New York, Los Angeles Lay Out Problems Posed by Mandate They Give Up T-Band Spectrum
The cities of New York and Los Angeles told the FCC having to move their operations out of the T-band, as required by last year’s spectrum law, would pose a huge burden. In February, the FCC’s Wireless and Public Safety bureaus sought comment on implementation of Section 6103 of the Middle Class Tax Relief and Job Creation Act of 2012, which requires public safety to leave the 470-512 MHz band within nine years of enactment (http://bit.ly/142X3QG).
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The T-band is used by public safety in 11 major metropolitan areas. In March, the National Public Safety Telecommunications Council estimated that the overall cost of moving from the T-band could be more than $6 billion (CD March 30 p6).
The T-Band issue also came up at the NPSTC meeting Wednesday (see separate report in this issue). David Buchanan, chair of the Spectrum Management Committee, said the FCC can do little to override a congressional mandate, but the commission still has a role to play. “The FCC did not create the legislation so they can’t cancel the legislation, that’s something that Congress has to do,” he said. “The issue of a freeze is really under the FCC.” Buchanan said NPSTC as a group doesn’t lobby on Capitol Hill “but that’s something NPSTC members can do.”
New York has “serious concerns” about moving off the band in the timeframe required by the spectrum law, the city said in an FCC filing. “The City’s responders are reliant on mission critical voice communications in the T-Band and in all foreseeable events within the time period identified in the legislation will need this essential operable and interoperable voice capability,” New York said (http://bit.ly/101aInR). “The City makes extensive ‘24/7/365’ use of T-Band spectrum to support its first responder communications systems operated by the New York City Police Department, New York City Fire Department and New York City Department of Information Technology and Telecommunications. Without comparable alternatives that have been proved and tested and meet public safety standards, removal of the T-Band spectrum will place the City’s communications in severe jeopardy."
The NYPD alone uses more than 56,000 portable radios and 6,000 mobile radios tied to the T-band, the city said. “NYPD 911 calls are dispatched on local Radio Zone channels in the UHF T-Band. NYPD Police Officers in patrol cars and on foot patrol respond to these emergency calls,” the city said. “NYPD special commands such as the Detective Bureau, Special Operations Division, Intel Division, Internal Affairs, Emergency Services, Harbor and Aviation units all use UHF T-Band channels for mission critical voice communications. NYPD Special Commands operate throughout the City performing specific police functions unique to their respective Command."
New York also asked the FCC to lift its April 2012 freeze on new T-band licenses or modifications to existing licenses that would expand the footprint of T-band operations. “The City believes the T-band suspension is detrimental to T-Band licensees who rely on this spectrum for public safety communications,” New York said. “Under the Act, it is almost 8 years before the Commission must start the auction in February 2021. It is highly likely that cities currently relying on T-Band will need some type of expansion or upgrade before 2021. For example, under the suspension the City cannot license new radio frequencies for operation at critical sites that require in-building communications systems supporting the City’s first responders."
Los Angeles said moving off the T-band would pose a “significant burden” and there’s no suitable spectrum available for it to relocate its operations. “The City has made significant investments in its public safety communications infrastructure utilizing its 123 T-Band frequency pairs for voice and data communications supporting the Los Angeles Police Department; the Los Angeles Fire Department; the Port of Los Angeles and the Los Angeles World Airports,” the city said (http://bit.ly/16zG1gL). “The City’s relocation from the T-Band will be a complex transition requiring new spectrum resources and timely funding in order to allow for a gradual migration from the band."
"The preservation of safety in our cities and nation as a whole relies on effective and unhindered radio communications,” said the Los Angeles County Police Chiefs’ Association (http://bit.ly/15MSG0v). “It is imperative that public safety communications systems be available to respond accordingly when that safety is threatened. For all the reasons noted in this filing, it is a matter of public responsibility that the Federal Communications Commission discontinues the T-Band freeze while public safety agencies and associations such as ours can concurrently working with Congressional leaders to repeal the T-Band give up language in H.R. 3630."
The Association of Public-Safety Communications Officials urged the FCC to lift the T-band freeze and said that forcing public safety to move off spectrum it’s used for more than 40 years will create major problems for some of the largest U.S. cities. “The T-Band provides radio communications for some of the nation’s largest police and fire departments and is critical to the protection of tens of millions of people,” APCO said (http://bit.ly/13xnApV). “There are nearly 300,000 public safety mobile and portable radios and over 3,000 transmitter sites using T-Band frequencies. Forcing these public safety users to vacate the T-Band will be extraordinarily disruptive and expensive, and could endanger the safety of life and property."
The Telecommunications Industry Association (http://bit.ly/17uWGC9) and Enterprise Wireless Association also said the FCC should lift the T-band freeze. “EWA’s position on this issue has been clear from the outset: The Commission’s decision to freeze virtually all T-Band-related activity, relocating stations, adding channels, even exchanging one channel for another, years in advance of the mandated auction and prior to formulating a proposal for relocating incumbents is unprecedented and contrary to the public interest,” the group said (http://bit.ly/YJqlCL).