DAVID D. RINES202.416.6751

DRINES@LERMANSENTER.COM

December 18, 2019

Marlene H. Dortch, SecretaryFederal Communications Commission445 12th Street, SWWashington, DC 20554

Re: Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, WC Docket No. 17-84; Unlicensed Use of the 6 GHz Band, ET Docket No. 18-295; Notice of Ex Parte Presentation

Dear Ms. Dortch:

On December 17, 2019, David Rines, Counsel to Xcel Energy Services Inc. (“Xcel Energy”) and Tom Breuckman of Xcel Energy, together with Eric Langley, Counsel to Southern Company, Allen Bell of Georgia Power Company, Kasey Chow and Alan McIntyre of Southern Communications Services, Inc. d/b/a Southern Linc, and J. Wells Ellenberg of Southern Company (collectively, “Southern”), spoke via conference call with William Davenport, Legal Advisor to Commissioner Starks.

The purpose of this conference call was to discuss the Commission’s efforts to promote the deployment of infrastructure for 5G and other wireless services. In addition, Southern briefly discussed the Commission’s consideration of unlicensed use of the 6 GHz band.

Wireless Colocation on Utility-owned Street Lights

Southern and Xcel Energy described how certain electric utilities, such as Xcel Energy and Southern’s electric utility subsidiaries, Georgia Power and Alabama Power, have voluntarily implemented programs and partnerships to proactively facilitate the colocation of small cells and other wireless communications facilities on utility-owned street lights. Southern and Xcel Energy explained how these programs foster innovation and cooperation that result in faster and more efficient deployment of 5G and other wireless infrastructure than could be achieved through regulation.

Marlene Dortch, SecretaryDecember 18, 2019Page 2

Southern and Xcel Energy provided Mr. Davenport with a set of photographs of some utility-owned street lights, as well as examples of successful conversions of Georgia Power and Xcel Energy street lights into small cell sites. A copy of this presentation is included with this filing.

Southern and Xcel Energy discussed some of the complex practical and logistical issues involved in colocating wireless facilities on street lights. As an initial matter, street lights may be installed, owned, and maintained by a variety of different entities, and utilities are only one of many options available to public and private customers for street lights and street light service. Utilities install and maintain street lights only at the request of a street light customer; it is the lighting customer that determines not only the location but also the type and nature of the pole to be installed, based on the customer’s own lighting and aesthetic requirements, and the customer may also require a street light to be removed. The utility must defer to the contractual rights of its street light customer, and therefore does not have sole discretion with respect to street light colocation issues. Accordingly, converting a street light into a small cell site is a situation that requires cooperation among multiple stakeholders: the street light customer, the municipality (which may be the customer), the electric utility, and the wireless provider.

In addition, the vast majority of street lights are not structurally capable of supporting wireless communications facilities, thus requiring the complete replacement of the street light structure in order to accommodate wireless colocation. The replacement of an existing street light with a new one that can accommodate a small cell while maintaining the lighting customer’s aesthetic requirements requires cooperation and innovation to ensure that the needs and interests of all stakeholders are met.

The street light colocation programs implemented by Xcel Energy, Georgia Power, Alabama Power, and other utilities are already proving effective in accelerating wireless deployment, and many more utilities are observing closely as they consider similar programsbased on their own unique local conditions and considerations. Southern and Xcel Energy therefore urge the Commission to focus on ways to encourage and incentivize voluntary programs and partnerships such as these, which provide the most effective way to accelerate the availability of 5G and other advanced wireless services to the public.

Unlicensed Use of the 6 GHz Band

Southern briefly discussed the Commission’s consideration of unlicensed use of the 6 GHz band. At this point, the issues under consideration can be grouped in three categories: (1) unlicensed outdoor operation; (2) unlicensed indoor operation; and (3) unlicensed operation of “very low power” (“VLP”) devices. Southern urged the use of Automated Frequency Coordination (“AFC”) for both outdoor and indoor operations in order to ensure the full protection of incumbent licensed operations in the 6 GHz band and urged further analysis of the potential impact of unlicensed VLP operations. Southern stated its appreciation of the Commission’s focus on reaching an outcome based on a sound and thorough technical analysis

Marlene Dortch, SecretaryDecember 18, 2019Page 3

and again urged that the Commission require rigorous field-testing of any AFC systems that may be proposed in order to ensure that the AFC system will work as planned.

Pursuant to Section 1.1206 of the Commission’s Rules, this letter is being filed electronically via the Electronic Comment Filing System in the above-referenced proceedings.

Respectfully submitted,

/s/ David D. RinesDavid D. RinesCounsel to Xcel Energy Services Inc.

Encl.

cc: William Davenport

ENHANCING 5G DEPLOYMENT THROUGH SMALL CELL COLOCATION ON STREETLIGHTS

This is a distribution pole with a light. This is not what we mean by a “streetlight.”

DISTRIBUTION POLES WITH LIGHTS ARE NOT THE ISSUE

STREETLIGHTS

Georgia Power streetlight near downtown Atlanta, Georgia Georgia Power decorative area lighting in downtown Atlanta, Georgia

STREETLIGHTS

Xcel Energy street light (15-ft fiberglass) Xcel Energy street light (15-ft fiberglass)

STREETLIGHTS

Xcel Energy street light (30-ft fiberglass) Xcel Energy street light (30-ft aluminum)

SUCCESSFUL STREETLIGHTCOLOCATION

CONVERSION OF A GEORGIA POWER STREETLIGHT TO A SMALL CELL SITE

SUCCESSFUL STREETLIGHTCOLOCATION

CONVERSION OF AN XCEL ENERGY STREET LIGHT TO A SMALL CELL SITE

(NOTE ORIGINAL STREET LIGHTS IN BACKGROUND)

SUCCESSFUL STREETLIGHTCOLOCATION

CONVERSION OF AN XCEL ENERGY STREET LIGHT TO A SMALL CELL SITE

(NOTE ORIGINAL STREET LIGHT IN BACKGROUND)