Subject: [NEXTEL-1] APCO Files Narrowband-PETITION FOR RECONSIDERATION

From: [email-masked]
Date: Tue, 19 Aug 2003 05:05:34 -0400

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC  20554
In the Matter of

Implementation of Sections 309(j) and 337 )   WT Docket No. 99-87
of the Communications Act of 1934 as
Amended
Promotion of Spectrum Efficient    RM-9332
Technologies on Certain Part 90 Frequencies)
To:	The Commission
	PETITION FOR RECONSIDERATION

INTRODUCTION AND SUMMARY
The Second R&O reflects the Commissions desire to improve spectrum efficiency in the crowded VHF and UHF land mobile radio frequencies below 800 MHz.
The goal is to move licensees to narrower channels and, in theory, multiply the number of available channels within the same amount of spectrum.    Prior efforts to refarm land mobile spectrum have been ineffective, due in part to the absence of a requirement that licensees convert to more efficient narrowband radio equipment by a specific date.
Instead, the Commission had merely used its equipment authorization process to force manufactures to offer narrowband equipment, without any concurrent requirement that users purchase or deploy narrowband capabilities.
Now, the Commission has taken a more affirmative step and established ultimate
dates by which licensees must implement narrowband (12.5 kHz) equipment for
existing systems. 

 For public safety licenses, a deadline of January 1, 2018, was
established for VHF High Band (150-170 MHz) and UHF (421-512 MHz) systems.3  We do not object
to a mandatory conversion date, which we agree is necessary to achieve better
efficiency in the land mobile spectrum.4  Indeed, if other aspects of Second R&O are modified
as discussed below, we believe that the 2018 deadline can and should be moved up to
January 1, 2013.5

The Commissions Second R&O went well beyond adopting a final date for narrowband conversion.  

It also mandated that, within just six months of Federal
Register publication (i.e., January 13, 2004), applications to expand the coverage area of
existing systems would only be approved for narrowband (12.5 kHz) operation.  The
Commission also adopted rules that will terminate the manufacture and importation
of radios with wideband (25 kHz) capability by 2008, well before the date by which
licensees must otherwise cease wideband operations.  Finally, the Commission
limited licensees flexibility to combine channels, while maintaining equivalent throughput
efficiencies, for mobile data or multi-bandwidth equipment.

If not changed, the near-term dates and requirements adopted in the Second R&O will prevent public safety licensees from adding critical capacity and coverage for existing systems, locking them into current channels and equipment supplies, or forcing them to expend scarce resources to replace prematurely their entire radio systems.
Therefore, the rules adopted in the Second R&O must be modified to ensure that, pending the final conversion date, public safety agencies will continue to have the necessary flexibility to modify and add to their radio systems to accommodate changing public safety operational requirements.

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514682297

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