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?

As if they don't exist, allowing the airwaves to be given to other applicants
76% (121 votes)
As if they are compliant licensees using 12.5 kHz channels, leaving little spectrum available to new users
23% (36 votes)
Something else (leave a comment)
2% (3 votes)
Total voters: 160

Discuss this poll 30

Anonymous
on Jan 1, 2013

The FCC is more than 2 months behind on granting Modificattions on licenses, even if everyone had 20 years to complete the project, If the FCC can't handle the license process how can they be trusted to make rational decisions about who is out of compliance. I think the FCC should at least be caught up before they start charging people 10's of thousands of dollars.

WV

Anonymous
on Dec 31, 2012

The original FCC requirement for narrowbanding was issued in 1994. If you have not done so by now, you had no intention of fulfilling the requirement, and your license should be cancelled. If you are found to be operating with an emission mask greater than allowed - a notice of apparent violation should be issued.

The rest of us have worked hard - long days to get customers (many of them procrastinators) narrowband compliant. For the rest of them - they had 19 years - no excuses!

Anonymous
on Dec 20, 2012

A waiver to continue operation should be appropriate due to unforeseen circumstances if all due diligence such as planning, engineering, licensing, purchasing, and construction has occured. It happened to us when a control system software driver problem was discovered too late for the vendor to have it ready by the end of the year.

Anonymous
on Dec 20, 2012

Give a 6 month grace period. After which point they either will be compliant or revoked. No more extensions. Period.

Anonymous
on Dec 20, 2012

They should be cancelled, and as of Feb 1, a list be published of newly available frequencies available for applications. The FCC should also consider TETRA applications, and fill the 12.5 slots first before consuming the 25 kHz ones, so that folks considering TETRA may have a chance. I wish that an area could be reserved for later 25 kHz allocations within the band.

Anonymous
on Dec 17, 2012

What sense do rules make if they will not be enforced? Many agencies have complied with the mandate, many at considerable expense. The FCC has "drawn the line" as the saying goes and to have any legitimacy they must follow through. Send out the notices now that as of the 2013 deadline those agencies not narrow banded, no license application in the works or no waiver will be considered in violation of the FCC rules and will be subject to the penalties as prescribed. Title it "We regret to inform you..." but act according to your rules.

Anonymous
on Dec 18, 2012

1). Physically demonstrate how narrowbanding actually provides new "Useable" channels.. It doesn't.. If two or 3 wide band (25 KHz ) channels are close together geographically, there is no place for the 12.5 narrow to go to function without interference from other 12.5 KHz channels.. Give up!
2). There are many square miles in the USA where Narrowband is wasted, there are plenty of 25 KHz channels available in areas like Nevada, Montana, Wyoming, WV, NC, etc. Narrowbanding these areas is not fair, not cost effective, so give up on NB...
3). there is a major push to migrate agencies and users to commercial service at cellular freqs, and migrate up to 700 - 800 MHz. This leaves lower (150 - 512) empty.... Fallow!! Give up on NB
4). Pub Safety has been pleading for advanced radio services, images, mobile data/computing at moderate data speeds, image transfer. license plate reading, drivers license swipe for Wants/warrants search, etc. This requires a modest increase in data rates over the air, which requires utilizing 25 KHz bandwidth. Keep the 25 KHz channels for these agencies and services, if the agencies have the need, license the 25 KHz channels to them. Give up on NB.
5) Reorganize the channels into a managed Tx/Rx pair so that geographic reuse is facilitated, eliminate simplex freq base station authorizations to promote the geographic reuse.

Give up on NB

Anonymous
on Dec 27, 2012

The fact that the FCC won't allow one to narrowband an older radio with a kit speaks to the fact that this mandate is as much about more selling new radio systems as it is freeing up bandwidth.

Anonymous
on Dec 20, 2012

Only one response - 20 YEARS TO PLAN FOR THIS!!!

Anonymous
on Dec 18, 2012

I have recently come upon two agencies that narrowbanded but neglected to tell the FCC and have their license modified. One thought that their licensing company would "do this automatically" for them, the other believed that this change in their license was "automatic" since it was mandatory, and that no action was required on their part.

So my thoughts:
1) Send a letter directly to licensees (not via licensing companies, some of which are no longer in business) with a direct reply mechanism (email, form, etc)
2) Quick reply and narrowbanded - assist to update license
3) Quick reply - not narrowbanded - start proceedings to revoke license, expecting this will get them to narrowband
4) No reply after 6 months -> cancel license

Anonymous
on Dec 18, 2012

Licensees who invested significant time and money to bring their current radio systems into compliance or purchased new compliant radio systems should be rewarded with access to spectrum held by licencees who failed to heed FCC warnings regarding the narrowbanding deadline not being extended and did not comply or file for a waiver.

Anonymous
on Dec 14, 2012

The LMCC representing both BILT and PS coordinators reached an agreement early this year they would not recognize a license having only wide emissions as of February 1, 2013 unless the licensee either had a waiver or had an application in process. The FCC partially agreed with this when they stated they would consider a wideband licensee as compliant if they had a license application for narrowband in process. The coordinators will let the FCC and the other coordinators know what call signs are in process as of midnight on December 31st. If an app is received after midnight or a licensee continues to operate wideband without a waiver, then they are operating without a valid license and subject to fines.

Anonymous
on Dec 14, 2012

20 years is enough. Cancel licenses and enforce the rules. That was the same problem with TV switch just a few years ago. Users can turn down deviation, suffer the consequences and buy new equipment! Sorry, no easy solution from me!

Anonymous
on Dec 13, 2012

Most of us have narrowbanded at considerable expense. Screw them! If you are non-compliant, you are illegal.

Anonymous
on Dec 13, 2012

There are about 28,000 licensees now that have not filed modifications with FCC to reflect narrow-band operation. There are probably thousands more that have updated their license, but failed to implement the changes. One problem is that a licensee could be using 25 KHz bandwidth if they are using a system like Tetra that allows two or more channels within that space. In the past the FCC's enforcement bureau has been primarily complaints-based and finding a problem on their own was rare. I doubt the FCC has the resources to monitor each and every transmission over the air for compliance. The FCC should: 1) cancel the licenses of remaining unmodified licenses after 1/15/13 (allow the mail to arrive in Gettysburg), and 2) Let the coordinators and new licensees report offending stations to the FCC for enforcement.

Anonymous
on Dec 13, 2012

With only 20 some years of prior notice, it's conceivable that some people didn't get the notice (please interpret with heavy sarcasm). If they haven't modified their license, first step would be a letter from the FCC of non-compliance with all the usual threats of expensive fines, and a deadline of compliance of 6 months or so. Step 2 would be for the FCC to follow up to confirm the licensee has complied and the case is dismissed. If the licensee is still not compliant, the Step 3 would be grant another 6 months to be compliant or loss of license and the obligatory $10,000 fine. Step 4 would be at the end of the 6 months have the Enforcement Bureau to show up on the licensee door step and politely yet firmly, hand them their $10,000 fine and say have a nice day.

Anonymous
on Dec 13, 2012

Why should someone who has failed to narrowband his license in the approximately 15 years since the FCC mandated narrowband, be given preference over someone who wants a license to operate narrowband now?

Anonymous
on Dec 11, 2012

I see some opinions from people who probably have something to gain from the FCC whisking away licenses en masse. There might be people with errors on their license having to do with contact information. Some average joes might not have heard diddly about narrowbanding. Also, some people might continue noncompliant without causing any harm, especially the 4w ERP portables on UHF in rural areas.

Anonymous
on Dec 7, 2012

If they're not licensed for narrowband [or have a waiver], then their licenses should expire on 1 January. Therefore they don't legally exist.

Anonymous
on Dec 7, 2012

Treat the existing licenses as if they are compliant until it is proven otherwise. If they are not compliant, they will incur interference from the adjacent users as the new channels are used and they will have no recourse. The new users will file interference complaints and the wideband offenders will be found and face the wrath of the FCC.

Anonymous
on Dec 7, 2012

Cancel the licenses

Anonymous
on Dec 6, 2012

Label the wideband licensees as non-interference basis (NIB), if they have no waiver. If there is no other spectrum available to a narrowband compliant requester, license them despite the non-waivered wideband holder. If the wideband, non-waivered, system interferes with narrowband system, they wideband system owner must take immediate steps to mitigate the interference up to and including shutting down. If the narrowband, non-waivered, system experiences interference, they have to put up with it, just like a Part 15 device. The caveat is the whether or not the wideband system has applied for and gotten a waiver, keeping them as a primary user, or has not requested a waiver.

Anonymous
on Dec 6, 2012

Licensees have had plenty of time to bring their systems into compliance and plan for adequate resources to fund any new buildouts.

Anonymous
on Dec 6, 2012

I think there is enough spectrum available with out impacting tbelow 512 MHZ

Anonymous
on Dec 6, 2012

There should be at least a year of treating non-compliant licenses as secondary and they cannot interfere but they must accept interference (ala Part 15). After that then they should be treated as cancelled licenses.

Anonymous
on Dec 6, 2012

We all had our chances. If you didn't plan, you start over from scratch.

Anonymous
on Dec 6, 2012

If the existing license has not expired, the FCC should treat it as if it is NB compliant and issue new licenses based on the NB channel spacing - then wait for interference reports and investigate where a site is still transmitting wideband

Anonymous
on Dec 6, 2012

Everyone has had over 10 years to get this done including an extention.

Anonymous
on Dec 6, 2012

As if they don't exist, allowing the airwaves to be given to other applicants. This is my take.
They have had "Many Years of Warning" that this day would come.
Do it ( narrow-band ) or loose it!
If you have no waiver, then your hosed....It is plain and simple, you have been warned many times.

Anonymous
on Dec 6, 2012

Do the due diligence by attempting to contact the licensed users. If abandoned, re-license the frequency. If still active, notify FCC for enforcement action.

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