Is Your FCC Part 90 VHF-UHF Radio System Narrowband Ready?

In December 2004, the FCC issued an Order mandating that all Part 90 business, educational, industrial, public safety, and state and local government VHF (150 – 174 MHz) and UHF (421 – 512 MHz) private land mobile radio (PLMR) licensees convert their radio system operations from legacy wideband (25 kilohertz) to narrowband (12.5 kilohertz or equivalent) operation by Jan. 1, 2013. That date is now just over 3 years away.

Contrary to what some may have heard or been led to believe, the Order does not require licensees to change to new radio frequencies or different frequency bands, nor does it require moving from analog to digital or from a conventional to a trunked radio system. However, they are options that some licensees may want to more fully explore with the guidance of a qualified radio communications system professional. The Order also doesn’t mean that licensees need to replace all their current radio system equipment — only any soon-to-be-non-compliant equipment.

What the FCC’s mandate does require is that all wideband-only conventional or trunked VHF and UHF radios, including handheld portables, vehicle-mounted mobiles, dispatcher stations, wireless data, telemetry, or supervisory control and data acquisition (SCADA) link radios (called subscriber radios) and any associated wideband-only conventional or trunked base or repeater stations (called infrastructure radios), be replaced with narrowband capable equipment prior to the 2013 date to continue legal use of Part 90 radio frequencies beyond that date. FCC radio system licenses must also be modified to reflect the change to narrowband emissions and operation.

Migration Steps

Over the last several years, in response to the mandate, many licensees have started the narrowband migration process by deploying dual-mode subscriber radios — those capable of both wideband and narrowband operation — as new radios have been added to their systems or as older wideband-only radios were lost, damaged beyond repair or otherwise removed from service. While this strategy is a practical, cost-effective approach, particularly by those with large numbers of subscriber radios in their fleets or those with multiple radio frequencies, base stations and repeaters in their systems, this method addresses only the first step of a multi-step process.

Unless a radio system is initially implemented as a narrowband system - as most new systems have been during the past eight to ten years - many dual-mode replacement subscriber radios deployed into pre-mandate or older, conventional or trunked VHF or UHF radio systems have typically been programmed for wideband rather than narrowband operation. This best-practices method was necessary to retain compatibility with existing wideband subscriber and infrastructure radios in use in those systems. (NOTE: the mixing of wideband and narrowband radios on the same frequency of a system is generally not encouraged nor recommended. Doing so has the potential to render most voice - and especially data - transmissions between wideband and narrowband radios unintelligible, distorted or unreliable). The method also allowed the expense of replacing infrastructure radios at the same time to be deferred, as the year 2013 seemed a long way off.

In many instances, however, the need to address the deferred replacement of wideband-only infrastructure radios may have inadvertently been overlooked or even forgotten by some licensees or radio system managers. This is particularly true when it comes to the many smaller business, educational, and industrial users of two way radio who typically don't keep up with current FCC Rules or the responsibilities that go along with being a Part 90 licensee, and, who quite often simply take the use and benefit of their radio systems for granted. Consider this post a "wake-up" call to all licensees that, until all subscriber and infrastructure radios are fully migrated to narrowband operation, many radio systems may still be operating in the wideband mode, which is legal only until Jan. 1, 2013.

Migration Planning

Has your company or organization developed a migration plan and budget to address the next steps necessary to complete the narrowband migration process and become fully FCC compliant? These steps include replacing any remaining wideband-only subscriber radios still being used; procuring and installing narrowband base stations, repeaters or other infrastructure radios as needed; preparing a well-planned, coordinated approach to re-programming all radios to narrowband operation; and modifying a radio station license to reflect any new emissions designators. Click here for more migration suggestions.

The 2013 date isn’t that far away, particularly if funding needs to be secured and budgets prepared or, when any operations dependent on uninterrupted radio communications may be jeopardized. Companies and organizations that recognize and appreciate the value of their Part 90 two-way voice and data radio communications systems are advised not to wait until the last minute to begin or complete the narrowbanding process. By waiting, they are risking not only the loss of use of their current radio frequencies, but the return on the investment (ROI) and associated benefits provided by their radio system equipment as well.

More Information

Follow these two links to official documents and complete background information on the FCC’s narrowbanding mandate:

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-292A1.pdf (2004 Order)

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-271692A1.pdf (2007 Update)

For on-line discussions regarding the mandate, licensees and other interested parties are invited to join the LMR Narrowbanding Yahoo! Group

Additional Part 90 Narrowbanding information and resources are also available here: http://www.wirelessradio.net


NR

IP to kill radio in public safety market

It's absolutely amazing (and disturbing) to see these types of what could be deemed mis-leading if not mis-representative articles from so-called industry experts who should know better.

Mr. Filipowski must be what some would call a "futurist". Who knows - perhaps many of his predictions will come to pass in the distant future but, after reading (and re-reading) this article several times to convince myself that he actually said what he said, I'd suggest that his BER needs some immediate attention in the interim.

He is way off-frequency when it comes to his belief that 1) radio is obsolete; 2) IP technology will replace radio; and 3) that cellular/public networks are public safety's salvation.

It might do him some good to get out of his lab and into the real world sometime soon - before making himself look any more foolish than he already has.

NR

Tweet the FCC on Twitter

To stimulate public dialogue over the development of a National Broadband Plan, (GN Docket 09-51) the Federal Communications Commission (FCC) has initiated a new blog called "Blogband." The blog will chronicle the development of the broadband plan and invites comments from its readers.

Take a look here: http://blog.broadband.gov/

And, the Commission also has joined the Twitter revolution:

http://www.twitter.com/fccdotgov

Nice to see the folks on the 8th floor at the Portals finally making an effort - albeit a somewhat radical one - to reach out to America (and the rest of the world as well), particularly in view of the way former Chairman Martin communicated with the public.

I'm sure the "new" FCC will get much more "dialog" and "stimulation" than they may be expecting from these initiatives once the general public discovers them (there are already over 10,000 responses to the Broadband Plan on the FCC's ECFS site). There's no doubt that both of these new sites will be ones to keep your eye on.

NR

Senate Committee ok's "Spectrum Chaos"

Today (08/05/2009) a Senate Committee ok'd the use of cell phone "jammers" in prisons. Here's the committee's press release with an overview of the bill:

Senate Commerce, Science, and Transportation Committee Cellular Jammer Press Release

Which has prompted this "spurious emission"....

Ok, everyone - calm down a moment and read the press release (above) Yes, the lid to Pandora's Box may have been cracked open a bit today but the good news is that jammer devices have NOT been approved by the full Congress or the FCC - yet. However, because of the actions of this Senate committee, we as an industry need to work even harder to keep their bill from ever becoming law.

NOW - today - is the time for those seriously concerned about this matter to "express themselves" - before this nonsense is allowed to go very much further and the lid to Pandora's Box actually is opened completely with the possible legal approval of these "spectrum chaos" causing devices.

If you care, you need to speak out now before it's too late. Here are a couple of links with contact info to help get you started:

U.S. Senate Contact Info

U.S. House of Representatives Contact Info


I hope many of you will join me in "expressing" yourself to your Congressional Representative.


NR

GAO to FCC & DHS - Improve Emergency Communications & Collaboration

The following was excerpted from a recently released United States Government Accountability Office (GAO) Report to the Chairman, Subcommittee on Communications, Technology, and the Internet, Committee on Commerce, Science & Transportation, United States Senate titled

"EMERGENCY COMMUNICATIONS - Vulnerabilities Remain and
Limited Collaboration and Monitoring Hamper Federal Efforts"

"Limited collaboration and monitoring jeopardize federal emergency communications efforts, even as the federal government has taken strategic steps to assist first responders. Federal agencies have demonstrated limited use of some best practices that GAO previously reported as helpful for addressing issues like emergency communications. Delays in establishing the Emergency Communications Preparedness Center, which would help define common goals and mutually reinforcing strategies—two collaboration best practices—undermine the National Emergency Communications Plan’s implementation. DHS and FCC have also not applied these practices in FCC’s effort to promote a public safety network for emergency communications. Agency officials reported it was either too early or not the agency’s responsibility to use these best practices in developing this network. DHS did not submit formal comments to FCC and FCC officials described its proposed network as separate from DHS emergency communications efforts. However, GAO found potential opportunities to align these agencies’ efforts. Another collaboration best practice is leveraging resources, which DHS has done in providing emergency communications technical assistance and planning guidance. But efforts have focused on state and local jurisdictions and less on federal agencies, some of which lack formal emergency communications plans. Monitoring is also crucial in helping agencies meet goals."

You'll need to read the report to learn what the four recommendations made to improve federal agencies’ collaboration and monitoring in efforts related to emergency communications were.

NR

Spectrum Policy in the Age of Broadband: Issues for Congress

A little light reading from the Congressional Research Service (CRC) for those at all interested in or even a bit concerned about the future of the RF spectrum from a policy standpoint.....

Spectrum Policy in the Age of Broadband: Issues for Congress

Summary

The convergence of wireless telecommunications technology and Internet protocols is fostering new generations of mobile technologies. This transformation has created new demands for advanced communications infrastructure and radio frequency spectrum capacity that can support high-speed, content-rich uses. Furthermore, a number of services, in addition to consumer and business communications, rely at least in part on wireless links to broadband backbones. Wireless technologies support public safety communications, sensors, medicine and public health, intelligent transportation systems, electrical utility smart grids, and many other vital communications.

Existing policies for allocating and assigning spectrum rights may not be sufficient to meet the future needs of wireless broadband and national broadband policy. A challenge for Congress is to provide decisive policies in an environment where there are many choices but little consensus. In formulating spectrum policy, mainstream viewpoints generally diverge on whether to give priority to market economics or social goals. Regarding access to spectrum, economic policy looks to harness market forces to allocate spectrum efficiently, with spectrum license auctions as the driver. Social policy favors ensuring wireless access to support a variety of social objectives where economic return is not easily quantified, such as improving education, health services, and public safety. Both approaches can stimulate economic growth and job creation. Choices about the direction of policy, however, can favor some industries over others.

Deciding what weight to give to specific goals and setting priorities to meet those goals pose difficult tasks for federal administrators and regulators and for Congress. Meaningful oversight or legislation may require making choices about what goals will best serve the public interest. Relying on market forces to make those decisions may be the most efficient and effective way to serve the public but, to achieve this, policy makers may need to broaden the concept of what constitutes competition in wireless markets.

This report considers the possibility of modifying spectrum policy: (1) to support national goals for broadband deployment by placing more emphasis on attracting new providers of wireless broadband services; and (2) to accommodate the wireless broadband needs of industries that are considered by many to be the economic drivers of the future, not only communications, but also areas such as energy, health care, transportation, and education.

Among the spectrum policy initiatives that have been proposed in Congress are: allocating more spectrum for unlicensed use; auctioning airwaves currently allocated for federal use; and devising new fees on spectrum use, notably those collected by the Federal Communications Commission (FCC). The FCC’s statutory authority to implement these measures is limited. Substantive modifications in spectrum policy would almost surely require congressional action. The Radio Spectrum Inventory Act introduced in the Senate (S. 649, Senator Kerry) and the similar House introduced Radio Spectrum Inventory Act (H.R. 3125, Representative Waxman) would require an inventory of existing users on prime radio frequencies, a preliminary step in evaluating policy changes. The FCC also has the opportunity to establish a new course for spectrum policy in the preparation of a Congressionally mandated report on broadband policy, due in February 2010.


NR

Cell Phone "Jammers" = "Pandora's Box"

If you are one of those who are thinking of purchasing a so-called "signal blocker" or cell 'phone "jammer" -- an electronic device designed to curb the real or perceived inappropriate use of wireless phones in restaurants, theaters, commuter trains, hospitals, and other similar public gathering places -- and, which are being advertised and sold on numerous Internet web sites, you may not know or realize that such devices (with certain well-defined exceptions) are nonetheless illegal to use in the United States.


I won't bore you with a long dissertation on the supposed pros and cons of the devices or the consequences that could result from the unchecked and potentially dangerous use of them. Rather, I have chosen to share the following pertinent excerpts from the U.S. government and the FCC for your information instead.


FCC Public Notice DA # 05-1776 - June 27, 2005

Sale or Use of Transmitters Designed to Prevent, Jam or Interfere
with Cell Phone Communications is Prohibited in the United States

http://www.fcc.gov/eb/Public_Notices/DA-05-1776A1.html

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-1776A1.pdf


Additionally, below are what appear to be the applicable Rules regarding "signal" or "cellular jamming" or similar devices. Perhaps the Commission should be sharing this information with those who apparently are in violation both Section 302 [47 U.S.C. 302], Section 333 [U.S.C 47 333] and, possibly other sections of the Act?

Communications Act of 1934, as
Amended by the Telecommunications Act of 1996

TITLE III--PROVISIONS RELATING TO RADIO
PART I--GENERAL PROVISIONS

SEC. 302. [47 U.S.C. 302] DEVICES WHICH INTERFERE WITH
RADIO RECEPTION.

(b) No person shall manufacture, import, sell, offer for sale, or
ship devices or home electronic equipment and systems, or use
devices, which fail to comply with regulations promulgated
pursuant to this section.

SEC. 333. [47 U.C.S. 333] WILLFUL OR MALICIOUS INTERFERENCE.

No person shall willfully or maliciously interfere with or
cause interference to any radio communications of any station
licensed or authorized by or under this Act or operated by the
United States Government.

TITLE V -- PENAL PROVISIONS -- FORFEITURES

SEC. 501. [47 U.S.C. 501] GENERAL PENALTY.

Any person who willfully and knowingly does or causes or suffers
to be done any act, matter, or thing, in this Act prohibited or
declared to be unlawful, or who willfully and knowingly omits or
fails to do any act, matter, or thing in this Act required to be
done, or willfully and knowingly causes or suffers such omission
or failure, shall upon conviction thereof, be punished for such
offense, for which no penalty (other than a forfeiture) is provided
in this Act, by a fine of not more than $10,000 or by imprisonment
for a term not exceeding one year, or both; except that any person,
having been once convicted of an offense punishable under this
section, who is subsequently convicted of violating any provision
of this Act punishable under this section, shall be punished by a
fine of not more than $10,000 or by imprisonment for a term not
exceeding two years, or both.

SEC. 502. [47 U.S.C. 502] VIOLATION OF RULES, REGULATIONS,
AND SO FORTH.

Any person who willfully and knowingly violates any rule,
regulation, restriction, or condition made or imposed by the
Commission under authority of this Act, or any rule, regulation,
restriction, or condition made or imposed by any international
radio or wire communications treaty or convention, or regulations
annexed thereto, to which the United States is or may hereafter
become a party, shall, in addition to any other penalties provided
by law, be punished, upon conviction thereof, by a fine of not
more than $500 for each and every day during which such offense
occurs.

SEC. 510. [47 U.S.C. 510] FORFEITURE OF COMMUNICATIONS DEVICES.

(a) Any electronic, electromagnetic, radio frequency, or similar
device, or component thereof, used, sent, carried, manufactured,
assembled, possessed, offered for sale, sold, or advertised with
willful and knowing intent to violate section 301 or 302, or
rules prescribed by the Commission under such sections,
may be seized and forfeited to the United States.

The text of the entire Act can be found here:

http://www.fcc.gov/Reports/1934new.pdf


In view of the above, consider yourselves forewarned about the use of "jammers" ......because spectum matters.


NR

Defining the "Harm" in "Harmful Interference"

Here's a post from CommLawBlog which readers might find both interesting and informative when it comes to radio and wireless communications system interference....

(Excerpt): "The concept of “harmful interference” is central to FCC spectrum policy. (It might surprise you however, that) the FCC has never said just what the term means. Oddly, though, that might be a good thing.

Nearly every band of the radio spectrum is shared among two or more categories of users. If we think of the spectrum as being spread out horizontally, the users of each band are stacked vertically. To see how this looks, click here.

Each band has a predetermined pecking order among its users: primary, secondary, and unlicensed. The relationships among all of these turn on harmful interference. Specifically:

• “Primary” users are protected against harmful interference from all other users.
  
  
• “Co-primary” users – services in the same band jointly designated as primary – may not cause harmful interference to each other.
  
  
• "Secondary” users may not cause harmful interference to primary users, and must accept harmful interference from primary users.
  
  
• Unlicensed users may not cause harmful interference to primary or secondary users, and must accept harmful interference from everybody.

The notion of harmful interference being key to the whole enterprise, we might expect to find a crisp and objective definition in the FCC rules. But when we look, we find something else. " (End excerpt)

Take a few minutes to learn more about the often mis-understood element of "harmful interference" - which is found in all radio and wireless communications systems - and the criteria that the FCC uses to help define it, here:

http://www.commlawblog.com/2009/01/articles/broadcast/finding-the-harm-in-harmful-interference/

It's actually a pretty tough job these days, especially when spectrum matters....

See http://en.wikipedia.org/wiki/Spectrum_management for more insight.

NR

Latest Wireless Absurdity from Congress

Politicians on Thursday (02/19/09) called for a sweeping new federal law that would require all Internet Service Providers (ISP's) and operators of millions of Wi-Fi access points, including hotels, local coffee shops, and private in-home users, to keep records about users who access their networks for two years to aid police investigations. They even have come up with a silly acronym so that the title of the bill - Internet Stopping Adults Facilitating the Exploitation of Today's Youth Act - spells out "Internet SAFETY Act."

More on this absurdity here:


http://news.cnet.com/8301-13578_3-10168114-38.html?part=rss&subj=news&tag=2547-1\
_3-0-20


Geeez...and to think we elected some of these folks. What's the matter with us, anyway? Would someone explain to me just how this law will help prevent the "exploitation of today's youth"? IMHO, the promoters of this legislation have either lost track of reality or, are suffering from a high BER. (Actually, it's probably some of both!)


NR