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‘High Level’ Estimates

NPSTC Says Most Public Safety Agencies Using T-Band Don’t Have Suitable Replacement Spectrum

Public safety agencies in at least five of 11 metro areas that use the T-band for communications don’t have anyplace to go if they clear the band, as directed by the February 2012 spectrum law, said a report released Tuesday by the National Public Safety Telecommunications Council. The report from NPSTC’s T-band task group estimated the overall cost of moving from the T-band could be more than $6 billion. While the spectrum act would pay for relocation through the sale of the spectrum, NPSTC questioned whether auction proceeds would cover the costs of moving the systems.

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As a central compromise in the spectrum bill, public safety got $7 billion to build FirstNet and use of the 700 MHz D block, but had to give up use of the T-band, which the FCC is required to auction within nine years of enactment and clear within 11 years.

The five metro areas “without sufficient spectrum in any band to relocate their existing T-Band operations” are Boston, Chicago, Los Angeles, New York and Philadelphia, NPSTC said (http://bit.ly/YSIyMU). “The adequacy of relocation spectrum in three additional areas, San Francisco, Washington, D.C., and Pittsburgh is marginal.” Public safety users in three T-band areas -- Dallas, Houston, and Miami -- potentially have adequate spectrum to relocate, the report said.

The report reviews various alternative spectrum bands and explains why each may not be suitable. “Of the potential alternative spectrum analyzed, VHF, UHF, and the 800 MHz band have practically no available channels,” the report said. “The 700 MHz narrowband General Use spectrum not yet licensed is insufficient to compensate for loss of the T-Band public safety channels in the Boston, Chicago, Los Angeles, New York, and Philadelphia metro areas. Those areas would still face a shortfall of spectrum."

NPSTC based its cost estimates on FCC data from the Universal Licensing System and on the results of a questionnaire NPSTC sent to licensees. It offers only “high-level estimates,” the report said. “Unfortunately, with roughly 1,000 licensees, NPSTC lacks the resources for a comprehensive analysis of the transition cost for each licensee,” the report conceded. “As a result, the Task Group determined that it should approximate the cost and make assumptions based on available data.”

One factor driving up the costs is that an agency can’t shut down its old T-band system until the new system is in operation, the report said. “Due to the complexities of a transition out of the band, the Working Group assumed that transition required parallel operations of a T-Band and ‘other band’ system."

Towers, shelters and other “site related” expenditures are the single biggest ticket item, NPSTC said. Since two systems will have to be operational at the same time and since “many existing towers or supporting facilities are overloaded, this requirement could trigger upgrades or replacements to many facilities in the 11 markets,” the report said. Costs would vary widely across the 11 markets, with a high of $1.4 billion in New York, where site development alone would cost an estimated $314 million, to Philadelphia ($1.2 billion) to a low of $11.4 million in Houston, NPSTC found.

In the end, NPSTC questions whether moving public safety operations out of the T-band, as required by the law, adds up. “It appears the intent of the law may be to gain additional broadband spectrum for public use,” the report said. “Extensive TV broadcast operations throughout the country and industrial/business systems in 11 metro markets will remain on T-Band channels even if public safety systems are relocated out of the band. These circumstances are unlikely to produce the auction revenue needed for public safety relocation or result in additional broadband spectrum for public use.”