Chances are your agency operates radios and various other equipment that work on a radio frequency. Legally, your department must obtain and maintain a license for each "call sign" or frequency through the Federal Communications Commission (FCC) for authorized use. Frequency licensing is required for everything from two-way radios to remote use bomb disposal robots. As mundane as it may seem, having the proper paperwork in order is necessary to maintain use of these frequencies critical to daily operation.
Such licenses have been important since before the days of "Dragnet" and "Adam 12." But with the advent of cell phones, the Internet, and other technological innovations, increasing competition for available bandwidth has led the FCC to make changes, including reallocating the spectrum to provide room for everyone. This involves migrating to a different bandwidth.
What does this mean for you? New regulations require that every public safety agency switch over to narrowband frequencies by 2013 or else. Now law enforcement agencies that don't bring their equipment and licenses up to date could find themselves in a world of hurt.
Rebanding and Narrowbanding
Rebanding and narrowbanding are separate issues police departments are tackling simultaneously to bring their communications systems into the modern age.
"Narrowbanding is where everybody has to migrate from a 25kHz bandwidth system to 12.5kHz bandwidth," explains Farokh Latif, director of automated frequency coordination at APCO.
This switch will require that licenses be updated. And in some cases it might require changes in equipment. Radios and other equipment operating on wideband will not be available for purchase after January 2011, and no new or modified wideband frequency licenses will be authorized after that time.
"Rebanding is the effort that started three years ago, where Sprint Nextel is vacating some of the channels and relocating public safety licenses to another portion of the band in order to alleviate the interference issues that were being experienced by public safety agencies due to Sprint Nextel and other cellular carriers," says Latif.
The year 2013 might seem a long ways off, but it takes time to process license modifications authorizing a switch to narrowband. It can take even more time if your agency wants or needs to make any additional changes to its licenses, such as increasing wattage or moving transmitters to prime locations.
In fact, any changes could add two or three months to the already month-long process. And license applications that are close to Canada undergo review by Industry Canada (the Canadian version of the FCC) to ensure that no interference will be caused to Canadian licensees, which could add more processing time. If that puts you past the deadline, you could find yourself out of luck. Especially with so many agencies scrambling to switch over at the same time.
"We're getting very few requests for changes to narrowband right now, which is a concern because the licensing system is already glutted with requests for licensing," says Jack Campbell, regulatory affairs manager at Milwaukie, Ore.-based Radio Licensing Services. "Once everyone starts going full bore to narrowband on their licenses, I think they're going to overtax the system. There just isn't going to be the personnel to handle all those changes all at once."
In other words, if your agency hasn't started switching over to narrowband, it better start now.
Where to Start
First of all, if you haven't already, make room in your agency's budget to pay for licensing and upgrades. Again, this might not seem like a high priority, but if money isn't set aside now, it will take all that much longer to get the ball rolling. And you don't want to wait until the eleventh hour.
Finding out how much money is needed will require talking to whomever is in charge of communications and/or frequency licensing for your department—whether that be in house or an outside consultant.
If it's a smaller department and the chief is the default person in charge of maintaining frequency licenses, he or she might not be aware of this new deadline looming. Or it just might have fallen through the cracks amid other more immediate concerns. A large agency might have its own unit devoted to managing licenses. This can be more cost effective than hiring an outside company to fulfill this function on an ongoing basis.
If your agency often works with surrounding departments and communications interoperability is an issue, you'll also need to make sure all involved agencies will be able to switch to narrowband at the same time.
Regardless of your situation, if you are unsure how to go about making the transition to narrowband frequencies, contact APCO (Association of Public-Safety Communications Officials) or a reputable consultant who specializes in such matters.
Working with a Consultant
"Legally, public safety agencies can file for their own license—if they know how to," says John Black, president of Spectrum License Consultants in Dallas, Texas. "It's kind of like, legally you can do your own income taxes, but it's so complex that most people use a CPA."
This analogy is especially apt since the FCC began using a system of forms similar to that used by the Internal Revenue Service. Everyone needs to fill out one main form, but there are additional "schedules" that may or may not need to be filed, depending on the license and the situation. Consultants fill out and file the necessary paperwork and follow through to make sure the license is granted.
But paperwork is only part of the process. Many consultants also assist departments with basic system configurations to accomplish their desired goals.
"For example, they may want to put a radio tower in a certain location, but they're not quite sure if it's going to give them the coverage they need throughout their jurisdiction," says Black. "In that case, we can do engineering studies to determine theoretically if a transmitter at that location is going to give them the coverage that they require."
One of the major advantages of using a consultant is that the company not only has the expertise to handle all licensing requirements, but is tasked solely with keeping on top of any changes. You don't have to worry about the FCC mailing an important notice to a person who no longer works at your agency, resulting in a lapsed license because no one ever filed the proper paperwork. APCO now provides an automated system designed to prevent this from happening.
If you work at a large agency, you might use an in-house department to take care of licensing requirements. But even someone who is responsible for communications and everything that includes might have too much on his or her plate—not to mention a lack of very specific technical skills—to properly fill out often confusing forms.
"I actually started in the radio business," says Spectrum License Consultants' Black. "There are a lot of symbols and codes on the forms. You're simply not going to know how to answer those unless you understand radio."
It's also not enough to just file for a new or modified license. Follow-up paperwork is just as important.
"Once a license is granted—and this applies to either a new license or a modified license—that department has one year from the date of grant to file another set of papers with the commission," says Black. "It's called a schedule K, or 'notification of construction,' advising the commission that the department is now operational on those frequencies. If you don't do that, the FCC will automatically terminate your license."
Of course, your agency doesn't need to work with a consultant, as long as someone can keep all licenses up to date.
"The best thing we recommend is for licensees to review their administrative information on the universal licensing system at least once a year to make sure that all the information on there is correct and accurate," says APCO's Latif. "It can be done for free online on the universal licensing system and it will not take longer than 10 minutes of their time."
Dire Consequences
The FCC routinely notifies all its licensees of important announcements and of the need for license renewals. Agencies have also known about the new narrowbanding requirements for years. So although this might seem like a lot to handle, from the FCC's perspective it is being more than fair.
Usually a public safety frequency licensee renews a license every 10 years or when any modifications to frequency, equipment, or locations are needed. But you cannot renew an expired license. There is some recourse for a lapsed license if there is a good reason. But otherwise it must be handled as a new license. That requires starting the process—and the processing time—all over again.
To make matters worse, once you've lost a frequency, others can gain authorization to use it. And if you're in a metropolitan jurisdiction, agencies are scrambling for anything that becomes available. You might need to get on a waiting list to obtain any frequency to replace the one you lost when your license lapsed.
If you choose to ignore the deadline for upgrading or renewing your frequency license, you can be fined $10,000 per day per license, according to the FCC policy statement 1.80. But there are other possible outcomes.
According to Spectrum's Black, if an FCC inspector is feeling charitable, he or she might first only issue a warning to get a lapsed license corrected immediately. "Or he can say, 'You must cease and desist all operations until you correct the license,'" says Black. "That's a horrible thing. That's actually worse than a fine."
If you need to get new frequencies, you will also have to spend the time and expense to reprogram your radios and other equipment to the new frequencies.
"Sometimes that even entails changing other equipment at the site itself, because now you're introducing a different frequency into your combiner or multicoupler," explains APCO's Latif. "They may even have to change antenna spacing, depending on what the frequencies are and how much separation there is from one frequency to another. It will definitely affect the design and coverage of the system."
The bottom line is that every law enforcement agency needs to take frequency licensing seriously. Maintain your current licenses. If you still need to switch to narrowband, work toward a solution now so you won't run out of time. If you're unwilling to do so, it won't go well for your agency.
"The people at the FCC, they're not the big bad wolf," says Spectrum's John Black. "They really do try to work with you. But you've got to work with them, too. And if you choose to be belligerent, well they can be pretty tough, too."
