On June 6, the FCC issued an Order granting permission to Progeny LMS, LLC to begin commercial operation of its multi-lateral location and monitoring service (M-LMS) in the 900 MHz spectrum band. Progeny’s system is expected to improve on existing location services like GPS by providing information on height – it can tell what floor a person is on in a high rise, for instance. In addition to commercial applications, the service is intended for Enhanced 911 (E-911), which provides 911 operators with the physical location of the caller. The company has received support from public safety agencies nationwide.
However, the utility industry is in an uproar. Petitions for reconsideration were filed by seven entities last week, including Silver Spring Networks and the Part 15 Coalition (which includes companies like GE Digital Energy, Itron, Landis+Gyr, the UTC, and others).
The hubbub stems from the likelihood of interference with already deployed utility advanced metering infrastructure (AMI) and supervisory control and data acquisition (SCADA) systems, which operate in unlicensed 900 MHz spectrum. Progeny uses licensed spectrum, and in granting the company permission to begin commercial operations, the commission made it clear that it placed Progeny’s business case (and potential E-911 benefits) ahead of the concerns raised by the utility industry. In fact, the Part 15 system operators and devices are at the bottom of the heap when it comes to sharing spectrum in the lower 900 MHz band.
Unlicensed system operators are expected to make nice and engineer their systems so that signals can find alternate routes around interference – and for the most part, that’s what existing users have done. The concern over Progeny’s system is that it is a high power system—30W—whereas most of the utility applications like AMI and SCADA are low power (from 1-3W). Where interference develops, existing systems may have to be reconfigured, physically in some cases, and/or more hops may be required for a signal to reach its destination, increasing the latency of the data messages.
Safety Above All
Petitions for reconsideration point out that Progeny’s field tests – which were a requirement of the approval – didn’t test a wide-enough variety of devices. In particular, they didn’t test against distribution SCADA systems that are dependent upon low latency. Instead they tested only against AMI systems, which are less time-sensitive. In its order, however, the FCC “concluded that the purpose of the field test is to promote the coexistence of M-LMS and unlicensed operations in the band by ‘minimizing’– not eliminating – the potential for M-LMS interference to Part 15 operations.”
The Order does require Progeny to work with other system operators to alleviate interference and also to report interference complaints to the Commission. It also required Progeny to set up a reporting website for interference issues and to report launched markets, which it did June 21.
A review of that list reveals that Progeny is already operational in 40 major markets covering two-thirds of the U.S. population. “Operational” means that it has deployed equipment to cover at least one-third of the market.
Even before the order was adopted, PG&E filed ex parte comments with the commission describing SCADA interference that occurred at one of its sites in San Francisco last fall. Based on how widely the Progeny system has already been deployed, such problems could soon arise in other cities.
The LMS spectrum license was originally established by the FCC in the mid-1990s, well before the widespread deployment of smart grid technology. But in applying license conditions established nearly 20 years ago in its review of the Progeny situation, the commission appears to have been more motivated by the post-9/11 reverence for public safety than by smart energy goals. In its petition for reconsideration, Silver Spring Networks asserts that “the Commission’s substantive rebalancing of the governing policies was peculiarly myopic, preferring a disappointingly modest improvement in E-911 services to a number of other important public policies, such as the reliability of critical infrastructure [and], amelioration of anthropogenic climate change.”