FCC should heed NPSTC concerns about 2011 deadlines

For most of the radio community, the key target date for narrowbanding from 25 KHz channels to 12.5 KHz channels below 512 MHz is Jan. 1, 2013, because that’s when the job must be completed. But the interim deadline of Jan. 1, 2011, includes some stipulations that could have some unexpected interoperability and equipment-cost issues that the National Public Safety Telecommunications Council (NPSTC) believes should be avoided.

That’s why NPSTC recently asked the FCC to adopt a petition to stay the Jan. 1, 2011, deadline, according to NPSTC Chairman Ralph Haller. But before explaining his organization’s reasoning for the petition, Haller emphasized that NPSTC is not looking to delay the ultimate narrowbanding deadline of 2013 in any way.

“NPSTC is not suggesting any chance whatsoever in the 2013 date,” he said. “We are very strongly supporting the 2013 date.”

But NPSTC is not as supportive of the 2011 deadline, which now is less than 15 months away. Current FCC rules prohibit manufacturers from importing or manufacturing equipment that can operate on 25 KHz channels after 2011 and mandate that all equipment be able to operate in 6.25 KHz or equivalent channel efficiency.

These mandates are problematic for public-safety agencies for multiple reasons, Haller said. Agencies planning to make the switch from 25 KHz to 12.5 KHz near the 2013 deadline effectively would not be able to expand their 25 KHz-channel systems after 2011, because equipment likely would not be available.

In addition to this internal issue, there are questions regarding interoperability. If one agency has completed narrowbanding and another one hasn’t, their ability to communicate during an incident could be compromised, Haller said.

“You’ve got 12.5 KHz radios trying to talk to 25 KHz radios, and the net result is — at least for this two-year period — there’s a really good possibility that the interoperability between agencies is going to be adversely affected because people are operating different-bandwidth equipment,” he said.

NPSTC’s third issue with the 2011 deadline is the requirement that vendors include 6.25 KHz efficiency in equipment sold after 2011. The problem is that the Project 25 Phase 2 standard still has not been ratified and likely will not be completed in time for manufacturers to include it in their next generation of products, Haller said.

However, to comply with the FCC mandate, manufacturers will have to develop proprietary 6.25 KHz technologies to include in post-2011 equipment. This will increase the cost of the equipment and likely will be of little benefit to public-safety agencies, most of which will want a standards-based 6.25 KHz solution, Haller said.

“It causes an issue of public-safety entities that are really strapped for money anyway having to pay for a mode of operation in equipment that they likely will never, ever use,” he said.

Of course, public-safety entities and vendors have known about the 2011 deadline for a long time, so the FCC understandably may be hesitant about issuing a stay. More importantly, if the 2011 stipulations are waived, it’s important that the commission word its order in a manner that does not undermine the 2013 date.

And, thus far, there is no indication the FCC is inclined to budge on the 2013 date.

“People can ask for waivers, but I think the commission is going to weigh the fact that these regulations have been out there for so long and the equipment has been available since 1997,” said Jamie Barnett, chief of the FCC’s public-safety and homeland-security bureau. “I’m trying to give [public-safety officials] the information they need to go to their budgeters to say, ‘This really does need to be included now, and we need to finish this transition.’”

That position makes sense. In the meantime, the FCC needs to address the 2011 issues raised by NPSTC, questions regarding enforcement of narrowbanding — what happens if an agency doesn’t narrowband by 2013 — and when interoperability channels should be narrowbanded. Such an FCC notice promises to have an impact in several areas, including agencies should expand systems or whether it’s necessary to stockpile 25 KHz-capable radio equipment after 2011.

Because public-safety agencies need to make budgetary decisions quickly regarding their narrowband migrations, the sooner the FCC can provide such clarity, the better.