Narrowbanding Brings FCC Processing Delays
Wednesday, March 30, 2011 | Comments
By Wesley Wright
The FCC’s 2013 narrowbanding deadline is quickly approaching, and applicants for FCC radio licenses are already feeling the effects. In December, the FCC’s Wireless Telecommunications Bureau received a substantial number of applications for new and modified private land mobile licenses in the VHF (150 – 174 MHz) and UHF (421 – 512 MHz) bands, seeking authority to operate on narrowband assignments. This influx of applications has caused the commission’s processing time for private land mobile applications to increase significantly during the past few months. The land mobile application increase appears to have extended the processing time for microwave applications as well.
The FCC’s first narrowbanding deadline was Jan. 1, 2011. As of this date, licensees can no longer file applications for new wideband (25 kilohertz) operations or modify existing wideband stations to expand the authorized interference contour. After Jan. 1, 2013, licensees in the VHF and UHF bands must operate on 12.5 kilohertz or narrower channels. As an alternative to these requirements, licensees may employ a technology that satisfies the so-called “data equivalency standard,” requiring a minimum of 4,800 bits per second (bps) per 6.25 kilohertz of channel bandwidth. 
Because reports indicate that as many as two-thirds of impacted licenses still remain without narrowband emission designators, it’s expected that the number of applications will continue to remain high as licensees file applications to narrowband existing private land mobile systems in advance of the 2013 narrowbanding transition deadline.  
Application Nuts and Bolts
Licensees of affected stations that are transitioning to narrower bandwidths must file a modification application to either add a narrowband emission designator or change the wideband emission designator to a narrowband emission designator prior to Jan. 1, 2013.
Not all modification applications for authority to operate on narrowband technology are required to go through frequency coordination. Last year, the FCC released an order amending several provisions of its rules to make it easier for licensees to meet the narrowbanding deadline. For example, licensees are no longer required to submit applications to frequency coordinators if the application seeks only to reduce emissions on the same center channel (such as move from 25- to 12.5-kilohertz bandwidth) or delete an emission designator. Other applications, including those seeking authority to migrate from analog to digital equipment, must still be submitted to a frequency coordinator.
As the license is modified to include the narrowband emission designator, the licensee has no further obligation to notify the commission that the station has met the narrowbanding deadline. Wideband emission designators don’t need to be deleted from licenses prior to Jan. 1, 2013, to demonstrate compliance with the narrowbanding deadline. Instead, absent information to the contrary, stations authorized to operate with both wideband and narrowband emissions prior to Jan. 1, 2013, will initially be presumed to be operating only with narrowband emissions after Jan. 1, 2013.
In addition, adding or changing an emission designator for an existing frequency doesn’t trigger a new construction requirement, so the licensee will not need to file a new construction notification if it only adds narrowband emission designators to existing channels. For stations authorized to operate with a bandwidth exceeding 12.5 kilohertz, the licensee will be required to certify that it is operating narrowband-equivalent equipment that complies with the data equivalency standard. This is necessary because it may not be apparent from a license’s technical parameters whether a 25-kilohertz station is a noncompliant wideband station or a compliant narrowband-equivalent station.
Because tens of thousands of these types of applications are being filed on top of the FCC’s normal workload in a relatively short period of time, application processing times are expected to remain longer than usual through Jan. 1, 2013. Licensees should allow for extended application processing times when planning new land mobile and microwave systems.  
Conditional Temporary Authority
In light of this increased processing time for most applications, applicants should be aware that the commission’s rules permit many private land mobile and microwave systems to begin operating under conditional temporary authority (CTA) while their applications are pending at the FCC. For example, applicants for new and modified land mobile licenses operating on frequencies below 470 MHz are eligible to operate under CTA 10 business days after the application has been filed with the FCC if the following conditions are met:
1. The proposed transmitter site doesn’t require Canadian coordination.
2. Authorization of the proposed station doesn’t require a rule waiver.
3. The proposed station will not significantly affect the environment as defined by 47 CFR § 1.1307.
4. The proposed station or tower structure doesn’t pose a hazard to aviation safety and does not create any FCC antenna clearance issues.
5. The proposed station doesn’t threaten any of the protected sites listed in 47 CFR § 1.924 of the rules.
6. Frequency coordination has been secured or was not required.
Applicants for most new or modified microwave systems may begin operating under CTA if similar conditions are met. The principal difference is that microwave applicants may begin operating under CTA immediately and are not required to wait 10 business days after the application is filed with the FCC. This will provide relief to some, but not all, applicants.
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Wesley K. Wright is an associate at Keller and Heckman. Wright joined Keller and Heckman in 2006 and practices in the areas of telecommunications and transactional law. His telecommunications practice focuses on assisting corporate clients and trade associations with various legal and regulatory matters before the FCC, FAA, courts and state agencies. Contact Wright at

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