Strict Narrowbanding Deadline Less Than a Year Away

On Jan. 1, 2013, all public safety and business industrial land mobile radio systems operating in UHF/VHF channels (the 150 to 512 mHz radio bands) need to have switched from using 25 kHz efficiency technology to at least 12.5 kHz efficiency technology. Moving to a narrower bandwidth accommodates more users. This includes many transit agencies across the United States.

“The best way to describe it is, the UVF/VHF spectrum is like beach front property; it is fabulous, it has been used forever, it propagates really well, it has good in-building penetration, there’s a big robust market for it,” Roberto Mussenden, attorney advisor at the Federal Communications Commission, explains. “Everyone’s familiar with it, and so as demand increased and technologically advanced, manufacturers were able to develop radios that were able to use less bandwidth.”

Mussenden says this is not the first time there’s been a call for narrowbanding. Back in the 1960s there was a move to reduce VHF channels from 60 kHz to 30 kHz, and UHF channels from 50 kHz to 25 kHz.

While this deadline was set back in 2004, there are a number of agencies that have not yet made the change. With less than a year until the deadline, it’s crunch time. Alan Tilles, chairman of the Narrowbanding Committee for the Joint Council on Transit Wireless, says depending on the size of your agency, it could take years. “Denver and OCTA started three or four years ago. This is a mandate; this deadline has been imposed since 2004. This is nothing new,” he says.

Barry C. Einsig, Harris Corp. transportation market director and chair of the Joint Council on Transit Wireless, says, “Radio systems pre-1997 broadcast on channels that were 25 kHz wide. Spectrum is very valuable because there are so many new wireless technologies that people want to use the capabilities for. So, the FCC is constantly trying to help allocate new spectrum so people have it available for all these cool things that everybody wants. First they required manufacturers to do this; in 1997 all manufacturers were required to start building equipment that could work as efficiently — do the same job — in 12.5 kHz channels, half the amount of spectrum.”

Not Just Another Burden

Now it is time for the users to come into compliance with the new regulations. While initially the requirement to update your radio system may seem like just another burden, it does offer the opportunity to update your system in other ways, too. For example, while it is not required to switch from analog to digital, according to Tilles and Einsig, making that switch does add the capability to use the system for data and not just voice.

“There’s not a requirement to do that, but you gain a lot of functionality. It’s no different than your cell phone,” explains Einsig. “When you went from an analog cell phone — 10 or 15 years ago we carried around these big huge things and that was a cellphone and the radio was an analog radio in that cell phone and it didn’t do anything but voice. Then we went to digital and we started doing things like texting and some of the other cool things that you get with digital systems. There’s a lot of functionality you get with a digital system.”

In addition to the added options of sending data information over a digital system, it will also increase your interoperability with other agencies, whether that is the police and fire departments or other transit agencies in the area, Tilles says.

Tilles adds: “If there is a disaster in Chicago, and Chicago needs to be evacuated, how do we get those people out of Chicago? We’re going to send them on mass transit, right? Well in that event there needs to be coordination between the police, the fire folks, as well as the transit folks. OK? I need a bus over here. Or there’s a bus driving around and there’s a stickup on the bus; well, we want transit agencies to think about increasing their interoperability with police and fire folks so in the event of those types of emergencies they have access. Or if you’re thinking about making it a little bit bigger, you have the El in Chicago, which I think has its own police force, and we want those folks to be able to talk to the Chicago police in times of incidences. You want to leverage this opportunity to look at the interoperability that you do have and what you can do to have more.”

Handling Violations

According to a guide put out by the FCC (A Practical Guide to Narrowbanding), “The FCC rule applies to both conventional and trunked radio systems and affects all FCC-licensed state and local emergency response radio systems. Wideband radio operation will violate FCC regulations beginning in 2013, and agencies that do not meet the deadline face — enforcement action, including admonishments, monetary forfeitures and/or license revocation, as appropriate.”

Einsig says transit agencies “need to know that the FCC is serious about the deadline. The deadline is Jan. 1, 2013. I think that there is a lot of discussion around waivers and extensions, and the FCC has made it very clear that those waivers will only be made in exceptional cases. So, not having a contract to put in a new system or repair your existing system, not having a budget, not having a plan, not having a schedule are not reasons that are likely to be accepted by the FCC.”

Tilles stresses that not having the budget to narrowband won’t be tolerated. “I hear that all the time. I have two responses. No. 1, that’s always the excuse. You always hear there’s no money, there’s no money; I don’t care when we’re talking about. You can talk about the go-go days of the Clinton years, we still hear the same thing: we don’t have any money in our budget to do that. So get over it.”

He adds: “But just as importantly, there are a whole host of funding grants and programs through not only the FTA, but also through various public safety grants. Remember transit, you’ve got to think of yourself as public safety too.”

According to Mussenden the way violations are handled is a complaint-driven process. So for instance, if a licensee alleges that your system is causing them interference, one of the first steps the FCC will take in investigating the complaint is to determine whether or not your system is still operating in wideband mode. If so, you are operating outside the terms of your license. At a minimum, the FCC will direct you to find ways to eliminate the interference, but you may be subject to additional sanctions.

According to the FCC Public Notice DA 11-1189, which was issued July 13, 2011, “Operation in violation of the Commission’s rules may subject licensees to appropriate enforcement action, including admonishments, license revocation and/or monetary forfeitures of up to $16,000 for each such violation or each day of a continuing violation and up to $112,500 for any single act or failure to act.”

Approaching Your Updates

Tilles recommends that the first step agencies should take is to take a look at their own agency and figure out if they are of enough size that they need outside help. If you are going to need the help of a consultant, Tilles stresses how important it is to carefully vet your consultants.

“What happens is you get all these consultants that go, ‘I’m an expert in narrowbanding.’ Well, we’re a very small community, and if I haven’t seen them in the 30 years I’ve been doing land mobile, hmmm, not likely that they’re truly an expert consultant. Yet we have them crop up all the time. You’ve got to sort through those people and you’ve got to sort through the people who have a prejudice toward one vendor or another,” he says.

The next step, whether you are using a consultant or not, is to figure out what the impact will be on your agency. Tilles says to look at whether your radios need to be completely replaced or if they can be reprogrammed.

“Then the next thing you do is to figure out, OK, now that I have to do this work, what other work would I like to do while this is going on? Would I like to leverage this as an opportunity to increase our system’s services and the things we do on the system and what else do we want to do with that,” Tilles says.

He continues, “Then if you’re going to do that, we have to go through a fairly complicated series of steps to figure out, gee am I going to do it on this band, or gee should I look at other options as to what to do to meet my radio needs? Is there a possibility of going on the statewide 800 mHz radio system instead of replacing my system? I’m just going to tear it down and go on the statewide system. There are pluses and minuses to each of those things.”

Once you make the decision on what you are going to do, it’s important to make a business case for it since ultimately you will need to take this plan to a boss or city council. You will need to tell them what you plan to do and why this is best for the agency and why you want to do it this way.

Einsig encourages agencies to not look at the new requirement as simply another federal regulation holding them back.

“Instead of looking at it as hey this is another federal mandate coming down that I have to comply with, if they kind of step back and say if I’m going to go through this expense and I’m going to put the agency through this change is there something really positive that can come out of it,” Einsig says. “Many agencies have done that; many agencies have really kind of done a holistic approach and said we’re going to use this opportunity because you only replace radio systems every 15 years or so. We’re going to take that opportunity to really do a technology refresh of the system and serve passenger needs. That to me is a very mature approach.”

The change to 12.5 kHz may be a requirement, but it offers plenty of opportunities for overall improvements to your system.

For more information on narrowbanding:

www.fcc.gov/encyclopedia/vhfuhf-narrowbanding-information

http://transitwireless.org/website/information-topics/narrowbanding/additional-narrowbanding-information

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