Time's Running Out for Agencies to Comply with Narrowbanding

The FCC deadline to convert LMR functionality to narrowbanding is quickly approaching, and it’s estimated that only one-third of the nation’s jurisdictions have converted.

by Andy Opsahl / August 12, 2011

In 2004, the FCC set a deadline of Jan. 1, 2013, for public safety agencies to convert their land mobile radio (LMR) functionality to narrowbanding — a method that allows radios to use spectrum more efficiently, freeing up extra capacity for additional licenses. The mandated change will avert agencies from a more bandwidth-hungry approach called widebanding and make available additional spectrum licenses for crowded metropolitan jurisdictions. It has been a costly burden, however, for jurisdictions already satisfied with the capacity they possess and those gravely unprepared to meet the deadline.

Agencies often can’t afford new equipment, or their leaders are ill-equipped from predecessors who did nothing to prepare. In some cases, especially in rural areas, agencies are unaware of the deadline or think their failure to convert will go unnoticed by the FCC. Once the deadline passes and those who converted their equipment start narrowbanding, that equipment could interfere with LMRs in neighboring jurisdictions still in wideband-mode. The FCC has refused to extend the official deadline, which means some portion of the country will be in violation after it passes, said David Furth, deputy chief of the FCC’s Public Safety and Homeland Security Bureau. He estimates that one-third of jurisdictions in the nation have already converted. Therefore, the remaining two-thirds are made up of jurisdictions still transitioning and poised to meet the deadline and jurisdictions that are already too behind and won’t meet it — but it’s unknown how many jurisdictions fall in the former and latter categories.

Those that miss the deadline will need to submit applications for special waiver extensions, but they can’t claim that they weren’t given enough time, said Dave Buchanan, committee chair of the National Public Safety Telecommunications Council’s (NPSTC) Spectrum Management Committee. The FCC started this endeavor in 1991 and by 1992, the agency established its narrowbanding initiative. It asserted that all public safety and business LMRs operating in the 150-512 MHz radio bands should cease using 25 kHz efficiency technology and begin operating using at least 12.5 kHz efficiency technology. Public safety lobbying organizations objected to the costly new rule during the 1990s, but didn’t prevail. LMR vendors began selling narrowband-capable equipment in 1997, and the FCC specified in 2004 that the conversion deadline was 2013. Over the years, the agency has urged public safety leaders to seek additional funding early and to purchase all refreshment LMRs with narrowband capabilities. An assessment of the challenges that lay ahead both before and after the deadline is a critical step for any public safety agency that’s behind schedule.

What’s Needed and How to Get It

Jurisdictions unprepared for narrowbanding should first hire a consultant or ask the local LMR vendor to determine what equipment needs adjustment, Furth said. Necessary changes may go beyond buying and installing new radios or reprogramming existing ones, explained Harlin McEwen, chairman of the Public Safety Spectrum Trust. Municipalities need to install additional base stations and towers because a narrowband channel doesn’t cover as wide an area as a wideband channel. Without additional infrastructure, switching to narrowband could leave some sections of a jurisdiction without LMR functionality. And adding that infrastructure can be very difficult, McEwen said. “Base stations and towers are expensive, and people don’t like them.”

Getting community approval for those towers could involve a lot of bureaucratic hassles, depending on the areas affected, said John Powell, chair of NPSTC’s Interoperability Committee. Infrastructure installed during the mid-1990s and before, however, likely won’t be affected since jurisdictions in those days tended to install more capacity than needed, so equipment could be sufficient for full coverage in narrowband-mode. Success, Powell said, would depend largely on how effectively a radio frequency engineer recommended extending and tilting existing antennas. Any governments wanting to implement those recommendations using internal staff should start with just one antenna and test it thoroughly, he insisted. While recommendations from an engineer usually look like they’d work on paper, Powell said problem areas are frequently revealed during implementation. The engineer may need to do revisions before the municipality rolls out the full redesign. Governments without a narrowbanding vendor may be running out of time to find one.

McEwen and others fear that if too many jurisdictions wait much longer, there may not be enough product and technical assistance on the market to transition all jurisdictions before the deadline hits. After securing an appropriate vendor, the next step is to begin the funding request processes. The FCC cautions that persuading legislators to fund the proposals can be difficult, so it would be beneficial to emphasize the mandatory nature of the FCC’s rule.

An agency that hasn’t already started its budget proposal probably must wait for next year’s funding cycle, Powell said, since local budget proposals must usually be submitted before July when most budgets begin. Jurisdictions that don’t get funding until July 2012 will have only six months to finish with the January 2013 deadline looming. Given the scarcity of local tax dollars, the FCC said many jurisdictions will likely need supplemental grants, but the agency doesn’t offer them. Instead, it points to the U.S. Department of Homeland Security (DHS), where leads on grants can be found at fema.gov/grants. The Web page includes application instructions, answers to common questions and a drop-down menu of states for finding local inquiry phone numbers. Jurisdictions can also e-mail grant inquiries to the DHS’ Office of Emergency Communications at oec@hq.dhs.gov. Other opportunities exist for funding beyond the DHS, Furth said.

“We’ve been working with the Department of Agriculture because they have a lot of programs for rural development that can be used for a variety of purposes,” he said. “It turns out that one of the purposes is to help with public safety.” Furth also recommended approaching the Agriculture Department about grants, though he cautioned that such grants are tough to come by, so localities may want to look at ways to reduce costs. One option is purchasing any discounted equipment they can through state contracts. 

Before deployment, a locality must complete the FCC’s frequency coordination process. This ensures that the new narrowband frequency coordinates with frequencies used by other localities. The International Association of Fire Chiefs and International Municipal Signal Association are available to help with this process. Both organizations are certified public safety frequency coordinators and are recommended by FCC Narrowbanding Mandate: A Public Safety Guide for Compliance. The document says that in many cases, licensees’ new narrowband systems will operate on the same frequencies their prior systems used in wideband-mode, just with a narrower channel bandwidth. The license modification process should be fairly simple in those cases, the document said. If a jurisdiction is seeking to license additional channels, success will depend on channel availability and a satisfactory demonstration of need, the document went on to explain.

Life After Deadline

Given that some portion of the country will be in violation of the narrowbanding deadline after Jan. 1, 2013, public safety officials are likely wondering what will happen next.

If one jurisdiction has begun narrowbanding while its neighbor is still in wideband-mode, the FCC would be obligated to shut down the widebanding jurisdiction’s equipment if it interfered with the narrowbanding jurisdiction’s equipment, Powell insists. But if that happened, would citizens be at risk because public safety in the widebanding jurisdiction would potentially be without radio communication? Neither Furth nor Powell offered a concrete answer, though Powell said he believed the question was probably unanswerable at this point. Furth hopes that any jurisdiction diligently converting to narrowband is pressuring its neighbors to do the same. After all, compliant neighbors are often a requirement for a successful narrowband conversion.  

“We really encourage that kind of peer pressure,” Furth said. “We’ve been in contact with state and local government agencies, statewide interoperability coordinators and regional planners for just that reason.”

The threat of interference from adjacent wideband equipment is only a risk if it’s in close proximity to narrowband equipment, Powell said. In many rural cases, interference won’t be a problem because those neighboring systems would be miles apart. Powell believes that’s likely the case for any jurisdiction still unaware of the deadline. 

“If you’re really out of touch, you’re probably so rural that you could keep operating wideband for 100 years and nobody would ever know the difference,” Powell said. “If you go out in the middle of Wyoming, Montana or some of the bayous in Louisiana and the very remote areas, especially if you’re operating a mobile-only system or you’ve got a portable-only system — no high-powered base stations — the chances of somebody picking up on that immediately are probably not too high.”

But that’s not a green light for rural officials to relax, Powell warned. The FCC has a database of licensees, and after the deadline, it will be clear which licensees are not using narrowband equipment. The FCC most likely will want to avoid shutting down equipment if possible, but it’s still a reason for jurisdictions to be concerned.

“There are a lot of enforcement remedies we have, whether monetary forfeitures or other types of sanctions that don’t go to the extent of saying, ‘We’re taking away your license. You have to shut your system down,’ but still can exact a cost that licensees need to think about,” Furth said.

He said ignorance of the deadline would not be a viable excuse for public safety officials seeking extension waivers. The issue had been highlighted on the front pages of numerous government publications and ample notices had come from the FCC, Powell added.

Even more, in April 2011, the FCC sent a letter to all private- and public-sector licensees emphatically reminding them to be ready. Furth said he wouldn’t know what legitimate grounds for receiving a waiver extension would be until the applications arrived. And jurisdictions expecting to need waivers should plan on submitting the applications well in advance of the deadline.

“It’s not that people need to file waivers tomorrow,” Furth said, “but they should at least be talking to us and starting to look at whether they’re going to need one.”

Powell offered speculation on what would likely persuade the FCC to grant a waiver extension. He thinks jurisdictions will have a decent chance if they’ve switched their mobile devices and had their frequency coordination work done to accommodate narrowband functionality. In that case, the agencies would need an extension to complete the fixed infrastructure adjustments, like for base stations. 

“If you can show you have a migration plan in process — you’re aware of the issue, you’ve taken steps to start the process, you’re just not done — I think you’d be able to argue successfully for some kind of relief,” Powell said.

Jurisdictions unable to show that kind of effort, Powell said, will likely receive penalties while continuing in wideband until they complete their conversion.