WT Docket No. 99-87 Mandatory Narrowbanding Ten Years of Tinkering Robert L. Ritter, Esquire Shulman, Rogers, Gandal, Pordy & Ecker, P.A. www.shulmanrogers.com IWCE April 6, 2005
Who Are We? Full Service Law Firm In Rockville, Maryland FCC Representation Counsel To Frequency Coordinators (PCIA, ITA And FIT), Public Safety And Private Radio Licensees And SMR Operators Since 1984 Advanced Frequency Search Capability Experienced Licensing Preparation Personnel Auction Assistance License Swap Negotiations Wi-Fi/WLAN And Tower Negotiations Complete General Business Representation Corporate, Litigation, Real Estate, Trusts & Estates, Immigration, etc. 2
Background: 1995 Report & Order 1995 FCC Refarming Docket Decisions No Certifications For New 25 khz Only Equipment After February 1, 1997 Multi-Mode Mode Equipment (i.e. 25 khz & 12.5 khz) Permitted Equipment Certified Under Old Rules May Continue To Be Manufactured New Wide-Band Only Equivalent Efficiency Equipment Permitted No Certifications For New 12.5 khz Only Equipment After January 1, 2005 Multi-Mode Mode Equipment (i.e. 12.5 khz & 6.25 khz) Permitted Equipment Certified Under Old Rules May Continue To Be Manufactured 3
FCC Summary: 1995 Order Deadlines June 1995 1 st R&O March 2003 2 nd R&O Dec. 2004 3 rd R&O New 25 khz Apps Mods to expand 25 khz Contours Certification of 25 khz equipment 2/1/1997 Build or import 25 khz equipment Mandatory B/ILT 12.5 khz conversion Mandatory PS 12.5 khz conversion 6.25 khz requirements 1/1/2005 4
Background: 1995-2003 1998 AMTA Files Petition For Rule Making Requesting That These Frequencies (And( 800 MHz Non-Auctioned Spectrum) Be Channelized At 12.5 khz 1999 FCC Issues Further Notice Of Proposed Rule Making Asking Whether Mandatory Migration Date Should Be Set March 2003 2 nd Report & Order Issued Petitions For Reconsideration 5
March 2003 2 nd MO&O FCC Decisions New 25 khz Applications For 150/450/470 MHz Frequencies Prohibited Six Months After Report & Order Is Published Deadline Was January 13, 2004 Modification Applications To Expand Incumbent Contour Prohibited At Same Time Petitions For Reconsideration Filed On Time Frame Public Safety Agencies Wanted Longer, B/ILT Want Shorter FCC Issued Stay While Reviewing 6
March 2003 2 nd MO&O FCC Decisions Prohibits Certification Of Equipment Capable Of Operating With Only One Voice Path Per 25 khz Beginning January 1, 2005 No More Multi-Mode Mode Equipment Prohibits Manufacture Or Importation Of Equipment Capable Of Operating One Voice Path Per 25 khz Beginning January 1, 2008 MO&O Unclear As To Whether 25 khz Equivalent Efficiency (Such As TDMA) Permitted 7
March 2003 2 nd MO&O FCC Decisions Mandatory Migration To 12.5 khz Operation (Or Better) for 150/450/470 MHz Licensees By January 1, 2013 For Non-Public Safety By January 1, 2018 For Public Safety Continued Operation After These Dates, Even On A Secondary Basis, Prohibited NPRM Requesting Comments On Migration To 6.25 khz Or Equivalent Technology 8
FCC Summary: 2003 Order Deadlines June 1995 1 st R&O March 2003 2 nd R&O Dec. 2004 3 rd R&O New 25 khz Apps 1/13/2004 Mods to expand 25 khz Contours 1/13/2004 Certification of 25 khz equipment 2/1/1997 1/1/2005 Build or import 25 khz equipment 1/1/2008 Mandatory B/ILT 12.5 khz conversion 1/1/2013 Mandatory PS 12.5 khz conversion 1/1/2018 6.25 khz requirements 1/1/2005 TBD 9
December 2004 3 rd MO&O FCC Decisions Mandatory Migration Date January 1, 2013 Bus/Ind Licensees Must Migrate To 12.5 khz Or Equivalent Technology By January 1, 2013 Public Safety Licensees Must Migrate To 12.5 khz Or Equivalent Technology By January 1, 2013 10
December 2004 3 rd MO&O FCC Decisions Deadline For Wideband Applications Is January 1, 2011 After January 1, 2011 Applications For New Operations Must Be For No More Than 12.5 khz Bandwidth (Or Equivalent Efficiency) Applications For Modifications Of Existing Operations That Expand The Contour Of The Existing Station Must Be For Narrowband Or Equivalent Efficiency 11
December 2004 3 rd MO&O FCC Equipment Sales Decisions Wideband Only Equipment Manufacturing And Importation Deadline January 1, 2011 Equivalent Efficiency Wideband Equipment Will Be Permitted One Channel Per 12.5 khz (Voice), 4800 bps Per 6.25 khz (Data) New Equipment Certifications New Equipment Models Submitted For Type Certification After January 1, 2005 May Specify 25 khz Operation, But Must Meet Equipment Efficiency Of 6.25 khz One Channel Per 6.25 khz (Voice), 4800 bps Per 6.25 khz (Data) However, Deadline Stayed Pending Comments On 3 rd NPRM Paging-Only Frequencies Exempt From Narrowbanding 12
December 2004 3 rd Notice Of Proposed Rule Making FCC Seeks Comments On Elimination Of Mandatory Migration To 6.25 khz Equivalent Technology Comments Due 60 Days After Publication Of NPRM In The Federal Register Reply Comments Due 90 Days After Publication Of NPRM In The Federal Register 13
FCC Summary: 2004 Order Deadlines June 1995 1 st R&O March 2003 2 nd R&O Dec. 2004 3 rd R&O New 25 khz Apps 1/13/2004 1/1/2011 Mods to expand 25 khz Contours 1/13/2004 1/1/2011 Certification of 25 khz equipment 2/1/1997 1/1/2005 1/1/2005 (Stayed) Build or import 25 khz equipment 1/1/2008 1/1/2011 Mandatory B/ILT 12.5 khz conversion 1/1/2013 1/1/2013 Mandatory PS 12.5 khz conversion 1/1/2018 1/1/2013 6.25 khz requirements 1/1/2005 TBD Eliminate????? 14
THANK YOU! Robert L. Ritter, Esquire Shulman, Rogers, Gandal, Pordy & Ecker, P.A. 11921 Rockville Pike, Third Floor Rockville, Maryland 20852 www.shulmanrogers.com 15