FCC Faces Tough Assignment Addressing Narrowbanding Waiver Requests
The New York City Transit Authority sought a 42-month waiver of the FCC’s Jan. 1, 2013, narrowbanding deadline. Some other large systems also are applying for waivers, raising a host of issues for the FCC, where officials say they won’t grant waivers lightly. The transit authority’s filing speaks to the complexity of meeting the deadline and the difficulty, especially for large systems. The authority said it will need until June 2016 to complete the transition to a narrowband system.
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"Whenever the FCC issues a rule and parties file waivers, the reviews of the waivers are usually pretty intense because if everybody is asking for waiver of the same rule, then perhaps there’s a problem with the rule itself,” said a public safety official. “If everybody is asking for a waiver with a slightly different explanation or justification then it’s going to create more work for the commission to thoroughly review each of them as they're submitted."
"As the largest public transportation agency in North America, the Authority has spent considerable time and money carrying out a comprehensive program designed to ensure that its vital subway communications will not be compromised during the transition from wideband to narrowband technology,” the authority said (http://xrl.us/bmqffo). “Despite the Authority’s good faith efforts to meet the Commission’s deadline, the enormous scope of the narrowband project, coupled with unusual circumstances beyond the Authority’s control, will prevent the Authority from transitioning to narrowband technology” by the deadline.
The transit authority noted in its filing, that its board approved a contract in 2010 for the narrowbanding of the system, but that contract was rejected by the New York State Comptroller in December 2010 “based upon the conduct of the chosen proposer in connection with its performance of an unrelated City contract.” The transit authority had to issue a second request for proposals and its board approved a contract with Alcatel-Lucent last October.
Moving to a narrowband system is a huge job, covering 800 miles of track traversing four boroughs of New York City, 486 stations and 119 radio sites, and costing an estimated $200 million, the authority said. “To manage such a large and complex system, the Authority must carefully plan, coordinate, and implement all major network upgrades, particularly those requiring the total replacement of radio equipment, such as the narrowband migration at issue,” the transit authority said. In addition, most of the radio equipment is at least 30 years old and must be replaced by the city as it moves to a narrowband system, the authority said. “Despite the Authority’s diligent and sustained efforts to meet the FCC’s narrowband deadline, the magnitude and complexity of the Narrowband Project, and the unusual factors noted above that prevented the timely awarding of the narrowbanding contract, have made the Authority’s initial and revised migration plans and schedules no longer viable."
The state of Maine sought a one-year waiver, as it completes a complete changeover of its radio system, which is estimated to cost $54 million (http://xrl.us/bmqfmd). Its move to narrowbanding is also complex, Maine said: “The State of Maine consists of 33,215 square miles of extremely diverse geography that includes 17 million acres of forest, 3,500 miles of coastline, 6,000 lakes and ponds, and the longest land border with Canada (611 miles) of any state other than Alaska.” Part of the problem it has faced is slow FCC action approving the applications the state has filed seeking frequency allocations for the new system. “The new system will make full use of the VHF Public Safety Pool, including channels already assigned to the State, to the maximum extent permitted by frequency coordination policies, engineering practices, and FCC licensing rules,” the state said. “A substantial number of the State’s applications for additional Public Safety Pool channels are still pending as of the date of this waiver request. Due to a variety of factors, including the FCC’s processing backlog, some of these applications are unlikely to be granted until early in 2012."
The Spokane (Wash.) Regional Emergency Communications Systems asked for a one-year waiver. Spokane said it has been working diligently with Motorola to complete narrowbanding, but has run into unexpected complications building new radio sites (http://xrl.us/bmqfm4). “Some of the sites are well over 3000 feet in elevation, with the highest sites over 5000 feet, and become inaccessible during the winter months,” the filing said. “Because each facility must go through a comprehensive permitting review process and this has taken longer than originally anticipated, permits for construction of some facilities have only recently become available."
The FCC recently sought comment on various waiver requests that have been filed (http://xrl.us/bmqgxy).