The FCC's release in December 2009 of a public notice on narrowbanding provides more clarity to the mandate, but some important issues remain for licensees.

For instance, while the notice makes clear that licensees must narrowband, there is no option to keep wideband equipment and operate on a secondary basis. Licensees that have a 25 kHz bandwidth authorization will be required to file a license modification to add the appropriate narrowband emission designator, or to replace the wideband designator. For these licensees, the FCC will be creating a certification mechanism, which will require licensees to certify narrowband compliance before 2013. For licensees which already have dual emission designators, the commission will assume compliance by the applicable date. This is a little confusing, so it is hoped that there will be some clarification later.

The commission shortly will begin to place special conditions on new, renewed and modified licenses to remind licensees of the deadline. Given the number of impacted licensees that are still unaware of narrowbanding requirements, this is a crucial step.

Recently, questions have arisen as to whether wideband-only repeaters can be modified with third-party kits to meet the narrowbanding requirement. While blanket statements regarding equipment are difficult to come by, the FCC has stated in several situations (and at least one manufacturer has confirmed) that such action may require new type-certification for the equipment.

The notice did not address NPSTC's request for a delay of the 2011 deadline for the manufacture of wide-band equipment and expansion of wideband systems. While the Jan. 1, 2011, deadline does not prohibit the sale of wideband-mode radios (it certainly will take some time to delete stock), the availability of new 25 kHz radios post-2010 is a planning issue for licensees. Thus, in order to have certainty for manufacturers and users, it is important that the commission address these issues promptly.

Meanwhile, I'll try to clear up the confusion about a number of other items that have circulated around the industry, such as:

Channel centers

Licensees are not required to change their existing channel centers when they narrowband their system.

Paging-only channels

The only channels excluded from the narrowbanding requirement are the paging-only channels. This is different than paging on voice channels, which do (presently) have to be narrowbanded. In public safety, there are two paging-only channels that do not require narrowbanding: 152.0075 MHz and 157.450 MHz. I have seen presentations and e-mails stating that 163.250 MHz remains wideband, but this is not accurate.

6.25 kHz mandatory narrowbanding

I have seen presentations and e-mails asserting that licensees must narrowband to 6.25 kHz (or equivalent) equipment by 2017, but this also is inaccurate.

We will be devoting a full six hours at IWCE 2010 in Las Vegas next month (www.iwceexpo.com) to narrowbanding education. Included in our discussion will be issues such as potential system coverage loss, operating in a mixed 12.5/25 kHz mode during a transition, and LMCC coordination procedures. If you are a consultant or system operator who is significantly impacted, make sure that you're there.

What do you think? Tell us in the comment box below.

Alan Tilles is counsel to numerous entities in the private radio and Internet industries. He is a partner in the law firm of Shulman Rogers Gandal Pordy & Ecker and can be reached at atilles@srgpe.com.

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