Spectrum for Smart Grid

Policy Recommendations Enabling Current and Future Applications

Brett Kilbourne
Utilities Telecom Council Washington, DC USA Brett.kilbourne@utc.org

Klaus Bender
Utilities Telecom Council Washington, DC USA Klaus.bender@utc.org storms and other natural disasters. Finally, these systems must be cost-effective or they will not be approved by state regulators. The following paragraphs describe these criteria in more detail.1 Coverage is a key criterion. Utility infrastructure, including transmission facilities, is often located in rural and remote areas, where commercial services are not available or would be cost-prohibitive. In order to reach these areas, utilities will often use wireless solutions, which can be deployed cost-effectively. These systems can be microwave or land mobile, depending on whether utilities need fixed pointto-point or mobile wide area communications. These systems will also use spectrum that provides favorable propagation characteristics, tailored to geographic conditions. Utilities need spectrum below 2 GHz to support both wide-area land mobile radio coverage and long-range point-to-point microwave capacity. Lower frequency ranges are necessary for smart grid applications at the edge of the network in order for signals to penetrate through walls and overcome other line-of-sight (LOS) issues, such as foliage and rain fade. That way, quality, cost-effective communications coverage is ensured across a utilitys entire service territory. Capacity is also critical. The networks must have sufficient capacity to ensure effective communications. The narrowband communications systems that utilities have used to support voice communications simply wont support additional demand from certain new applications, such as video surveillance and broadband mobile data. However, these systems do not need to be designed to the same capacity requirements as commercial systems. There must be a balance between capacity and costeffectiveness. Latency is increasingly important too. Tele-protection systems that utilities use to isolate faults on the grid must operate within milliseconds. Otherwise these faults can have more widespread effects. This is just one example of a utility application that requires low latency. The number of low latency applications will only increase in the future, as utilities
1

AbstractUtilities need access to spectrum to meet their communications needs to support smart grid applications, and federal policy should enable utilities to share spectrum with public safety and with federal government users. Keywords-smart grid; spectrum; wireless; utilities.

I.

INTRODUCTION AND OVERVIEW

Utilities need access to an allocation of 30 MHz of licensed spectrum in a frequency range below 2 GHz to promote the development and deployment of smart grid. Currently, utilities operate extensive private internal communications to support the safe, efficient and reliable delivery of essential services to the public at large. However, these communications systems are not suited to support the demands of smart grid. Many systems lack sufficient bandwidth and/or coverage to support two-way communications to the customer premises, and to the extent that utilities wireless systems do support such two-way broadband communications, these systems are either subject to interference from other users or there is insufficient additional channels available to expand those systems in terms of coverage or capacity. As such, there is a spectrum crisis for utility communications, and the Federal government should make an additional 30 MHz of spectrum available below 2 GHz to support smart grid and other utility communications. This paper recommends that Federal policymakers take immediate action to promote utility access to spectrum by enabling utilities to share 700 MHz public safety spectrum and to share federal spectrum, such as the 1800-1830 MHz band, which is currently allocated in Canada for utility communications. II. DEMAND SIDE ANALYSIS

A. Private internal networks provide the reliability that utilities need. Utilities have demanding standards for communications. They need networks that provide ubiquitous coverage across their entire service territories. They need sufficient capacity to support mission-critical communications, particularly during emergencies. These mission-critical communications must also meet low latency and high security requirements. Of course, utilities need communications that are always available, and they may deploy multiple systems to ensure communications are available when needed. Their communications networks must also be able to survive extreme conditions, including wind and ice, so that communications are maintained during

For a complete description of utility communications networks and their requirements, See e.g. Comments of the American Electric Power Company, Inc.; Comments of DTE Energy, Inc., Comments of Florida Power & Light Company, Comments of The Sempra Energy Utilities, Comments of Southern California Edison and Comments of Southern Company filed in FCC Docket No. GN 09-51 (Oct. 2, 2009).

978-1-4244-6511-8/10/$26.00 2010 IEEE

578

begin to deploy smart grid and manage their transmission and distribution infrastructure in real-time, monitoring and controlling potentially millions of devices producing multimegabits of data. Security is essential for mission-critical communications. While utilities have always focused on network security, new North American Electric Reliability Corporation Critical Infrastructure Protection (NERC CIP) requirements are now in effect, requiring utilities to address physical and cyber vulnerabilities, including those on communications networks that are critical assets that affect the bulk power system. As such, private internal networks must remain secure in order to protect the integrity of utility infrastructure against internal and external threats. Of course, communications must be available when needed. That is why utilities will often deploy multiple technical solutions to ensure communications availability. Back-up and redundant networks are necessary to route traffic, when systems go down. Similarly, utilities operate in demanding environments, such as underground conduit, where communications can be subject to interference. Again, utilities must design their systems to ensure communications are available in these demanding environments. As such, availability is a major criterion for utility network design. Survivability of the communications infrastructure is fundamental. That is why utilities design their wireless networks with extended battery back-up and/or generators to ensure that they continue to operate when the power goes out. That is also why their handsets are ruggedized and antenna towers are reinforced to withstand damage from manmade and natural incidents. These networks are built to last and can be used for decades, as was proven in the aftermath of Hurricane Katrina and the other Gulf Coast hurricanes of 2005. 2 Bottom line: cost is another key factor. While safety and integrity of communications must be maintained, utility networks must be cost-effective. Investments must be
Utility communications networks proved their survivability in the aftermath of Hurricane Katrina and other Gulf Coast hurricanes during 2005. While commercial systems were out for a week or more after the hurricane, SouthernLINC Wireless (a subsidiary of Southern Company) reported that 98% of its cell sites were back in operation within three days. It also reported that SouthernLINC wireless contributed greatly to public safety and restoration of public services, including electric service in the affected states. See generally Letter from Jeffrey L. Sheldon, Counsel to Southern Company, to Nick Sinai, Energy and Environment Director at FCC, FCC Docket No. 0951 (filed Feb. 5, 2010). See also Final Report of the Commissions Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks (Katrina Panel Final Report) at http://www.fcc.gov/pshs/docs/advisory/hkip/karrp.pdf (stating that Mississippi Power relied on its only viable form of communication its internal system Southern Linc Wireless. This system was designed with considerable redundancy and proved reliable despite suffering catastrophic damage. Within three days, the system was functioning at nearly 100 percent.) And see Hurricanes of 2005: Performance of Gulf Coast Critical Infrastructure Communications Networks, United Telecom Council, November 2005 at http://www.utc.org/fileshare/files/3/Research/white_papers/2005_-_UTC__HURRICANES_OF_2005_PERFORMANCE_OF_GULF_COAST_CIC_N E.
2

prudently incurred; otherwise state regulators will disallow recovery of utility costs. B. Wireless is a key component of private internal networks. Utilities rely on wireless communications for their private internal networks. Wireless technologies provide wide area coverage. They are scalable, and can be deployed and redeployed quickly and cost-effectively as needed with minimal sunk cost and risk of stranded investment. Of course, wireless also can be used for mobile as well as fixed services. Finally, new wireless technologies can increasingly support higher bandwidth applications, making them an attractive alternative to wireline technologies. As described above, coverage is a key criterion for utilities, and they often will use wireless technologies because they provide wide area coverage. In fact, utilities have been using wireless technology solutions for decades, long before there were commercial wireless networks. As such, wireless technologies are fundamental to utilities private internal networks. Another reason that utilities use wireless is that it can be cost-effectively and quickly deployed. It avoids the substantial cost and delay associated with deploying wireline solutions in underground or overhead facilities, such as poles, ducts and conduit. Wireless systems are also used as a quick means of providing connectivity to areas where higher bandwidth wireline solutions are deployed later. Wireless solutions can be directed in order to provide targeted connectivity to insular areas, and they can be reused to avoid stranded investment. Finally, new wireless technologies, such as wireless mesh and WiMAX, are increasingly used by utilities for highbandwidth applications for local and neighborhood-area communications, in urban, suburban and rural areas. These new technologies are being used to support advanced metering and to enable remote monitoring of substations. C. Utilities spectrum needs are increasing. Utilities are increasingly dependent on their wireless communications networks to support the safe, reliable and efficient delivery of essential services to the public at large. They use wireless for voice services, such as routine dispatch and emergency response, and the bandwidth requirements for these services is increasing. At the same time, they use wireless for data services, including smart grid, and the bandwidth requirements for these services is increasing even more. Utilities have estimated that smart grid alone will require that their communications systems be capable of supporting throughput speeds of 3-10 megabits per second (mbps).3 These estimates are based on the combined throughput requirements of various smart grid applications, such as Automated Metering Infrastructure (AMI), Supervisory Control and Data Acquisition (SCADA) and demand response. Some of these applications (e.g. AMI) will require more capacity than others,
3

See e.g. Comments of American Electric Power, DTE Energy, Florida Power & Light, and Sempra Energy, supra, n 1 (stating generally that 3-10 mbps throughput is required to support smart grid).

579

due to the sheer numbers of devices involved. Others will require more capacity, because of the nature of the application itself (e.g. video surveillance) or because of the criticality of the communications (e.g. low-latency, security and Quality of Service (QoS) requirements). These estimates must also account for future communications needs, as well. For example, plug-in-electric vehicles and sources of distributed generation, such as solar and wind, will place additional demands on the grid, which must also be controlled using smart grid technologies. These estimates must also account for peak load scenarios, such as emergency restoration, when additional capacity will be required. Finally, different utilities will take different approaches towards implementing smart grid, and as such communications requirements may vary between utilities, depending on the applications that they use, as well as other factors, including the size of each utility and the number of customers they serve. These various new and evolving smart grid applications, coupled with increasing demand for voice and other data services will require access to 30 MHz of additional licensed spectrum to satisfy current and future communications requirements for smart grid and other utility applications.4 This spectrum will primarily be used for wide-area land mobile radio and point-to-point microwave communications at the distribution layer of the network. While utilities will use fiber and other alternative technologies, such as power line carrier (PLC) and unlicensed wireless (e.g. mesh networks), these alternatives are limited and will mainly be used at the backbone layer of the network, as well as the home area network layer. Finally, utilities will need access to additional spectrum, because existing spectrum is insufficient to meet their current and future functional requirements, as more fully described below. III. SUPPLY SIDE ANALYSIS Utility wireless networks have evolved over time. Starting in the 1920s, utilities began using the HF bands below 54 MHz, and gradually migrated as others did in the 1960s and 1970s into higher frequency ranges that supported higher fidelity communications. Today, utilities operate in a variety of frequency bands for both land mobile and microwave communications. These wireless systems provide highly reliable communications in order to support essential utility
See Comments of the Utilities Telecom Council in response to the U.S. Department of Energy Request for Information on Implementing the National Broadband Plan by Studying the Communications Requirements of Electric Utilities To Inform Federal Smart Grid Policy, filed July 12, 2010 at http://www.gc.energy.gov/1592.htm (explaining the case for access to 30 MHz of licensed spectrum in a frequency range below 2 GHz). Note that this estimate is consistent with the work that is currently ongoing within OpenSG and National Institute of Standards and Technology (NIST), which are developing a more granular analysis of the various smart grid use cases and their functional requirements. See OpenSG smart grid use cases that have been submitted to the NIST at http://osgug.ucaiug.org/UtiliComm/Shared%20Documents/Interim_Release_4 /SG%20Network%20System%20Requirements%20Specification%20v4.0.xls (estimating payload requirements for certain smart grid applications).
4

services and protect the safety of field crews and the public that relies on their services. However, as these systems have evolved over time, they operate in various bands and use different technologies, which may or may not interoperate with other utilities or with public safety agencies with whom they respond during emergencies. Moreover, access to spectrum for these systems has been limited, and utilities have been forced to share many of these bands with other users or relocate from these bands to make way for commercial services. This has created problems of interference and congestion in existing bands that utilities use for critical infrastructure communications, and it has limited the expansion of these systems to meet increasing demands. The following sections describe the bands of operations and these issues in closer detail. A. Utilities lack access to suitable spectrum to support smart grid in existing bands. Utilities only have access to about 30 MHz of spectrum for land mobile communications. This includes 6.95 MHz in the VHF band, 11.85 MHz in the UHF band, 6 MHz in the 800 MHz band and 5 MHz in the 900 MHz band. No new allocations of licensed spectrum have been made available since the 900 MHz band was allocated in 1986.5 In 1992, the FCC began refarming the VHF and UHF spectrum between 150-512 MHz, in order to make more efficient use of the spectrum. The FCC decided to consolidate the 20 different radio service pools, including the Power Radio Service that was home to utilities, into two pools (Public Safety and Industrial/Business). As a result, utilities were forced to share spectrum with a variety of other business and industrial radio users in the Industrial Business pool. At the same time, the FCC also adopted a policy of competitive coordination, which allowed any certified coordinator (except a coordinator for the Public Safety pool) to coordinate frequencies in the consolidated Industrial/Business pool.6 The consolidation of the frequency pools caused interference and spectrum congestion for utilities, as applicants became eligible for licensing frequencies that were formerly allocated in one of the 20 service pools, including the Power Radio Service pool. Competitive coordination compounded the problem because there were no established standards for coordinating facilities. As a result, a coordinator may coordinate a facility that overlaps the radio frequency service contour of another licensed facility, which can cause interference between neighboring licensees. And because coordinators compete with each other, there are incentives for coordinators to coordinate facilities in close proximity with each other. The only effective way to protect against interference in the VHF and UHF bands is to implement trunking, which entitles the licensee to co- and adjacent channel interference protections, under the FCC rules.
5

Comments of the Enterprise Wireless Association in FCC Docket No. GN 09-51 at 2 (June 8, 2009). See Replacement of Part 90 by Part 88 to Revise the Private Land Mobile Radio Services and Modify the Policies Governing Them, Report and Order and Further Notice of Proposed Rule Making, PR Docket No. 92-235, 10 FCC Rcd 10076 (1995) (Refarming Report and Order).

580

Utilities also share spectrum with other types of radio users in the 800 MHz and 900 MHz bands. Unlike the VHF and UHF bands, there are co- and adjacent channel separation requirements for the coordination of frequencies in these bands, which protects against interference. Utilities migrated to these bands to get away from the interference and congestion in the VHF and UHF channels, but even these bands have become plagued by congestion and interference, mainly due to commercial specialized mobile radio (SMR) operators, such as Sprint Nextel. Currently, the 800 MHz band is undergoing rebanding to protect public safety operations against interference from these SMR operations. While this rebanding process is underway, there is a freeze on the licensing of additional 800 MHz channels by utilities and others. Similarly, there is a freeze on the licensing of additional 900 MHz channels, which will only be lifted after part of the 800 MHz rebanding process is completed on a region-by-region basis.7 As a result of the spectrum issues in the land mobile bands, there is no spectrum home for utilities, and they must operate disparate systems using disparate equipment on narrowband channels that are subject to interference and are, in any event, insufficient to support many smart grid applications and other advanced communications systems. Similarly, utilities have been displaced from microwave spectrum. To make way for Personal Communications Services, Mobile Satellite Services, and Advanced Wireless Services, the FCC required utilities and other incumbent microwave licensees in the 2 GHz band to relocate to comparable facilities in other frequency bands. The relocation of utilities is still ongoing, but many utilities have been moved. While this transition provided reimbursement for utilities costs of relocation, it was nonetheless disruptive to utility operations. 8 Moreover, it meant that more private radio spectrum was lost to commercial services. In addition to relocating utilities out of the 2 GHz band, the Commission also disrupted utility microwave operations in the 900 MHz MAS (multiple address system) channels, when it instituted a freeze on licensing while it considered auctioning portions of the spectrum. These MAS are heavily used for SCADA and other mission-critical microwave communications. While the freeze was ultimately lifted, and only a portion of the frequencies were auctioned, it took years to resolve. The relocation of utility microwave systems out of the 2 GHz band and the MAS freeze further illustrate the extent to which utilities are losing access to spectrum that is being auctioned for commercial services.

B. Spectrum auctions and unlicensed spectrum do not represent alternatives for utilities to acquire suitable spectrum to support all smart grid applications. While utilities could buy licensed spectrum at auction, as a practical matter they have had little success. First, they compete with commercial service providers with deep pockets and that can pass along their spectrum auction costs to their customers. Second, their service territories do not conform to the geographic licenses that are auctioned. Third, build-out requirements for some of these licenses may be too difficult for a utility to meet. Finally, equipment designed for some of these largely commercial spectrum auctions is unsuitable for use in utility environments. To be sure, some utilities have acquired spectrum at auction, but they have been the exception rather than the rule. As an alternative to licensed spectrum, utilities have turned to unlicensed radio solutions to meet their needs, which provide significantly greater bandwidth than is available on their narrowband licensed radio systems. In addition to greater bandwidth, unlicensed provides more regulatory flexibility to deploy systems. Many utilities have used unlicensed radio for metering, using mesh or point-to-point communications over spread spectrum and/or OFDM techniques. While unlicensed solutions have filled utilities immediate needs, utilities report that they have run into interference problems with WISPs and with the ambient noise floor in certain areas. And they expect that interference will increase, as more use is made of the 900 MHz ISM bands, and the lightly-licensed 3.65 GHz bands. As such, utilities need more licensed spectrum (with a low noise floor) to future-proof their bandwidth needs. IV. RECOMMENDATIONS

A. Share 700 MHz Public Safety spectrum to capitalize on synergies between public safety and utilities. Utilities and public safety have similar communications requirements and are compatible users of spectrum. Their missions are similar and in fact they do need to coordinate with each other during emergencies. As such, it would make sense for utilities to share spectrum with public safety and there are several examples of shared systems between public safety and utilities.9 The 700 MHz public safety spectrum is suited for sharing between utilities and public safety to meet their mutual needs. For utilities the spectrum provides sufficient bandwidth to support the throughput speeds that they would need to support voice applications, such as emergency response and to support data applications, such as smart grid. For public safety, utilities could help build-out the networks by leveraging utility infrastructure and other resources. For both, a shared system would promote interoperability, which is particularly important during emergency response. And it would expand the potential market for equipment manufacturers, encouraging market
9 See e.g. Connecting America: The National Broadband Plan, FCC, at 253 (citing Nevada Shared Radio System and SouthernLINC as examples of shared systems between utilities and public safety.)

See Improving Public Safety Communications in the 800 MHz Band, Report and Order, Fifth Report and Order, Fourth Memorandum Opinion and Order, and Order, WT Docket 02-55 (FCC 04-168), rel. Aug. 6, 2004.

See e.g. Amendment of Part 2 of the Commissions Rules to Allocate Spectrum Below 3 GHz for Mobile and Fixed Services to Support the Introduction of New Advanced Wireless Services, including Third Generation Wireless Systems, ET Docket No. 00-258, IB Docket No. 99-81, Third Report and Order, Third Notice of Proposed Rulemaking and Second Memorandum Opinion and Order, 18 FCC Rcd 2223 (2003) (AWS Third R&O, Third NPRM, and Second MO&O).

581

entry, equipment availability and economies of scale, thereby reducing equipment costs and promoting innovation. B. Share Federal spectrum to promote national policy goals and promote efficient use of spectrum. Utilities and Federal government both depend on private internal networks for reliable communications where commercial systems are unavailable or unsuitable. Thus, their communications networks are both designed with reliability in mind. Moreover, there is Federal spectrum below 2 GHz that is uniquely suited for sharing with utilities. Specifically, the 1800-1830 MHz band, which is allocated for Federal use in the U.S., is allocated for utility purposes in Canada. 10 This spectrum would provide sufficient bandwidth to support smart grid and other advanced communications systems. The sharing of this band would promote interoperability among utilities in the U.S. and Canada, and it could promote interoperability with power marketing administrations (PMAs), such as Tennessee Valley Authority and Bonneville Power Administration. Moreover, the sharing of this spectrum would advance the Federal governments larger policy goals of promoting smart grid for energy independence, environmental quality and national security. Because Federal spectrum is classified, it is uncertain whether the 1800-1830 MHz can be shared. Even if it is not suited for sharing, in order to advance the national policy goal of promoting smart grid, the Federal government should look for other bands of similar bandwidth that would be available for sharing. REFERENCES Regulations and other examples related to utilities and public safety communications: 1. 49 USCA Sec. 60102(a)(1)(B) of the Pipeline Safety Act requires gas pipelines to establish emergency plans that include adequate means of communications with fire, police and other public officials for the emergency shutdown and pressure reduction in any section of a pipeline; reliable and secure private communications are essential to meet these requirements FEMA Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Plants requires utilities to have reliable primary and backup means of communications and the preparation of an emergency plan to include use of these communications between a nuclear facility and the utilitys near-site emergency operations facilities, state and local emergency operations centers, and radiological monitoring teams.

3.

FEMA specifies in its Functional Criteria for Emergency Response Facilities that reliable primary and backup means of communications are necessary between the Emergency Operations Facility, Technical Support Center, Nuclear Regulatory Commission and state and local emergency operations centers; reliability of these communications systems has to be demonstrated under emergency conditions. Many state public service commissions require utilities to respond to reports of downed electric lines and gas leakages within 30 minutes; by law, police and fire personnel cannot enter unsafe or burning buildings until the electricity shut off - this requires interference free communications capabilities with emergency field crews (can cite interference from NY limousine service on 16 separate occasions which prevented central dispatch from contacting field crews in response to fire emergencies). Susan Lau, A Day Unlike Any Other: ConEd Maintains Critical Communications Recovery, UTC Journal, December 2002. Letter to Michael Chertoff, Secretary U.S. Department of Homeland Security, et al. from Haley Barbour, Chairman of the Southern Governors Association, dated May 15, 2007 (recommending 1) a nationwide spectrum allocation for utilities and other emergency services; 2) priority access for utilities and others in the public safety community on existing spectrum below 1 GHz in times of emergency; 3) a review regulations that discourage utilities from building shared systems to support public safety communications and recommend any actions that may be required to eliminate those regulations that discourage the development of shared systems by utilities that promote interoperable public safety communications ). Final Report of the Commissions Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks (Katrina Panel Final Report) at http://www.fcc.gov/pshs/docs/advisory/hkip/karrp.pd f

4.

5.

6.

7.

2.

10 See http://www.ic.gc.ca/epic/site/smtgst.nsf/en/sf08971e.html for more information on this proceeding.

582