Public Safety Advocate: A T-Band Call to Action

 

Many people, even some of those involved in public safety, have no idea what the T-band is and why it is of vital importance to 11 metro areas with a combined population of more than 90 million. When Congress passed Title VI of the 2012 Middle Class Tax Relief Bill creating FirstNet, and giving an additional 10 MHz of broadband spectrum to public safety, there was a “spectrum give-back” required.  It turns out this “give-back” in the bill Congress passed also stated that the major cities and their suburbs using the T-Band for public safety services (no mention of business and industrial LMR users) would have to suspend operations on the T-Band, “no later than 9 years after the date of engagement of this title.” The title was enacted in February of 2012 and if you 9 years to that it lands in 2021. Further, the law states, “Relocation shall be completed no later than 2 years after the date on which the system of competitive bidding described in subsection (a)(2) is completed.”

The T-Band give-back date is drawing closer. In spite of the wonderful reports the National Public Safety Telecommunications Council (NPSTC) wrote and submitted to Congress and the FCC, and the hours and hours of lobbying by the cities and agencies affected by this portion of the bill, Congress has shown no interest in removing this requirement from the law. Without action from Congress, and soon, the requirement to move off of the T-band will begin to present some really serious problems for both public safety agencies in these areas and the citizens they protect. The time to rally together to push out the give-back deadline is now.

What Exactly Is the T-Band?

The T-Band is radio spectrum that was allocated to UHF-TV channels in the 470–512-MHz band. In most of the United States, TV stations are actually operating on this spectrum. However, in the 11 metro areas some of these channels remain unused in order to provide spacing between the UHF channels in use to prevent the TV channels from interfering with each other. Because public safety and, in some areas, business and commercial operators had run out of available spectrum, in 1971 the FCC authorized the allocation of 470–512-MHz channels for Land Mobile Radio (LMR) licensing.

When public safety agencies in Los Angeles and other major cities ran out of land mobile radio spectrum and needed more channels, the quest to “find” some unused spectrum that could be used to augment the normal land mobile radio channels began. It became apparent that one place where spectrum was lying fallow was in the UHF-TV band in major cities. In order to ensure that home TVs could receive over-the-air broadcasts, it was determined that there should be a least one TV channel dividing the active channels.

For example, in Los Angeles, TV channel 11 has a broadcast station licensed and on the air as does channel 13. So Public Safety asked for and received permission to occupy the unused radio spectrum between the TV channels already on the air in each of the major metro areas. This resulted in Los Angeles public safety being able to use vacant TV channels 14, 15, 16, and 20. In Miami the only channel available for use was channel 14, and Boston employs vacant TV channels 14 and 15. It should be noted that frequencies only in the 470–512-MHz range were allocated (TV channels 14 through 20) to ensure that LMR radio equipment could be developed to operate over this portion of the radio spectrum and it could be used in each of the metro areas where T-Band usage is permitted.

Congressional Missteps

When the T-band was included as a “give-back” in the FirstNet portion of the tax relief bill, Congress made some missteps and has, to my knowledge, not corrected them.

(Editor’s Note: Actually, the entire “give-back” issue is interesting since most Congressional bills do not contain any type of “we will give you this but you will give back this.” The only explanation I have for this being included in the FirstNet creation portion of the bill was the mistaken assumption by members of Congress that the T-Band spectrum, if auctioned, is worth a fortune and could be used to help pay down the national debt.)

The first and one of the most glaring missteps is that the law only requires public safety and not the business and industrial users to vacate the spectrum. This of course means that in some T-Band areas the spectrum won’t really be cleared.

Next up was the assumption that this spectrum has real value and can be auctioned with part of the auction funds being used to relocate public safety users. The missteps for this include:

  • In the T-band there are more than 325 full-powered TV stations operating within the United States. The impact of this is
    1. Clearing the spectrum on a nationwide basis is neither feasible or technically possible.
    2. Putting the T-Band up for auction in only the 11 metro areas where it is used will most likely result in a failed auction.
      1. The value of the spectrum is diminished by the fact that it is only available in some of the markets and nowhere else.
  • It is questionable if this spectrum is even usable for mobile broadband services because of the technical requirements of antenna size and battery life for devices.
    1. Further, the cost to add this spectrum to user devices for use only within a specific region does not seem to be economically feasible.
  • There is no other spectrum for existing T-Band users.
    1. The balance of the public safety spectrum in these areas is, for the most part, already licensed.
  • The idea that FirstNet will be 100-percent mission-critical and offer both on and off-network Mission Critical Push-To-Talk (MCPTT) by 2021 cannot be guaranteed. There is no way any of these agencies could simply plan to join FirstNet for all of their dispatch, routine, and incident communications. So what are they going to do?

Where We Are Today

The NPTSC initial report and update reports paint a very clear picture of the logistics and costs involved in relocating existing T-Band users. The FCC, which has received both reports, is not in a position to implement changes to a law that was passed by Congress and signed by the President. The only relief for this issue will have to come from Congress itself.

So far, all of the requests made to Congress, and they are numerous and repeated, have been met with little if any interest in correcting the problem. If this law remains as it is today, the way it is written essentially requires public safety to migrate off the channels prior to any auction and perhaps there will be funds from the auction to pay for the move (or not) if there was anywhere to move! If agencies wait until the auction is completed and funds are (or are not) made available, relocating somewhere else in the spectrum, even if there was room, would take considerably longer than 2 years. Note that the FCC has granted the TV stations being relocated by the 600-MHz auctions 36 months to move to a lower channel and this involves a single transmitter, as compared to hundreds of radio base stations and thousands of mobile and portable radios.

At the moment, it appears as though this Congress won’t entertain the idea of rescinding the T-Band give-back, we have nowhere for these users to go, and the clock is ticking.

My Suggestion

Recently I have been considering an approach that might, in fact, be agreeable to Congress. What if the public safety community were to request an extension of the time before the move is required as opposed to repealing the law? I think a five-year extension would provide enough time to figure out if FirstNet will be capable of handling the traffic in these 11 heavily congested metro areas, or if the FCC can find additional spectrum (and funds) for relocation elsewhere.

I have to believe this extension of time rather than a full reversal of this portion of the law will be easier to sell to Congress, the Executive Branch, and the FCC. It is in keeping with FirstNet/AT&T statements that FirstNet is not designed to replace LMR but to augment it. If T-Band users are required to relocate and the only place they have to go is FirstNet in the timeframe currently allocated, I do not believe the network will be able to absorb these users nor will the network be able to provide full mission-critical services including off-network unit-to-unit communications (see my Article on LMR/LTE PTT ).

Conclusions

I have shared my idea with several well-respected people who have been instrumental in the creation and development of FirstNet and the network and so far the idea has been met with positive responses. I believe that if Public Safety decides this may offer a sensible solution to the T-Band problem they can bring their clout to bear just as we did prior to the law being passed. I would think both FirstNet and AT&T would support this plan because it will provide more time to prove the network is or is not capable of being the one and only mission-critical network needed by public safety.

At the end of the day, of course, it is the public safety community that needs to be fully confident in FirstNet’s capabilities and trust their lives to the network. It certainly would be better if T-Band users had a five-year reprieve in order to ensure that the optimism surrounding FirstNet is warranted and also to give AT&T more time to make sure all the multiplicity of pieces that must come together to make this network truly mission-critical and a success are in place and working.

I am ready to start promoting this concept. Who will join me?

Andrew M. Seybold
©Andrew Seybold, Inc.

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