June 3, 2016–An updated report released today by the National Public Safety Telecommunications Council (NPSTC) on the impact of a congressional mandate that requires the FCC to reallocate the T-band by 2021 says that “little has changed” since a report prepared more than three years ago estimated the cost of relocating public safety T-band operations to other frequencies would total more than $5.9 billion (TRDaily, March 15, 2013).
The earlier report said Congress should reconsider its T-band reallocation mandate, which was included in the Middle Class Tax Relief and Job Creation Act of 2012, which also established the First Responder Network Authority (FirstNet).
“The NPSTC T-Band Report, issued March 15, 2013, detailed the lack of alternative spectrum and significant cost impact public safety entities on T-Band would face as a result of the provisions in Section 6103 of Public Law 112-96. As shown in this T-Band Update Report, little has changed over the last 3 years,” the report released today concluded. “Public safety’s strong demand for T-Band spectrum is virtually unchanged, as indicated by analysis of FCC T-Band licensing records. On the spectrum supply side, the Commission has made an additional 24 narrowband channels available in the 700 MHz band. However, the resulting 700 MHz narrowband channels available to licensees for potential T-Band relocation still pales in comparison to the channels to be re-accommodated in at least the top five T-Band areas.”
The report continued, “Although there has been significant progress in the development of mission critical voice standards for LTE broadband technology, much work remains to provide a viable broadband mission critical voice-over-LTE solution with sufficient coverage and reliability.” The report added that “many unanswered questions remain, and it is premature for public safety to plan to abandon battle-tested T-Band voice systems.
“Finally, even if public safety was to vacate the T-Band, it is unclear what public interest benefit would be gained by reallocating the T-Band spectrum for commercial use,” the report argued. “The T-Band also supports critical industrial and business systems on T-Band channels outside the public safety spectrum, not addressed in Section 6103 of Public Law 112-96.”
“While most of Public Law 112-96 is positive for public safety, Section 6103 of that law which requires auction of the T-Band spectrum will impose a negative impact on public safety communications and interoperability,” the report stressed. “In turn, this also could negatively impact the operations of public safety agencies that provide emergency response to a population of more than 90 million people in the 11 T-band areas.”
The report “also provides additional detail on the 325 full power and Class A television stations on TV channels 14-20, i.e., the 470-512 MHz T-Band spectrum. The presence of these stations could seriously impair use of the T-Band spectrum for nationwide commercial wireless operations even if public safety systems were cleared from the band. The update study confirms the conclusions from the original NPSTC T-Band Report remain valid.”
FCC licensing records show that public safety T-band spectrum is still in high demand, according to the report.
“Analysis of FCC licensing records shows only 6 out of a total of 925 licensees, i.e., fewer than 1%, cancelled a T-Band license,” it said. “License expirations are higher with 68 of 925, i.e., 7.4% of licensees allowed a T-Band license to expire without renewal. However, that needs to be placed into context. Thirteen of those 68 licensees have pending applications for replacement authorizations. That indicates these expirations without renewal could have been accidental rather than intentional. Furthermore, a number of the licensees with expired licenses also already have other T-Band licenses. Therefore, they cannot be counted as no longer relying on the T-Band spectrum. In addition, the FCC has issued a few Special Temporary Authorities (STAs) to cover continued T-Band operations pending any issuance of replacement licenses.” – Paul Kirby, firstname.lastname@example.org