The Telecommunications Industry Association (TIA) sought clarification of the Federal Communications Commission’s Order waiving the Jan. 1, 2013, deadline for private land mobile radio (PLMR) licensees in the 470-512 MHz band (T-Band) to migrate to narrowband (12.5 kHz or narrower) technology, specifically requesting that the commission clarify that it is waiving the ban on 25 kHz technologies in radios for use in the 470-512 MHz band (T-Band) portion of the Part 90 VHF/UHF in certification applications filed on or after Jan. 1, 2011. Should public-safety entities be unable to replace communications equipment during the interim transition period for the T-Band, these licensees face a dangerous prospect.

The Commission’s statement in Footnote 19 of the T-Band Order, while providing that permissive changes may be possible in some circumstances for existing certifications during the transitioning of the T-Band, does not appear to account for the possibility that “wideband,” i.e. 25 kHz technology radios, may not be available in the interim time period. If licensees are unable to replace equipment that requires new certifications, they are at risk of reduced equipment availability and capabilities required for continued protection of the public.