play not only in our daily lives, but in times of disaster response and recovery.  When the
World Trade Center collapsed, utilities needed to be shut off or restored.  It was important for
sufficient water pressure to be continuously available for firefighting, and when the airlines were
grounded, people and commerce relied more on the railroad industry for transportation. 
Since this report is based predominantly on comments received from the industry and
public, and information from federal agencies with oversight or regulatory authority over these
industries, NTIA is unable to validate specific requirements and issues highlighted herein, such as
exclusivity and congestion.  However, NTIA suggests some of these issues may be addressed or
mitigated with the use of advanced communications technology or newly allocated frequency
bands, such as the 700 MHz guard bands.
xxii
NTIA believes the significance of these industries and the urgency of these issues may
have changed as a result of the September 11th events.  Therefore, it is of utmost importance that
the Federal Communications Commission revisit these critical issues in order to accommodate the
increasing role these industries play in maintaining quality of life.
1  National Telecommunications and Information Administration, U.S. Dept. of Commerce, Manual of
Regulations and Procedures for Federal Radio Frequency Management, at Chapter 2 (Jan. 2000).
2  See Federal Funding, Fiscal Year 2001, Pub. L. No. 106-553, 114 Stat. 2762, 2762A-73 (2000).
3  The events of September 11, 2001, prevented the National Telecommunications and Information
Administration (NTIA) from being able to complete its report by the date mandated in the law.  As a result, NTIA
has informed Congress of the delay.
1-1
SECTION 1
INTRODUCTION
BACKGROUND
The National Telecommunications and Information Administration (NTIA) is the
Executive Branch agency principally responsible for developing and articulating domestic and
international telecommunications policy.  NTIA’s responsibilities include establishing policies
concerning spectrum assignments, allocation and use, and providing various departments and
agencies with guidance to ensure that their conduct of telecommunication activities is consistent
with these policies.1  Accordingly, NTIA conducts studies and makes recommendations regarding
telecommunications policies and presents Executive Branch views on telecommunications matters
to the Congress, the Federal Communications Commission (FCC), and the public.
NTIA is responsible for managing the Federal Government’s use of the radio frequency
spectrum.  The FCC is responsible for managing the spectrum used by the private sector, and
state and local governments.  In support of its responsibilities, the NTIA has undertaken
numerous spectrum-related studies assessing spectrum utilization, studied the feasibility of
reallocating spectrum used by governments or relocating government systems, identified existing
or potential compatibility problems between systems, provided recommendations for resolving
any compatibility conflicts, and recommended changes to promote efficient and effective use of
the radio spectrum and improving spectrum management procedures.
Public Law (PL) 106-553 appropriated funds to the Departments of Commerce, Justice,
and State, the Judiciary, and Related Agencies for fiscal year 2001, and directs NTIA to submit to
Congress a study of the current and future use of spectrum by providers of energy, water, and
railroad services to protect and maintain the Nation’s critical infrastructure.2  NTIA must submit
this report to Congress no later than 12 months after PL 106-553 was enacted.3  The statute also
requires the Chairman of the FCC to submit a subsequent report to Congress addressing any
needs identified in NTIA’s study.  The FCC’s report must be submitted to Congress within six
months after the release of NTIA’s study.  This document constitutes NTIA’s study required by
PL 106-553.
4  The IRAC, consisting of representatives of 20 federal agencies, serves in an advisory capacity to the
Assistant Secretary of Commerce for Communications and Information.  The IRAC, in existence since 1922,
assists the Assistant Secretary in the discharge of his responsibilities pertaining to use of the electromagnetic
spectrum.  The IRAC was given informational updates on February 27, 2001, and July 10, 2001.  Furthermore,
NTIA met with private sector organizations engaged in energy, water and railroad activities to obtain background
information about their respective industry.  NTIA also met with federal departments and/or agencies who regulate
these industries.
5  66 Fed. Reg., 18448 (April 9, 2001).  See copy of the published RFC in Appendix B.
6  Letter from William T. Hatch, Associate Administrator, Office of Spectrum Management, National
Telecommunications and Information Administration (NTIA) (July 5, 2001), [hereinafter Federal Letter]. See
Appendix C.
1-2
OBJECTIVE
In accordance with the requirements of PL 106-553, the objective of this report is to
investigate and determine current spectrum usages and potential future spectrum requirements of
entities providing energy, water and railroad services.  Consistent with the requirements of the
statute, these determinations were made after seeking public comments and consultation with the
other federal departments and agencies responsible for regulating the core operations of these
entities.
APPROACH
To comply with the requirements of PL 106-553 and the specific objectives stated above,
the following steps were taken:
1.
Members of the Interdepartment Radio Advisory Committee
(IRAC) were given background information pertaining to the
requirements of PL 106-553 and their assistance was solicited.4
2.
A Request for Comments (RFC) was published in the Federal
Register soliciting comments on current and future spectrum
requirements for entities engaged in energy, water, and railroad
activities.5
3.
As part of NTIA’s study, a letter was sent to federal departments
and/or agencies that exercise oversight over the energy, water, and
railroad industries, soliciting their comments on current and future
spectrum requirements for these entities.6
4.
Information pertaining to current spectrum use by providers of
energy, water, and railroad services; their future spectrum
requirements; and pertinent regulatory issues was obtained from a
variety of sources, including:
•
The Public Safety Wireless Network (PSWN),
•
The Federal Communications Commission,
7  See generally Federal Letter.  NTIA received replies from the Environmental Protection Agency (EPA),
the Department of Energy (DOE) and the Federal Energy Regulatory Commission (FERC).  Copies of these
responses are on file at NTIA.  Copies of these responses may be obtained by contacting NTIA’s Office of Public
Affairs.
1-3
•
Data sources available within NTIA, and
•
Relevant public literature articles, reports, and studies that
describe spectrum use by entities providing energy, water,
and railroad services.
NTIA reviewed the information collected through comments, reports, and other sources of
information.  NTIA presents its findings in this report based upon such data.  NTIA did not
independently validate the energy, water, and railroad industries’ current and future spectrum
requirements.
Letter Soliciting Responses from Federal Agencies
On July 5, 2001, NTIA sent letters to federal departments and agencies responsible for
regulating the energy, water, and railroad industries and requested they respond to the following
questions by August 6, 2001:7
1.
Please provide a brief description of your agency’s mission, including the
extent to which it provides regulatory oversight for any of the energy,
water or railroad industry.  Please indicate the aspects of the industry that
your agency regulates, e.g., safety, industry standards,  market supply,
distribution, transport, disposals, and pricing, and provide citations to your
regulations.
2.
Does your agency also promulgate regulations concerning communications
or spectrum-related issues?  Please provide the citation to these regulations
and summarize your agency’s regulation(s) regarding current spectrum
requirements and usage by the industry.
3.
Will the industry  your agency regulates require additional spectrum
allocations in the future?  If so, please provide details. 
4.
Are wireless technologies crucial to compliance of these regulation(s)? Are
they crucial to maintaining the nation’s critical infrastructure?  What
alternatives to wireless technologies can be utilized?
5.
Do you consult with the industry certified frequency coordinator regarding
spectrum allocations?  If so, please provide contact information.
8  Supra note 5.  Comments were due on or before June 8, 2001.  All comments are available on the
National Telecommunications and Information Administration’s Web site at:
http://www.ntia.doc.gov/osmhome/utilities/CommentPage.html.  All federal agency responses are on file at NTIA. 
A list of responders to both the RFC and letter to the federal agencies, and the acronym used to refer to each
responder in this report, is attached as Appendix D.  The first reference to each comment and/or response will
include the full name of the organization, its acronym, and the page number.  Subsequent references will be cited
as “[acronym] at [page].”  NTIA received 19 written comments from the public, of which five are from industry
trade organizations.  The five trade organizations are: American Petroleum Institute, American Water Works
Association, Association of American Railroads, National Rural Telecommunications Cooperative, and the United
Telecom Council.  The trade organizations are made up of members of each industries and, through their
members, they represent the members and the industry.
9  Supra note 5.
1-4
Request for Comments from the Public
Public Law 106-553 mandates that NTIA study the current and future spectrum
requirements of the water, energy, and railroad industries.  To assist in this effort, NTIA
published a Request for Comments (RFC) in the Federal Register on April 9, 2001, to solicit
comments from industry and the public.8
In the RFC, NTIA asked for information concerning any issues of fact, law, or policy
about the spectrum requirements of the energy, water, and railroad industries and for responses to
six questions.  Specifically, NTIA asked the following questions:9
1.
How much spectrum is presently available for the energy, water and
railroad industries?
2.
In which spectrum bands and in which radio services do these industries
operate radio communications equipment?
3.
What kinds of spectrum-dependent telecommunications equipment are
currently being used by the energy, water, and railroad industries?
4.
Are there non-spectrum dependent alternative technologies or commercial
services currently available?
5.
What part of the spectrum do the energy, water, and railroad industries
foresee for possible future use?  What is the rationale for these additional
spectrum requirements?
6.
What non-spectrum dependent communications technologies or
commercial alternatives will be available in the future for the energy, water
and railroad industries?
REPORT OVERVIEW
Section 2 of this report provides information regarding industry certified frequency
coordinators and federal regulatory agencies.  Sections 3, 4, and 5 provide comprehensive
1-5
information extracted from the public comments and federal agency responses to the questions
raised by NTIA for the energy, water, and railroad industries, respectively.  Each section will
provide a brief overview of the industry.  Based on the responses received by NTIA, the current
spectrum requirements of each industry are discussed in terms of wireless communications
infrastructure and wireline and commercial services.  Technical issues and trends are then
addressed.  Finally, the future spectrum requirements for each industry are discussed.  Section 6
provides a summary of spectrum usage for the three industries in terms of current usage and
possible future needs.  Section 7 provides the findings reached from NTIA’s investigation.
10  Formerly grouped into the Public Safety Radio Services, Special Emergency Radio Service, Industrial
Radio Services and the Land Transportation Radio Services categories.  The frequencies within the
Industrial/Business Pool are specified in 47 CFR § 90.35(b)(3) of the FCC Rules.
11  The Industrial/Business Pool includes the Industrial Radio Services (Power, Petroleum, Forest
Products, Film & Video Production, Relay Press Special Industrial, Business, Manufactures, and Telephone
Maintenance Radio Services) and Land Transportation Radio Services (Motor Carrier, Railroad, Taxicab, and
Automobile Radio Services) categories.
12  Part 90 Order at 14308.
13  Part 90 Order at 14319.
14  Part 90 Order at 14322.
15  Part 90 Order at 14330.
2-1
SECTION 2
CERTIFIED FREQUENCY COORDINATORS AND 
FEDERAL REGULATORY AGENCIES
BACKGROUND
This section describes the role and frequency assignment process of Certified Frequency
Coordinators and federal regulatory agencies associated with the energy, water, and railroad
industries, with whom NTIA consulted in the development of this report.  A frequency
coordinator is an entity or organization that has been certified by the FCC to recommend
frequencies for use by licensees. Frequency coordinators provide a useful service as the link
between the FCC and end user. They ensure that the spectrum is used efficiently.
CERTIFIED FREQUENCY COORDINATORS
In accordance with rules implemented in 1997, the FCC consolidated 20 previously
exclusive Private Land Mobile Radio (PLMR) services10 into two frequency pools - the Public
Safety Pool and the Industrial/Business Pool.11  The FCC promulgated these new rules to
“provide for more efficient allocation of the increased capacity created by the introduction of
more efficient technology.”12  Each of the 20 PLMR services has one designated certified
frequency coordinator (see Table 2-1).  Eligibility for the Public Safety Pool is restricted to local
government, police, fire, highway maintenance, forestry-conservation, emergency medical and
special emergency services.13  Eligibility for the Industrial/Business Pool is available to any entity
engaged in a commercial, educational, philanthropic, or ecclesiastical activity.14  In general, an
eligible applicant can request any frequency in the Industrial/Business Pool.  However,
applications for frequencies previously allocated solely to the railroad, power, and petroleum
radio services must be submitted to the respective railroad, power, or petroleum certified
frequency coordinator within the Industrial/Business Pool.15  The FCC states in its Second Report
16  These frequencies are annotated with a Railroad, Power or Petroleum designator (LR, IW, or IP
respectively).
17  Part 90 Order at 14309.
18  Part 90 Order at 14333.
19  Id.
20  Id.
21  Id.  
22  Id.
23  Part 90 Order at 14335.
2-2
& Order (PR Docket 92-235 dated March 12, 1997):
...we have identified three types of entities within the new Industrial/Business pool
– railroad, power, and petroleum companies16 – that routinely use PLMR
frequencies for critical public safety-related communications.  To ensure that the
integrity of these communications is not impaired, we will require anyone who
seeks to use the frequencies previously allocated specifically for these types of
operations to go through the same frequency coordinators that have been
responsible for coordinating these frequencies.17
Frequency coordinators are not required to maintain a common database.18  However,
they are required to “provide notification of all frequency recommendations within one business
day of making such recommendations to every certified in-pool coordinator that is also certified
to coordinate that frequency.”19   In addition, this notification must be made to all in-pool
coordinators at approximately the same time.20  This notification should include an applicant
name, frequencies recommended, antenna height, antenna locations, type of emissions, effective
radiated power, description of service area, and time of recommendation.21  The in-pool
coordinators are required to communicate at least once daily; even if no license applications are
received.22  Furthermore, applicants must wait ten business days before transmitting pursuant to
temporary and conditional authorization.23
Comments to the RFC were received from 3 of 18 certified frequency coordinators
(power, petroleum and railroad) within the Industrial/Business Pool.  They did not provide
additional data (e.g., types of systems used) regarding current use of the frequencies in the
Industrial/Business Pool by providers of energy, water, and railroad services.  NTIA was unable
to determine the number of frequency applications that were submitted to other frequency
coordinators within the Industrial/Business Pool (See Table 2-1 on page 2-4).  However, it would
24  Supra note 16.
25  47 CFR § 90.35.
26  Id.
27  American Petroleum Institute (API) at 1.
28  Id.
29  Id.
30  United Telecom Council (UTC) at 3.
31  Id.
2-3
not be surprising if the number of applications was significant considering the large number of
frequencies not managed by the power, petroleum, or railroad frequency coordinators.24
The Energy Industry
The American Petroleum Institute (API) and the United Telecom Council (UTC) are the
two certified frequency coordinators authorized by the FCC to process requests for channel
assignments from energy providers eligible to hold frequency authorizations in the
Industrial/Business Pool, as outlined by Part 90 of the FCC rules and regulations.25  Furthermore,
UTC and API were the only certified frequency coordinators for the Industrial/Business Pool to
submit comments on behalf of the energy industry.
The API is designated as the “Petroleum Coordinator (IP)” for all energy providers of
petroleum or petroleum-based energy products.26  API manages over 34,100 licenses authorized
for operations in frequency bands below 512 MHz.  Over 5,000,000 mobile units and 43,000 base
stations operate under these licenses.27  API is also a national trade association representing
various facets of the petroleum and natural gas industries, ranging from exploration and
production to the transportation, refining, and marketing of those energy sources.28  API is a
forum for its 400 plus members of all sectors of the oil and natural gas industries to pursue
common goals and to protect certain public policy objectives.29
The UTC is designated as the “Power Coordinator (IW)” for all non-petroleum energy
providers and water utilities (both waste water and drinking water) seeking to hold frequency
authorizations in the Industrial/Business Radio Pool.  UTC has been the national representative on
communications matters for the Nation’s electric, gas, water and steam utilities, and natural gas
pipelines since its formation in 1948.30  UTC’s members range in size from large combination
electric-gas-water utilities that serve millions of customers, to smaller, rural electric cooperatives
and water districts that serve only a few thousand customers each.31  
32  Part 90 Order at 14324-14325.
2-4
Table 2-1
List of Radio Services and Corresponding Frequency Coordinators32
Radio Service
Frequency Coordinator
Local Government and Police
Association of Public-Safety Communications
Officials-International, Inc. (APCO)
Fire and Emergency Medical
International Association of Fire
Chiefs/International Municipal Signal Association
(IAFC/IMSA)
Forestry-Conservation
Forestry Conservation Communications
Association (FCCA) 
Highway Maintenance
American Association of State Highway and
Transportation Officials (AASHTO)
Special Emergency
Personal Communications Industry Association
(PCIA) and IAFC/IMSA
Power
United Telecom Council (UTC) 
Petroleum 
American Petroleum Institute (API)
Forest Products
Forest Industries Telecommunications
Film and Video Production
Alliance of Motion Picture and Television Producers
Relay Press
Newspaper Association of America
Special Industrial
Industrial Telecommunications Association (ITA)
Business
PCIA
Manufacturers
Manufacturers Radio Frequency Advisory
Committee
Telephone Maintenance
Telephone Maintenance Frequency Advisory
Committee
Motor Carrier
American Trucking Association
Railroad
Association of American Railroads (AAR)
Taxicab
International Taxicab and Livery Association
Automobile Emergency
American Automobile Association (AAA)
33  Water utilities is considered a power service, therefore, frequency coordination falls under UTC’s
penumbra.
34  UTC at 3.
35  Association of American Railroads (AAR) at 2.
36  Id.
37  Supra note 25.  AAR is designated as a Railroad Coordinator or LR.
38  AAR at 2.
39  UTC at 3.
2-5
The Water Industry
The UTC is also designated as the FCC frequency coordinator for water utilities seeking
to hold frequency authorizations in the Industrial/Business Radio Pool.33  As noted before, UTC
serves as the national representative on communications matters for the Nation’s electric, gas,
water and steam utilities, and natural gas pipelines since its formation in 1948.  UTC’s members
range in size from large combination electric-gas-water utilities that serve millions of customers,
to smaller, rural electric cooperatives and water districts that serve only a few thousand
customers.34  UTC was the only certified frequency coordinators for the Industrial/Business Pool
to submit comments on behalf of the water industry.
The Railroad Industry
The Association of American Railroads (AAR) is a non-profit organization composed of
railroad companies operating in the United States, Canada, and Mexico.35  AAR members
generate about 97 percent of the total revenues of all railroads in the United States.36   The AAR
is the FCC certified frequency coordinator for railroads seeking licenses for frequencies in the
Industrial/Business Radio Pool.37  AAR represents its members on routine federal regulatory
issues in the railroad industry, communications matters, and subjects regarding access to RF
spectrum.38  AAR also participates in UTC’s Critical Infrastructure Communications Coalition
(CICC).39  AAR was the only certified frequency coordinator for the Industrial/Business Pool to
submit comments on behalf of the railroads. 
FEDERAL REGULATORY AGENCIES
PL 106-553 requires NTIA to consult with federal departments and agencies responsible
for regulating the core operation of entities that provide energy, water, and railroad services.  The
following paragraphs list the department and/or agencies who responded to NTIA’s inquiry for
each of the three industries at issue.
40  Department of Energy (DOE) at 1.
41  Id.
42  FERC homepage at <http://www.ferc.gov/about/about.html>.
43  Department of Transportation hompage at <http://ops.dot.gov/toc.htm>.
44  Marine Safety and Environmental Protection Directorate, U.S. Coast Guard, U.S. Dept. of
Transportation, U.S. Coast Guard Marine Safety and Environmental Protection Business Plan FY 2001-2005 at I-
2, (August 2000).
45  Letter from Charles Fox, Assistant Administrator, U.S. Environmental Protection Agency, to William
E. Kennard, Chairman, Federal Communications Commission (Dec. 20, 1999) at 5, [hereinafter Fox Letter].
2-6
The Energy Industry
The Department of Energy’s (DOE’s) mission is to foster a secure and reliable energy
system that is environmentally and economically sustainable.40  DOE does not regulate the core
operations of the energy industry because regulation of core operations is generally accomplished
at the state level.41  The Federal Energy Regulatory Commission (FERC) is an independent
regulatory agency within DOE that regulates the transmission, sale and wholesale of natural gas,
oil (by pipeline interstate commerce) and electricity.  The FERC also licenses and inspects private,
municipal, and state hydroelectric projects.  Environmental matters related to the providers of
energy are overseen by the FERC.42
Within the Department of Transportation (DOT), two entities have regulatory oversight of
the energy industry. The Research and Special Programs Administration, Office of Pipeline Safety
(OPS) is responsible for promulgating regulations governing the safety and environmental matters
of pipelines carrying gas (natural gas, flammable gas, or gas which is toxic or corrosive) and
hazardous liquids (petroleum, petroleum products, and anhydrous ammonia).43  As part of its
mission to “protect the public, the environment, and U.S. economic interests through the
prevention and mitigation of maritime projects,”44 the U.S. Coast Guard is responsible for
promulgating safety regulations and inspecting petroleum transfer facilities (e.g., refineries,
barges, etc.), and tanker ships that transport petroleum products.
The Water Industry
The Environmental Protection Agency (EPA), U.S. Army Corps of Engineers (USACE),
and Department of Interior (DOI) share responsibility for management of the water industry.  The
EPA, as directed by the Clean Water Act, Safe Drinking Act and Sanitary Sewer Overflow Rule,
has placed increasingly strict performance requirements on drinking water and wastewater
treatment facilities to “. . . protect public health and the environment, requirements which demand
frequent monitoring for both large and minimally-staffed smaller water and wastewater
systems.”45  The EPA does not promulgate regulations concerning communications or spectrum
46  Environmental Protection Agency (EPA) at 1.
47  EPA at 2.
48  Id.
49  Id.
50  U.S. Army Corps of Engineers homepage at <http://www.usace.army.mil/who.html#Mission>.
51  U.S. Department of Transportation hompage at <http://www.fra.dot.gov/o/safety/ers/esxecsu0.htm>.
52  Id.
2-7
related issues.46  However, EPA believes that the water quality and drinking water programs pose
substantial challenges to the regulated community in its compliance with federal and state
requirements.47  Thus, the EPA projects that “the wastewater and drinking water utilities will need
the communications tools to successfully achieve and maintain compliance objectives.”48  EPA
informed NTIA that they do not consult with the industry certified frequency coordinator
regarding spectrum licensing.49
Since the first Flood Control Act was enacted by Congress in 1917, USACE has been the
primary federal agency responsible for civil works programs throughout the U.S. Management of
dams and locks at various U.S. locations is also part of the USACE’s responsibilities.50
In addition, the Tennesee Valley Authority, Bureau of Land Management, U.S. Geological
Service, Bureau of Reclamation, and International Boundaries and Water Commission, all within
the Department of The Interior, share regulatory oversight of the water industry.
The Railroad Industry
The Federal Railroad Administration (FRA), is an agency within the Department of
Transportation, is responsible for working with the railroad industry to ensure it complies with all
federal safety and communications regulations.  The FRA is required by law “to monitor railroad
compliance with federally mandated safety standards.”51  The FRA employs 400 inspectors in 47
offices nationwide to manage a site-specific inspection program.52 
According to information supplied by the various federal agencies with regulatory
oversight over energy, water, and railroad industries, none of the federal departments or agencies
are involved with or support the private sector’s spectrum matters.  Furthermore, these regulating
departments or agencies do not promulgate specific rules concerning spectrum use.  Private sector
companies approach the appropriate certified frequency coordinators when the need for spectrum
arises.
53  Formed in December 1999, CICC represents industries that include representatives of the electric, gas,
water, railroad, and petroleum industries.  CICC’s mission is to promote legislative and regulatory policies that
protect the internal communications systems of these industries.  Specific participants of CICC include the
American Gas Association, American Petroleum Institute, American Public Power Association, American Water
Works Association, Association of American Railroads, Association of Oil Pipe Lines, Edison Electric Institute, 
Interstate Natural Gas Association of America, National Association of Water Companies, and the United Telecom
Council.  UTC at 3.
54  UTC at 3.
55  Id.
56  Exec. Order No. 13010, 61 Fed. Reg. 37347 (July 15, 1996).
3-1
SECTION 3
THE ENERGY INDUSTRY
BACKGROUND
The UTC’s Critical Infrastructure Communications Coalition (CICC)53 contends its
members’ unique operational needs make consistent and immediate access to exclusive radio
frequency spectrum imperative to continuity of operations of the energy, water, and railroad
industries.54  According to the CICC, disruptions to the communications infrastructures of these
industries can threaten public safety.55  
Furthermore, the 1996 Executive Order pertaining to critical infrastructure protection
states:
[c]ertain national infrastructures are so vital that their incapacity or destruction
would have a debilitating impact on the defense or economic security of the United
States.  These critical infrastructures include telecommunications, electrical power
systems, gas and oil storage and transportation, banking and finance,
transportation, water supply systems, emergency services (including medical,
police, fire, and rescue), and continuity of government.  Threats to these critical
infrastructures fall into two categories: physical threats to tangible property
(physical threats), and threats of electronic, radio-frequency, or computer-based
attacks on the information or communications components that control critical
infrastructures (cyber threats).56 
A 1997 report of the President’s Commission on Critical Infrastructure Protection identifies oil
and gas production and storage, the water supply and electrical power infrastructures as integral
57  President’s Commission on Critical Infrastructure Protection, Critical Foundations - Protecting
America’s Infrastructures, The Report of the President’s Commission on Critical Infrastructure Protection (Oct. 13,
1997) at i.
58  Cinergy letter dated November 29, 2001
59  BPA is a U.S. Department of Energy (DOE) agency that markets and transmits electric energy from
federally owned hydroelectric and transmission facilities.  BPA is represented on the IRAC through the DOE. 
60  Letter from Howard Landon, Chief Information Officer, U.S. Department of Energy, to William T.
Hatch, Associate Administrator, Office of Spectrum Management, National Telecommunications and Information
Administration (Aug. 9, 2001), [hereinafter Landon Letter], BPA Attachment at 5. 
61  Id.
62  Id.
63  Id. at 7.
64  Id. at 2.
3-2
components of “the critical infrastructures that constitute the life support systems of our Nation ...
.”57  Cinergy Corporation contends in supplemental comments that utilities play a critical role in
the quality of life for the Nation, especially during a local or national crisis.58
The Bonneville Power Administration (BPA)59 has stated that the loss of wireless
applications would interfere with energy companies’ compliance with environmental and industry
standards and regulations pertaining to power distribution.60  BPA emphasizes that wireless
applications are crucial to real time operations and activities related to safety, maintenance, and
construction.61 “Removing wireless systems on power networks would be like removing the
backbone and nervous system of an animal and then asking it to walk and talk.”62
Many power transmission, energy supply, and distribution systems are located in sprawling
rural service territories, underground, or in remote, isolated areas where placement of non-
spectrum dependent facilities such as fiber optics or commercial wireless networks are not cost
effective, practical, or feasible.63  Urban areas are also becoming more dependent on wireless
technologies because of the high demand for energy by rapidly growing population centers.
Energy providers are continuously adding power substations, transmission lines, and
communications systems to control these facilities.  DOE states that, as infrastructure is added,
the expansion of Land Mobile Radio (LMR) voice and data communication systems must also
grow to allow maintenance crews to operate in the expanded areas.  This expansion in generation
capacity also allows for increased sharing (energy resources) between utilities in areas where
deregulation has been implemented.64  These technologies feature advance power meters that
provide reactive/apparent power, time of use data (i.e., in segregated time frames), and special
65  J.D. Kuecek, B.J. Kirby, J. Eto, R.H. Stuanton, C. Murray, C.A. Martinez, C. Goldman, Oak Ridge
National Laboratory, U.S. Department of Energy, Pub. No. ORNL/TM2001/97, LBNL-47983, Load As a
Reliability Resource in Restructured Electricity Markets (June 1, 2001) at 3, [hereinafter Load Report].
66  UTC at 7.
67  Landon Letter, in BPA Attachment at 6.
68  President’s Commission on Critical Infrastructure Protection, Critical Foundations - Protecting
America’s Infrastructures, The Report of the President’s Commission on Critical Infrastructure Protection (Oct. 13,
3-3
communications features that operate via phone, radio, or power lines.65  Energy producers,
suppliers, and distributors utilize the radio frequency spectrum to implement operations in the
PLMRS, SMR, MAS, and Fixed Microwave Service to provide a variety of critical services that
utilize various voice and data communications systems and applications.  These networks facilitate
the control and monitoring of power grids and pipeline distribution systems, and the exploration
for petroleum and natural gas.66
Energy providers use a combination of spectrum dependent technologies and wireline
technologies to maintain a secure, reliable, and safe voice and data communications infrastructure
to preclude disruption of service caused by natural disasters or equipment malfunctions.  Wireless
voice and data networks also enable energy producers, suppliers, and distributors to comply with
existing state and federal safety and environmental requirements that in many instances have
specific system restoration and emergency notification time requirements.  The BPA states that:
BPA’s power reliability, control, maintenance, safety and peripheral devices for
metering, alarms and reporting are dependent on wireless.  In many real time line
protection applications such as a transfer trip, a line disconnect operation must be
completed within 8 [millisecond] (ms) for system protection.  Another example is
BPA’s long distant Remedial Action Schemes that require completion of action
within 50 ms for line isolation and power stability through its controllers.  SCADA
require 2.5 seconds for responses from queries.  Safety of linemen, maintenance,
construction crews [sic] and equipment are dependent on wireless technologies. 
Emergencies dealing with restoring the power grid because of environmental, or
other contingencies must be met by supporting wireless technologies.  In summary,
the loss of real time control operations with regulations is crucial to our nation’s
[sic] critical infrastructure and would cease today’s power operations immediately
in most cases without wireless operation.67
Any system disruptions that are not quickly restored pose potential threats not only to
public safety, but also to the nation’s economic security.  Just as the September 11, 2001, 
terrorist attacks on the World Trade Center and the Pentagon disrupted our economy, crippled
the airline industry, and compromised our national security, a disruption in a power generating
station’s control computer or a petroleum pumping facility could be just as devastating.68  The
1997) at x.
69  DTE Energy (DTE) comments at 1.
70  North Atlantic Energy Service Corp (NAES) at 3-4.  NAES further asserts that users are being licensed
within 30 miles of the station disregarding a 70-mile exclusion area guideline used by frequency coordination
agencies.
71  Cinergy Supplemental comments (Cinergy Supp.) at 6.
72  See 47 CFR § 90.617 (c) and § 90.35.
73  See generally Itron, The Critical Role of Advanced Metering Technology in Optimizing Energy
Delivery and Efficiency, A Report to the U.S. Department of Energy (May 5, 2000), [hereinafter Itron Report].
74  USA TODAY, Savings Seen In Hour of Energy Use, Section A (July, 16, 2001) at 3A.
3-4
utility command and control infrastructures do not have exclusive radio frequency spectrum
assigned or priority access to the available radio frequency spectrum.  The Detroit Edison
Company (DTE), an energy provider, emphasized in their comments that slivers of the radio
spectrum are shared by the energy, water, and railroad industries along with public safety entities. 
These frequencies are fragments of the entire band as compared to the spectrum allocations for
broadcast television.69  North Atlantic Energy Service (NAES) - Seabrook Station contends that
there is insufficient radio spectrum and that its work crews, dispatchers, and command centers
have continually encountered interference from other users who operate in close proximity to the
station.70  Cinergy Corporation (Cinergy) states in supplemental comments for this report that
energy providers operating in the 800 MHz band must compete with livestock breeders, concrete
manufacturers, taxicabs, buses, lumberjacks, and film producers.71  The FCC has determined that
any commercial business is eligible to be assigned channels in the 800 MHz and 900 MHz
Industrial /Land Transportation pools.72
INDUSTRY GROWTH
Consumer Demand and Industry Trends
The current power crisis in certain parts of the United States, where demand far exceeds
supply, serves as an example of why real-time redundant wireless communications technologies
are essential to meet growing consumer requirements.73  Many energy suppliers and distributors
are utilizing wireless technologies to match increasing load requirements with escalating consumer
demand.  For example, over a dozen utility companies in 17 states offer pilot programs with real
time-of-day pricing for electricity.  In some cases, consumers are charged different rates during
the day instead of a fixed rate.74   “More recently, utilities such as Florida Power & Light,
Potomac Electric and Xcel Energy (formerly Northern States Power) have offered price breaks to
customers who allow their utility to automatically shut down their air conditioners or hot-water
75  Id.
76  Id.
77  API at 23.
78  Utilities Spectrum Assessment Taskforce Final Report (USATFR) at 1.
79  Florida Power and Light Company and GPU Energy, Inc. (FPL & GPU) at 4.
3-5
heaters by radio control when demand for electricity is high.”75  These programs would not exist
but for the use of “cellular meters that transmit how much electricity is used minute-to-minute,
matching the power use to the real-time cost of electricity.”76
As shown in Figures 3-1 and 3-2, on pages 3-6 and 3-7 respectively, consumer demand for
energy has historically increased and it is projected that consumer demand and advances in
technology will be significant factors affecting the growth of the energy supply and distribution
industry during next ten years.  American Petroleum Institute (API) anticipates an increased need
for spectrum allocations based on petroleum and natural gas production and consumption
forecasts through the year 2020.  This increased production and consumption will require
additional communications capabilities to sustain all stages of the exploration, production and
distribution process.77
The wireless voice and data infrastructure required to keep pace with projected industry
growth must be reliable and have the capability to provide real-time network command and
control.  Electricity, natural gas, and natural gas pipelines utilities have extensive
telecommunications requirements.  An expansive, sprawling infrastructure, whether it is
transmission lines, water pumps, or electric substations, requires maintenance, remote control, and
monitoring.  These objectives can be met effectively through telecommunications services.  One
of the most critical components in a utility's telecommunications arsenal is its wireless network.78 
Florida Power & Light and GPU Energy have indicated in joint comments for this report that,
“because of the rise in electrical consumption and power shortages that may arise as a result of
increased demand, wireless control of circuits in real time mode is becoming more important in
order to maintain the stability of the power distribution grid. For example, wireless home
gateways at customer premises can be utilized to monitor loads during peak hours. Such systems
can be used to curtail use (e.g., shut down electric hot water heaters or air conditioners) during
peak usage or emergency conditions during hot summer days when the electrical network is
maximally taxed.”79
Deregulation
Deregulation is another reason why energy providers have had increasing difficulty
keeping pace with growing consumer demand.  Deregulation opens retail energy markets to 
80  U.S. Department of Energy, Annual Energy Outlook 2001, DOE/EIA-0383 (Dec. 22, 2000) at 6.
81  Central Maine Power (CMP) comments, page 4-5
82  UTC at 2.
3-6
Figure 3-180
competition and separates electric generation from the transmission and distribution of electricity. 
Previously, utilities maintained the entire end-to-end generation, transmission, and distribution of
service.  Now multiple companies are involved in various components of providing electric
power.81  UTC emphasizes that wireless systems will be increasingly important to critical
infrastructures entities in the future because of deregulation, regulatory requirements, and system
growth.82  “Power outages and rolling blackouts in California are prime examples of what can
occur when there is insufficient power system capacity, or proper control of the power system
cannot be maintained.  As new generation capacity is brought on line and new
83  North American Reliability Council homepage at <http://www.nerc.org>.
84  Landon Letter at 2.
85  Niagara Mohawk Power Corporation (NMPC) at 2.
3-7
Figure 3-283
transmission systems are installed in the power grid to allow sharing between utilities, spectrum
requirements will increase for all electric utilities.”84 
WIRELESS COMMUNICATIONS INFRASTRUCTURE
The wireless telecommunications infrastructures of energy providers include applications
that process both voice and data information.  Energy providers utilize multiple frequency bands
in the PLMRS, MAS, and the POFS.  They operate SMR systems and maintain service with
commercial wireless providers.  Voice-related systems, such as land mobile, often use frequencies
below 470 MHz for crew dispatch and emergency restoration efforts.  Higher frequency bands
used by microwave systems are being utilized for multiple address telemetry applications, point-
to-point microwave for data and voice communications, and special applications such as control
of electric power and natural gas SCADA networks.85  This section will focus on “private and
86  USATFR at 12, for industry definitions of private and commercial telecommunications systems.
87  USATFR at 5.
88  Id.
89  Cinergy Supp. at 5.
90  Omaha Public Power District (OPPD) at 4.
91  Id.
3-8
commercial”86 voice and data applications commonly used by the energy industry in day-to-day
operations and emergency response situations.
Voice Requirements
PLMR is used to coordinate daily activities of work crews and equipment for routine
maintenance operations and restoration of service.  Dispatchers and managers utilize systems in
the PLMRS to communicate directly to mobile crews to safely restore power, to give operating
orders, and to receive crew reports of job completions.  Listed below are various modes of
operations used for voice communications.87
Dispatcher to Crew/Crew to Crew/Group Dispatch.88  This is a versatile mode of
communications between managers, dispatchers and field personnel.  Mobile voice is the primary
mode of communication when coordinating the activities of work crews for routine maintenance. 
Service must be restored quickly when unexpected outages occur because of natural disasters,
human error or intentional disruption of service (e.g., acts of terrorism, vandalism etc.).  Group
dispatch allows multiple parties to communicate on the same channel simultaneously.89  Wireless
voice calls enable work crews to maintain real-time communications with managers while working
in remote or rural areas where wireline communications could be expensive and unreliable if
available.  Wireless land mobile operations maximize the reliability of real-time exchanges of
information in various settings and conditions and are not tied to a specific location.90  Omaha
Public Power District states that real-time communications are crucial because they enable
maintenance workers to communicate and coordinate their efforts for quick restoration of
power.91
Emergency Calls/Mutual Aid/Interoperability.  This mode of communication also allows for
optimum use of safety procedures while maximizing the efficiency of operations in situations
where serious injury has occurred or loss of life or property is imminent.  Utility providers require
reliable real-time communications with law enforcement, fire department, and emergency services
in situations dictating emergency response. The utilities industry’s transmission and distribution
networks will become increasingly diversified with the onset of deregulation.   Reliable
communications with adjacent utilities is crucial if adjustments to energy transmission and
92  DTE at 2.
93  USATFR at 5.
94  UTC at 25.
95  USATFR at 7.
3-9
distribution load requirements caused by growing consumer demand are to be made in a timely
manner.  DTE states that the mobile radio system is the only means of communications for
overhead line crews attempting to render mutual assistance to other utilities during adverse
weather situations such as hurricanes, tornados, or ice storms.92
Interconnect.93  In nearly all field activities, utility personnel need to communicate with
supervisors, engineers, contractors, consultants and others via land line telephones from the field
(e.g., managers without access to LMR or SMR units).  “Telephone interconnect” patches radio
calls to land lines through command consoles.  They provide real-time communications between
various utilities work crews and managers.
Data Requirements
The primary goal of energy providers engaged in the exploration, production, distribution,
and storage of energy is the efficient, reliable, and safe management of that resource.  Producers,
suppliers, and distributors of electricity, water, nuclear power, steam, and petroleum-based energy
use various data collection and management systems to accurately align energy supply with
consumer demand, which in turn lowers costs while enhancing reliability.  These data collection
and management systems also enable energy providers to comply with numerous state and federal
regulations.94   Energy providers depend on wireless data communications applications to
monitor, control, and repair enormous production and distribution networks that extend between
densely populated urban areas and rural, remote areas that are not easily accessed by repair
personnel.  The use of these systems (e.g., MAS and POFS systems) enable managers to dispatch
field personnel more efficiently.  Deregulation also necessitates the use of wireless data
communications if energy suppliers and distributors in various sectors are to maintain reliable real-
time communications in a competitive environment.  Listed below are some of the major data
collection and management systems used by the industry to efficiently monitor and manage energy
resources.
Telemetry/Protective Relaying.95  The energy utility industry uses wireless data telemetry
systems to monitor and control electrical distribution systems and pipelines for natural gas,
petroleum, steam, and water.  Electrical distribution systems utilize these data links to trip circuit
breakers when power faults or short circuits occur. They also utilize these systems to control the
load level that generation facilities have to provide during peak demands.  Suppliers are able to
direct resources to consumers with much greater precision and efficiency by utilizing  data
collection and analysis, precision load forecasting, long-term power purchase contracts, pro-active
96  Itron, Inc. (Itron) at 3.
97  DTE at 2.
98  API at 6.
99  Itron at 1.
3-10
load management and control, demand-side management programs and incentives, dynamic rate
structures, and conservation programs.96  The pipeline systems utilize similar techniques for the
purposes of controlling valves to reroute or inhibit the flow of materials in the event of a failure of
a section in a pipeline network.
SCADA.  SCADA systems are generally computer-controlled radio communications links that
allow a user to control and monitor power generation, storage and distribution systems without
having to deploy staff where the equipment is located.   These systems generally operate using
MAS in the 900 MHz band, point-to-point microwave systems in the 2 GHz, 6 GHz, and 11 GHz
bands, and unlicenced spread spectrum in the 2 GHz and 5 GHz bands.  As modern utility systems
have increased in complexity, SCADA systems have become critical components of their
command and control infrastructure.  These systems help to automate tasks like opening and
closing circuit breakers, monitoring system stability, and monitoring alarms for overload
conditions.  Additionally, they are used for monitoring and controlling pumping stations and other
critical components of water networks.  Information supplied by DTE indicates that direct radio
control of its remote substations, gas compressor stations, and pole top switches allows for
prompt customer service and restoration of service.97  The API indicates that petroleum, natural
gas, and energy distribution industries have increasingly relied upon MAS assignments from the
900 MHz band for the operation of SCADA systems as their command and control infrastructures
grow.  These systems involve two-way traffic that requires paired channels, allowing a master
station to monitor and control the status of a multitude of measurements and tolerance limits at
wellheads, compressor stations, and valves, thereby eliminating requirements for constant manual
surveillance.  SCADA systems are deployed in production fields and along pipelines to monitor
and adjust a variety of operating parameters, such as temperature, pressure level, and volume.
These monitoring functions are crucial in satisfying safety and environmental objectives while also
maintaining an acceptable level of production.98
AMR.  All energy providers use some form of wireless technology to monitor and transmit usage
data from utility meters to utility databases in real time.  Accumulation of real time data gives a
utility company the ability to develop a new portfolio of dynamic rate structures and incentive
programs, real-time pricing packages, and interruptible rates that can be targeted to specific
customers to significantly improve load management and reduce peak demand.99  This is generally
accomplished with a mobile system or a fixed network.  The mobile system employs a handheld
unit or a van-mounted unit, which polls consumer meters (typically with a licensed frequency) and
“wakes” the meter unit.  The remote meter unit then sends metering data back to the mobile unit
(generally on an unlicensed frequency).  This record of energy consumption is segregated into
100  Load Report at 47.
101  CMP at 5.
102  National Rural Telecommunications Cooperative (NRTC) at 7.  NRTC is a non-profit cooperative
consisting of 705 rural electric cooperatives, 128 rural telephone cooperatives, and 189 independent rural
telephone companies located throughout 48 states and its mission is to provide telecommunications technologies
and services to rural America.  NRTC at 2.
103  Id.
104  Itron at  6.
105  Itron Report at 4.
106  Id.
3-11
adjustable time frames (typically a month) and set to correspond to “on-peak” and “off-peak”
prices.100  The fixed networks generally use a pair of licensed frequencies.  These systems operate
in a manner similar to the mobile system except that there are numerous “mini-master” stations
deployed to interrogate meters.  Central Maine Power Company (CMP), an electric utility
servicing central and southern Maine, states: “[u]tilities are also increasingly relying on wireless
communications to obtain accurate customer profile information.  Utilities now seek to read
customer meters daily and to gather a wide range of information that ensures the efficient
generation of electricity. Automated meter reading (AMR) and electronic meter reading (EMR)
have flourished in recent years to meet this need. Collection and assimilation of these vast
quantities of data are essential to the core functions of utility facilities.”101
The energy industry considers AMR systems to be less expensive than wireline systems
because they require only the initial investment for radio equipment that has a long life span.102 
Wireline systems require a dedicated land line for each AMR unit.103  Furthermore, Itron
attributed the following as beneficial use of AMR:  automation of costly “off-cycle reads”
associated with beginning-and-end-of-service transactions, a reduced number of erroneous
readings, the ability of customers to monitor or make changes to their equipment from a remote
location using wireless sensor devices, no degradation of service because of weather, the
elimination of dangerous access situations, and automatic outage notification.104  
Energy theft pertaining to metering and meter reading is another issue confronting energy
providers, regulators, and consumers that can be addressed with AMR technology.105  Industry
groups and analysts estimate that energy theft in the United States is between 0.5 percent and 3.5
percent of annual gross revenues.106  In the late 1990s, U.S. electricity revenues were
107  Id.
108  Id.
109  Itron Report at 4.
110  A DS-3 link is equivalent to one TV channel, 28 T1 circuits, 762 voice channels, or 45 Mb/s.
111  U.S. Department of Commerce, National Telecommunications and Information Administration, Staff
Study, U.S. National Spectrum Requirements/Projections and Trends (Mar. 1995) at 69.
3-12
approximately $280 billion per year.107  However, electricity theft was estimated to be between $1
billion to $10 billion annually, and that does not include theft of natural gas.108
Meter tampering is not only costly to consumers, but theft of electricity and natural gas
service also causes significant public safety issues.  For instance, a consumer tampering with a gas
meter could cause a meter to leak, increasing the risk of an explosion.  Tampering with an electric
meter poses the risk of electrocution or other serious injury.  Technology is currently available
and in use that is capable of automatically detecting meter tampering.  This could provide a
crucial asset in efforts to improve public safety and deter energy theft.109 
WIRE-BASED AND COMMERCIAL SERVICES
In most instances, wire-based services are leased from commercial providers because of
the high cost of components (e.g., installation costs, maintenance and repair costs, etc.). 
Although some media, such as fiber optic cables, have shown a high capacity for relaying data,
they also have distinct disadvantages when utilized by energy providers.  Each wire-based or
commercial medium and its feasibility is discussed below.  For an overview of the advantages and
disadvantages of wire-based and commercial services go to Table 3-1.  This table was derived
from comments in response to the RFC.
Fiber Optic
In some instances, fiber optic networks can be a robust alternative to the use of spectrum-
dependent equipment, such as point-to-point microwave or MAS.  “A single fiber can carry 2,400
megabits per second (Mb/s) of data (48 DS-3 Circuits110); the maximum capacity of a commercial
microwave channel is 135 Mb/s (three DS-3 circuits).”111  Fiber can be used instead of spectrum-
dependent equipment to process voice and data information, such as land mobile voice, SCADA
and AMR between meter devices and main offices.
112  OPPD at 9.
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Table 3-1
Summary of Commercial Services as Indicated by Commenters
Wire Based or
Commercial Service
Disadvantages
Advantages
Fiber Optic
Limited coverage area in rural and remote areas
Expensive components
Difficult to install in remote, rural or inhospitable
areas
“Right-of-way” land rights must be obtained
Very susceptible to damage
No priority of service for public safety agencies &
utilities
Channel capacity
Beneficial for network
redundancy
Power Line Carrier
Limited coverage area in rural and remote areas
Susceptible to damage
Interference
Low channel capacity
Pre-existing network
Commercial
Telephone
Limited coverage area in rural and remote areas
Susceptible to damage
Dependent on reliable power supply
Low channel capacity
Requires complicated design scheme
No priority of service for public safety agencies &
utilities
Pre-existing network
Commercial Wireless
Telephone
Limited coverage area in rural and remote areas
Complexity of dealing with multiple carriers
Frequent network saturation
Long restoration time when outages occur
No priority of service for public safety agencies &
utilities
Pre-existing network
Cellular Digital Packet
Data
Limited coverage area in rural and remote areas
Longer implementation time
Complexity of dealing with multiple carriers
Frequent network saturation
Long restoration time when outages occur
No priority of service for public safety agencies &
utilities
Pre-existing network
To lay fiber, a utility needs to acquire the right-of-way to the land, which can be
particularly difficult if the terrain is uninhabited or the fiber needs to traverse a waterway or
ravine.  As a result, it is often much more expensive to lay fiber for long distances than it is to use
spectrum-dependent equipment such as a MAS.112
113  Data Flow Systems, Inc. (DFS) at 12.
114  UTC at 29.
115  API at 22.
116  A transmission facility providing greater than 45 Mbps (T3).  Harry Newton, Newton’s Telecom
Dictionary, (1996) at 113.
117  UTC's Power Line Telecommunications Forum was established in 1998 as a neutral platform where
utilities, manufacturers, service providers, consultants and potential users of power line products and services can
work together as equal partners to determine the scope, viability, and benefits for power line telecommunications
services in the United States. The Forum consists of three committees: business applications, technical, and
regulatory.
118  UTC homepage at <http://www.utc.org/?v2_group=0&p=187>.
119  Load Report at 50.
3-14
DFS states that there is also the problem of service interruptions.  Like other land lines,
fiber optic cables are susceptible to damage by careless construction workers, unaware
homeowners and a multitude of natural events such as thunderstorms, ice storms, tornadoes,
hurricanes and floods.113  Baltimore Gas & Electric uses fiber optic routes in redundant
configurations with microwave point-to-point systems.114  It should be noted that fiber optic
networks are also installed along various pipeline networks by the administrative and operational
centers of the oil and gas industry to forward data received from remote locations to various field
offices.  However, the API stated in its comments:
some pipeline companies have deployed private fiber optic networks along their
rights-of-way.  However, with some notable exceptions, most pipeline companies
have been reluctant to deploy fiber optic networks because of operational
concerns.  The principle concern with such deployment is twofold: operating and
maintaining fiber networks could interfere with “core business” pipeline
operations; and, communications may be lost at the most inopportune time, such as
when a high-pressure pipe bursts and destroys the fiber optic cable at the same
time.115
Power Line Carrier (PLC)
PLCs send communications signals over pre-existing power line networks.  This
technology transmits information using broadband communications.116  The UTC Power Line
Telecommunications Forum117 has identified technical hurdles that include signal-to-noise ratio,
interference, bypasses of transformers, segmentation of the feeder and various safety and
procedural considerations.118  The primary advantage to using PLCs is the pre-existing
communications network.119  The BPA has indicated several disadvantages restricting the use of
120  Landon Letter, in BPA Attachment at 7
121  Id.
122  BPA at 7.
123  The basic forms of existing PCS include cordless telephone, one-way paging and various cellular
services than enable customers maintain service between cell sites and the public switched telephone network.
124  Load Report at 53.
3-15
PLCs alternatives to wireless technologies:
(1) [t]he communication channels travel on the same power line that it is to
relay/switch out for protection and does not provide the required reliability.  This
decreases the power transmission system reliability for many applications.  (2) The
noise on the communication channels is high for many applications and does not
provide the required reliability.  (3) The amount of communication channels is
restricted to low capacities.  BPA requires larger amounts of channel capacity for
its existing and future operation and does not provide the required reliability.  (4)
Future expansion is restricted in channel capacity and application requirements. 
(5) Future improvement of this technology is required for BPA’s reliability.120
Commercial Telephone Lines
Commercial telephone has been used for many years by the energy industry.  However,
spectrum dependent communications are considered to be much more reliable.  DTE states that
disadvantages to use of commercial telephone lines include high leasing costs and circuit failure
during adverse weather conditions.121  BPA indicates that technical restrictions include the high
noise volume on communication channels (which cause real time controls to be unreliable when
outages occur), the complicated design schemes of substation environments, and restricted low
channel capacity.122
Commercial Wireless Telephones
Energy providers are among more than 95 million users of cellular telephones on a routine
basis.  This number will continue to grow rapidly as cell phone carriers acquire more RF
spectrum, increase their coverage area and implement new service such as PCS123 which features
wireless Internet access in addition to processing voice and data information.124  However, energy
providers contend that the major obstacles to increase use and reliance on this medium include
unreliability due to limited coverage areas and frequent system saturation during peak hours and
crisis situations.   In supplemental comments for this report, Cinergy emphasizes that the events of
the  September 11, 2001, terrorist attacks illustrated how quickly a commercial wireless network
could become completely saturated:
125  Cinergy Supp. at 13.
126  CMP at 4.
127  Id.
128  Id.
129  Id.
130  Id.
3-16
After the attacks occurred, Consolidated Edison (“Con Ed”), electric, gas and
steam utility for lower Manhattan, had to respond quickly to the crisis. 
Fortunately, Con Ed was able to rely on its own private internal communications
system because it otherwise would not have been able to rely on a commercial
carrier.  The commercial wireless providers were inundated with calls from their
customers immediately after the attacks.  Telephone and wireless traffic “surged by
as much as 400 percent above normal levels.”  This resulted in commercial wireless
systems being overwhelmed.  This was particularly true in Manhattan where
Verizon stated that close to 100% [sic] of its wireless calls in lower Manhattan
were blocked and failed to get through.  As a result of the congestion, wireless
companies asked their customers to use the phones only if it was an emergency. 
Not only was wireless service in New York and Washington, DC affected by the
events of September 11th, wireless users nationwide got busy signals for much of
the day.  Utilities cannot depend upon commercial wireless providers for their
telecommunications needs because the commercial wireless provider cannot
guarantee that a utility would have service during an emergency.125  
CMP indicates that a major ice storm during the winter of 1998 accentuated the
shortcomings of commercial cellular service in a crisis situation.126  In the aftermath of the storm,
CMP tried using public cellular networks to dispatch out-of-state crews working in Maine.127  But
other energy providers were also relying on cellular telephones to repair damage from the
storm.128  Both the wireline and cellular telephone networks were deluged and could not be relied
upon to dispatch repair crews.129  CMP further states that a lack of wireless communications
capability in emergency situations is unacceptable; as a consequence, private internal wireless
networks are needed for the provision of reliable, safe electric service.130  There is no priority of
service afforded to public safety agencies and energy providers when a commercial wireless
network becomes saturated or a major service disruption occurs.  Commercial service providers
operate on a “first come, first serve basis.”  Neither are they subject to state and federal
requirements for restoration of service as is frequently the case with energy providers.
131  USATFR at 9.
132  Id.
133  UTC at 1.
134  Id.
135  Supra note 5.
136  See API at 2 -7; CMP at 1-2; Cinergy Corporation (Cinergy) at 2; Delmarva Power & Light Company
and Atlantic City Electric Company (DPLC &ACE) at 2; DTE at 1; Dominion Resources Services, Inc (Dominion)
at 1-2; FPL & GPU at 1-3; NRTC at 4; NMPC at 2-3; NAES at 1; OPPD at 2-4; SCANA Corporation (SCANA) at
2-4; UTC at 8 and Williams Gas Pipeline (WGP) at 3.
3-17
Cellular Digital Packet Data (CDPD)131
CDPD is a commercial wireless data service that uses the cellular network to provide
packet data capabilities.  It uses a data format similar to Internet communications while dividing
data into packets that are transmitted over the cellular network.  Data is processed utilizing 30
kHz voice channels in the 800 MHz cellular band, which are subordinate to voice transmissions. 
When a voice transmission is initiated, the data is rerouted to another channel.132  CDPD is also
subject to the same disadvantages attributed to commercial cellular voice service.
SUMMARY OF SPECTRUM AND SYSTEMS CURRENTLY USED
Reliable energy service is easily taken for granted.  Whether we flip a switch or pump
gasoline, the energy industry is able to provide these resources on demand in part due to the
expansive nature of their infrastructure.  Infrastructure that includes transmission lines, water
pumps, railroads or electric substations, requires maintenance, remote control, monitoring, and
repair.133  Whether an entity is in the electric, natural gas, petroleum, nuclear, delivery,
transmission, storage, or renewable energy business, the overriding similarity between these
companies is their telecommunications requirements.134
In the first and second question of NTIA’s RFC, NTIA asked how much spectrum is
presently available and in which spectrum bands and radio services the energy industry operates
radio communications equipment, respectively?135  As a whole, the energy industry uses
frequencies anywhere from 25 MHz to 25 GHz.136  Within this range, companies use point-to-
point microwave systems, shared Industrial/Business Pool, and systems in VHF and UHF.  Table
3-2, on page 3-19, illustrates the frequency bands and applications the energy industry utilizes in
their daily operations.  These bands are used by systems that are needed to maintain radio
communications
137  See generally API at 3, CMP at 2, DPLC and ACE at 3, DTE at 2, FPL and GPU at 3, NMPC at 2-3,
OPPD at 2, WGP at 4.
138  Cinergy at 2.
139  API at 5.  See also 18 C.F.R. § 284.13(c)(1).
140  API at 7, 10.
141  Supra note 5.
142  See API at 2-7, CMP at 2, Cinergy at 2, DPLC and ACE at 2, DTE at 2, Dominion at 2, FPL and GPU
at 3, NRTC at 3-5, NMPC at 2-3, OPPD at 2, SCANA at 2-3, UTC at 11-17, and WGP at 3.
3-18
throughout all stages of the exploration, production, distribution, maintenance, and restoration
processes of energy companies.137
Specifically, one commenter, Cinergy, indicated that they used “spectrum-dependent
equipment for two way radios, private paging, electric and gas distribution system control and
data acquisition, generation control, generation scheduling and dispatch, electric system
protective relaying, mobile data to field service trucks, electrical feeder lockout alarms, meter
reading, phone service, and data network communications.”138  There was insufficient information
from the commenters or coordinators to determine how much spectrum is available or used in the
frequency bands in Table 3-2.
According to industry comments, the pipeline companies have a growing need for these
communication systems to be compliant with Federal Energy Regulatory Commission regulations
that require companies to electronically disseminate an index of all their company transportation
and storage customers under contract as of that date on the first business day of each calendar
quarter.139  API stated its use of radio systems is for its public safety support and emergency
response roles, as well as for protection of the environment.140
The third question NTIA asked was what kinds of radio equipment were being used?141 
Commenters informed NTIA that various systems were used including Private Land Mobile Radio
Service or two way radios, fixed microwave services, supervisory control and data acquisition
(SCADA) systems, spread spectrum, data service and Multiple Address System (MAS).142
TECHNICAL ISSUES
Energy providers share RF spectrum with a broad range of users of spectrum in the
Industrial/Business Pool of frequencies, as outlined by FCC regulations.  They are afforded no
specified separation rights or other interference protection.  Some of these frequencies are used 
3-19
Table 3-2
Summary of Bands and Applications Currently Used by The Energy Industry
Based on Input from Commenters
Frequency Bands
Applications
Frequency Bands
Applications
25-50 MHz
PLMRS
932-941 MHz
SCADA
48-50 MHz
Voice Dispatch,
Alarms From
Remote Stations
935-940 MHz
PLMRS
50 MHz
PLMRS, MAS
941-944 MHz
POFS
150-170 MHz
Voice Dispatch,
Load Management
Control
952/956/959 MHz
MAS
150-175 MHz
Alarms From
Remote Substations,
PLMRS
952-960 MHz
POFS
220 MHz
SCADA
956, 959 MHz
Mobile Meter
450-470 MHz
Voice Dispatch,
Mobile Data,
PLMRS
1.427-1.432 GHz
AMR
470-512 MHz
PLMRS
1.85-1.99 GHz
POFS
800 MHz
Voice Dispatch,
Mobile Data
Terminals, Trunked
PLMRS
2 GHz
PLMRS, POFS,
MAS, SCADA,
Point-to-Point
Microwave, Spread
Spectrum
806-821 MHz
PLMRS
2.4 GHz
Point-to-Point MW
821-824 MHz
PLMRS
5 GHz
Spread Spectrum
851-866 MHz
PLMRS
5.8 GHz
Point-to-Point MW
866-899 MHz
PLMRS
5.9-6.4 GHz
Point-to-Point MW
896-901 MHz
PLMRS
6 GHz
Point-to-Point MW
900 MHz
 MAS
6.5-6.8 GHz
Point-to-Point MW
Microwave
902-928 MHz
SCADA
6.525-6.875 GHz
POFS
928-929 MHz
POFS
11 GHz
Point-to-PointMW
928/932/941 MHz
MAS
18-19 GHz
Point-to-Point MW
928-952 MHz
SCADA
21.2-23.6 GHz
POFS
929-930 MHz
PLMRS
24.25-25.25 GHz
POFS
932-935 MHz
POFS
143  Supra note 25.
144  UTC at 18.
145  Id.
146  Id.
147  Cinergy at 12.
148  API at 6.
3-20
on a shared basis.143  UTC specifically states, “[Private Land Mobile Radio] PLMR users continue
to experience increasing levels of ambient noise on various frequency bands, as well as harmful
interference.”144  UTC further states that notwithstanding the FCC’s public safety radio services
determination for critical infrastructure, “. . . adjacent channel interference remains a threat to the
safe and reliable operation of utilities and pipelines.”145  In addition, UTC informed NTIA that,
“[a]s private wireless spectrum grows more congested, there are increasing reports of harmful
interference to energy activities, including critical power restoration.”146  Cinergy seconds this
assertion by stating, “Interference also can occur even if the utility is allowed to operate on a
frequency exclusively, and adjacent licensees and co-channel licensees are obeying all FCC
regulations.”147  In addition, API states that:
 . . . [p]rimarily because of the lack of adequate licensed spectrum, oil and gas
companies also currently operate private internal communications systems utilizing
frequencies on an unlicensed basis in the 902-928 MHz band, the 2.4 GHz band
(2400-2483.5 MHz) and the 5.8 GHz band (5725-5850 MHz).  These systems are
governed by certain technical and service requirements under Part 15 of the FCC’s
Rules and Regulations which, among other things, require users to accept any
interference that may occur from other radio systems (licensed or unlicensed) or
industrial, scientific or medical systems (including microwave ovens and
microwave lighting systems).  A growing problem for systems that operate in the
unlicensed bands is the raising of the noise floor.  That is, as more and more
unlicensed systems are deployed within close geographical proximity to one
another, the systems become less and less reliable because the aggregation of
transmitted energy begins to reduce each system’s ability to discriminate its desired
signal from the noise.  Notwithstanding the noise problem, however, such
unlicensed systems are being used to provide high speed data transfer capabilities
through direct sequence spread spectrum systems and lower speed data acquisition
in frequency hopping, MAS-like, point-to-multipoint systems.  Although
unlicensed spectrum helps to meet the oil and gas industry’s need for radio
spectrum, the unlicensed bands cannot be relied upon to meet the system integrity
and communications reliability requirements demanded by the public safety aspects
of oil and gas pipeline operations.148