Before the
Federal Communications Commission
Washington, D.C. 20554
Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550- ) REPLY COMMENTS OF EXELON CORPORATION
Exelon Corporation (“Exelon”) hereby submits its Reply Comments in the above- referenced Docket.The Exelon companies – ComEd, PECO Energy, and Baltimore Gas and Electric (“BGE”) – provide critical infrastructure energy delivery services to approximately 6.6 million customers. ComEd serves more than 3.8 million electricity customers in northern Illinois, including Chicago. PECO Energy serves about 1.6 million electric customers and 494,000 natural gas customers in southeastern Pennsylvania, including Philadelphia. BGE serves about 1.2 million electric customers and more than 650,000 natural gas customers in Exelon submits these Reply Comments regarding the potential effect of the Commission’s proposals on energy delivery operations and supports the comments submitted in response to the Commission’s Notice of Proposed Rulemaking in this Docket by the Utilities Telecom Council, the Edison Electric Institute, and the National Rural Electric Cooperative Association (collectively, “the Associations”). 1 Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550-3650 MHz Band, GN Docket No. 12-354, Notice of Proposed Rulemaking and Order, 27 FCC Rcd 15594 (Dec. 12, 2012); Order, DA 13-298 (Feb. 28, 2013) (extending reply comments to April 5, 2013). Specifically, Exelon supports the Commission’s proposals and the comments submitted by the Associations on the following items: • The proposal to allocate 100 MHz of spectrum for a new Citizens Broadband Service at 3550-3650 MHz (“the 3.5 GHz Band”). • The availability of a new Citizens Broadband Service with a Priority Access tier in which utilities would be eligible to access the 3.5 GHz Band in the Priority • The creation of a General Authorized Access (“GAA”) tier and an Incumbent Access tier, under the Commission’s proposed multi-tiered framework. • The creation of a multi-tiered, license-by-rule licensing framework for authorizing users in the 3.5 GHz Band, and the establishment of a Spectrum Access System • The proposal to combine the 3.5 GHz Band with the 3650-3700 MHz Band (“the The 3550-3650 MHz frequency band is adjacent to dedicated, licensed spectrum currently used for energy delivery smart grid technology (“Smart Grid”). Exelon recommends that the Commission create a new Citizens Broadband Service in the 3550-3650 MHz frequency band and allocate a Priority Access tier for utilities as an alternative to licensed spectrum. Exelon believes that Citizens Broadband and Priority Access operations should be permitted so that utilities’ existing services can be enhanced, bandwidth limitations can be addressed, and new services can be utilized. Exelon believes that Priority Access users would be able to achieve a meaningful level of service in areas where Priority Access is authorized, given the restrictions that the Commission has proposed to protect Incumbent Access tier users. The Commission would permit such Priority Access operations only in areas where Citizens Broadband operations would not cause interference to incumbent operations and where no interference would be expected from incumbents (Priority Access Zones). Priority Access tier users would be required to register in the SAS database, use mitigation techniques, and take steps to avoid causing interference to incumbents, such as the use of small cells that have relatively short range and low power levels. However, similar to the Associations’ position, Exelon does not believe that Priority Access tier operations will be primarily used for indoor operations, and opposes any regulations that would restrict Priority Access to indoor use only. Utilities will likely use this band for a variety of fixed operations, such as Smart Grid, as well as mobile applications. As such, issues including antenna gain and height are important for those operations. Therefore, the Commission should provide rules for those small cell characteristics and installations. Exelon supports the Commission’s proposal to include a GAA tier for a variety of consumer applications that would only operate in GAA and Priority Access Zones. Exelon agrees with the Associations’ view that this would make efficient use of the band and that the same equipment could be used in both the GAA and Priority Access tiers, thereby promoting economies of scale in equipment supply. Exelon also supports the Commission’s proposals to protect against interference from GAA operations to Priority Access tier and Incumbent Access tier operations. Like the Associations, Exelon believes the Commission should ensure that GAA users incorporate interference mitigation capabilities in their equipment and require them to register with the SAS database. Exelon fully agrees with the Commission’s approach (in addition to protecting Priority Access and Incumbent Access tier users as outlined above) not to provide GAA with any expectation of interference protection from either Priority Access tier or Incumbent Access tier operations. Exelon supports allowing GAA users to use at least 50 MHz of the 3.5 GHz Band in Priority Access Zones (depending on whether Priority Access services are in active use or not at a given location). Like the Associations, Exelon believes that spectrally separating GAA from Priority Access operations by segmenting the band in Priority Access Zones would help to guard against congestion as well as interference. Exelon agrees with the Associations that the Commission, if it allows GAA users to use 100% of the 3.5 GHz Band in Priority Access Zones in areas where there are no active Priority Access services, should clarify that GAA must return to the 50% of the spectrum that is allocated for GAA use when Priority Access use commences in that area. Exelon also supports the Commission’s proposal to combine the 3.5 GHz Band with the 3650-3700 MHz Band (the 3.65 GHz Band). Specifically, Exelon supports the Commission’s technical proposal to adopt a license-by-rule, SAS database approach for the combined band. Electric utilities and other critical infrastructure industries use the 3.65 GHz Band for advanced metering applications and would potentially benefit by having greater licensing flexibility and greater capacity. Electric utilities have encountered challenges finding available spectrum in parts of the 3.65 GHz Band. Opening up the 3.5 GHz Band would alleviate some of those constraints, and economies of scale could drive down the price of equipment for both bands. In addition, combining the 3.65 GHz Band with the 3.5 GHz Band presents an opportunity to clean up the database of licenses that are currently registered in the 3.65 GHz Band and incorporate that data into the SAS. There are some operations that have not properly registered with the database and there are also some licensees that have registered but are not in operation. These are just some of the benefits that could result from combining the 3.65 GHz Band with the 3.5 Unlike telecommunication service providers, electric utilities do not earn revenue from radio spectrum. Electric utilities cannot compete with Verizon, AT&T and other telecommunication service providers for spectrum nor can they justify paying for spectrum beyond license fees. Additionally, electric utilities’ spectrum needs are not as demanding as those of the telecommunication service providers; electric utilities tend to be local rather than wide area spectrum users. However, the reliability requirements of electric utility communications, especially during times of disasters, are very high. Electric utilities need spectrum that they can easily obtain at a reasonable cost to use in conjunction with operating the power system. Electric utilities are considered critical infrastructure and, as such, require reliable communication based monitoring and control, often known as Smart Grid, to meet Respectfully submitted, /s/ Sharon M. Bertelsen Sharon M. Bertelsen, Esq. Ballard Spahr LLP 201 South Main Street, Suite 800 Salt Lake City, UT 84111 (801) 517-6833 John C. Halderman, Esq. Exelon Corporation 2301 Market Street Philadelphia, PA 19103 Counsel to Exelon Corporation



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