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Back to Archives | Back to April 2005 Contents 

Communications:800 MHz Public Safety Rebanding:A Solution for Commercial Mobile Radio Service Interference to Public Safety Radio Systems and Its Effect on Public Safety Agencies

By Harlin R. McEwen, Chief of Police (Retired), Ithaca, New York, and Chairman, IACP Communications and Technology Committee; and Robert M. Gurss, Legal and Government Affairs Director, Association of Public-Safety Communications Officials International, and Telecommunications Attorney, Fletcher, Heald & Hildreth, PLC






tarting later this year, and continuing for the next several years, many public safety radio communications systems will be required to modify their radio frequencies as part of a Federal Communications Commission (FCC) plan to prevent interference problems. The affected radio operations are in the 800 MHz band, where Nextel and other cellular-type commercial radio service (CMRS) providers operate alongside public safety and Private Wireless radio systems, such as those used for internal business operations. Unfortunately, that interleaving of CMRS and non-CMRS systems has led to dangerous interference during many public safety operations. The FCC's solution, supported by IACP, APCO International, and others, is to reband 800 MHz to separate public safety channels from CMRS channels. Although that will require most public safety 800 MHz systems to change frequencies in the band, Nextel will cover all of the costs of the rebanding. The details for rebanding each public safety system will be addressed through negotiations with Nextel, subject to approval by the independent Transition Administrator and, if necessary, the FCC.

History of the Problem
In August 1999 the Phoenix Police Department and other public safety agencies discovered they were experiencing serious interference in their 800 MHz public safety radio systems. CMRS licensees in the band created the interference. Much of the interference was traced to Nextel, but interference also was traced to other cellular providers. Public safety officials launched several efforts to address the causes and possible solutions to the interference problems. Despite considerable efforts by the public safety community to solve the problem, it continues to escalate, and more and more public safety agencies throughout the country are identifying similar problems in their jurisdictions.

There are two fundamental reasons for CMRS interference in public safety radio systems. The first reason is the mixed and interleaved allocation and licensing of CMRS and public safety radio systems throughout the 800 MHz band. Because public safety channels are mixed among commercial channels, public safety receivers hear radio frequency (RF) throughout the band and can't be filtered to limit their sensitivity; for instance, public safety receivers today hear cellular A and even B carriers as well as Nextel.

The second reason for CMRS interference is that the basic designs of public safety and CMRS systems have diverged in the last five to 10 years and are basically incompatible in the same spectrum and geography. Public safety systems typically have one base station or a few base stations serving a large metropolitan area, and the resultant signal strength varies substantially due to buildings, terrain, and distance. CMRS systems use hundreds of low-power base stations in a metropolitan area with frequency reuse to provide greater capacity and in-building service. Locally robust CMRS transmissions may create intermodulation (IM) products and noise that overpowers less robust public safety transmissions within a few hundred yards of the CMRS base station. CMRS base stations lower than about 75 feet with cellular and Nextel co-locations are more likely to produce IM, particularly where the public safety signal is weak.

IM is the primary interference mechanism. Locally stronger cellular and Nextel signals, on nonpublic safety frequencies, can combine in the public safety receiver itself to form a new frequency. If that new frequency is being used by the public safety system, interference occurs.

Events Leading to the Rebanding Solution
November 21, 2001: Nextel filed a letter (commonly referred to as the Nextel White Paper) with the FCC proposing a substantial reallocation of the 800 MHz band in an effort to address some of these issues. The representatives of six major public safety organizations, the International Association of Chiefs of Police (IACP), Major Cities Chiefs Association (MCC), National Sheriffs' Association (NSA), Major Counties Sheriffs Association (MCSA), International Association of Fire Chiefs (IAFC), and the Association of Public-Safety Communications Officials (APCO) International were briefed by Nextel on the proposal prior to its submission. As a result of the Nextel briefing, the public safety organizations sent a letter to the FCC stating that the Nextel proposal was a major step in the direction of solving the problem and offering to work with the FCC and the CMRS industry in addressing and resolving the difficult interference problems in the 800 MHz band.

March 15, 2002: The FCC released a Notice of Proposed Rulemaking (NPRM) in response to the Nextel White Paper and solicited comments from all parties. The NPRM was titled "Improving Public Safety Communications in the 800 MHz Band and Consolidating the 900 MHz Industrial/Land Transportation and Business Pool Channels."

May 6, 2002: The IACP, MCC, NSA, and MCSA filed initial comments with the FCC applauding the FCC for opening a rulemaking focused on improving public safety systems and eliminating interference. The comments urged the FCC to adopt rules to solve the problems.

August 7, 2002: The IACP, MCC, NSA, MCSA, IAFC, and APCO International joined with a group of Private Wireless and CMRS organizations, including Nextel (referred to as the Joint Commenters), to file reply comments with the FCC. This filing referred to as the Consensus Plan was signed by organizations representing most of the affected licensees in the 800 MHz Land Mobile Radio band. This plan proposed to establish two separate contiguous spectrum blocks at 800 MHz to separate cellular and noncellular systems and suggested a mechanism for accomplishing this, including $500 million funding by Nextel to pay for public safety costs for relocating within the band.

On September 23, 2002, December 24, 2002, and February 25, 2003, the IACP, MCC, NSA, MCSA, IAFC and APCO joined with the Joint Commenters to file further consensus comments with the FCC.

July 8, 2004: The FCC adopted a report and order that, as recommended by the national public safety organizations, calls for a reconfiguration of the 800 MHz band to eliminate interference to public safety.

August 6, 2004: The FCC released the text of the report and order. Part of the report and order requires Nextel to "provide an irrevocable letter of credit securing $2.5 billion." It envisions that the letter of credit will serve as the funding source for the costs involved in reconfiguring the 800 MHz systems for non-Nextel licensees. The FCC also directed a process to select an independent party, the Transition Administrator (TA), to oversee the reconfiguration of the 800 MHz band.

October 29, 2004: The FCC Wireless Telecommunications Bureau (WTB) issued a public notice stating that the WTB concurred with the search committee's selection of a three-organization team to serve as the Transition Administrator. The team consists of BearingPoint, Squires-Sanders-Dempsey LLP, and Baseline Telecom Inc.

December 22, 2004: The FCC issued a supplemental order on reconsideration that was intended to clarify various issues raised in the proceeding.

January 31, 2004: The Transition Administrator submitted its proposed rebanding schedule to the FCC. The schedule divides the nation into four geographic waves, with the first wave starting the process on June 27, 2005, and additional waves starting at subsequent three-month intervals. The first wave includes the East Coast from Maine to Virginia (excluding Western Pennsylvania and Northern and Western New York), Indiana, Illinois, Wisconsin, Colorado, Utah, Nevada, Northern California, Oregon, and Hawaii. The second wave includes all other states except the Southeast and certain Canadian and Mexican border areas (Alaska, Arizona, Southern California, Michigan, New Mexico, Western and Northern New York, Ohio, Western Pennsylvania, Washington, and portions of Texas). The third wave is the Southeast including Alabama, Florida, Georgia, Mississippi, North Carolina, and South Carolina. The fourth and final wave covers all remaining areas of the Mexican and Canadian border areas noted above. Note that within each wave there are two phases, the first involving channels in the 806-809/851-854 MHz portion of the band, and the second involving the 821-824/866-869 MHz portion of the band (also known as NPSPAC).

Thus, when a particular public safety system will begin rebanding will depend upon the portion of the 800 MHz band in which it operates, and the geographic wave in which it is located. Within each wave, the entire process will take approximately 30 months. The timing for the Canadian and Mexican border areas is contingent upon bilateral treaty negotiations.

February 7, 2005: Nextel formally accepted the terms of the FCC's order.

Local Department Rebanding
Many public safety agencies operating in 800 MHz, especially those in the first phase of the first wave, will soon be contacted by Nextel to initiate negotiations for the rebanding process. Agencies that prefer not to negotiate directly with Nextel have the option of using the Transition Administrator as an intermediary. The Transition Administrator is also available to mediate if parties are unable to reach agreement in the negotiations.

In most cases, rebanding will require each radio on the system to be retuned although some older radios used on certain portions of the 800 MHz band will need to be replaced. In either case, the cost of retuning or, if necessary, replacing radios must be paid for by Nextel. Agencies have the option of making expenditures and obtaining reimbursement, or requiring Nextel to pay costs directly. Agencies may also receive reimbursement for reasonable internal labor costs and reasonable fees for consultants and attorneys. Most importantly, the rebanding must occur in a manner that does not disrupt emergency communications. The FCC's rules also ensure that the replacement frequencies are comparable to current frequency assignments.

Local Steps to Rebanding
Public safety system operators in the 800 MHz band should take several steps to prepare for this process.
First Step: Local agencies should determine whether they operate on frequencies subject to the rebanding requirement (some 800 MHz channels will remain unchanged).

Second Step: Local agencies should review the FCC-approved schedule and determine the likely timing of rebanding for their system.

Third Step: Agencies should update their equipment inventory to ensure that they have accurate information regarding the number, model, and location of all radios that may require retuning or replacement.

Fourth Step: Agencies should consider whether they will need assistance from engineering or legal consultants to guide them through the rebanding negotiations and implementation.

Most importantly, affected agencies should stay informed. One excellent way of doing so is through APCO's 800 Alert Web site (www.800mhz.org), which provides detailed information and links to related sources of information offered by the FCC and the Transition Administrator. ■










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From The Police Chief, vol. 72, no. 3, April 2005. Copyright held by the International Association of Chiefs of Police, 515 North Washington Street, Alexandria, VA 22314 USA.








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