NYPD plans to file narrowbanding waiver by end of year

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902

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Looks like they're anticipate investing in public safety 700MHz LTE instead of narrowbanding their UHF infrastructure.
Sounds reasonable... IF they include a timetable to cancel all of their LMR licenses and return all of their 450-488 MHz frequencies (except the interops) to make them available for other agencies within the region. If that ever flies, no open-ended, sliding scale returns (like the Sprint-Nextel rebanding debacle with is STILL not completed). Deadline date, timetables, and fines for missing the deadlines.

The last time the region got an infusion of frequency resources was when NYPD vacated the VHF band around 1974. Fort Lee was able to go from 155.610 to 155.670 and Teaneck picked up 155.700 for their repeater pair.
 

cg

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They are asking for a waiver to change to a technology that doesn't even seem to have a completed standard yet. A LTE system would be many years away and cost much more than $100 million dollars for NY City coverage. If NYC can get it, I would argue that every user of the future nationwide LTE system could get a waiver as well.
I don't see how the waiver criteria (link below) allows going to a yet to be designed system to be a valid reason for an exemption.
http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0713/DA-11-1189A1.pdf

chris
 

radioman2001

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New York City has the resources to do whatever it wants. they got the entire TV channel 16 for themselves (albeit 2 12.5 kc channels for 1 for Yonkers and 1 for Suffolk) They could just go to Congress as they did for TV-16 and get it legislated, no biggy for them they have the money and the lawyers. The main problem for NYPD is the infrastructure, the repeaters, voters, etc, the portable and mobile radios themselves are replaced every 10 years anyway.
 

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(albeit 2 12.5 kc channels for 1 for Yonkers and 1 for Suffolk)
Not to mention using 6.25 kHz channel centers for 12.5 kHz wide operations so that you couldn't even reuse the channel elsewhere without encroaching into their channelspace.
 

ff-medic

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Kinda a dang if you do and a dang if you don't. FCC regulations change, frequently. As does their guidelines.

25 KHZ to a 12.5 MHZ spectrum really does not change things, for some / alot of , agencys.

I see no need for an agency to go out and buy new radios, UNLESS they want to file an application for new radio frequencys. Then since the new frequencys will be under the new 12.5 KHZ spectrum, yes you would have to upgrade your radios. But if you are not changing radio freqs in the applicable bands, WHY go out and spend thousands of dollars, and buy new radios to be compliable. This mostly for rural and semi rural areas where the radio freqs are the same, as for mutal aid for other ajoining agencys.

" Oh my gosh, the radio spectrum has changed per FCC regulations. We must come up with thousands and thousands of dollars to buy new radios." Well, not really. Not unless you need to transmit, or use new radio freqs in the new spectrum.

The hype, the hype.

FF - Medic !!!
 
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Thunderknight

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Kinda a dang if you do and a dang if you don't. FCC regulations change, frequently. As does their guidelines.

25 KHZ to a 12.5 MHZ spectrum really does not change things, for some / alot of , agencys.

I see no need for an agency to go out and buy new radios, UNLESS they want to file an application for new radio frequencys.
Please don't spread misinformation. Narrowbanding effects ALL part 90 licenses in 150-512 (minus a couple of specific paging channels), regardless of whether they file an application for new frequencies.

If your agency is licensed for, say, 155.010 MHz wideband, when you narrowband you are still on 155.010 MHz. However, your occupied bandwidth is less. Your radios must support this. If not, they have to be replaced.
 
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902

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Kinda a dang if you do and a dang if you don't. FCC regulations change, frequently. As does their guidelines.

25 KHZ to a 12.5 MHZ spectrum really does not change things, for some / alot of , agencys.

I see no need for an agency to go out and buy new radios, UNLESS they want to file an application for new radio frequencys. Then since the new frequencys will be under the new 12.5 KHZ spectrum, yes you would have to upgrade your radios. But if you are not changing radio freqs in the applicable bands, WHY go out and spend thousands of dollars, and buy new radios to be compliable. This mostly for rural and semi rural areas where the radio freqs are the same, as for mutal aid for other ajoining agencys.

" Oh my gosh, the radio spectrum has changed per FCC regulations. We must come up with thousands and thousands of dollars to buy new radios." Well, not really. Not unless you need to transmit, or use new radio freqs in the new spectrum.

The hype, the hype.

FF - Medic !!!
Sorry, but you've been misinformed. That's incorrect.

The reason for narrowbanding is ostensibly to create more channels. That doesn't always work, however. On UHF, where channel centers are spaced in 6.25 kHz increments (in practice, the 6.25 kHz incrementalization is only useful for NXDN emissions) and most commonly apportioned in 12.5 kHz increments for narrowband systems, this is true. As spectrum doesn't overlap, adjacent frequencies may be assigned closer, often without need for geographic separation. On VHF, there is still overlap and the creation of more channels with 7.5 kHz channel centers still requires adjacent channel protection, often in the form of geographic separation of some sort. If agencies ignored the narrowbanding mandate, both UHF (with neatly conforming bandwidths and channel centers) and VHF (a nightmare for many reasons), these interstitial channels that allow for more densely apportioned use would be completely unusable because of spectral overlap between the narrowband 7.5 kHz adjacent and the incumbent wideband.

I think the misunderstanding is in the frequency's channel center. Your agency can have a legacy 20K0 channel center, but they must still reduce the bandwidth on it. It affects everyone on either side of your agency.

So, no, it's not optional. Your agency will have to do it, like it or not. Filing a waiver can DELAY the process if the Commission approves it, but WILL NOT get the agency a dispensation to continue to operate in wideband without some definitive timetable and end-date. I've been told that these waivers will not be rubber stamped and that they should be filed before the end of the year in order to be processed on time. Yes, narrowbanding does benefit some frequency bands and some users. No, it's not magic or a miracle fix.

What some here have observed is that NYPD is proposing a forklift replacement of their LMR system with unproven technology that is vaporware for the proposed application. I'll add that LTE has no provisions for peer-to-multi-peer off-network communication, making it potentially unsafe for public safety application as a voice replacement technology... as it stands right now. We'll see where manufacturers take this. Proprietary "enhancements" and "solutions" aside, there probably will be no interest in 3GPP to consider off-network implementation (going off-network with a cellphone means it is using radio spectrum without paying some company to use it, and that is incongruent with their world view), meaning another very expensive device.

Anyway, the question is should the FCC allow an agency to not narrowband because of vaporware that's not ready for prime time.

Seems a few more active duty and recent duty "responders" and a few less lobbyists, politicians, and sales engineers (who've never, ever worn a uniform - or moldy oldies/rubber guns that have been driving a desk for the last 30 years) should have been involved in this one.
 

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I think you missed ff-medic's point. It's unnecessary to narrow band, and it's all hype, there isn't going to be a floodgate of new available frequencies as a result. Most of the splinters on UHF are already licensed in markets that NEED frequencies, in the boonies there is no need, so there are plenty of frequencies already available. The VHF spectrum gains nothing either, since the radio coordinators have already told the FCC that they will not license operations on the splinters that don't meet the already in place interference contours. So why is it being done, my guess is to make licensees buy new radios since the old ones don't break, and to eventually get everybody on commercial systems that the FCC doesn't have to administer,ala LTE. Plus the money they will get auctioning off all the spectrum from abandonded frequencies. Just look at any tower/radio site nowadays, there isn't but maybe 10% of the equipment that was there 15 years ago.
Public safety makes up the most personally owned equipment these days, and if the get them to go with a quasi public/private system the FCC won't have to admister anything.
 

ff-medic

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Ahhhh. Dah Radio Man. Dunka ( thanks in German - One soldier to another ).

I have a GP Large set up in the woods. Its fall, the air is cool and clean ; and the leaves are changing. I have Chips, snacks. Lots of beer ; and a spades game going on. Join in. Copenhagen and Skoal on the table being you. There is no guard duty tonight, or "Stand To" in the morning. Go ahead...Get drunk. I am !!!! :) :) :) :)


FF - Medic !!!
 
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902

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I think you missed ff-medic's point. It's unnecessary to narrow band, and it's all hype, there isn't going to be a floodgate of new available frequencies as a result. Most of the splinters on UHF are already licensed in markets that NEED frequencies, in the boonies there is no need, so there are plenty of frequencies already available. The VHF spectrum gains nothing either, since the radio coordinators have already told the FCC that they will not license operations on the splinters that don't meet the already in place interference contours. So why is it being done, my guess is to make licensees buy new radios since the old ones don't break, and to eventually get everybody on commercial systems that the FCC doesn't have to administer,ala LTE. Plus the money they will get auctioning off all the spectrum from abandonded frequencies. Just look at any tower/radio site nowadays, there isn't but maybe 10% of the equipment that was there 15 years ago.
Public safety makes up the most personally owned equipment these days, and if the get them to go with a quasi public/private system the FCC won't have to admister anything.
Radioman2001, I think you've just about nailed it. As for the coordinators, with so many diverse emissions, the only real evaluation of co-existence these days is TR-8's TSB-88.1(C... at the moment... maybe going to Rev. D sometime soon?), which evaluates a variety of situational factors between proposed and incumbent. The threshold value is 5% of service area reliability degradation. The incumbent's service contour should not be degraded by the proposed by more than 5%. Right now, that's very tedious and time consuming combing through candidate frequencies looking for the least-harmful interaction. The biggest enemy for reuse has been poor legacy practices without right-sizing excess or addressing warehousing of frequencies.

Narrowbanding for UHF would allow somewhat more aggressive 12.5 kHz adjacent channel reuse. Just saw one potential frequency that could have been used if the adjacent channel incumbents had narrowbanded, but they have not, so the new system currently has nothing. That splinter could have been used, but has to protect the two wideband incumbents on either side.

You can play softball in some sites that were loaded with LMR, SMR, and paging equipment not long ago. Most business systems have been replaced by Nextel and Nextel voice seems to have been largely replaced by SMS. High sites (500 ft. towers) with big antennas (DB-264s, SuperStationmasters, etc.) have been supplanted by many, many low sites with vectored directional and diversity reuse schemes.

If you want to, go to Google Scholar and type in the FCC's former chief technology officer, Jon Peha. His work gives a bit of insight to what some in the industry believe should be the migration path for public safety spectrum policy.
 

radioman2001

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Warehousing of frequencies is the biggest problem in the NYC area. The FCC made a big mistake by not forcing these frequencies to be used. If the used the same criteria that is used on the TV band channels, there wouldn't be a problem in NYC. If you want one of these channels the license holder wants 1 million each! There have been some PS agencies that did buy a few fueling the hording of channels hoping for a big payday.
The coordinators for VHF are using the 38db contour for their minimum,not easily doable in NYC. Again the FCC would like to get out of the frequency business unless it makes money.
 

kb4mdz

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Narrowbanding of radio systems is something that has been coming for ummmmm 15 years or more?? The M1225 & P1225 series radios came out in the mid 90's, partly in response to narrowbanding as something on the horizon. (I said partly, not completely.) And one of the biggest cities in the country couldn't get their act together in all that time, to phase out old equipment, phase in new frequencies and infrastructure? I'm sorry, that's like spending 9 months pregnant, then being surprised that diapers are involved in the process of raising a baby. I won't even get into the supposedly technically based arguments, some of them flying here. There has been plenty of time to make & implement plans.
 

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In my opinion, the FCC shouldn't grant a single exception. As kb4mdz said, the narrow band mandate is nothing new. I was told over 10 years ago by a radio dealer up here that it was on the horizon. If NYPD (or any other user) didn't react in a timely manner, they deserve every dollar in fines the FCC should subject them to.
 
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The irony is that the agency sitting on the most frequency spectrum is the one wanting waivers from a requirement that it caused, at least in part.
 

radioman2001

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Again for the most part you missed the point, NYPD and NYC in general has the resources and the excuse(the biggest terrorist target in the world) and more than likely will get the waiver or they will just go to Congress as they have before and get it legislated. If I were NYC I would do it too, I think one of the reasons not stated here is to hold off any reuse of the splinters. NYC has always gotten a 300mi corridoor on their frequencies, and the coordinators I spoke to are salivating at the possibility of over 3mhz of spectrum. If you are not from the NYC area you really cannot speak about frequencies, for availability they are far and few between, and some they come with numerous conditions. Take the T-band frequencies, split the Hudson River in two, on the east side you can have up to 350 watts 1.1k ERP, on the west side 110 watts and 722w ERP. That's for just less than 1 mile of separation.
Personally I think all the TV frequencies 14 to 20 should be converted to P.S. and or private use. They have a much better coverage capability than 700 mhz, and there are already areas of the county using them. I have heard that in California the broadcasters are licensing TV 14-20 just to keep P.S. off of them. I would prefer to have more P.S. channels than a TV channel broadcasting a picture of a lake as was done in the Hartford area for over 6 months, just to keep the license.
 
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Again for the most part you missed the point, NYPD and NYC in general has the resources and the excuse(the biggest terrorist target in the world) and more than likely will get the waiver or they will just go to Congress as they have before and get it legislated. If I were NYC I would do it too, I think one of the reasons not stated here is to hold off any reuse of the splinters. NYC has always gotten a 300mi corridoor on their frequencies, and the coordinators I spoke to are salivating at the possibility of over 3mhz of spectrum. If you are not from the NYC area you really cannot speak about frequencies, for availability they are far and few between, and some they come with numerous conditions. Take the T-band frequencies, split the Hudson River in two, on the east side you can have up to 350 watts 1.1k ERP, on the west side 110 watts and 722w ERP. That's for just less than 1 mile of separation.
Personally I think all the TV frequencies 14 to 20 should be converted to P.S. and or private use. They have a much better coverage capability than 700 mhz, and there are already areas of the county using them. I have heard that in California the broadcasters are licensing TV 14-20 just to keep P.S. off of them. I would prefer to have more P.S. channels than a TV channel broadcasting a picture of a lake as was done in the Hartford area for over 6 months, just to keep the license.


Narrow banding will no doubt help many here in the greater NYC/LI/NJ area. Wideband adjacent channel users will have some room to wiggle no that spectrum will not overlap.

The fact of the matter is that NYC is a spectrum hog. They have more BS systems they keep building and no one uses them to the fullest capability (DoItt 800, CH16 UHF trunked, Conv UHF PD, Conv UHF FD, VHF FD, etc, etc.) They need to build a technology platform city wide in one band and put the city agenices on it, period.

As far as narrow banding is concerned and what the city did regarding the CH16 system is simple. Wide Band operation with the spectral efficency of 12.5. Perfectly legal, however because they are using true 6.25 channel centers (split one wide channel into two), this traffic must be treated as wide band adjacent channel traffic. In the T-band world this means TSB88 studies for anything less than 64 km or 40 miles station to station. This is a real PIA. This is similar to the Two Slot DMR stuff on the market. While you may currently have a 12.5 emission designator of 11k2.. If you change you system out for one of these TDMA based DMR systems your have already meet the spectral efficiency requirement of the ever looming 6.25 mandate. I
 

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The fact of the matter is that NYC is a spectrum hog. They have more BS systems they keep building and no one uses them to the fullest capability (DoItt 800, CH16 UHF trunked, Conv UHF PD, Conv UHF FD, VHF FD, etc, etc.)
Excuse me, I beg to differ. Each one of the systems you mentioned is being used, and not to the "fullest capability" - intentionally - to allow for extra loading when the "big one" hits (think the East Coast Blackout, events like that). DOITT's 800 MHz trunked radio system is used extensively by DEP, Housing, and over a dozen other smaller agencies. Their 400 MHz TRS is used by the FDNY, OEM, DoT, Parks, and Correction - among other agencies. UHF Conventional FD goes without saying in my opinion. Conventional PD could be argued that utilization could be revised, but I am going to set that aside [no waivers!].

Your reference to VHF FD touches on the real problem. With the successful move by Sanitation, Transportation, and Parks and Recreation to the CRN, why does DOITT keep renewing licenses for the legacy conventional frequencies all these agencies used to operated on? When the FDNY is done with the switch over from VHF to UHF, is DOITT going to hold on to those ten VHF frequencies too? That is the textbook definition of hoarding spectrum.
 
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