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By Sandra Wendelken
The Association of Public-Safety Communications Officials (APCO) International asked the FCC to consider modifying its rules, or adopting an expanded waiver policy, to relieve public-safety licensees in the UHF T-band from any obligation to narrowband their existing radio systems.
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Section 6103 of the Middle Class Tax Relief and Job Creation Act of 2012 requires that, within nine years, the FCC reallocate and auction spectrum in the 470 – 512 MHz band used by public-safety and industrial and business (I/B) entities, which will then have two years to relocate from the band. Auction proceeds will be used to pay the cost of the public-safety relocation.
Licensees in the T-band, as well as other portions of the UHF and VHF bands, are also subject to the FCC’s narrowbanding mandate with a Jan. 1, 2013, deadline. “However, the act creates a substantial disincentive for entities to deploy new facilities in the T-band as they would be required to relinquish their radio systems within 11 years,” said an APCO letter to the FCC. “Therefore, a substantial question arises as to whether it is still in the public interest to require public-safety T-band licensees to go through the expensive and disruptive process of converting to narrowband operations.”
APCO officials said they continue to support the narrowbanding rules as a means of improving spectrum efficiency in the UHF and VHF bands. “Some [T-band licensees] may still choose to proceed as part of planned system upgrades, but forcing them to do so provides no meaningful public benefit,” said APCO. “We hope that the commission will give prompt consideration to this important issue.”
For the Los Angeles Regional Interoperable Communications System (LA-RICS) Joint Powers Authority (JPA), the T-band issue, along with comments from National Telecommunications and Information Administration (NTIA) officials earlier this month asking Broadband Technology Opportunity Program (BTOP) grant recipients to hold off on Long Term Evolution (LTE) equipment purchases, have put the project in a holding pattern, said Patrick Mallon, LA-RICS executive director.
The LA-RICS JPA completed the evaluation process for its procurement, which includes mission-critical voice in the UHF T-band and 700 MHz public-safety broadband systems, and held its first meeting with the prevailing vendor. However, based on the NTIA request, the JPA suspended negotiations with the vendor but hopes to restart them.
“We’re in a hold,” Mallon said. “We are evaluating our options before we move forward with our project. We haven’t made a decision yet on how to address the T-band issue.”
The LA-RICS JPA restarted its procurement for LMR and LTE technology last summer because of legal restrictions. Los Angeles County won $154.6 million in BTOP funds to build LA-SafetyNet, a 700 MHz public-safety broadband network extending across all of Los Angeles County. The contract also included a mission-critical voice network to support more than 34,000 first responders and local public-safety officials within the region. The total system price tag has been estimated to be around $600 million.
The city of Chicago, which uses the T-band spectrum for its public-safety communications and is upgrading its UHF radio networks with a $23 million investment, asked the FCC where its system should be moved from UHF T-band channels and how the city should fund the move.
“As the commission can well imagine given the recent experience with the rebanding of the 800 MHz spectrum, the cost of retuning radio networks is quite expensive and the challenges created are quite daunting for public-safety licensees,” said Chicago officials in a letter to the FCC. “Accordingly, the commission is presently positioned to take up these issues and provide necessary guidance to adversely affected licensees.”
Chicago said the UHF T-band spectrum is the only viable spectrum available in the metropolitan area. The channels support first line defense for the citizens within 50 miles of the city through infrastructure for multiple police, fire, supervisory control and data acquisition (SCADA) and a host of other critical operations, while providing a foundation for interoperability throughout the region. “If the fixed network equipment has to be replaced; the cost is close to the $75 million range,” the city said. “If the mobile equipment also needs to be replaced, the cost will skyrocket to the $200 million range.”
“Chicago respectfully requests that the commission address the issues and provide to the city and surrounding areas an advisory opinion that will assist the city in obtaining a greater appreciation for federal policies threatening the city’s public-safety radio systems and its funding,” the letter said.
The Enterprise Wireless Alliance (EWA) said there are 281 I/B entities operating 910 systems employing 7,566 frequency pairs at 410 sites in the UHF T-band spectrum. “A significant majority of these systems are operating on exclusive-use frequency assignments, and a significant majority of these I/B licensees are well on their way toward compliance with the FCC’s narrowbanding requirements,” said EWA. “It is estimated that these system statistics represent hundreds of millions of dollars towards wireless system investments by I/B licensees.”
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