Congress needs to drop T-Band mandate

On Monday, I wrote a short story on the report issued last Friday by the National Public Safety Telecommunications Council (NPSTC) that characterized the plan to move licenses out of the T-Band spectrum — used by public safety in 11 cities — as “infeasible.”

This is a Congressional mandate contained in the legislation that reallocated the D Block spectrum in the 700 MHz band to public safety for the purpose of building a nationwide broadband network for first responders. The law requires the FCC to begin auctioning the T-Band spectrum (470-512 MHz) by February 2021, and all public-safety operations in the band must cease within two years after the auction closes.

The next day, I spoke with Ralph Haller and Doug Aiken — NPSTC’s chairman and vice chairman, respectively — Stu Overby, vice chairman of the organization’s spectrum management committee, and Joe Ross, co-chair of its T-Band working group, to try to gain greater visibility into the report.

The biggest problem is that there isn’t enough spectrum to accommodate the proposed relocation. For example, there’s only 3.6 MHz of VHF spectrum that is eligible for public-safety use.

“When you look at that, it is way, way, way shy of what [public safety would need] in most of the markets,” Overby said.

Haller agreed.

“To accommodate all of the existing licensees at VHF, and then to try to accommodate all the people that are in T-Band, the band simply will not handle it,” he said.

I asked whether the T-Band licensees could be parsed out across several bands, wherever pockets of spectrum are available. Overby said that such a strategy might work in markets where there is a relatively small number of public-safety entities, but that would depend largely on the number of business-and-industrial operators.

“In Houston, for example, you have a low number of public-safety users, but a corresponding high number of industrial business users, because you have all of the petrochemical systems there,” Overby said.

Interoperability also would be an issue, according to Overby.

“If you have people spread out across different bands … that, of course, can have some impact on interoperability, unless everybody has multiple-mode radios that cover all those bands,” he said. “But there’s a cost to that.”

Aiken agreed.

“Aggravating the interoperability issue is not going to do anything to support public safety,” he said. “Take a look at just one market — Boston — where there is heavy use of the mutual-aid system by fire on T-Band. If you’re going to parse them out over a bunch of bands, you’re going to eliminate the current systems that operate, and I don’t see that as a viable solution.”

I asked whether moving to 6.25 kHz-wide channels would clear enough capacity to accommodate the T-Band users. Haller didn’t think so.

“The channel centers at VHF are 7.5 kHz apart,” he said. “However, on each of those 7.5 kHz channel centers, there are licensees at 12.5 kHz bandwidth. So, the net result is that they currently overlap. … When you coordinate, you have to do some geographic separation, if you’re going to have adjacent licensees 7.5 kHz apart with a wider bandwidth. However, there are already people on all of those channels.

“So, if you went to the narrowband [tactic], you would free up little pockets here and there, where you could probably squeeze somebody else in. But it’s not like you would create twice as many channels if you narrowband. While I don’t think that there’s been any study done to answer your question with 100% reliability, just based on my experience as a frequency coordinator, I don’t think that would free up enough to accommodate all of the T-Band.

There’s a practical reason why such a tactic wouldn’t work, Haller added.

“You would totally disrupt everyone else out there who just now finished spending the money to go to 12.5 kHz equipment [to meet the FCC’s narrowbanding mandate],” he said. “They need to fully depreciate that [investment]. So, if you figure a 15-year depreciation cycle on equipment, they’re not going to be ready to do something else in 9 years.”

According to Ross, the situation is causing a great deal of angst and uncertainty in the public-safety community.

“That uncertainty is causing a lot of problems,” Ross said. “Do you make an investment to meet your immediate needs, or do you hold off because you’re going to be forced off the band?

Haller offered an example.

“Let’s say that a city annexes a new area, they’re on the T-Band, and their current coverage doesn’t adequately include that area” he said. “They can’t go in and get another site, because if they expand their current coverage area, it’s forbidden by the freeze.”

The FCC issued a public notice last year that effectively froze operations in the T-Band spectrum until the commission figures out how to implement the congressional mandate.

“They couldn’t even add a channel if their current traffic exceeds their capacity — they’re frozen in time,” Aiken said.

Obviously, public safety needs some answers soon, because the nine years between now and the deadline for vacating the T-Band will pass in the blink of an eye. NPSTC doesn’t see one in the offing. While many elected officials have speculated that public-safety T-Band users could migrate to mission-critical voice over broadband in the 700 MHz band at some point, no one in the industry knows when that will be technically feasible, much less reliable enough for first responders to bet their lives on it.

There is a non-technology solution to the problem. The simple and most effective way to resolve this matter would be for Congress to rescind the requirement that public-safety users abandon the T-Band.

I’ve heard many times over the past year that clearing the T-Band spectrum, once vacated, is necessary in order to replace the revenue that was lost, because the D Block wouldn’t be auctioned to commercial interests.

Such a notion strikes me as specious. According to wireless industry consultant Andrew Seybold, the value of the T-Band spectrum — after some spectrum-repacking exercises involving users from higher bands — arbitrarily was set at $3 billion, which not coincidentally was the value placed upon the D Block. But according to NPSTC, it’s going to cost $5.9 billion to move the T-Band licensees. So, how is this revenue neutral?

In addition, there still will be business-industrial users in the T-Band, even if the public-safety users are cleared. Either they will need to be cleared as well — again, an expensive proposition, and one with no clear spectrum solution — or the concept of easily repacking spectrum from higher bands will be extremely difficult to execute.

I’ve also heard many times that the T-Band requirement represented the proverbial “pound of flesh” that public safety was expected to give up in exchange for the D Block. If so, that’s an even worse reason for doing this.

What would serve the public interest best would be to leave the public safety entities using the T-Band right where they are — and that’s exactly what Congress should do, as soon as possible.

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