As evidenced by the number of VHF and UHF public safety and industrial/business entities in the FCC ULS database that are still only licensed for 25 kHz operation, there are still many of you who are scrambling to get into compliance with the FCC narrowbanding mandate.
The Utilities Telecom Council will help its members through any outstanding narrowbanding compliance and implementation issues at its May 15-17 UTC Telecom 2013 Conference in Houston, Texas. I will be speaking at the UTC panel session “Narrowbanding: I Missed the Deadline. Now What?” Please join me on May 16, from 7:30 – 8:30 AM in Room 320AB at the George R. Brown Convention Center. The panel is moderated by Don Vasek, UTC Director of Spectrum Services, and joining me is Richard Donaldson, IT PMO Manager at Duke Energy.
The panel will address Duke Energy’s lessons learned and pitfalls to avoid in completing your system narrowbanding, possible FCC audit and enforcement considerations, frequency coordinator treatment of remaining non-compliant systems, and recommendations for resolving non-compliance and project completion issues. I will mainly address narrowband impact on manufacturers, what it means to you the licensee, and what to do if you still need to buy 25 kHz capable radios or multi-mode radios that have some exceptions to the FCC mandate.
In addition, there is a second regulatory-related panel session in which I am also speaking aimed at those of you interested in gaining access to 700 MHz public safety broadband communications. I invite you to attend “Mission Critical Readiness: Are You Prepared for the Public Safety Broadband Network?” on May 16, from 2:30 – 3:45 PM also in Room 320AB. Joining me on the panel is my Motorola colleague Jared Pickrell, Director of Engineering, Strategic Products, and John Chaney of Harris County Texas. Harris County is currently implementing an early deployment of the 700 MHz nationwide PSBN in the Harris County (Houston) area, and John will share what they are doing on network sharing. I will address last year’s legislation that enables critical infrastructure access, how the PSBN can leverage utilities infrastructure assets, plus how utilities can promote partnership opportunities. Jared will provide valuable insight on LTE and broadband applications for utilities, the energy worker of the future and multi-service, multi-use priority and access.
Al Ittner is Senior Manager of Spectrum Strategy at Motorola Solutions, Inc.
Now that the January 1stFCC narrowband deadline has passed, I am busier than ever answering process-related questions for our customers, sales teams and channel partners. Below are the most pressing questions being asked. I covered some of these in my last “At the Wire!” blog, but they are important to reiterate.
1. What if I am out of compliance and still operating at 25 kHz wideband efficiency on Part 90 150-174 MHz or 421-470 MHz channels mandated to be narrowbanded by now? Immediately file a waiver request with the FCC to request authorization to operate beyond the deadline. This will at least get you on the record with the Commission that you missed the narrowbanding deadline but are looking to do the right thing in asking its permission to temporarily continue operating for a limited time. And don’t forget to check your current license. If you are still licensed at 25 kHz-only operation, immediately submit a license modification application to include a 12.5 kHz emission designator.
2. What if I need additional 25 kHz radios that operate on these channels? FCC rules don’t prohibit manufacturers and equipment providers from marketing and selling 25 kHz capable equipment out of remaining inventory after the deadline, as long as that equipment is manufactured or imported prior to Jan. 1, 2013. However, if you need manufacturers to build additional 25 kHz-capable equipment for you this year, the FCC requires you, the licensee, to first file a manufacturing waiver request with the FCC. The FCC will not consider such manufacturing waiver requests unless you have already filed and been granted a waiver to continue operating in 25 kHz beyond the deadline (see above). Once the FCC grants that manufacturing waiver request, Motorola and others can manufacture or import such equipment specifically for you.
3. Can I continue to order 25 kHz radios if I am operating LMR radios on channels other than these? The following are specifically excluded from the FCC narrowbanding mandate:
Canada and other foreign countries
U.S. federal government agencies
Licensees operating LMR on Part 80, 74, 22, 15, or any other non-Part 90 channels in the 150-174 MHz and 421-470 MHz bands
Licensees operating in T-Band (470-512 MHz band in 11 major metro areas)
Licensees that have been granted a waiver by the FCC to temporarily continue operating at 25 kHz efficiency on the narrowband mandated bands beyond the January 1, 2013 deadline (see above Question 2 for ordering additional 25 kHz equipment)
Licensees operating paging on the following paging-only channels: Public safety (152.0075, 157.450), Business/Industrial (152.480, 157.740, 158.460, 462.750, 462.775, 462.800, 462.825, 462.850, 462.875, 462.900, 462.925)
Note that radios operating on channels that include both the narrowband-mandated and exception channels must still narrowband on the mandated Part 90 channels. Contact your Motorola account manager or Motorola channel partner who can assist you in properly ordering radio equipment for these and all other frequencies.
4. Can radio service continue to repair my 25 kHz radios? The FCC has not prohibited service shops from repairing 25 kHz-capable equipment after the deadline. Motorola and independent service shops can continue to repair such equipment and return the repaired radio to the licensee with 25 kHz capability. However, Motorola is advising customers that such equipment may not be operated in 25 kHz mode on Part 90 channels after Jan. 1, 2013 deadline, without an FCC-granted waiver or exception.
5. How will the FCC know whether I am narrowband compliant or not? The Enforcement Bureau will use a number of means to determine non-compliance, including:
a. The Land Mobile Communications Council (LMCC), which represents all of the authorized frequency coordinators, notified the FCC that as of Feb. 1, 2013 all coordinators will consider any non-compliant 25 kHz systems as if they were operating at 12.5 kHz analog systems for purposes of identifying frequency assignments in the VHF and UHF bands. Coordinators will report such non-compliant 25 kHz systems to the Enforcement Bureau. In addition, these remaining 25 kHz systems will likely interfere with new systems operating on adjacent 12.5 kHz channels, resulting in notifications by the new system licensees to the Enforcement Bureau for resolution.
b. The Enforcement Bureau will conduct an audit of licensee that still report a 25 kHz-only emission designator to verify that you are (a) still in operation, and (b) operating in compliance with narrowbanding rules. Inactive licenses will be terminated and non-compliant licenses will be subject to enforcement actions, which have been detailed in several previous blogs.
c. At this time, the FCC does not require existing licensees to provide a certification to show that they are operating at least 12.5 kHz technology on 12.5 kHz channels, or 12.5 kHz equivalent technology on 25 kHz channels (such as four voice paths in a 25 kHz channel or data radios with minimum data rates of 19.2 kHz on a 25 kHz channel). It may do so in the near future, and at license renewals or modifications.
For the past few years one of the key two-way radio programs has been VHF and UHF narrowbanding. I have provided much guidance through a series of blogs on how to Narrowband as the deadline grew nearer. But now it is time to begin talking about life after narrowbanding.
IWCE 2013 runs from March 11-15 in Las Vegas, and I will be speaking at a panel session “Life After Narrowbanding: Was It Worth the Effort?” I’d like to personally invite you to join me on Thursday, March 14, from 9:45-11 a.m. PST for the session. I will be addressing how manufacturers are impacted by and complying with the FCC narrowbanding mandate, what that means to you the licensee, and what to do if you’re still not narrowband compliant or need to obtain 25 KHz capable radios after the deadline.
In addition to this topic, there are other regulatory-related sessions at IWCE 2013 that I think will be equally engaging. If you are attending IWCE, I invite you to attend these sessions where my fellow Motorola colleagues will be speaking:
Panelists include: David Eierman, Principal Staff Engineer, Spectrum Strategy, Motorola Solutions
Description: Now that T-Band licensees have been given a reprieve from their narrowbanding mandate, they must plan for their equipment future. Learn the most efficient and effective ways to maintain your system until the T-Band auction in nine years.
Panelists include: Sean Taylor, Senior Sales Specialist, LTE, Motorola Solutions
Description: At a 50,000-foot level, examine both the short- and long-term impacts of the migration to LTE technology. Discuss standards development, system design and funding, and how the transition will affect the operation of existing networks.
In addition to these wonderful seminars, I would also like to invite you to stop by the Motorola Solutions booth # 527, on Wednesday, March 13, or Thursday, March 14, where you can speak to our experts and see the latest interoperable technology communications, in-vehicle communications, wearable communications technology, next generation command and control, real-time video and so much more.
I am looking forward to the conference next week - I hope to see you there!
Al Ittner is Senior Manager of Spectrum Strategy at Motorola Solutions, Inc.
Did you ever let your driver's license expire? A few years ago, I spent most of my birthday waiting at the motor vehicle bureau because I had forgotten to renew my license. Instead of enjoying cake with my family, I stood in line waiting to have my picture taken. The mug shot was awful, but the peace of mind was awesome. I didn’t have to worry about being pulled over and getting fined for operating illegally.
If you missed the January 1, 2013 deadline to narrowband your VHF or UHF radio network, you’re now operating with an expired FCC license. If you’re caught, the potential fines are a lot more than you’ll pay for a traffic violation.
Do You Know Why I Pulled You Over?
The FCC will start enforcing the narrowbanding mandate soon. Are you thinking you won’t be caught for operating illegally in the wideband mode? Would you be more inclined to act if you were worried about being pulled over? Here’s what could happen if FCC enforcement bureau personnel were authorized to make traffic stops.
FCC officer: Do you know how wide you were going?
You: I was just keeping up with traffic. Excuse me, did you say how wide?
FCC officer: I clocked you at 25 kHz in a 12.5 kHz zone. What’s the expiration date on you license?
You: November 2013 – it’s still valid.
FCC officer: Not your driver’s license, the FCC license for your radio system
You: Let me check . . . Oh, it looks like it expired on January 1st.
FCC officer: Yes, you’re operating illegally in the wideband mode. I have the authority to fine you up to $16,000 and shut down your radio system.
Excuses Won’t Get You Off the Hook
Have you ever tried to talk your way out of a traffic ticket? The police officer who pulled you over has heard “I was just keeping up with traffic” and “I didn’t know about the law” hundreds of times. If you’re caught driving twice the speed limit, your excuses won’t stop the officer from issuing a citation that could keep you off the road.
Excuses won’t help you convince an FCC enforcement officer to let you off the hook. He or she doesn’t care that your neighbor is still using wideband radios or that you didn’t have time to comply with the 2004 narrowbanding ruling that gave you eight years to update your system. If you’re operating at twice the posted bandwidth, your excuses won’t stop the FCC from initiating action that could take you off the air.
It’s Time to Go Straight – and Narrow
The January 1, 2013 deadline has passed but the requirement to narrowband hasn’t. If you’re still operating in the wideband mode, you should take action now to go straight and narrow. You’ll need to narrowband your system to 12.5 kHz operation by reprogramming or replacing equipment and also get your license modified. Check the narrowbanding resources on the Motorola Solutions website if you need help determining how to upgrade your radios and infrastructure.
You won’t have to wait in line at the DMV to update your radio license. The first step is to go online and file a waiver application to let the FCC know you’re in the process of modifying your radios. If your waiver’s approved, you’ll still have to modify your equipment, but you’ll have permission to operate in the wideband mode a little longer.
So don’t wait until your birthday to update your FCC license. Narrowbanding your system isn’t a piece of cake, but taking action now means you’ll have the peace of mind you can’t be “pulled over” for operating your radio system illegally.
Rick Pollak is a Business Development Manager for Motorola Solutions, Inc.
Now that the FCC narrowbanding deadline is just days away, this could be considered the “last chance” blog.
Unless you have completed or are well into narrowbanding your system to operate in 12.5 kHz efficiency, or you have filed a waiver request with the FCC to temporarily continue operating in 25 kHz efficiency after the 1st of January, there are few options left. Note that as of the January 1st deadline, the FCC requires licensees to not only be properly licensed to include 12.5 kHz or better emission designators, but to also be operating at 12.5 kHz or better efficiency.
If you are still licensed at 25 kHz-only operation, submit a license modification application to the FCC to include 12.5 kHz or better emission designators. The FCC stated that modification applications to show compliance with the narrowbanding mandate should be received by the FCC prior to the January 1st deadline. However, if your modification requires coordination, the FCC further noted that it will not consider you in violation if the application was submitted to the coordinator by the deadline, but not yet submitted to FCC.
If you are still not operating at 12.5 kHz or better efficiency, immediately file a waiver request with the FCC to request operating at 25 kHz beyond the Jan. 1, 2013 deadline for a limited time. As of now, the FCC has not set a date after which it will no longer accept waiver requests.
The most risky choice is to keep doing nothing, continue operating in 25 kHz, and wait until the FCC Enforcement Bureau knocks on your door (more than likely mails you a letter) to tell you that your system is out of compliance. The Public Safety & Homeland Security Bureau and the Wireless Telecommunications Bureau have publicly stated that they will turn over all licenses that are only licensed with a 25 kHz emissions mode to the Enforcement Bureau after the 1st.
The Enforcement Bureau indicated it intends to conduct an audit to verify with the licensees that their systems are still in operation and will likely cancel the rest of the licenses. While it might take a few months to do this, you will find yourself in a position to either confirm that you are indeed operating 25 kHz illegally or ignore the audit letter. Either way, chances are good that your license could get cancelled.
As noted in my previous blog, the Land Mobile Communications Council (LMCC), representing all FCC certified frequency coordinators, agreed that effective February 1, 2013, coordinators will no longer consider non-compliant 25 kHz systems for purposes of identifying frequency assignments for use with LMR systems. Exceptions are 25 kHz systems that have a pending modification application evidencing compliance or a pending or granted waiver request for an extension of the narrowband deadline. The coordinators will inform both the non-compliant 25 kHz system licensees and the new applying 12.5 kHz system licensee that such continued non-compliant 25 kHz use may likely lead to interference. This may likely then involve the Enforcement Bureau for resolution.
On November 30th, the FCC has issued a Public Notice that clarifies a number of open issues and, once again, reiterated the FCC deadline and potential consequences for failing to do so. Clarifications include the following:
The narrowbanding rules do not prohibit the sale after January 1, 2013 of 25 kHz capable Part 90 VHF/UHF equipment as long as it was manufactured or imported prior to that date. Motorola is complying with the FCC recommendation to let customer know that such equipment may not be operated in 25 kHz mode after January 1, 2013 without an FCC granted waiver or exception.
Note that the FCC has still not ruled on Motorola’s request for a limited waiver which requests that the FCC allow manufacturers to continue manufacturing and importing equipment after the January 1st deadline that is 25 kHz capable, but only for licensees that have been granted a waiver or exception by the FCC. Until the FCC approves this limited waiver, Motorola will not be able to manufacture or import radios capable of 25 kHz operation after the deadline, even if customers have been granted a waiver for such operation.
Service shops are not prohibited from repairing 25 kHz capable equipment. Motorola will repair such equipment and return the repaired radio with 25 kHz capability. Again, we are complying with the FCC recommendation to let customer know that such equipment may not be operated in 25 kHz mode after January 1, 2013 without an FCC granted waiver or exception.
The FCC also issued an Order on November 30th that impacts only the 470-512 MHz (T-Band) rules. It allows manufacturers to continue filing applications for FCC certification of radios that are capable of 25 kHz radios operation after the January 1, 2013 deadline. As you will recall, the FCC waived the requirement to narrowband radios in the T-Band and allowed continued operation, manufacture and import of 25 kHz radios. The November 30th Order allows T-Band customers access to the newest radios and features in 25 kHz over the coming years.
The FCC addresses frequently asked questions and additional narrowbanding migration and compliance information at its narrowbanding website http://www.fcc.gov/narrowbanding. The FCC has named following contact points for all narrowbanding questions and instructions:
Public Safety and Homeland Security Bureau (for public safety licensees) Roberto Mussenden 202-418-1428 Roberto.Mussenden@fcc.gov