NPSTC Says Costs of Moving Narrowband Incumbents Should Be a FirstNet Expense
The National Public Safety Telecommunications Council said in a filing at the FCC posted Tuesday the costs of moving the public safety agencies with narrowband operations in spectrum that will be used for FirstNet’s wireless broadband network should be paid for by FirstNet. The NPSTC responded to a March 7 NPRM that asked broad questions about technical rules for the new public safety network.
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The NPRM (http://bit.ly/130Wkz9) estimated the cost of relocating narrowband operations could be as high as $74 million. Those costs were to be paid by the money raised through the sale of the 700 MHz D block, but when that spectrum failed to sell in the 2008 auction, it left public safety without a fallback funding mechanism other than FirstNet. The systems that need to move were early adopters that launched operations in the spectrum prior to the 2007 reconfiguration of the 700 MHz band plan.
"NPSTC notes that the Commission previously recognized that these narrowband 700 MHz licensees deployed under the rules in effect at the time and that providing reimbursement funding was appropriate,” NPTSC said (http://bit.ly/13g1tCn). “Because the original mechanism for that funding is no longer available, an alternate funding source needs to be determined. NTIA, FirstNet and FCC should coordinate to determine relative responsibilities and develop and implement a relocation mechanism. We recommend that FirstNet, in consultation with the Commission, consider an approach that allows the legitimate costs of relocating these narrowband 700 MHz systems in the spectrum in accordance with the revised bandplan to be designated as an eligible expense under the broadband deployment funds Congress has provided FirstNet."
The Association of Public-Safety Communications Officials said FirstNet should provide “fair and reasonable reimbursement” for narrowband incumbents who must move (http://bit.ly/13g2pqq). “The goal should be to afford FirstNet with the greatest possible range of options to address these matters, so that it can ensure the deployment of an advanced, interoperable, public safety broadband network while protecting the interests of incumbents,” APCO said. “For example, FirstNet may determine to include the relocation needs of incumbent public safety narrowband operations as part of its request for proposals to implement the [public safety broadband network] in states having such incumbent operations."
"The cost of relocating these narrowband systems to comply with the revised band plan [should] be deemed an eligible expense from the broadband funds provided to FirstNet,” Motorola said (http://bit.ly/12fZlz0). “While narrowband relocation is not specifically addressed in the Spectrum Act, MSI sees no provision in that Act that would prohibit such a practical solution."
Most commenters agreed with a proposal in the NPRM that the technical service rules for the 758-768/788-798 MHz public safety broadband spectrum should be consolidated under Part 90 of the commission’s rules. “Such a consolidation is a logical outgrowth of the reallocation of the D block spectrum to public safety,” NPSTC said. “These technical service rules, together with other provisions yet to be defined by FirstNet, the nationwide licensee of the spectrum, will form the basis for operations in the public safety broadband spectrum."
"Alcatel-Lucent agrees with the Commission’s proposal to consolidate the technical rules for the D Block and existing public safety broadband spectrum so the entire FirstNet spectrum allocation is subject to a common set of rules,” the equipment maker said (http://bit.ly/19jKeok). “Alcatel-Lucent further supports that the newly unified technical rules governing FirstNet’s operations mirror commercial operations in the 700 MHz band to the maximum extent possible. The proposal to move technical service rules from Part 27 to Part 90 achieves this."
"As a broad principle of general application to this proceeding, TIA advocates that the Commission should avoid unintended uncertainly [sic] or unnecessary ambiguity in new Technical Service Rules,” the Telecommunications Industry Association said (http://bit.ly/18x37mi). “Broadly then, we concur with the Commission on the consolidation of Part 27 and Part 90 rules since it’s consistent with the principle of retaining existing practices.” TIA said since FirstNet is expected to rely on existing commercial standards, “the adoption of specialized or unique requirements would increase the deployment costs and diminish product availability."
On another issue raised in the NPRM, APCO said it’s too early to consider rules for states that want to opt out of FirstNet. “APCO submits that it is entirely premature to consider matters related to the opt-out provision,” the group said. “Many steps must occur before the opt-out provision even comes into play, and then a state desiring to opt out must overcome a number of significant showings.”