Comments and reply comments submitted to the FCC regarding the proposed public-private shared broadband network at 700 MHz before last week’s deadline generated much expected posturing and a few interesting twists.

As noted in this space previously, there is little consensus about the best way to establish a broadband network for public safety—in fact, there are major disagreements within the wireless-carrier and public-safety communities, much less the expected differences between the two groups. But one common thread in all proposals for all entities is that public-safety narrowband operations at 700 MHz must be relocated to clear a contiguous 10 MHz swath of public-safety spectrum for broadband uses.

This is not news, as the FCC established a new spectrum plan for the 700 MHz more than a year ago. At the time, only a handful of public-safety narrowband systems had been deployed on the spectrum, and the FCC estimated that they could all be rebanded for $10 million, which would be paid by the winner of the commercial D Block spectrum.

Of course, no qualified bid was made on the D Block, so no winner emerged to fund the relocation. When the FCC proposed new rules for the D Block this fall, the narrowband relocation cost was set at $27 million, a figure that public-safety officials have deemed inadequate for the task. Last week, Motorola told the FCC that a $76 million cap should be established to fund narrowband relocation.

That’s a big increase over the original $10 million estimate, although the $76 million figure pales in comparison to the $20 billion this proposed network would cost if built on a nationwide basis. That is why Motorola believes paying for relocation will not deter carriers from bidding on the D Block.

Regardless what the correct estimate is, the problem with the FCC plan is that it requires a D Block winner (or winners, based on the proposed regional approach) to provide the funding necessary to relocate the narrowband systems.

Even under the most accelerated timeline, the D Block would not be licensed until the middle of 2009, with funding not being available for some time after that. Another scenario is that the D Block reauction would not be conducted until late next year or early 2010. Of course, as we learned in the first auction, the fact that the FCC runs an auction does not mean a D Block winner will emerge—a scenario that could lead to still more delays.

This is not the way to proceed. Under any plans for the spectrum, narrowband relocation has to happen—and the sooner it happens, the easier it will be for one of the many broadband proposals to become reality. Leaving existing 700 MHz users in limbo is not advisable, especially if the D Block licensee wants to begin deploying its network as soon as possible.

With this in mind, Congress should fund the relocation of the 700 MHz narrowband systems immediately to avoid further delay. Money from an eventual D Block auction can be used to offset this appropriation, but the relocation work should be done sooner rather than later. The longer we wait, the more complex the 700 MHz rebanding job almost certainly will become.

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