What’s the Best Path Forward for T-Band Users, by Sandra Wendelken, Mission Critical

Source: Mission Critical Magazine , May 14, 2014, by Sandra Wendelken

Although some industry insiders are pushing for an industry-designed plan to help guide the FCC on how to move forward with the issue of the UHF T-band spectrum, others said mission-critical licensees should lobby their lawmakers to change the law that created the problem.The bill that gave public safety the 700 MHz D block spectrum and created the First Responder Network Authority (FirstNet) — the Middle Class Tax Relief and Job Creation Act of 2012 — also had a stick. The legislation requires public-safety licensees in the UHF T-band spectrum to relocate out of the spectrum within nine years with relocation to be completed two years after the spectrum is competitively bid. Proceeds from auctions will be used to cover the costs to relocate the affected public-safety licensees, the bill says.

The UHF T-band (470 – 512 MHz) also includes business/industry (B/I) users and SMR operators in 11 of the largest U.S. cities. Those cities include Boston, Chicago, Dallas/Fort Worth, Houston, Los Angeles, Miami, New York, Philadelphia, Pittsburgh, San Francisco and Washington. The legislation doesn’t address B/I licensees.

The law causes many problems for licensees in the band. T-band channels are mixed and interstitial and not the same in each market. “How would you auction it with TV stations still there in somemarkets and not nationwide?” asked Stu Overby, vice chair of the National Public Safety Telecommunications Council (NPSTC) Spectrum Management Committee. “Five of the 11 markets have insufficient spectrum for T-band system relocations to another band.” NPSTC estimated in a 2013 report that it would cost nearly $6 billion to relocate public-safety users in the T-band spectrum to 700 MHz narrowband spectrum. “Auctioning the spectrum is unlikely to yield the funding needed for public-safety relocation,” Overby said. “Interoperability will be negatively impacted by removal of T-band spectrum.”

The cost to move 764 B/I T-band UHF systems into a single portion of contiguous T-band spectrum would be nearly $450 million, according to research from the Enterprise Wireless Alliance (EWA).

In April 2012, the FCC “froze” the UHF T-band, suspending the acceptance and processing of T-band applications to stabilize the spectral environment while the commission considers future use of the T-band.

In March, industry leaders discussed the issue at the International Wireless Communications Expo (IWCE). Alan Tilles, chair of the telecommunications practice at Shulman Rogers, said the industry should come together to hammer out a proposal for the T-band licensees and present it to the FCC.

“We need to turn this around into an opportunity,” Tilles said. “Has the FCC ever mandated licensees out of their current spectrum and not provided for funding for that move? No, so we need to craft a methodology to get that done.”

Tilles said the T-band licensees must move to a new band, and it would require new equipment because it will not be compatible with current spectrum. “You will get an all-new system,” he said. “It’s up to us to tell the FCC what to do and get it moving.”

“We’re subject to Congress and it’s their law,” said Roberto Mussenden, attorney/adviser in the policy division of the FCC’s Public Safety and Homeland Security Bureau (PSHSB). “There is someinterpretation. We have to be careful with that and how much interpretation we can give. The more help we can get from the industry — that helps us come to a decision.”

The FCC can interpret the law, but any big changes must come from Congress through a new piece of legislation. “Mission-critical licensees should go to their lawmakers,” said Rick Burke, partner at consulting firm Televate. “They should start there. Congress made this deal and didn’t know at the time what they were getting themselves into. There was no analysis or research on the impact on critical operations. Because that wasn’t undertaken and a deal was made at the last minute, if we revisit it, wiser minds will prevail.”

Burke said licensees should explain the implications to their senators and representatives. EWA President Mark Crosbysuggested congressional intervention was the best solutionin 2012.

Tilles said the freeze on the band and the unknowns make it hard for licensees to make decisions about their networks. However, T-band licensee Los Angeles County last year contracted Motorola Solutions for a $280 million public-safety narrowband radio system procurement using both UHF T-band and 700 MHz spectrum with a goal of migrating the T-band users to 700 MHz spectrum over time.