TIA, APCO Want More Flexibility for Spectrum Shared with Broadcasters
The Telecommunications Industry Association, APCO and the Los Angeles County Sheriff’s Department filed comments at the FCC supporting rule changes for the 470-512 MHz band requested in a February petition by the National Public Safety Telecommunications Council. They said the changes would make the band more useful to public safety and should not cause interference to TV broadcasts given changes in technology. The NAB and Association for Maximum Service Television said any changes must apply only to public safety use of the spectrum.
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NPSTC said in its petition for rulemaking that the FCC opened the band, TV channels 14-20, in 1971 for land mobile sharing and the rules have remained the same since then. Major public safety agencies, including the New York Police Department, the Los Angeles County Sheriff and the Los Angeles City Police and Fire departments, use the spectrum for lifeline voice operations, the group said. In total, public safety agencies in 11 markets have some operations in the band.
A key limitation is that the rules limit the location of land mobile base stations to within 50 miles of the city center, the NPSTC said. The petition requests instead that the commission amend its rules to increase the mobile/TV channel sharing area to 80 miles. “The 80 kilometer (50 mile) restriction has some undesired consequences,” the NPSTC said. “Suburban areas around these cities, that may well be part of the economy of the cities, may be excluded from land mobile operations.”
The NPSTC argued that with the transition to DTV, the FCC can safely reduce the spacing required between land mobile and TV stations without causing interference to TV broadcasts. “Notably, in adopting rules for the 700 MHz band, the Commission has already studied some of the issues that would pertain to such a relaxation at 470-512 MHz,” the group said. It also suggested that public safety entities be given access to the first 300 kHz of each available broadcast channel without the need for a waiver from the FCC.
TIA said it “strongly” supports the rule changes sought by the NPSTC. “With the June 12, 2009, transition from analog television to DTV, the Commission has the opportunity to provide greater flexibility in land mobile/television sharing,” the group said. “The NPSTC Petition proposes effective rule changes to reflect the significant advancement of television broadcast technology in recent past … Given the fact that DTV receivers are less susceptible to interference than analog receivers, NPSTC’s recommendations will not harm television viewing. The result of such modifications will provide significant benefits to public safety and other land mobile users and allow more efficient use of a scarce spectrum resource.”
APCO also endorsed the changes sought by NPSTC. “Expanding the permitted radius from 50 to 80 miles will allow some public safety radio systems to cover sprawling suburban communities that are often more than 50 miles from city centers,” the group said. “This will improve regional interoperability, and enhance coverage and capacity for systems serving rapidly growing communities.”
The L.A. County Sheriff’s Office said the 470-512 MHz band likely will remain the main public safety radio frequency band in that area for many years to come. “Therefore, it is critical that public safety systems in the band be allowed to operate to the maximum extent possible without causing interference to television stations entitled to interference protection under FCC rules,” the agency said. “The transition to digital television provides an excellent opportunity to update those rules as digital television transmission is less susceptible to interference than analog transmissions.” The agency asked the FCC to make an additional change specific to its county and change the geographic center listed for Los Angeles. “The geographic center specified in the rule is at Los Angeles City Hall,” it said. “However, because of the size and shape of Los Angeles County, the current 50-mile radius excludes portions of the County’s jurisdiction north of the San Gabriel Mountains.”
The Land Mobile Communications Council endorsed the NPSTC petition, but asked for one change, saying the first 300 kHz of each available channel should not be set aside just for public safety. “This segment of most channels has been set aside for common carrier operations under Part 22 of the Rules,” the group said. “LMCC urges the Commission not to reserve unused frequencies within the broadcast channels for public safety use only, but to make them available to any applicant eligible for licensing under Sections 90.20 and 90.35 of the Rules. It is evident that wireless common carriers have made only very limited use of the 470-512 MHz band and, instead, are providing service on the substantial amounts of cellular.”
NAB and MSTV did not oppose the changes outright, but said the FCC should proceed with caution. The broadcaster groups said they would support a rulemaking notice on the NPSTC’s proposed changes, but only covering public safety. “MSTV and NAB support providing public safety users with appropriate flexibility,” they said. “It is important to note, however, that the public interest justifications for permitting expanded land mobile operations in television channels 14-20 are sufficient at this time only for public safety users but not for other land mobile operators.”