FCC Grants First Narrowbanding Waiver to St Louis Urban Area

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FCC Grants First Narrowbanding Waiver to Missouri Petitioners (2/21/12)
The FCC granted the first waiver of the Jan. 1, 2013, VHF/UHF narrowbanding deadline to the Missouri counties of St. Louis and St. Charles, the Jefferson County 9-1-1 Dispatch Board and the East-West Gateway Council.
The FCC’s narrowbanding mandate requires private land mobile radio licensees in the 150 – 174 MHz and 450 – 512 MHz bands to operate using channel bandwidth of no more than 12.5 kilohertz.
The waiver extends the narrowbanding deadline to Dec. 31, 2013, with two conditions. The first condition requires any licensee in the St. Louis Urban Area seeking to have the waiver apply to its facilities to file a letter within 90 days confirming that it consents to the terms of the waiver order and agrees to them. The second condition requires the petitioners to file within six months of the order a list of VHF/UHF frequencies and licenses that will be relinquished.
The waiver requests encompassed multiple VHF and UHF authorizations in the petitioners’ respective jurisdictions. The petitioners are members of the St. Louis Urban Area, which is in the process of constructing a multicounty interoperable 800 MHz radio system.
The jurisdictions said they passed sales tax initiatives to secure funding for the new 800 MHz system, which has an FCC-approved extended implementation schedule until Dec. 31, 2013. The counties intend to transition their VHF/UHF operations that are the subject of the waiver requests onto the new system and subsequently will vacate their UHF and VHF authorizations.
However, because the new system will not be operational by the Jan. 1, 2013, narrowbanding deadline, the petitioners sought a waiver of the deadline until the end of 2013 to avoid having to divert financial, technical and administrative resources to narrowbanding of their existing VHF and UHF systems pending the transition.
“If we were to strictly apply the narrowbanding rules, petitioners would be required to expend significant financial and administrative resources to narrowband their existing VHF/UHF wideband facilities by January 1, 2013, even though they plan to decommission these facilities and vacate their VHF/UHF frequencies no more than twelve months later when they migrate to the new 800 MHz system,” said the FCC in its order. “We conclude that strict enforcement of the narrowbanding deadline under these circumstances would not serve the underlying purpose of the rule and that a waiver would be in the public interest.”
The commission noted the petitioners met several factors identified in its Narrowbanding Waiver Guidance Notice, including demonstrating diligence in planning and implementing their transition to the 800 MHz band; showing that the waiver will not harm neighboring systems or impair interoperability during the waiver period; and committing to relinquish substantial VHF/UHF spectrum once migration to the new 800 MHz system is complete.
In related action, the commission released a public notice to provide additional guidance to parties seeking waivers of the narrowbanding deadline for the 150 – 174 and 421 – 512 MHz bands.
“Specifically, we recommend that licensees seeking waivers ensure that their submissions include, or are amended to include, a definitive list of the frequencies for which they are seeking a waiver, a list of frequencies that will be relinquished (if applicable, e.g. if the licensee intends to migrate to the 700 MHz or 800 MHz band and relinquish VHF/UHF spectrum), and representations from all licensees covered by the waiver request that they have committed to take any actions that form the basis for the waiver justification.”
Additional information about narrowbanding is available here.
Your comments






St. Louis Narrowband Waiver

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Published February 21st, 2012
Federal Communications Commission
DA 12-245
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
)
)
County of St, Louis St. Louis County, Missouri,
)
WT Docket 99-87
St. Charles County, Missouri, Jefferson County 9-
)
1-1- Dispatch Board of Jefferson County,
)
Missouri, the East-West Gateway Council of
)
Governments
)
)
Request for Waiver of Section 90.209(b) of the
)
Commission’s Rules
)
ORDER
Adopted: February 21, 2012
Released: February 21, 2012
By the Chief, Public Safety and Homeland Security Bureau:
I.
INTRODUCTION
1.
We have before us the requests of St. Louis County, Missouri (St. Louis County); St.
Charles County, Missouri (St. Charles County); the Jefferson County 9-1-1 Dispatch Board of Jefferson
County, Missouri (Jefferson County); and the East-West Gateway Council of Governments (collectively,
Petitioners),1 for a waiver until December 31, 2013, of the Commission’s January 1, 2013 VHF/UHF
narrowbanding deadline, which requires private land mobile radio licensees in the 150-174 MHz and 450-
512 MHz bands to operate using channel bandwidth of no more than 12.5 kHz or equivalent efficiency by
January 1, 2013.2 By this Order, we conditionally grant the Waiver Requests.
II.
BACKGROUND
2.
Petitioners operate multiple VHF and UHF facilities in their respective jurisdictions that
are the subject of the Waiver Requests.3 Petitioners are also members of the St. Louis Urban Area, which


1 See Request for Waiver of Commission Rules, filed September 3, 2010, updated June 17, 2011, by the County of
St. Charles, Missouri and the East-West Gateway Council of Governments (St. Charles Waiver Request); Request
for Waiver of Commission Rules, filed September 3, 2010, updated June 17, 2011, by the County of St. Louis,
Missouri and the East-West Gateway Council of Governments (St. Louis Waiver Request); and Request for Waiver
of Commission Rules, filed September 3, 2010, updated June 17, 2011, by Jefferson County 911 Dispatch of St.
Jefferson County, Missouri and the East-West Gateway Council of Governments (Jefferson Waiver Request). The
East-West Gateway Council of Governments (East-West Gateway Council), which has no FCC authorizations, is an
umbrella agency responsible for implementing the Land Mobile Communications Plan of the St .Louis Urban Area.
The East-West Gateway Council filed a status update on the Petitioners’ progress on June 17, 2011. See also
Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as Amended; Promotion of Spectrum
Efficient Technologies on Certain Part 90 Frequencies, Third Memorandum Opinion and Order and Third Further
Notice of Proposed Rule Making and Order, WT Docket No. 99-87, RM-9332, 19 FCC Rcd 25045 (2004).
2 47 C.F.R § 90.209(b)
3 St. Louis County seeks waivers for 222 frequencies held by 73 licensees. St. Louis Waiver Request at 7, Appendix
B. St. Charles County seeks waivers for 215 frequencies held by 15 licensees. St. Charles Waiver Request at 7,
Federal Communications Commission
DA 12-245
is in the process of constructing a multi-county interoperable 800 MHz radio system.4 Petitioners note
that they have passed sales tax initiatives to secure funding for the new system,5 which has a
Commission-approved extended implementation construction schedule until December 31, 2013.6
Petitioners state that upon completion of the 800 MHz system, they intend to transition their VHF/UHF
operations that are the subject of the Waiver Requests onto the new system and will vacate their
associated VHF and UHF authorizations.7 However, because the new system will not be operational by
the January 1, 2013 narrowbanding deadline, Petitioners seek a waiver of the deadline until December 31,
2013 to avoid having to divert financial, technical, and administrative resources to narrowbanding their
existing VHF/UHF facilities pending the transition.8
3.
On November 12, 2011, the Public Safety and Homeland Security Bureau (Bureau)
issued a Public Notice seeking comment on the Waiver Request.9 We received comments from the
Region 24 800 MHz Regional Planning Committee (Region 24)10 and joint comments from the
International Municipal Signal Association (IMSA) and International Association of Fire Chiefs
(IAFC).11 Region 24 supports the Waiver Requests but expresses two concerns. First, Region 24 states
that it has requested but has yet to receive a list of VHF/UHF frequencies and licenses that each Petitioner
will relinquish when construction of the 800 MHz system is completed.12 Second, Region 24 notes that
many of the VHF/UHF licenses in the Petitioners’ counties are held by agencies other than the Petitioners
and that Petitioners have proposed no mechanism to ensure that these agencies will relinquish VHF/UHF
spectrum.13 IMSA and IAFC also support the Waiver Requests but question whether it is necessary for
the Bureau to issue a narrative public notice seeking comment each time a licensee files a request for
waiver of the narrowbanding deadline.14
III.
DISCUSSION
4.
Petitioners seek relief pursuant to Section 1.925 of the Commission’s rules, which
provides that to obtain a waiver of the Commission’s rules, a petitioner must demonstrate either that: (i)





Appendix B. Jefferson County seeks waivers for 274 frequencies held by 27 licensees. Jefferson Waiver Request at
7, Appendix B.
4 The St. Louis Urban Area consists of the Missouri counties of Franklin, Jefferson, St. Charles, St. Louis, the
independent City of St. Louis, and the Illinois counties of Madison, Monroe, and St. Clair. See Jefferson Waiver
Request at 2-3, fn. 2.
5 St. Louis Waiver Request at 5; Jefferson Waiver Request at 5; St. Charles Waiver Request at 5.
6 St. Louis Waiver Request at 5, 8; St. Charles Waiver Request at 5, 8; Jefferson Waiver Request at 5, 8.
7 St. Charles Waiver Request at 8; St. Louis Waiver Request at 8; Jefferson Waiver Request at 8.
8 St. Charles Waiver Request at 7; St. Louis Waiver Request at 7; Jefferson Waiver Request at 7.
9 See Public Safety and Homeland Security Bureau Seeks Comment on Requests for Waiver Of The January 1, 2013
VHF-UHF Narrowbanding Deadline Filed By St. Louis County, Missouri, St. Charles County, Missouri, Jefferson
County 9-1-1 Dispatch Board and The East-West Gateway Council Of Governments, Public Notice, DA 11-1784
(rel. Oct. 26. 2011).
10 Region 24 is the State of Missouri, which includes the Petitioners’ jurisdictions.
11 Comments of the Region 24 800 MHz Regional Planning Committee, filed Nov. 9, 2011 (Region 24 Comments);
Comments of the International Municipal Signal Association and the International Association of Fire Chiefs, filed
Nov. 10, 2011 (IMSA/IAFC Joint Comments).
12 Region 24 Comments at 2.
13 Id. at 2-3.
14 IMSA/IAFC Joint Comments at 6-9.
2
Federal Communications Commission
DA 12-245
the underlying purpose of the rule(s) would not be served or would be frustrated by application to the
present case, and that a grant of the waiver would be in the public interest;15 or (ii) in view of unique or
unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly
burdensome, or contrary to the public interest or the applicant has no reasonable alternative.16 Applying
this standard to narrowbanding, we have stated in the Narrowbanding Waiver Guidance Notice, jointly
issued by the Wireless Telecommunications Bureau, the Public Safety and Homeland Security Bureau,
and the Office of Engineering and Technology, that narrowbanding waiver requests “will be subject to a
high level of scrutiny” under the waiver standard.17 We have also provided recommended guidance on
the factors that licensees should address in their requests and have recommended that in addressing these
factors, licensees should seek to demonstrate that “(i) they have worked diligently and in good faith to
narrowband their systems expeditiously; (ii) their specific circumstances warrant a temporary extension of
the deadline; and (iii) the amount of time for which a waiver is requested is no more than is reasonably
necessary to complete the narrowbanding process.”18
5.
Based on the record before us, we conclude that Petitioners have presented sufficient
facts to meet the high standard for grant of the requested waiver, subject to several conditions discussed
below. The record shows that Petitioners have been planning since 2007 to migrate their VHF/UHF
public safety communications operations to the 800 MHz band.19 Migrating to the new multi-county 800
MHz system will increase the reliability of public safety communications and will significantly improve
interoperability among the multiple jurisdictions operating in the St. Louis Urban Area. Ideally,
Petitioners would be able to complete construction of the 800 MHz system in time to migrate their
VHF/UHF operations before the narrowbanding deadline. However, Petitioners indicate that it will take
until December 31, 2013, a year after the narrowbanding deadline, to complete the new system due to its
size and complexity.20
6.
If we were to strictly apply the narrowbanding rules, Petitioners would be required to
expend significant financial and administrative resources to narrowband their existing VHF/UHF
wideband facilities by January 1, 2013, even though they plan to decommission these facilities and vacate
their VHF/UHF frequencies no more that twelve months later when they migrate to the new 800 MHz
system. We conclude that strict enforcement of the narrowbanding deadline under these circumstances
would not serve the underlying purpose of the rule and that a waiver would be in the public interest. In
reaching this conclusion, we place significant weight on the showing that Petitioners have made with
respect to the factors identified in our Narrowbanding Waiver Guidance Notice.
7.
First, Petitioners have shown diligence in planning for and implementing their transition
to the 800 MHz band, which will enable them to decommission their existing wideband facilities and
vacate their VHF/UHF frequencies.21 Planning for the transition began five years ago, and Petitioners
have provided for funding of the new system through local sales taxes. Based on the size and complexity


15 47 C.F.R. § 1.925(b)(3)(i).
16 47 C.F.R. § 1.925(b)(3)(ii).
17 Wireless Telecommunications Bureau, Public Safety And Homeland Security Bureau, And Office Of Engineering
And Technology Provide Reminder Of January 1, 2013 Deadline For Transition To Narrowband Operations In The
150-174 MHz And 421-512 MHz Bands And Guidance For Submission Of Requests For Waiver And Other
Matters, Public Notice, 26 FCC Rcd 9647 (2011) (Narrowbanding Waiver Guidance Notice).
18 Id. at 9649.
19 St. Louis Waiver Request at 5; St. Charles Waiver Request at 5; Jefferson Waiver Request at 5.
20 St. Louis Waiver Request at 6; St. Charles Waiver Request at 6; Jefferson Waiver Request at 6.
21 Narrowbanding Waiver Guidance Notice, 26 FCC Rcd 9647, 9649.
3
Federal Communications Commission
DA 12-245
of the new system, Petitioners have submitted and received Commission approval for an extended
implementation schedule until December 31, 2013.22 Under these circumstances, we conclude that the
one-year waiver period requested by Petitioners is no more than is reasonably necessary to vacate their
existing VHF/UHF facilities.23
8.
Second, the record indicates that grant of the waiver will not harm neighboring systems
or impair interoperability during the one-year waiver period.24 Because the waiver will cover most
VHF/UHF operations in the St. Louis Urban Area, we find no indication that it will have any negative
impact on co-channel or adjacent channel VHF/UHF operations.
9.
Third, Petitioners plan to relinquish substantial VHF/UHF spectrum once Petitioners and
other licensees migrate to the new 800 MHz system.25 Grant of the waiver will avoid the diversion of
Petitioners’ financial, technical, and administrative resources to narrowbanding their existing VHF/UHF
facilities pending the transition to the 800 MHz band and will allow Petitioners to devote their resources
to decommissioning their existing wideband facilities and vacating their VHF/UHF frequencies. This
will facilitate efficient use of scarce VHF/UHF spectrum and free up capacity for potential new spectrum
users, which are key goals of the narrowbanding program.26 Petitioners have shown that these
circumstances support a temporary extension of the deadline.
10.
However, while the Petitioners represent the interests of multiple licensees, we agree with
Region 24 that they lack the authority to legally bind all of the licensees whose authorizations are the
subject of this waiver request.27 Thus, as a condition of the waiver, we require that each individual
licensee in the St. Louis Urban Area that seeks the benefit of the waiver relief granted by this Order must
submit to the Commission, within 90 days of the release date of this Order, a letter confirming that, as
represented in Petitioners’ waiver requests, it consents to the terms of this Order and will transition its
operations to the new 800 MHz system and, upon doing so, relinquish any VHF/UHF spectrum for which
it has obtained relief under this Order. Licensees should attach these letters to their licenses via the
Commission’s Universal Licensing System (ULS). Any licensee that does not file such a letter in ULS
will not be afforded the waiver relief granted by this Order and therefore must comply with the January 1,
2013 narrowbanding deadline.
11.
Further, Petitioners have not yet identified the exact scope of the existing VHF/UHF
frequencies and licenses that each county will relinquish by December 31, 2013, or of the VHF/UHF
frequencies and licenses that each county intends to retain and narrowband by the January 1, 2013


22 See St. Louis Waiver Request, Appendix E, St. Charles Waiver Request, Appendix C; Jefferson Waiver Request,
Appendix C. The Bureau’s approval of extended implementation is attached to each authorization in ULS.
23 See Narrowbanding Waiver Guidance Notice, 26 FCC Rcd at 9649 (waiver applicant should show that “the
amount of time for which a waiver is requested is no more than is reasonably necessary to complete the
narrowbanding process”).
24 See id (waiver applicant should show “[p]lans to minimize the negative impact of extended wideband operations
on co-channel and adjacent channel operations”).
25 See id. (waiver applicant migrating to a non-VHF/UHF band (e.g., 700 MHz or 800 MHz) should indicate
“whether it will relinquish VHF/UHF spectrum once it has migrated and the amount of spectrum to be
relinquished”). Petitioners’ seek a waiver for more than 700 frequencies, see note 3, supra, which they plan to
vacate and relinquish once the licensees transition to their new 800 MHz system.
26 See Replacement of Part 90 by Part 88 to Revise the Private Land Mobile Radio Services and Modify the Policies
Governing Them, Report and Order and Further Notice of Proposed Rule Making, PR Docket No. 92-235, 10 FCC
Rcd 10076, 10077 ¶2 (1995).
27 Region 24 Comments at 3.
4
Federal Communications Commission
DA 12-245
deadline.28 Because our public interest determination in this case rests on the premise that Petitioners
(and the other licensees covered by this Order) will transition to an 800 MHz system and relinquish a
substantial amount of spectrum when they do so, we condition grant of this waiver upon Petitioners
identifying these frequencies and licenses in a list provided to the Commission no later than six months
after the release of this Order.29 This will allow us to ensure, based on the information submitted, that our
expectations in granting this waiver remain justified. A six-month deadline will allow ample time for
licensees other than Petitioners to finalize their lists of frequencies to be relinquished or narrowbanded.
We retain the authority to rescind or modify the waiver if we determine, based on the information
submitted, that it is no longer in the public interest.
12.
We expect that as a general matter in other cases, licensees seeking narrowbanding
waivers will ensure that their submissions include, or are amended to include, a definitive list of the
frequencies for which they are seeking a waiver, a list of frequencies that will be relinquished (if
applicable), and representations from all licensees covered by the waiver request that they have
committed to take any actions that form the basis for the waiver justification. Concurrently with the
release of this Order, we are releasing a Public Notice advising licensees of the need to provide such
information.
13.
Finally, as noted above, IMSA and IAFC question whether the Bureau should place
future narrowbanding waiver requests on individual public notice.30 Because this issue relates to the
Bureau’s future processes rather than the merits of Petitioners’ waiver requests, we do not consider it
here.
IV.
CONCLUSION
14.
Based on the foregoing, we conclude that grant of the requested waiver is in the public
interest subject to the conditions discussed herein. Accordingly, we grant Petitioners a waiver of the
Commission’s January 1, 2013 VHF/UHF narrowbanding deadline until December 31, 2013, subject to
the following conditions: (1) within ninety days of the release of this Order, any licensee in the St. Louis
Urban Area seeking to have the waiver apply to its facilities must file a letter in ULS confirming that it
consents to the terms of this Order and agrees to be bound by them; and (2) within six months of the
release of this Order, Petitioners must file with the Commission a list of VHF/UHF frequencies and/or
licenses that will be relinquished.
V.
ORDERING CLAUSES
15.
Accordingly, IT IS ORDERED pursuant to Section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C. § 154(i), and Section 1.925(b)(3) of the Commission’s rules, 47 C.F.R.
§ 1.925(b)(3), that the Request for Waiver, filed by St. Louis County, Missouri (St. Louis County); St.
Charles County, Missouri (St. Charles County); Jefferson County 9-1-1- Dispatch Board of Jefferson
County, Missouri (Jefferson County); and the East-West Gateway Council of Governments IS
GRANTED subject to the conditions stated herein.


28 Id. at 2. Region 24 states that Petitioners agreed to provide this information in consideration for its assigning 800
MHz frequencies to Petitioners for their new multi-county system. Id.
29 This list will be made publicly available on the Commission’s Electronic Comment Filing System. As a result, it
is unnecessary to require Petitioners to provide this information directly to Region 24 as Region 24 requested in its
comments.
30 IMSA/IAFC Joint Comments at 6-9.
5
Federal Communications Commission
DA 12-245
16.
This action is taken under delegated authority pursuant to Sections 0.191 and 0.392 of the
Commission’s rules, 47 C.F.R. §§ 0.191, 0.392.
FEDERAL COMMUNICATIONS COMMISSION
James A. Barnett, Jr., Rear Admiral (Ret.)
Chief, Public Safety and Homeland Security Bureau
 

hkrharry

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In other words they will get spanked hard if they don't do it correctly and even harder if they don't give up the channels they say they are going to and convert to P-25 trunking by the end of the year (2013).

They better get their ducks in a row ASAP!

hh
 

polo807

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Re

I know this fourm is about radio communications but here we go again the St.Louis area is FIRST again.
If it is not a crime stats it some other stat that sheds a negetive light on the St. Louis Area.
The word WAIVER I really think that the word has been beaten to death under this current admidistration (Obama) First it was HealthCare and then Imigration and now Radio Communications what's next?
I guest Ol'Jay or Stoolie Dooley called Claire and Claire called her buddy Obobo.Wham Bam
WAIVER. I guest Illinois or California will be next.
 
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kruser

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I found the number of frequencies to be much larger than I imagined.
I wonder where one can find the list of frequencies that will be relinguished when they do turn the new system on?

It seems they have some six months to provide this freuqncy list so I guess we will need to wait a while before we can see that info huh?
It will be an interesting list nontheless as it will show who intends on jumping ship to the new system(s).

If anyone has any info as to an existing list, pleast post a URL.
 
Last edited:

zzdiesel

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I know this fourm is about radio communications but here we go again the St.Louis area is FIRST again.
If it is not a crime stats it some other stat that sheds a negetive light on the St. Louis Area.
The word WAIVER I really think that the word has been beaten to death under this current admidistration (Obama) First it was HealthCare and then Imigration and now Radio Communications what's next?
I guest Ol'Jay or Stoolie Dooley called Claire and Claire called her buddy Obobo.Wham Bam
WAIVER. I guest Illinois or California will be next.
Thank you for telling the cold hard truth.
 

kruser

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I know this fourm is about radio communications but here we go again the St.Louis area is FIRST again.
If it is not a crime stats it some other stat that sheds a negetive light on the St. Louis Area.
The word WAIVER I really think that the word has been beaten to death under this current admidistration (Obama) First it was HealthCare and then Imigration and now Radio Communications what's next?
I guest Ol'Jay or Stoolie Dooley called Claire and Claire called her buddy Obobo.Wham Bam
WAIVER. I guest Illinois or California will be next.
I don't know, I've been receiving "waivers" for many many years for all kinds of things at the Federal, State, County and Local muni levels. Nothing negative about the St. Louis area either!

I don't feel this narrowbanding deadline extension waiver in any way sheds a negative light on the St. Louis area at all.
If anything, it was a brave move for requesting the extension in the first place. I'd bet many agencies or smaller municipalities would have never considered asking figuring they would just get shot down.

If you look at the number of frequencies involved in just this waiver, think about the cost that may have been avoided had all the associated radios needed to have been replaced or reprogrammed only to be switched out to a new 800 MHz radio a few months later. Or else the users could have kept operating wideband in violation of the new rules hoping they did not get caught. I don't know if fines have been set or mentioned for those that are caught operating wideband after the deadline but I'd guess they will not be cheap.

You must remember that the majority of radio systems in our area are VHF systems. There is no cheap way to switch in one move if the 800 MHz system is not ready and that is what they are planning on switching too. Asking for the extension makes sense and will save money that may have otherwise come from our very pockets.

I myself do not see anything wrong with us being the first to ask for and receive an extension to the original narrowbanding deadline. I'm not even certain we asked first either but we were granted the extension first apparently.

What makes you say that this sheds a negative light on the St. Louis area?
I think many will applaud us for being brave and asking if we were indeed the first to ask for an extension of time.

Unrelated to this extension waiver, I also wonder how well todays current crop of radios (scanner radios) with supposed NFM filters will really reject a signal that is setup right next door on one of the new narrow frequencies?

I've tested a few and found a narrowband transmitter bleeds right into the old wideband frequency 12.5 kHz away no matter if you set the radio for NFM or not. In fact, some seem to make no audible difference if set to NFM or FM at all. They simply cannot reject a narrowband signal well enough. I think it may very well create a new problem similar to how intermod sounds on the old double conversion receivers of yesteryear.
There will be no firmware updates that will correct this problem either.

My old Icom R9000 does a much better job at rejecting a narrowband signal right next to the frequency it's tuned too then any of my modern scanners I own do. This worries me.
I think it will be a long time before we see widespread use of the newly created frequencies or channels. Many are moving to 700 or 800 so if anything, VHF High will become more silent than it has been in years.
That's my take on it all anyway.
 
Last edited:

kruser

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In other words they will get spanked hard if they don't do it correctly and even harder if they don't give up the channels they say they are going to and convert to P-25 trunking by the end of the year (2013).

They better get their ducks in a row ASAP!

hh
There is nothing in the narrowbanding mandate that says anyone must convert to P25 trunking.

In this case, yes, if the county has applied for and received a license for digital emmisions only than it looks like that is what they had better do but the narrowbanding mandate itself does not require a digital signal of any kind.
 

zerg901

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The State of Missouri is building a statewide VHF TRS Probably 75% of the land area of Missouri is covered by VHF high band systems. If Saint Charles County and Saint Louis County want to have statewide coverage, they need to be on VHF. Unless they put dual radio systems in every unit, or buy all dual band radios. How much extra will that cost? If they want interops with the Fderalis at all, they need VHF (and probably UHF also).
 

kruser

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The State of Missouri is building a statewide VHF TRS Probably 75% of the land area of Missouri is covered by VHF high band systems. If Saint Charles County and Saint Louis County want to have statewide coverage, they need to be on VHF. Unless they put dual radio systems in every unit, or buy all dual band radios. How much extra will that cost? If they want interops with the Fderalis at all, they need VHF (and probably UHF also).
This is only partially true, the large metro areas will be on the existing 700 or 800 MHz systems only for MOSWIN. I was told the 7/800 MHz repeaters would take care of crossbanding into the VHF system so the users here and there would only need 7/800 radios depending on their local systems.

If you remember when the 800 MHz systems for St. Louis City and Independence, MO came online, they were marked as for the statewide system. This was before the term MOSWIN was even created. Same SysID and everything even though they are located across the state. The same goes for the 700 MHz system out in St. Charles.
The new St. Louis County 800 MHz system is also slated to be a part of the St. Louis City P25 system. Jeffcos license app notes an intertie with the STL system as well.
I was told all of this by a reliable source that is well involved with MOSWIN as well as some users from here.

There will be very little VHF MOSWIN use here in the St. Louis area and I think the same for Kansas City and its surrounding areas.
I think for the scanner hobbiest in these areas, you will monitor MOSWIN on 700 or 800 unless you are lucky enough to pickup one of the neighboring VHF counties.
In the areas that have no 700 or 800 MHz systems in place (most rural ares), they are building out VHF systems for MOSWIN like you said.
I think they already have some crossband equipment in place here to handle interops. At least I've heard some interop from 800 to VHF. Nothing crossing over to UHF though that I've ever heard.
 

jeatock

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How's that old saying go? Lack of planning on your part does not constitute an emergency on mine? Come on guys, the narrowband deadline was announced a decade ago.

My beef with the waiver is that I have public safety clients just outside the STL metro area who HAVE planned and budgeted, haven't spent public funds on something else, saved up their pennies and held fish frys to convert their VHF radios to narrowband. Some of our new freqs are on a narrow-only new channel with STL as the wideband neighbor.

We were promised clear bandwidth by the end of this year (provisos and technical issues apply; don't flame me on this). We can't wait for the day our loud neighbor gets their act together and narrows out of our allocated bandwidth.
 

kruser

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Some of our new freqs are on a narrow-only new channel with STL as the wideband neighbor.

We were promised clear bandwidth by the end of this year (provisos and technical issues apply; don't flame me on this). We can't wait for the day our loud neighbor gets their act together and narrows out of our allocated bandwidth.
This would be a problem if you are using those new narrowband frequencies already or planned on doing so on Jan 1st.
I cannot argue on this one as it is a valid point!

If your old wideband assignments happen to expire during the new deadline period, will they (FCC) allow you to continue using them or will you be forced onto the new narrow asignments even if your neighbor is allowed to operate wideband? I could see this being an issue for those that have expiration dates coming up and must vacate their old wideband frequencies during the new deadline period.

How bad is the bleedover from the STL county signals on your new narrowband frequencies? Is it really horrible or still useable but with some annoying splatter? I'd imagine you have tested even if not using them yet.
 

cifd64

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I agree with jeatock. 1997, it is now 2012. The problem is forward planning is 'not allowed' in government. They wont pay for something that hasnt happened yet. And i have worked for the government for years in both planning and emergency communications. And now I am on the private side. No matter the excuse, you had more than a decade to prepare for this. Its like saying "we know an earthquake will hit 10 years from now, but we will wait till the 11th year to prepare."

Now, as a dealer for over 2 years, I made sure that my clients were aware of this because though the FCC sent letters to LIC holders, nobody reads that crap. We helped them establish budgets for modifying their license, reprogramming and replacing equipment that wont work on 12.5/6.25. I spent the time working with them so there would be no need to file for a waiver.

NOW I have clients coming to me asking about waivers to save money. You know what I tell them? Pay it now or pay it later, one way or another you will have to do this. the only thing that is going to change is the price. Just like the earthquake scenario, it is much cheaper to get it done now.

I could care less about politics, because out by me the Republicans AND Democrats are demanding waivers too. Look at it anyway you want. I sleep better at night by not thinking about it at all.
 

zerg901

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I would like to add just 1 short comment about crossband repeaters. It might be useful to ponder exactly what is needed to bring full VHF coverage and full 700/800 coverage to the entire state. I suspect that either you need dual band mobiles and portables for everyone - or you need full VHF and 800 repeaters at all sites - or someone is going to get shortchanged somewhere someday. If a tornado hits a town 60 miles outside of Saint Louis, and 20 units from St Louis show up with 800 Mhz radios within 1 hour, will they have exactly one and only one 800 Mhz repeater channel to use? Will that be enough channel capacity?

If everyone was forced to narrowband - AND to move to VHF - maybe that would be a good idea.

Please give a little thought to what exactly is needed to provide patches between disparate radio systems. I think that a lot of money has gone down this rathole already - and much more is headed there.
 

ten13

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The narrowbanding process may have been 'in play' for ten years, but in those ten-plus years many, if not most, of the big urban areas are now in a state of financial 'flux,' not having the money to upgrade or even adapt their systems.

Let's keep in mind the number of cops and firemen who have been laid off of late thoughout the country.

With that said, there are reports that the New York City Police Department has also sought a waiver from narrowbanding mandates. Considering that Mayor Bloomberg is constantly threatening closing firehouses, there's little doubt about whether there is money to do anything with the extensive NYPD radio system.
 

cifd64

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Im sorry, but crying poverty is no excuse. We werent laying off firemen and cops 10-12 years ago when the economy was great. It should have been done then! Again, there is no forward planning. The NYPD is no different. They received clost to a billion dollars in grants since 1997, bought new radio systems since, and never thought to just go 12.5 when they installed it?

There will be a lot of excuses, but none are justified with the amount of time given to accomplish narrowbanding.
 

ten13

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"Im sorry, but crying poverty is no excuse."

So what will the FCC do if the NYPD...or any other major department...just says 'no,' and doesn't do anything?: shut their radio system down? Tell them to use telephones because their (perfectly good) radio system just doesn't happen to comply with some technically obscure regulation? Put debilitating fines on them for non-compliance?

Never happen.

One thing we had better all remember: in politics, what happened yesterday....much less a decade ago...has no bearing on what should happen today.

There's an old line in politics, when someone asks a politician for a favor: "What have you done for me....lately?"

Unless the economy turns around DRAMATICALLY in the near future (which it won't), at some point, either the whole narrowband thing will be shelved or compliance will be optional. The list of waivers will be longer than the list of department in compliance.

Let's all get our heads back into the real world of 21st Century economics.
 

iamhere300

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I would like to add just 1 short comment about crossband repeaters. It might be useful to ponder exactly what is needed to bring full VHF coverage and full 700/800 coverage to the entire state. I suspect that either you need dual band mobiles and portables for everyone - or you need full VHF and 800 repeaters at all sites - or someone is going to get shortchanged somewhere s

If everyone was forced to narrowband - AND to move to VHF - maybe that would be a good idea.

Please give a little thought to what exactly is needed to provide patches between disparate radio systems. I think that a lot of money has gone down this rathole already - and much more is headed there.
Zerg.... (shaking my head sadly)

Yeah, if 20 units show up from STL into say, Ellington MO, after it has been wiped clean by a tornado, they have about a dozen simplex channels on 800 - nationwide interop - that they can use to start operations. At the same time I am headed there (or one of my cohorts) with a regional command post that has 800, VHF, UHF and low band capability on PS freqs. It also has a bridge. I will be pulling a portable tower that has a VHF repeater, an 800 Mhz repeater, and other bands, as well as yet another bridge.

Simplex will work quite well, we will use the repeaters and bridges for longer distance. Normally those STL resources will carry on all their conversations on their 800 simplex channels. Their leader will have the capability to talk back to the EOC when he needs to. From the EOC up to the IC, we have no desire to listen to them as they clear individual houses, or secure intersections, we just want to know when they are complete, and what we can do to help them to complete.

They don't need to talk to the other teams on VHF either.

As IC, or COM-L - depending on what hat I am wearing, I have no business talking to every team at a large incident.

Interoperabilty does NOT MEAN EVERYONE HAS TO BE ABLE TO TALK TO EACH OTHER!

And it sure is not an equipment thing.
 

cifd64

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Thank you IAM Here. And you dont get shut down, you get fined. I believe it is in the 10's of thousands per license. I am not sure of the frequency of fines (no pun intended) but they can be levied more than once.

"at some point, either the whole narrowband thing will be shelved or compliance will be optional"

They have 8 months left to make up their minds.
 

ten13

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FCC waives narrowbanding requirement for T-Band systems

Apr 26, 2012 3:37 PM, By Donny Jackson





Public-safety and business/industrial LMR networks operating on T-Band (470–512 MHz) spectrum will not be subject to the narrowbanding deadline at the end of the year, the FCC stated in a public notice released today.



By waiving the narrowbanding mandate — rules requiring that LMR systems transition from 25 MHz channels to 12.5 MHz channels by the end of the year — the FCC met one of the key requests made by public-safety entities with narrowband systems in the T-Band in the aftermath of a new law that reallocated to the D Block to first responders. The new law requires public-safety agencies operating in the T-Band to vacate that spectrum within 11 years — a period so short that agencies narrowbanding this year would not be able to use the new equipment for its full life cycle.



“Continuing to require narrowbanding could force many licensees in the band to invest in narrowband systems that may subsequently have to be relocated,” the FCC states in its public notice. “We conclude that it would be inequitable and contrary to the public interest to require PLMR licensees to meet the January 1, 2013, narrowbanding deadline with respect to frequencies in the 470–512 MHz band.”



This news was not surprising within the LMR industry, because David Furth — acting chief of the FCC’s public safety and homeland security bureau — recently indicated that the agency would be issuing a narrowbanding waiver for T-Band operators and would freeze T-Band license applications, something the FCC did in a separate public notice today.



In the new law, only public-safety entities are required to vacate the T-Band, but business-industrial users of the spectrum also should expect to move, as well, Enterprise Wireless Alliance President and CEO Mark Crosby said yesterday during a webinar on the T-Band issue.



“Why would they freeze the band and waive narrowbanding for industrial-business folks, as well, if it wasn’t their intention … to have the industrial-business folks in the T-Band transition to another location, as well?” Crosby said in a subsequent interview.



In addition to waiving the narrowbanding requirement for T-Band operators, the FCC also lifted the ban prohibiting vendors from manufacturing or importing 25 kHz-only equipment that operates in the T-Band. While these exceptions exist within the T-Band, the FCC public notice reiterated the agency’s intention to maintain requirements for narrowbanding in the other impacted bands.
 
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