UHF T-band Comments and Why You Should Make Your Voice Heard

Monday was the deadline to submit comments to the FCC regarding the UHF T-Band givebacks mandate found in the Middle Class Tax Relief and Job Creation Act of 2012.  There were 27 responses to this request for comment, and some of the highlights reveal why it is so important for Public Safety agencies to speak up in whatever venue is available.

The FCC was provided with multiple concrete examples of why this mandate could be catastrophic for the Public Safety spectrum environment. Motorola Solutions submitted 15 pages of informative prose maintaining that the extensive nature of T-band public safety networks in (at least five) of the 13 urban T-band markets would be difficult, if not impossible, to reconfigure due to the lack of spectrum and funding.  One particularly difficult market will be the Los Angeles area, as apparent from the Los Angeles Regional Interoperable Communications System Joint Powers Authority comment.

Home to the City of San Francisco, Marin County, California operates a digital trunked voice radio system in the UHF T-band that was constructed specifically for county communications through the Marin Emergency Radio Authority (MERA).  There are 25 member agencies in MERA, operating on a hybrid trunked-simplex/conventional frequency authorization.  This system provides communications for more than 2,875 users including law enforcement, fire management, emergency medical, road maintenance, transit, public works, local government, in addition to other applications, which provides Interoperability to these agencies.  With the system overloaded by approximately 20%, anyone can see why Marin stated that "forcing these public safety users to vacate the T-band will be extraordinarily disruptive and expensive, and could endanger the safety of life and property."

The law does not specify whether non-Public Safety agencies will have to vacate the T-band, and this is a source of uncertainty surrounding the issue.  A Beep, LLC, a non-Public Safety entity recognized the notion that moving all non-public safety users to one portion of the band would allow the FCC to avoid complete replacement of all radio equipment in service "makes sense," but would certainly be costly.

Although some great feedback was provided in these comments, the fact that only 27 responses were received out of the thousands of agencies that would be affected by the UHF T-band mandate is surprising.  Time and budgetary constraints cause many agencies to miss out on the opportunity to provide comment, however if you don't make your agency's needs known, don't hold your breath that these needs will be considered in future Federal policy decisions.

Reply comments for the UHF T-band issue are due June 11, 2013.