Andy Seybold’s Public Safety Advocate, February 16, 2017

Congress Has a Problem Called The T-Band!

The T-band is in the 470–512-MHz portion of the radio spectrum and was part of the allocation for UHF TV channels 14-20. However, there was a shortage of land mobile radio (LMR) channels for Public Safety use in many major metropolitan areas. After much political wrangling, the T-band was made available for use by Public Safety and commercial LMR systems in FCC docket 18-261 in 1971. Each of the eleven metro areas was permitted to use some but not all of the TV channels, depending on what was already in service in each area. Since then, Public Safety agencies have made extensive use of this spectrum in these eleven major metro areas (Boston, Chicago, Dallas/Ft. Worth, Washington DC, and parts of Virginia and Maryland, Houston, Los Angeles, Miami, New York/Northwest New Jersey, Philadelphia, and San Francisco/Oakland). Each metro area was assigned one or more TV channels (6 MHz each) for use. However, in the same act that created FirstNet, signed into law in 2012, Congress required Public Safety (but not the commercial systems) to vacate this spectrum by 2022/2023.

At the time the bill that created FirstNet was being drafted, and then in order to get it passed, the bill was folded into the Middle-Class Tax Relief Act of 2012. Many in Congress made it clear they expected Public Safety to “give back” spectrum in exchange for the “D” block. In several of the bills introduced by Congress, various portions of the spectrum were mentioned. The most onerous was one bill that would have required Public Safety to give back all spectrum it occupied from 150 MHz to 470 MHz. This was quashed when the Public Safety Alliance met with some of the staffers and explained that this spectrum was not only allocated to Public Safety but to thousands of other types of radio systems as well.

The final bill that designated the give-back of the T-band was introduced on a Tuesday and passed that same Friday, precluding much discussion or many objections from the Public Safety community. Unfortunately, those who wrote this portion of the bill did not fully understand several things:

1) In addition to Public Safety in some of the cities, commercial LMR systems are also in use. These were not addressed by Congress nor were they required to vacate the spectrum.
2) The T-band allocation is for 1, 2, or 3 channels in each city but not for all of the spectrum, so there are TV channels on either side of the LMR allocations. This makes auctioning this spectrum for broadband use next to impossible and certainly deflates the value of the spectrum.
3) The auction would not be scheduled until 2021 and Public Safety would have to vacate the spectrum within two years. This is not a realistic amount of time to relocate large communications systems from one portion of spectrum to another (assuming there was somewhere else to build these systems). Any Public Safety-grade system takes a while to build and test to ensure that it is, in fact, Public Safety-grade.
4) The NTIA was the agency designated to administer grants for the cost of relocation but there are no guidelines for what costs would be covered and how soon the funds would be available.
5) There appears to have been a misconception in Congress by some that the FirstNet system would be able to accommodate all voice traffic in the T-band, even though at that point in time there were no voice standards for either push-to-talk or off-network communications for LTE.

In response to the T-band give-back, many Public Safety agencies tried to convince Congress to pay attention to these issues with no success. The National Public Safety Telecommunications Council (NPSTC) put together a task force and began work on a T-band paper. This paper was published in March of 2013 and an update was released May of 2016 The paper is detailed and explains, among other things, that there are not enough LMR channels available in any of the major metro areas to relocate these systems and that the cost to do so would exceed any auction costs. The reports are well done, and it is easy to see from the exhaustive work of the committee members the effects on the number of systems, the number of radio sites, mobiles, and portable radios.

These two reports were submitted to the FCC which, unfortunately cannot change a law passed by Congress, only Congress can do that. It is now 2017, FirstNet has yet to be able to announce a Partner to build and operate the system, and with the exception of a few early deployments, the United States does not have a single FirstNet cell site up and running. Further, it is questionable if even by 2023, FirstNet will be able to manage both on and off-network voice traffic in these areas on a true Public Safety-grade network. FirstNet was conceived by Public Safety for data and video services, and the idea of adding voice services came much later. While we now have some standards for mission-critical voice, it is yet to be determined how long it will be until FirstNet can be considered a truly Public Safety-grade network or how long, if ever, it will be before off-network unit-to-unit communications on the FirstNet spectrum becomes a reality.

There is an organization inside the Library of Congress known as the Congressional Research Service that provides those in Congress with research on any number of subjects. Until this past year, there was a person in charge of providing a yearly report on FirstNet to Congress. Last December, I am told, she passed away and her place has been taken by a gentleman who is making a valiant effort to come up to speed. The report CRS just released, with his name on it, is still largely the work of his predecessor, and does not fully address the box Congress has painted itself into. As his level of understanding increases, I hope the reports CRS puts out will, in fact, discuss in more detail these issues that are looming large on the horizon.

One of the things we learned when walking the halls of the U.S. House and Senate is that it is most important to educate the staffers who advise those elected to serve in Congress. Perhaps it is time to put together an effort on behalf of the cities that will lose most if not all of their LMR radio communications in the not-to-distant future and to once again walk the halls and shake the hands of the telecommunications staffers. At this point, I think there is sufficient new information regarding the actual use of the T-band that a new case can be made for at least extending the life of the T-band for another five or more years. To make the case I would start with the following:

1) An auction of the T-band spectrum is not a viable alternative for the following reasons:
a. The 600-MHz auctions that started out as an auction for more than 108 MHz of spectrum have been trimmed and trimmed and will end up with less than 80 MHz of available spectrum, leaving another 20+ MHz for future auction.
b. The T-band spectrum is not well suited for mobile broadband systems.
i. It is too low in the spectrum band and would require larger antennas and components not well suited for mobile devices.
ii. T-band channels are only available for use in selective cities and metro areas and not on a nationwide basis. For example, TV channel 14 would only be available in six of the eleven areas, Channel 15 in only three areas, and so on. In other areas of the United States these channels are in use as TV channels and since they cannot be auctioned on a nationwide basis, their value is greatly diminished.

When TV stations were transmitting over the air in analog they needed all 6 MHz of their spectrum for the video and audio carriers. Today, using digital techniques, up to seven sub-carriers can be placed in the same amount of spectrum. So in reality, the only reason for removing existing users from the T-band is to auction the spectrum, which, as mentioned above, is not worth a whole lot. The proceeds would not begin to pay for relocation of radio systems in use by the multitude of Public Safety agencies in these eleven metro areas, let alone to address the issue of what do to with the commercial systems now in operation on the T-band.

One of the premises for moving Public Safety off the T-band was the narrowbanding of other Public Safety spectrum in the VHF and UHF bands, that is, making more channels by making each channel smaller in size. However, before the T-band issue was raised, most if not all of these new channels were already allocated to Public Safety agencies that had been waiting, sometimes for years, to obtain more channels to help relieve overcrowding on their existing channels. Further, the fact that these channels were narrowbanded caused many systems to lose coverage area and systems had to be expanded simply to regain the coverage they used to have. All in all, the idea of relocating T-band systems to these new VHF and UHF channels could never be realized.

As the new administration comes up to speed, committees in Congress are reconfigured, and the deadline for losing the T-band draws closer, circumstances have changed since February of 2012 when the give-back was included in the FirstNet bill. Therefore, I think it is time to revisit this issue. I know many Public Safety agencies have already been active in this quest but just like when the spectrum was needed for FirstNet, it took the efforts of Public Safety agencies from all over the country to get the attention needed to make the changes. This is not simply a task for the agencies in the eleven metro areas affected, it is important to all of the Public Safety community to educate or re-educate those who make the laws so they understand that all spectrum is not there simply to be auctioned for broadband video streaming and to offset the national debt.

I am willing to bet that many in Congress view FirstNet as the only spectrum that will be needed for Public Safety going forward. This is not a fair assumption, at least not for a very long time, if ever. If we lose the T-band, what portion of the Public safety spectrum will be next to go on the auction block?

Andrew M. Seybold

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