With four weeks until LMR systems operating below 512 MHz are required to utilize 12.5 kHz channels instead of the traditional 25 kHz channels, it is clear that a significant percentage of affected networks will not be updated in time to comply with the FCC's narrowbanding deadline.

"I think the commission's enforcement staff is going to be very busy," Ralph Haller, general manager of the frequency-coordination operation for the International Municipal Signal Association/International Association of Fire Chiefs (IMSA/IAFC) and the Forestry Conservation Communications Association (FCCA) partnership, said during an interview with Urgent Communications. "I don't know what the commission is going to do. I think they're going to have a big task ahead of them to really ferret out people who are not in compliance."

Various industry sources have estimated that 20-35% of affected licensees will not be in compliance with the FCC's narrowband mandate, which becomes effective on Jan. 1, as the agency reminded in a public notice issued on Friday. Haller said that he does not have data regarding the number of potential licensees that will not meet the narrowbanding mandate, but he said the 20-35% estimate is probably "not a bad guess."

Haller added that he is seeing a lot of last-minute applications from entities trying to modify their licenses to narrowband their systems to 12.5 kHz channels, but that does not necessarily mean that they have changed their systems appropriately.

"The only thing we know for sure is whether someone has narrowband emissions on the license or not," he said. "Obviously, if it has narrowband only on the license, then you can assume they're operating narrowband. If it's got both narrowband and wideband, you have to assume they're narrowband, but there's just no way to tell if they really are, short of contacting them or the FCC actually monitoring them."

POLL: How should the FCC instruct frequency coordinators to protect licensees that do not meet the Jan. 1, 2013, deadline to narrowband their LMR systems and do not have a waiver or pending waiver request?

Indeed, the FCC has indicated that it plans to enforce the narrowbanding mandate, but the agency plans only to act in situations where complaints are filed. In addition, frequency coordinators will begin treating systems as if they are narrowbanded as of Feb. 1.

"Up until Feb. 1, if there is wideband on the license, we're still going to protect it as wideband," Haller said. "But, on Feb. 1, it's going to be protected as narrowband and … on the assumption that they are still active, they'll be protected as narrowband."

RELATED: FCC plans to enforce UHF/VHF narrowbanding mandate

In addition, licensees will be continue to be protected if they operate in the T-Band, have received a waiver from the FCC, or have a waiver request pending before the commission.

Because of the late date, Haller said that his frequency coordinators no longer are guaranteeing that applications filed now will be processed in time to meet the FCC's narrowbanding deadline, but he encourages all licensees to apply as soon as possible.

"Better late than never," Haller said, noting that he does not believe FCC enforcement will begin taking action on Jan. 2.