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IAFF: Voice Radio Communications Guide for the Fire Service, Section 8 - Radio spectrum licensing and the Federal Communications Commission


Editor's note: The IAFF and the USFA released an updated version of its Voice Radio Communications Guide for the Fire Service in Oct. 2008. The guide focuses on seven sections of communications – basic radio communication technology, radios and radio systems, portable radio selection and use, trunked radio systems, system design and implementation, interoperability, and radio spectrum licensing and the federal communications commission.

The FCC is an independent agency of the U.S. Government established by the Communications Act of 1934. It is made up of seven bureaus that are responsible for various communications areas, organized by function. The bureau that is most involved in public safety issues is the Public Safety and Homeland Security Bureau (PSHSB), which

…is responsible for developing, recommending, and administering the agency’s policies pertaining to public safety communications issues. These policies include 911 and E911; operability and interoperability of public safety communications; communications infrastructure protection and disaster response; and network security and reliability. The Bureau also serves as a clearinghouse for public safety communications information and takes the lead on emergency response issues.

As this description implies, the PSHSB is responsible for rulemaking, licensing, education, and outreach to public safety agencies. Portions of the activities of the PSHSB were previously carried out by the Wireless Telecommunications Bureau, particularly the rulemaking and licensing functions. The outreach and coordination functions were added to create a single bureau to handle all public safety issues.

The rules established by the FCC are located in the Code of Federal Regulations (CFR) Title 47. The section of these regulations that applies directly to land mobile radio systems used by public safety are located in Part 90 of 47 CFR. The Part 90 rules govern the operation of radio systems, as well as the frequencies available for use, what types of agencies are eligible to use the frequencies, and the procedures for licensing the frequencies.

When the FCC believes that a change is needed to the rules, generally it will first issue a Notice of Inquiry (NOI) asking for general information on the issues related to the change. Next, the commission will issue a Notice of Proposed Rulemaking (NPRM) outlining the proposed rule change. The NPRM allows the public to comment on the proposed change and proposed modifications. After the FCC reviews the comments and proposals, it may issue one or more Reports and Orders (R&O) that provide the final details on the rule changes. This process may repeat as necessary to refine the rule change. In addition, a type of appeals process is allowed, known as a Petition for Reconsideration. During the process, public presentations, comment documents, and expert testimony is heard by the FCC. Fire departments and professional organizations may participate in all portions of the process.

The FCC also governs the licensing of radio frequencies to agencies, and this process is handled separately from the rulemaking process, although issues that arise during the licensing process may result in future rule changes.

The licensing process starts with the agency defining the requirements for communications systems, including the type of radio system, the frequency band needed, the number of users that will used the proposed system, and the number of frequencies or frequency pairs required. After the requirements are defined, the agency finds the specific frequencies through a frequency search conducted by the agency, a consultant, or a manufacturer. The FCC Web site has tools to help agencies search for frequencies, including the Universal Licensing System (ULS) which is used to search for existing licenses, as well as for processing applications. The ULS also can be used to search for other agency licenses for examples on preparing a new license. Specific design parameters will be required to license the frequencies, including the transmitter locations, tower height, antenna height, and transmitter power output. Transmitter power output must be specified as “Effective Radiated Power,” which increases the actual power output from the transmitter by a gain factor specific to the antenna used in the system.

After all the system parameters and frequencies are determined, an application for license is prepared and sent to a frequency coordinator. The two coordinators used by most fire departments for frequency coordination are APCO and the International Municipal Signal Association (IMSA). The frequency coordinator acts as a prelicense verification to ensure that licenses meet the FCC rules and State and local coordination requirements before being submitted to the FCC. The coordinators take into account interference that may occur to other systems using the requested frequencies and adjacent frequencies. If there are any problems with the application, the coordinator works with the applicant to resolve them.

Once the application passes the frequency coordination process, the application is submitted to the FCC through the automated ULS. Agencies can enter the license information into the ULS and track it as it proceeds. The FCC uses a computer system to perform automated checks on the license and then will assign the license request to an examiner who will perform more extensive checks on the details of the application. The examiner then will either grant the license, or return it to the applicant for modification or additional documentation. If the request does not conform to FCC rules, it may be rejected outright, and will require a reapplication.

If the application does not conform to the FCC rules in Part 90, the applicant may request a waiver of the rules. The waiver process is complicated, and waivers are not granted frequently. An example of a waiver that has been granted is the use of UHF TV channels 14 and 16 for public safety use in the New York and Los Angeles metropolitan areas. These areas had significant needs for additional frequencies in the 1980s, before the 700 MHz and 800 MHz public safety bands were established. The agencies involved presented the needs along with extensive documentation on why the need could not be fulfilled with current frequency allocations. Departments that wish to pursue a waiver must present a detailed, well-thought-out case to be successful.

Federal Communications Commission Actions to Increase Public Safety Spectrum
Historically, all public safety systems used frequencies in the VHF low, VHF high, and UHF bands, with the systems progressing to higher frequencies as technology improved. Most fire and police departments in the U.S. still use radio systems in the VHF and UHF bands and have no plans to move to other bands. However, the population growth in large metropolitan areas has created rising demand for more radio frequencies. In many areas of the country, all available VHF and UHF frequencies are assigned to agencies, leaving no space for growth. The FCC, working with equipment manufacturers and public safety communications organizations, has developed several programs to increase the available frequencies for public safety communications.

National Public Safety Planning Advisory Committee
The first major expansion of frequencies allocated to public safety took place in 1986, when the FCC created the National Public Safety Planning Advisory Committee (NPSPAC) to develop frequency allocations on the 800 MHz band. Prior to the NPSPAC process, public-safety-licensed frequencies in the 800 MHz band were combined with commercial business and cellular companies, and the available frequencies were very limited. The NPSPAC frequencies were put under the control of 55 Regional Planning Committees (RPC). The RPCs are responsible for creating regional frequency plans that take into account agency needs, including metropolitan, rural, and statewide, and are responsible for initial coordination of applications.

Rebanding Below 512 MHz
The NPSPAC process provided additional frequency spectrum for new systems operating in the 800 MHz band, but most fire and police departments in the U.S. still operate in the VHF or UHF bands. To increase the available frequency spectrum for public safety in the VHF and UHF bands, the FCC began investigation into narrowing the bandwidth for frequencies in this band.

In these bands, channels were spaced 15 kHz apart, with transmitters operating with 25 kHz bandwidth. In addition, as shown in the illustration below, adjacent transmitters were separated geographically to minimize interference. It became apparent that, as the population served by these departments grew, their spectrum needs would grow as well, and the existing band plan would become inadequate for the needs.







With no unused spectrum available in these bands, the FCC proposed narrowing the bandwidth of the existing frequency assignments, dividing each existing frequency channel in half. Each frequency in the new plan is spaced 7.5 kHz from the previous, and has a bandwidth limited to 12.5 kHz.









The FCC developed a schedule in 1995 for migration from the current band plan to the new narrow band plan. This plan is often called “refarming” to relate it to changing the crops in a field. The schedule for refarming established by the FCC is divided into phases, with each phase increasingly restricting the use of wideband systems to encourage migration to narrowband.

The first phase began in 1997 with the FCC denying certification for equipment that operated with 25 kHz bandwidth if it did not also operate at 12.5 kHz or equivalent bandwidth. This prevented manufacturers from making equipment that would not be able to be used once the future phases came into effect. The FCC predicted that most (wideband) equipment manufactured before this date would become obsolete and unserviceable before the mandatory narrowband deadline.

At the time of this original order, the FCC also made other orders with respect to expansion of existing systems, creation of new systems, and the manufacture and importation of equipment. These orders staggered the restrictions over several years in an attempt to make the transition to narrowband communications less painful to local agencies. Unfortunately the complexity of the rules confused many agencies and, in 2004, before the new rules took effect, the FCC modified the order to have two deadlines, one in 2011 and the other in 2013.

In January 2011, the FCC will no longer accept applications for new systems, modifications to existing systems, or transmitters that operate using a bandwidth greater than 12.5 kHz or equivalent. In addition, the FCC prohibits the manufacture or import of radio equipment that is capable of operating on a bandwidth greater than 12.5 kHz or equivalent.

The final phase begins in January 2013 and prohibits the operation of radios and radio systems that do not comply with the narrowband requirements. All radios, portable, mobile, repeaters, and base stations, that operate in the VHF or UHF bands must be replaced and the systems they operate in must be redesigned before this date.

The FCC’s actions to refarm the VHF and UHF bands resulted in perhaps the most confusing set of orders from the FCC concerning public safety communications, resulting in many unnecessary system replacements. These replacements include departments transitioning to systems that do not meet their operational needs and are unnecessarily costly to procure, operate, and maintain. Agencies can keep their existing communications systems that they have been using for years, provided that they modernize the equipment and design by transitioning to 12.5 kHz bandwidth frequencies and equipment prior to 2013.

Public Safety Wireless Advisory Committee
Although the NPSPAC process provided additional frequencies in the 800 MHz band, in the early 1990s the need for more capacity became evident. This increasing need for more frequency spectrum was not limited to non-Federal agencies, as the Federal government had not made modifications to Federal agency needs in many years. In 1993, the FCC established the PSWAC, under direction from Congress, to address the radio frequency spectrum needs of Federal, State, and local agencies over the next 5 years, and over the next 15 years. The goal was to develop a plan to allocate additional spectrum for all users, as well as establish plans for communications interoperability between all levels of government.

The Final Report of the PSWAC recommended the allocation of 2.5 MHz of spectrum below 512 MHz for Federal, State, and local public safety interoperability, and the addition of approximately 25 MHz of new spectrum over the next 5 years, and 70 MHz over 15 years for Federal, State, and local public safety use. Although to date only approximately one-third of the new spectrum requested has been allocated for State and local public safety use, this is more than any request in the last 20 years.

700 MHz Spectrum Allocation
As a result of the PSWAC’s recommendation that additional spectrum be allocated to public safety, the FCC allocated 24 MHz of new spectrum. This allocation, from 764 MHz through 776 MHz and 794 MHz through 806 MHz, was part of the spectrum previously allocated to TV channels 60 through 69. This spectrum became available for use by public safety through the transition of television stations to digital systems. This portion of spectrum was chosen because it was adjacent to the existing 800 MHz band also used for public safety communications, and radio equipment could be designed easily to operate in both bands.

In 1998, the FCC issued an order that described the rules for the use of the new frequency band, as well as the new band plan. The order split the allocation of frequencies into four basic classes: general-use frequencies, State frequencies, interoperability frequencies, and wideband frequencies. The general-use frequencies could be licensed by both State and local entities, and the allocation and use of the channels would be governed by an FCC-approved regional plan developed by stakeholders in the region. The State frequencies would be licensed to each State, and could be allocated in any manner the State desires. The interoperability frequencies could be licensed by State, local, and, to a limited degree, Federal agencies, and the allocation and use of the frequencies would be governed by a plan produced by a State Interoperability Executive Committee (SIEC) in each State. The wideband channels were intended to provide the ability to develop regional and local high-speed data systems.

800 MHz Reconfiguration
The initial frequency allocations in the 800 MHz band were made available in 1974 by reallocating the frequencies used by television channels 70 through 83. This spectrum was available for use by public safety, business and industrial users, and cellular systems. The FCC allocated 70 channels to public safety and interleaved these with other channels for business and industrial users. Interleaving means that one channel was allocated to business, the next for industrial, and the next for public safety. This repeated, creating an allocation that is layered with public safety sandwiched between other users. Every public safety channel had a non-public-safety system on either side. Later, many of these channels were allocated to Specialized Mobile Radio (SMR) systems, which are private trunked radio systems used by businesses. Figure 34 shows the interleaved frequency allocation, with SMR systems on either side. The 800 MHz NPSPAC band is the block labeled Public Safety to the right of the Upper 200 SMR block.



In the early 1990s FleetCall, later to become Nextel®, started to develop a digital SMR network that incorporated the same features as cellular systems. This system used frequencies in the SMR bands, as well as frequencies in the interleaved band. Traditional cellular systems were not allowed to operate in these bands, but FleetCall received waivers from the FCC to operate the new system. At the same time, the deployment of cellular systems was increasing at a rapid pace.

One of the two bands assigned to cellular systems, the Cellular A band is directly adjacent to the NPSPAC 800 MHz band. The NPSPAC band is also adjacent to the Upper SMR band. With FleetCall systems on both sides of the interleaved band, and this and other systems interleaved, along with SMR systems and cellular sandwiching the NPSPAC band, public safety system were in a bad place.
Both the FleetCall system and cellular systems are designed with a large number (30 or more) of transceiver sites throughout the system’s coverage area. Compare this with the typical public safety system with one or two sites. The public safety systems were bound to have interference, but none of the system operators that were likely to interfere with the public safety systems recognized the potential.

By the late 1990s, the interference problem with public safety systems in the 800 MHz band had become well-recognized and agencies were demanding action to restore the ability to communicate on emergency incidents. To its credit, the FCC began a process to classify the problem and find a solution. In 2004, the FCC ordered that systems operators in the affected bands must take steps to minimize interference effects. The FCC also ordered that the 800 MHz band would be reconfigured to further minimize the interference from Nextel® and Cellular A band systems under a process known as “rebanding”.

Under the rebanding process, Nextel® will fund the effort of relocating existing systems in an equitable manner and in return will receive additional frequencies in the 1.9 MHz band. To supervise the rebanding process, the FCC appointed an independent consulting company BearingPoint as the Transition Administrator (TA). The TA has the responsibility of managing the process, including establishing the schedule, monitoring the process, and facilitating resolution of conflicts. The process was divided into four “waves” that group together the regions that will be reconfigured. All waves were scheduled to be reconfigured by the end of the second quarter of 2008 with the exception of Wave 4, which contains U.S.-Canada or U.S.-Mexico border areas. The reconfiguration of these areas was subject to treaty negotiations that delayed the process.





The reconfigured band in the figure above shows that the public safety portions of this new band will be isolated from the ESMR portion of the band where Nextel® operates. In addition, the NPSPAC band has been relocated away from the Cellular A band and is much less likely to suffer significant interference from non-public-safety systems.

Public Safety Broadband Network
In December 2006, the FCC made a statement of opinion in a Notice of Proposed Rulemaking:

We believe that the time may have come for a significant departure from the typical public safety allocation model the Commission has used in the past…While this system has had significant benefits for public safety users, in terms of permitting them to deploy voice and narrowband facilities for their needs, the system has also resulted in uneven build-out across the country in different bands, balkanization of spectrum between large numbers of incompatible systems, and interoperability difficulties if not inabilities.

This statement predicted the activities that would occur the next April and June, with the FCC’s Proposed Rulemaking and Second Report and Order on the 700 MHz band. In this rulemaking, the FCC proposed to create a nationwide public safety broadband data system by rebanding the 700 MHz public safety band to reallocate the 10 MHz wideband frequency allocation and combine this with 10 MHz of new spectrum that would be auctioned. The FCC would allow a single nationwide licensee for the reallocated 10 MHz of existing spectrum, and would auction the other 10 MHz of new spectrum, known as the D Block.

The auction would seek to find a bidder that would purchase the rights to the 10 MHz of D Block spectrum and would then have the rights to combine this with the 10 MHz of public safety spectrum to form a nationwide commercial and public safety network. The FCC rules stated that the network must meet the requirements of public safety agencies, and appointed the Public Safety Spectrum Trust Corporation (PSST) to represent the interests of public safety. The PSST developed a Bidder Information Document (BID) that outlines the requirements the new system must meet. These specifications include priority access for public safety users, backup power and networking requirements, and other features necessary to provide a high-reliability system. The PSST also became the licensee for the 10 MHz of reallocated public safety spectrum.

The D Block auction occurred along with other auctions in the first quarter of 2008. There was one bidder for the Block, but the reserve price (minimum bid) set by the FCC was not met, and D Block was not auctioned successfully. After the auction there was some discussion that the requirements for the system set forth in the BID created too much uncertainty as to the cost of constructing the system. This, along with the uncertainty of how many public safety agencies would participate may have led to the unsuccessful auction. The FCC and the PSST are reconsidering the specifications in the BID, and the FCC is evaluating the entire process for improvement prior to another auction attempt. If the nationwide broadband network is built successfully, it will be the first system of its size built specifically for public safety requirements and could serve as an evaluation model for a possible nationwide voice system in the future.

One problem common to all recommendations to increase the spectrum allocated to public safety agencies is accurately defining “public safety agencies”, and another lies in the politics of the allocations. Many State and local governments, and their communications managers in particular, lobbied to include “public service” or “public safety support” agencies in those eligible to license spectrum allocated to public safety.

The result of this is that agencies that do not support the emergency response aspect of public safety are eligible for licenses under the new rules. This includes such diverse groups as school bus companies, road and highway maintenance crews, and public solid-waste disposal agencies. In essence, any State or local government workgroup is eligible for licensing spectrum allocated to public safety, no matter how removed the agency is from emergency response activities. The benefit to State and local governments is that they can build communications systems that support all divisions with spectrum allocated to public safety. Unfortunately this is done by exploiting the public’s understanding of what falls under the umbrella of public safety and ultimately reducing the spectrum available for emergency response.

Not all of the responsibility for the lack of adequate spectrum for public safety response lies with the FCC or the various coordinating agencies. Public safety agencies themselves often perpetuate this inadequacy through their actions (or inactions). The insistence by many agencies to maintain “stovepipe” communications systems that duplicate the coverage of other systems and do not operate with neighboring agencies is one of the most egregious examples. The efficiency of frequency use could be increased dramatically if all agencies were committed to cooperative system development with the goal of maximum frequency use among all agencies in a system. The FCC and communications equipment industry are driven by the need to accommodate additional users in a limited amount of radio spectrum and economic forces. The fire service has an opportunity to be a part of the solution to this issue through coordinated organizational participation in the process. If the fire service cannot communicate its needs, or if the fire service voice is fragmented, then a solution will be imposed, and it is unlikely that solution will meet all the operational needs of the service.










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