Narrowbanding is full of surprises

As we approach the second half of 2012, narrowbanding work is proceeding at a furious pace. Although T-Band (470-512 MHz) users received a reprieve from the FCC, some of those licensees are choosing to go forward with their narrowband projects anyway, either because they're already way too deep into the project now to stop, or they need to get rid of some seriously ancient equipment.

For T-Band licensees choosing to keep their equipment, the Telecommunications Industry Association (i.e., radio manufacturers) have asked the FCC to allow the continued manufacture of 25 kHz equipment for the T-Band, in order to keep these systems running.

Meanwhile, back at the FCC, the commission is working on extension requests by both public safety and business/industrial users, and in the process is setting the bar regarding what extensions will be granted. This underscores the importance of adhering to the commission's extension criteria, which were laid out in its July 2011 public notice.

One extension was granted to the state of Missouri, in order to give users in the area time to migrate to a wide-area 800 MHz system. This grant demonstrates one of the long-term values of narrowbanding, which is to free up valuable spectrum.

Meanwhile, first out of the chute on the business/industrial side is the extension request from Delta Airlines (disclaimer, it was filed by our office). In that case, we were able to demonstrate that the enormous scope of this project (315 stations from coast to coast) would keep Delta from completing the entire project on time — although many of the stations in the largest urban areas will indeed by narrowbanded by the deadline.

However, the Delta filing uncovered an interesting situation. One of the FCC's directives to licensees seeking an extension is to demonstrate what the licensee will do to minimize the impact of the delay on other licensees. Our method of complying with the requirement was to serve a copy of the filing on all adjacent channel licensees, letting them know that if there was a problem, they could contact us to resolve it.

It was amazing how many telephone calls I received from licensees (yes, licensees) asking me why I sent the filing to them. Most claimed that they didn't have a wireless system, despite my description of their license. Note that these licensees weren't just small businesses — they included major retailers and hospitals.
This tells us that there are thousands, if not hundreds of thousands, of licensees on the FCC's database that will never narrowband, because they don't even know that they are a licensee. These deadwood licensees will remain on the database until the licenses are not renewed, or the FCC takes action. Fortunately, it also tells us that there are more spectrum opportunities for centralized trunking, which no doubt will be another long-term benefit of this effort.

So, what do we do about the deadwood licenses? At the recent Land Mobile Communications Council meeting, I suggested that the frequency coordinators ignore such deadwood licenses next year when coordinating applications for centralized trunked systems on adjacent channels. The rest of the coordinators agreed, and LMCC now has filed a notice with the FCC consistent with that recommendation.

Meanwhile, we have heard anecdotal stories about some licensees (including public-safety licensees) that are making an affirmative decision to ignore the deadline. We're not talking about folks filing extension requests; rather, they are just ignoring the mandate. This represents very dangerous thinking. Licensees face significant consequences from ignoring the mandate, including fine or license cancellation. If a licensee does not believe that the commission will act in such cases, despite the public safety status of the licensee, that licensee ought to peruse some of the FCC's public-safety fine and license revocation cases. Don't be foolish — be proactive.

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