Transcript: FCC Narrow-banding

P25 Phase II Roundtable Theme 2, recorded in Scottsdale, AZ, USA. October 19, 2011

The P25 Phase II Roundtable was a moderated open discussion. Several themes reoccurred through the day.

This transcript pulls together the phases of the discussion that centered on the theme “FCC Narrow-banding”.

Watch the video | Download the transcript (340 KB PDF)

 

Member: One of the questions you asked earlier, about “why go Phase 2?”, there is the 800-pound gorilla that hasn't been mentioned: which is the FCC. 

Moderator: Yes.

Member: I mean, 2017 is what is driving this. I put my hand up for Phase 2, because we are going to have to go there. There is no question. Everybody else will have to or will only be able to purchase equipment that is compatible with Phase 2 for the 700MHz band.

Moderator: So we have two compelling reasons. One is the regulatory reason, and that is one of the topics that I put on our road map. The other was the increased capacity, and the third one was simply having future proof equipment. 

Are those the only reasons? Is that all of the ones you see in Phase 2? Is there anything else that it brings? 

Member: I think a major - we talk about the FCC is the one that mandates, which is absolutely true, and probably inappropriately. But beyond that, and more important to us as human beings, is Phase II is more spectrally efficient.

Moderator: If you could raise your voice.

Member: Maybe I should speak louder - Phase 2 is more spectrally efficient. It comes with some negative components beyond that, but it is more spectrally efficient. You are going to be able to use more mobiles on the same piece of bandwidth that you have today, so it is more user efficient. 

So there is a lot in Phase 2 beyond just Phase 2. We shouldn't get hung up on it. But the fact of the matter is, we are moving to Phase 2 because the FCC has pointed out, has mandated that. 

And Project 25 recognized that in 1989 and said this is one of the things we need to move to. That is long before the Commission even thought about doing that, or at least articulated it in a public forum. 

 

At this point the roundtable discussion went onto another topic for a time. The conversation then returned to the “FCC Narrow-banding” as follows:

 

Member: Obviously, the Phase 2 process of getting an understanding on the user side that the P25 standard is a progression and not a change to help other systems. That is the problem. The big issue that we have regulatory-wise is the FCC throws out a date of 2017, and the folks in charge on our end, the first thing they do is they grab their calendar and go, I'm going to be retired by then. I'm not going to worry about it. Leave it for the next guy. 

 

At this point the roundtable discussion went onto another topic for a time. The conversation then returned to the “FCC Narrow-banding” as follows:

 

Member: One of the things, if I could, with regard to the timetable 2017. We are discussing this within the national regional planning council. We've also discussed it within my region, and the City of Phoenix has a major problem with the 2017 drop dead date, as it were. 

First and foremost, starting off with the City of Phoenix. The cost of conversion during these economic times appears to be beyond affordability. The city has very heavily invested into the Phase 1 infrastructure, because they were early adopters in all of this, and have also pushed forward regionality in the system design, which means they have thousands of customers, multiple cities that are members of it. And the cost of converting that old system is millions and millions and millions, none of which these cities really have right now in order to be able to start the phase transition. Because when 2017 comes around, you can't just drop it one day, reprogram 10,000, 20,000 subscribers and have everybody come up. It is a long-term situation. So the city has got a real issue with 2017. They've identified that it would be feasible many years past 2017. 

From the Region 3 aspect, we don't have a genuine need for more spectrum that Phase 2 would actually provide us, plain and simple. There is no need for additional channels, because, frankly, there is enough for our region. That isn't the reflection of other regions by any means. There is certainly a need for it elsewhere. 

And then, from the national standpoint, we are looking at trying to possibly bring the same type of rules of managing spectrum, narrowbanding, so on and so forth, to the 700MHz band that exists currently in the 800MHz band. In that, it is a choice on wideband, narrowband, you know, the different modes that you can go to. We would like to see, at least my region would like to see, and we are working with the NRPC on this - that the 2017 deadline is kind of dropped and it might wind up be a region-by-region decision based on the need, based on adjacent regions, and so on. 

Because the cost of membership is just not affordable in many cases, and there is no real need in many places. New Mexico, Montana, and so on and so forth, may just not have a need to convert from 12.5 to 6.25.

Moderator:  Any comments on that? I've got a few here. 

Member: I will comment on that, as well. From our perspective in Kansas, specifically within NRPC, what we are seeing are people, because we are not so jam-packed with systems that we are for lack of spectrum. So we actually have people running from 700MHz simply because of the '17 date. They are running to other spectrums. We do not have that saturation need for Phase 2 technology at this point in the '17 spectrum. 

Member: From a user perspective, the state of Mississippi, the primary focus was interoperability. And that was one of the things that P25 gave the state, is that there is a standard that everyone can go to give us the interoperability. The Phase II part is, in my mind, that we are going to Phase 2 next year and will implement that. That is just to give a growing spectrum capability so you don't run out of bandwidth. Do we need it now? No. But we may need it in the future, and it will be there if we start now. 

But our primary focus on going to a 700 MHz system is to get all of the users in the state a platform that we can all go to have interoperability. 

Member: With that said, Region 5 the 700 MHz plan is essentially filled. Including all of the state needs and interoperability needs and everything else. So, again, we are probably a little bit unique, but in southern California, I won't tell you the blood and gut battles that happen over spectrum. 

Moderator: Craig?

Member: I think we need to remember part of our discussion today is on 2013, not 2017, number (1). Number (2): 2017, although the Commission said, “This is what we want.” They didn't come out and say, “By God, you will do this by that day.” 

So add to that the fact that you are dealing with the federal government, which is one of the largest consumers of our niche market area, has said, “We have no intentions of moving to 6.25. We may use 12.5 TDMA Phase 2 stuff, but it is not our intention to require 6.25 within the federal government.” 

So there is not a lot of economic incentive for the manufacturers to just run out and do that, but there is an incentive to say 2013 is around the corner. How are you 60,000 public safety licensees and you 180,000 business licensees going to accomplish that task in the next year and a half? And I think that is what we need to focus on in here, because that is a major, major problem. It is a political problem. It is an economic problem. It is a technology issue. It is an operational issue. There are so many things that come into play, and there is nobody, at least in my mind, out there really saying, “Let's do this today. We really need to do something. We need to provide assistance to the state of Connecticut. We need to provide assistance to LA County on how they are going to meet it.” There is nobody providing that assistance. Everybody is talking broadband. Broadband is the solution to the future. Yet, you have people all over the country that are sitting on systems that the FCC is saying, January 1st those systems are no longer valid.

Moderator: So, if I can restate that, you are saying the 2017 700MHz deadline is really a stake in the sand, but that could change. The real barrier today is narrowbanding and that concerns the UHF/VHF users, and that is what we should be dealing with today. But isn't Phase 1 enough for that? What difference does Phase 2 make?

Member: I don't think really that…

Moderator: Not really. Phase II doesn't make any difference to that particular -

Member: Right. I don't think you can forget 2017, and that wasn't certainly my intent to say that. But I do think that if we are going to be objective today, we have to focus on a year and a half to two years, 2013. What can we walk out of this room today to tell the public safety community, to tell our peers and industry? And I'm using that term euphemistically, because none of us are your peers. But what can you use to tell them we've got to do something? We've got a very difficult problem. Let's face it. It is an economic problem for you, because if you are not selling equipment, you don't make money. It is an operational problem for all of us guys out there that suddenly big brother comes down and says, Oh, by the way, you have to shut down. It is not acceptable. 

Moderator: If I could push the point again: You are saying Phase 2 is not the thing we should be focusing on. It is actually the problem, the narrowbanding problem, and that could be met by P25 in any phase.

Member: Phase 2 is a solution. A solution.

Moderator: Sorry. Ken?

Member: Our plans right now are, obviously, to narrowband. LA County, from what I understand last week, has done away with some of their channels to not go to narrowband.  My contention is, in our region, when I go narrowband and stay conventional analog, I'm going to lose a ton of coverage. So what is going to help me migrate that and mitigate that? We've done the testing from help with people. We've done side-by-side testing of the same site between Phase 2 and P25 conventional.

Moderator: Steve… 

Member: Well, Phase 2 is just one of the standards within the suite of standards. Its impetus was spectral efficiency. Those folks who are constrained and need more communications to talk fast to take advantage of that particular common air interface. 

What is really important on Project 25, whether it be narrowbanding or not, is the whole suite of standards needs to be addressed and met. And by doing that, your interoperability becomes a little easier. So Phase 2 is for those folks who are spectrally challenged, but it is not necessary for 2013. 

Member: We see the narrowbanding being one of the drivers to replace systems, many of the systems are the age they should have been replaced a while ago. Again, it takes some political and economic will to push you over the line. And that is where the discussion opens up, especially on VHF and UHF, as to what should go in to replace the existing system that must be replaced because of narrowbanding. Typically you can't afford to lose the coverage, and that is really driven for two different reasons. One is, the system is designed 15 years ago and was probably designed for 90% coverage.

Communications, the expectations have changed. So even if you were to replace the system with like technology just to meet today's expectations, you are looking at building a more sophisticated system. And then you move into the thought process of, well, if I'm going to spend X millions of dollars on my new system, it has got to last. 

You know, again, back to what I said earlier. It should be at least ready for Phase 2. Should I implement Phase 2 today? And if I do, what are the implications? 

 

At this point the roundtable discussion went onto another topic for a time. The conversation then returned to the “FCC Narrow-banding” as follows:

 

It isn't…Phase II is one of the… probably one of the best solutions to the technical side of that problem, but that is not the problem. The problem is how do you focus the energy of this country into dealing with it? One thing, I say "you." Somebody is going to have to deal with this…is 2013 in this political environment a realistic date? I think you brought that up first thing. Is that really a realistic date? The Commission said absolutely not. We are not going to change it. End of story. But somebody has to bring the horsepower together to say, it may have been realistic then. It is not realistic now. And it is fair for them to say, well, you guys should have been doing something.

Member: But the City of New York has already put in their request for pushing their narrowbanding out. And that is into the commission now. I'm curious what is going to happen with that. 

Member: One other state did that, and they were denied. I don't recall who that was.

Member: New York City.

Member: Well, in the case of New York City, that is an agency. They should be going through the regional planning group, because the plan is actually the one that has been giving the authority to manage the spectrum. New York City doesn't have the ability to change anything like that.

Member: Yet they put in their request.

Member: Right. And that just holds - that just provides some fuel to the fire of the regions coming forward and everybody else coming forward asking for flexibility or to push it out.

Member: The regional planning committees have limited resources. 

Member: Well, the regional planning committees actually have full authority.

Moderator: Just interrupting the discussion here. Isn't the FCC caught between a rock and a hard place? On the one hand, there is a demand for more spectrum, and on the other hand, you know, if they don't put a hard date in, nobody is going to do anything to change anything.

Member: Nope. They are not caught between a rock and a hard place. Again, here is the reason why we are suggesting that a change is made to where the date is abandoned. We are not suggesting that the technology is not allowed. We are suggesting that the mandate- the date that is required - is turned back to the regional planning committees, which have the full authority to create and manage that spectrum, instead of the FCC, in working with all public safety agencies. Because the regional planning committees are made up with 100% of the public safety groups within that region. So they are the ones that are the best judge in working together as to when to go from Phase 1 to Phase 2. Not the FCC, because the FCC isn't even tracking the economic situation. The difficulty in being able to manage these systems and so on. 

So we are not suggesting at all that the FCC is between a rock and a hard place. When the technology becomes available, then the consumers will drive that market and make the change when needed in working with their other agencies.

Member: The FCC pushed that all out to the regions. If there is any kind of dispute - as far as the frequency spectrum - they pushed that to the regions to handle that. They've washed their hands of that. They don't want to deal with it.

Member: So this is the only thing they haven't released is the drop dead date of Phase II for 700MHz. And it really, in the scheme of the technology and all of the capabilities, when the manufacturers can provide the commitment, and so on: that deadline just doesn't seem to be applicable in any way, shape, or form. Yet, you will have some other regions, and, again, in the communications we've had with other regions, they don't want to change that. They want that mandate to happen, because they see a need for additional spectrum within their area. And some of these regional planning groups don't feel that they are empowered well enough to go back and suggest to the public safety agency members that there is anything different for whatever reason. 

But the RPC, [regional planning committee] should have full authority, should be in control of knowing when the best time to move from one - from Phase 1 to Phase 2. And a lot will happen with the equipment obsolescence, also.

Moderator: Or it changes the date slightly. It changes the process. It says it is not applied as a blanket date to everybody. But, nevertheless, even on a regional basis, the region may say, there is a date by which we can change and the technology, to be fair, is here now. Is it not, in Phase II? So -

Member: Mr. Moderator, I don't believe the availability of technology will be an issue. I think a mandate would not totally be unwise, because I think it moves the marketplace. But I think what the problem is that it is totally inflexible. The mandate didn't have enough caveats to protect those that either through ignorance or either through financial or through lack of need could opt out of that. It is just an either or. 

As we look at the mandate, forget everything else, in the marketplace, we have a lot of manufacturers that are dumping a lot of money into, quote, Phase 2 technology, end quote. That money is going to need to be recouped from someplace. So they are looking forward to some form of increase in the market place. I'm confident of that. Although I can't speak for them, because I don't build products, but I'm confident they are looking for a return on their investment. So there has to be some incentives built into the process to take care of that, but the incentives we are focused on is the incentive for the public safety community.

Moderator: Sure.

Member: And how we make that a win-win for public safety an industry. I don't know that…I haven't looked at…I guess, it is Steve's regional coordinator that you are referring to? 

Member: Yeah.

Member: I haven't looked at what they are proposing. I suspect you are absolutely right. Some people will like it. Some people will think it stinks, and I think that is appropriate. I think that kind of discussion should go on in an open forum so we can arrive at some conclusions.

And so that industry knows where they are going. 

 

At this point the roundtable discussion went onto another topic for a time. The conversation then returned to the “FCC Narrow-banding” as follows:

 

Moderator: Mark brought up the fact we need to support VHF analog for fire guys, and that is also going to be a problem. It is not just paging. It is also support for the fire guys in the building. Craig?

Member: Yes. Two things. First of all, the FCC is not requiring that public safety paging on 115 be narrowbanded. Number (2) there is really nothing that prohibits anybody from cross-banding to a paging channel.

 

At this point the roundtable discussion went onto another topic for a time. The conversation then returned to the “FCC Narrow-banding” as follows:

 

Member: To go back to your question originally. One of the things the 700MHz plans, or the basis for a lot of the 700MHz plans that were written in the loading criteria with 800MHz plans, and so on, it really pushed for regionalization loading. Now, there isn't any specific loading requirements by the FCC in 700MHz. That is pretty much built into the plans, and Arizona's plan is different than others as far as what the loading criteria is. But the preference for a lot of the planning committees, to go back to what you had asked about to the joint or regional system, was for that. 

As a matter of fact, we struggle with issues involving jurisdictional areas in where agencies can build systems at. In other words, if we didn't put restrictions within the plan, then agencies would be able to build sites all over the place. We kind of focus that in and encourage, in our own plan within Region 3, regionalization as best as possible by only allowing an applicant to license or build within a certain area, making sure they cover their jurisdictional area. If they need coverage outside of that area - again, per the plan - then they need to work with other agencies that are in that jurisdictional area to come together. 

So, again, 700MHz and 800MHz were pretty much built out, not necessarily to require it to a T, but to as best as possible.

Moderator: Encourage...

Member: Encourage, strongly encourage regionalization of systems and infrastructure.

 

This document is the second transcript in a series of theme-focused videos of the P25 Phase 2 discussion. 

Watch the video | Download the transcript (340 KB PDF)

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