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Your “tour guide” Bob Speidel, Esq. ( I do not provide Legal Representation to TE )

“Narrowbanding(?),” {this term is a total misnomer} Reconfiguration {that’s the official FCC term} & Broadband {and a bunch of 700 MHz stuff}. The Truth, The Whole Truth, Nothing but the Truth. Your “tour guide” Bob Speidel, Esq. ( I do not provide Legal Representation to TE )

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Your “tour guide” Bob Speidel, Esq. ( I do not provide Legal Representation to TE )

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  1. “Narrowbanding(?),” {this term is a total misnomer}Reconfiguration{that’s the official FCC term}& Broadband {and a bunch of 700 MHz stuff} The Truth, The Whole Truth, Nothing but the Truth Your “tour guide” Bob Speidel, Esq. ( I do not provide Legal Representation to TE ) Mgr, Government Affairs - Regulatory Policy (434) 455-9465 (434) 455-6712 (fax) speidelbo@tycoelectronics.com

  2. Topics • 800 MHz Reconfiguration (a/k/a Rebanding) • Broadband – 700 MHz/D-Block/PSST • “Narrowbanding” below 512 MHz Remember “Narrowbanding” is a misleading term • Changes at the FCC Questions are welcome at anytime throughout - Caveat Emptor - If I don’t know the answer, I will get you one or I will make one up that sure sounds good.

  3. 800 MHzNPSPAC structure (after Reconfiguration) You may be asking yourself – Why waste time talking about 800 MHz Reconfiguration – Didn’t the FCC require “Reconfiguration” to be completed NLT June 26, 2008? 806 MHz to 809 MHz (mobile to base) paired with 851 MHz to 854 MHz (base to mobile) The post-Reconfiguration NPSPAC structure and rules are essentially the same as the pre-Reconfiguration NPSPAC structure and rules. The only thing that changes, for all intents and purposes, is the specific frequency assigned to a specific channel number. YES! But like many other things coming from Washington deadlines are not always met! In fact, a revised agreement with Mexico probably won’t appear until mid-2009 at the earliest. 25.0 kHz 25.0 kHz 25.0 kHz 25.0 kHz 25.0 kHz 12.5 kHz 12.5 kHz Assuming an agreement with Mexico is in place by Mid 2009, my guess is that Reconfiguration in the US/Mexico region will not be complete much before 2013. Multiple emissions in a single channel (a/k/a ch. splitting) allowed. 47 CFR §90.645(f)

  4. 800 MHzNon-NPSPAC structure (after Rebanding) The post-Reconfiguration non-NPSPAC structure and rules are essentially the same as the pre-Reconfiguration non-NPSPAC structure and rules. The only thing that changes, for all intents and purposes, is the specific frequency assigned to a specific channel number. 809 MHz to 817 MHz (mobile to base) paired with 854 MHz to 862 MHz (base to mobile) 25.0 kHz 25.0 kHz 25 kHz Multiple emissions in a single channel (a/k/a ch. splitting) allowed.47 CFR §90.645(f) & Combining up to 5 channels allowed. (i.e. 125 kHz max) 47 CFR §90.645(g)

  5. 800 MHzWhat are the 800 MHz Efficiency Mandates? Nor has there been any “Refarming” of 800 MHz! There are NO NPSPAC or non-NPSPAC efficiency mandates on users either before or after “Rebanding!!” • Surely there are NPSPAC & non-NPSPAC efficiency mandates that either existed before “Rebanding” or that are imposed as a result of “Rebanding?” What are those mandates?

  6. 800 MHzWhat is this 800 MHz “Rebanding” Two-Step? Show me the 10,000 foot “bird’s eye” view of “Reconfiguration” in a Region? How does a Region “reconfigure” to get from here 806 809.75 816 821 824 825 TV Broadcast Ch. 60-69 General Category INCL. NEXTEL B/ILT & PS B/ILT & PS & ESMR Upper 200 SMR (NEXTEL) NPSPAC CELLULAR PublicSafety 793-805 [7.5 MHz] [12.5 MHz] [10 MHz] [6 MHz] 851 854.75 861 866 869 870 To Here 806 809 815 816 817 824 825 TV Broadcast Ch. 60-69 Exp. Band B/ILT & PS NPSPAC Guard Band Low-Site Cellular/ ESMR CELLULAR PublicSafety 793-805 Non-CII B/ILT (From 809.75-815) [6.0 MHz] [12.0 MHz] [2 M] [2 M] [14 MHz] 851 854 859 861 862 869 870

  7. 800 MHz - “Rebanding” - The Simplistic View RECONFIGURATION – Step 1 “Hey! Get Outta here!” Part A – Mandatory Component(s) Part B – Optional Component Step 1 - complete 809 809.75 815 816 817 821 824 825 806 GENERAL CATEGORY B/ILT & PS Upper 200 SMR TV Broadcast Ch. 60-69 PS(815-816) B/ILT & PS B/ILT & PS ESMR ( future ) Exp. Band NEXTEL/ESMR CELL-LIKE Guard Band NPSPAC CELLULAR NEXTEL/ESMR CELL-LIKE, (from 816-817) Guard Band {2 MHz} NEXTEL/ESMR CELL-LIKE B/ILT & PS(806-809) PublicSafety 793-805 [2 M] [6.0 MHz] [7.5 MHz] [12.0 MHz] [12.5 MHz] [2 M] [8 MHz] [10 MHz] [6 MHz] 851 854 854.75 859 861 862 866 869 870

  8. 800 MHz - “Rebanding” - The Simplistic View(continued) RECONFIGURATION – Step 2 NEXTEL/ESMR/CELL-LIKE NEXTEL/ESMR/CELL-LIKE (816-817) “Go West, young man!” Step 2 - complete 821 824 825 817 806 809 815 816 TV Broadcast Ch. 60-69 ESMR ( future) B/ILT & PS Exp. Band Guard Band NPSPAC CELLULAR ESMR PublicSafety 793-805 [2 M] [2 M] [14.0 MHz] [6.0 MHz] [12.0 MHz] [8 MHz] [6 MHz] 851 861 862 866 869 870 854 859

  9. 800 MHz - “Rebanding” - The Simplistic View(continued) RECONFIGURATION – Step 3 NEXTEL/ESMR/CELL-LIKE NEXTEL/ESMR/CELL-LIKE (816-817) finish “Movin’ on Up!” Step 3 - complete What did you get? 821 824 825 809 817 806 815 816 Low-Site Cellular/ ESMR TV Broadcast Ch. 60-69 Exp. Band B/ILT & PS NPSPAC Guard Band CELLULAR PublicSafety 793-805 [2 M] [6.0 MHz] [12.0 MHz] [2 M] [14 MHz] 851 861 862 866 869 870 854 859

  10. 800 MHz - “Rebanding”The “Hoped for” Outcome – Nirvana. - SMR - Business/SMR - Public Safety - Industrial/SMR 806 824 825 809 815 816 817 NPSPAC B/ILT & PS LOW-SITE CELLULAR/ESMR TV Broadcast Ch. 60-69 Public Safety 793-805 CELLULAR [2.0 MHz] [2.0 MHz] [12.0 MHz] [14 MHz] [6.0 MHz] 861 862 851 854 860 869 870 816-817/861-862 Guard Band – open for new PS or IB/SMRs vacating channels for PS NEW PUBLIC SAFETY/BI ON SPECTRUM VACATED BY NEXTEL 815-816/860-861 Expansion Band No PS required to remain or move to

  11. “Some” Reconfiguration Details Comparable Facilities • Same level of service as incumbent’s existing facilities • Minimal disruption to operations • Equivalent channel capacity • Equivalent signaling capacity, baud rate and access time • Equivalent geographic coverage • Equivalent operating costs • If reconfiguration entails a significant disruption of service during relocation process, Nextel will fund the installation of a redundant system

  12. Mexican Border IssueThe Gory Details - Revisited Requires Modification of International Agreement • Border Plan is in limbo • FCC’s reconfiguration plan not moving forward • Personnel changes necessitate education of Mexican & American staff • FCC extends Mexican Border negotiation period to ??? • During extended negotiation period, licensees not required to engage in planning or negotiations • Completion - Your guess is as good as mine

  13. Mexican Border IssueThe Future(?) Mexican Border will likely follow lead of Canadian Border • Stage 1 – Lower band channels vacated • Stage 2 – Public Safety moves to new channel assignments • When agreement reached between U.S. and Mexico • FCC sets date for submission of Req for Planning Funding (RFPF) • Planning Funding Agreement (PFA) to be negotiated within 30 days of submission of RFPF • Planning to be completed within 90 – 110 days

  14. Mexican Border IssueFinal? Mexican Border following lead of Canadian Border • Upon completion of planning and submission of cost estimate • Parties have 30 days to negotiate Freq Relocation Agreement (FRA) • Failing negotiation of FRA , parties are referred to mediation • Failing mediation, disputes are referred to FCC Bottom Line The entire reconfiguration process will “hopefully” be completed within 30 months from some point of time in mid 2009.

  15. Broadband-700 MHz 1st - What about 700 MHz NB? NB Channels 961 to 1920 NB Channels 1 to 960 Okay! Enough about “Reconfiguration.” BUT Before we leave Reconfiguration are there any questions or comments?

  16. What about 700 MHz? NB structural details 960 – 6.25 kHz channel pairs 25.0 kHz 25.0 kHz 12.5 kHz 12.5 kHz 12.5 kHz 12.5 kHz 6.25 6.25 6.25 6.25 6.25 6.25 6.25 6.25 Ch. 81 Ch. 82 Ch. 83 Ch. 84 Ch. 85 Ch. 86 Ch. 87 Ch. 88… For 12.5 kHz Channel – The channel number of the lowest 6.25 kHz channel in the combination must be an odd numbered channel. For 25.0 kHz Channel – The channel number of the lowest 6.25 kHz channel in the combination must satisfy the equation 4n+1, where n is any integer from 0 to 239. NB: Ch. Alignment - Different than “Refarmed” UHF

  17. What about 700 MHz? More details • Digital Modulation Only(except for designated lo-power channels) • Interoperability Mandates only applicable to subscriber equipment • P25 Phase 1 CAI CONVENTIONAL & IMBE vocoder for operation on designated interoperability channels • Compliance with Regional Plan only required for General Use channels. • Efficiency mandates are applicable. • Applicable only in the General Use and Statewide Set-aside spectrum. For all intents and purposes there is no such thing as WB (wideband) 700 MHz public safety spectrum any longer 700 WB was swept out the door when the band was restructured in 2007 into narrowband (NB) and Broadband segments!

  18. What about 700 MHz? Efficiency Mandates Application, on or after 1/1/2015 for new NB licenses or mods with expanded contours must employ 6.25 kHz technologies. All statewide or general use NB ops must be 6.25 kHz efficiency, or better, as of 1/1/2017

  19. 700 MHz Efficiency Mandates (graphically) USER 6.25 kHz Efficiency Reqmt’s MANUFACTURER 6.25 kHz Efficiency Reqmt’s

  20. 700 MHz Broadband Paired with the commercial D-Block winner or winners(?) ?

  21. 700 MHz Broadband • The Public Safety Spectrum Trust (PSST) is the Public Safety Broadband licensee (PSBL) • The idea was to do a public-private shared network between the D-Block winner and the PSBL, but the D-Block auction (Spring of 2008) was a bust. IMHO– The issue was the “business case” • The former FCC Chair was pushing to revise the D-Block rules, but may not have wanted to give up on the shared network idea. • As a result the D-Block and the PS community are wallowing in Limbo for all intents and purposes • Outlook for resolution – Hazy at Best • New FCC Interim & Permanent administrations • Secretary Napolitano’s “Interoperability” comments

  22. 700 MHzDTV transition • IMHO - The new Administration/Congress “wimped out.” • Approximately 2/3’s (probably more) of the primary TV stations in the Channel 60 through 69 spectrum did NOT transition on 2/17/2009 • In areas where it mattered almost none of the primary TV stations completed the transition on 2/19/2009 • The new transition date is June 12, 2009 A show of hands please. How many of you believe the June 12th date is actually set in stone?

  23. 700 MHzDTV transition – LoPower TV • Lo Power TV stations are secondary to PS operations in the Channel 60-69 spectrum • All PS needs to do is give the LoPower stations notice of intent to begin operations • The Lo Power station then has to do what is necessary to avoid interference to PS operations. NPSTC has published a brochure containing information about LPTV and PS operations in the 700 MHz band, including a template letter PS can use to communicate with the LPTV stations. The brochure is available at this link http://www.npstc.org/documents/20080213-Maximizing%20Availability%20of%20the%20700%20MHz%20Band.pdf • Lo Power stations are more of a “political” issue Talk to the Lo Power stations sooner rather than later – a year ahead might be good Be fair but firm – “Don’t cave-in to Political Pressures!”

  24. “Narrowbanding” below 512 MHzFCC VHF – LoBand (30 – 50 MHz) Okay! What more can we say about Broadband, etc. ? BUT Again before we leave 700 MHz are there any questions, comments, suggestions? Again 25 kHz 25 kHz 25 kHz 25 kHz 20 kHz No “Refarming” No efficiency mandates

  25. “Narrowbanding” below 512 MHzFCC VHF – HiBand (150-174 MHz) 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 25 kHz 15kHz Before Refarming Before Refarming Refarming Added 12.5 kHz 12.5 kHz 12.5 kHz 12.5 kHz 7.5 kHz Pre-Refarming Ch. center Pre-Refarming Ch. center Pre-Refarming Ch. center Pre-Refarming Ch. center Pre-Refarming Ch. center +/- 7.5 kHz +/- 7.5 kHz +/- 7.5 kHz +/- 7.5 kHz Shared Spectrum Don’t forget the Centrally Trunked rules! See 47 C.F.R. 90.187(b) NB: “Refarming” did not add channels such that spacing between channel centers would be less than 7.5 kHz in HiBand VHF – AND – Refarming did not adopt 6.25 kHz maximum operating bandwidths for any channel in the “Refarmed” HiBand VHF spectrum Ch Combining/Splitting - ? Refarming Mandated EQUIPMENT Efficiency Requirements USER Efficiency Requirements came later

  26. “Narrowbanding” below 512 MHzFCC UHF – (450-470 MHz & T-Band) 25 kHz 25 kHz 25.0 kHz 25.0 kHz Before Refarming NOTE – Ch. Alignment Refarming Added 12.5 kHz 12.5 kHz 12.5 kHz 12.5 kHz 6.25 6.25 6.25 6.25 6.25 6.25 6.25 kHz Pre-Refarming Ch. center Pre-Refarming Ch. center +/- 12.5 kHz +/- 12.5 kHz +/- 12.5 kHz + 6.25 kHz + 6.25 kHz + 6.25 kHz + 6.25 kHz + 6.25 kHz + 6.25 kHz Shared Spectrum(except T-BAND) Don’t forget the Centrally Trunked rules! See 47 C.F.R. 90.187(b) Ch Combining/Splitting - ? Refarming Mandated EQUIPMENT Efficiency Requirements USER Efficiency Requirements came later

  27. FCC UHF – (450-470 MHz)Channel Bandwidth Limitations 25 kHz maximum BW freq. ends in x.00000, x.02500, x.05000, etc. (freq. satisfies equation f = x.00000 + .025n)12.5 kHz maximum BW freq. ends in x.01250, x.03750, x.06250, etc. (freq. satisfies equation f = x.01250 + .025n)6.25 kHz maximum BW freq. ends in x.00625, x.01875, x.03125, etc. (freq. satisfies equation f = x.00625 + .01250n)

  28. FCC UHF – (T-Band)Channel Bandwidth Limitations 25 kHz maximum BWfreq. ends in x.012500, x.037500, x.062500, etc. (freq. satisfies equation f = x.012500 + .025000n) (where N = any integer between 0 and 119)12.5 kHz maximum BW freq. ends in x.025000, x.050000, x.075000, etc. (freq. satisfies equation f = x.025000 + .025000n) (where N = any integer between 0 and 118)6.25 kHz maximum BW freq. ends in x.006250, x.01875, x.03125, etc. (freq. satisfies equation f = x.006250 + .012500n) (where N = any integer between 0 and 239) Why are the bandwidth limitations by channel effectively shifted 12.5 kHz in T-Band as opposed to the 450-470 MHz band? Darn good question. If anyone knows the real answer please let me know. NB – Not all channels calculated are licensable – see §90.311

  29. T-BandWhat’s Special/Different? Centralized Trunking Authorized - if Loading Requirements are met (i.e exclusive channel use is allowed by rule)Channels paired with 3 MHz spread Available to LMR in select areas

  30. What areas?Part 90, SubPart L TV channel/ 14 15 16 17 18 19 20 frequency 470-476 476-482 482-488 488-494 494-500 500-506 506-512 Boston Boston Chicago Chicago Cleve Cleve Specific freqs available per TV channel for each geographic area listed in §90.311 DC/MD/VA DC/MD/VA DFW Detroit Detroit Houston LA LA LA** LA* * Public Safety pool eligible licensees only DA 08-2823 ** County of LA by waiver see DA 08-2823 Miami NYC/NJ NYC/NJ NYC/NJ* Phila Phila Pitt Pitt SFO SFO

  31. VHF/UHF (150 to 512 MHz) including T-BandEfficiency Mandates Application for new LMR licenses or mods with expanded contours between 150 & 512 MHz must employ 12.5 kHz technologies, as of 1/1/2011 All LMR voice operations between 150 & 512 MHz must be 12.5 kHz efficient (or better) as of 1/1/2013 6.25 kHz technologies mandate not YET imposed on USERS, but “allegedly” it will be imposed sometime in the future

  32. VHF/UHF (150 to 512 MHz) including T-BandEfficiency Mandates USER 12.5 kHz Efficiency Reqmt’s MANUFACTURER 12.5 kHz Efficiency Reqmt’s

  33. Meeting the UHF USER Efficiency MandatePractical Impacts of Alternatives? Slot 1 Slot 2 25.0 kHz 25.0 kHz NB: The considerations at VHF HiBand are very similar except you do not need to factor in any thought of having a maximum 6.25 kHz operating bandwidth on any channel. Alternative #1 Alternative #2 12.5 kHz 12.5 kHz 12.5 kHz 6.25 6.25 6.25 6.25 6.25 6.25 Reduce operating BW from 25 kHz to 12.5 kHz and get no benefit from the 12.5 kHz you relinquish, or Implement a true multiple access technology, e.g. 2 slot in 25 kHz or 4 slot in 25 kHz TDMA, and receive the benefit of additional talkpaths because you do NOT relinquish any BW, but at the same time you meet or exceed the existing mandate.

  34. VHF/UHF (including T-Band)What’s on the Horizon (post-completion DTV transition)? • Protection of DTV is the appropriate analysis – not protection of analog TV. • Possible expansion of the 80 km/50 sm rule from centerpoint – NPSTC Pet for Rulemaking filed Feb 2009 • Possibly new channels in existing T-Band geographic areas – similar to recent LA County waiver • Possibly new designated T- Band geographic areas Stay Tuned Keep your eyes and ears open

  35. Changes at the FCCWith apologies to the Eagles – “There’s a New Kid in Town” Looking into the “Crystal Ball” • New Chairman probably not in place until mid-2009 • Provides a ready-made “…didn’t happen on my watch…” excuse when people complain about losing QVC due to DTV transition. • Probably no substantive D-Block/PS Broadband decision for months • Impact of changes for Public Safety – Does PS move up or down the “pecking order” at the FCC? • My guess is little or no REAL change in the standing of the PS community, but • What was the REAL standing of the PS community under the “old” regime? • 1st & Foremost there is a big change in atmosphere at the FCC • Chairman Martin resigned late January • PS&HS Bureau Chief Poarch resigned late January • Cmmr Copps is now Interim Chairman Copps • Remarks to FCC Staff – January 26, 2009 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-288096A1.doc • Only 3 Commissioners at this time (Copps, Adelstein & McDowell) • Commissioner Taylor-Tate left in early January – end of term • David Furth named Acting Chief of PS&HS Bureau • A lawyer but a “good guy.” • Julius Genachowski nominated to be new FCC Chairman • Another lawyer ???? • Chief of Staff under Reed Hundt ???? • Law School buddy of the new President ???? Okay! Enough about “Narrowbanding.” (Remember – the term “narrowbanding” is a GROSS misnomer) BUT Before we leave “Narrowbanding” are there any questions or comments? When all is said and done I do expect the “new” FCC to be neither the Savior nor the Executioner of Public Safety Communications. I expect Public Safety Communications will receive the same treatment it has received during the last 8 – 16 years, namely a lot of “politically correct” hoohah, but substantively it will be the same old thing.

  36. ? Well, You’ve heard Enough from me. Before I close - Any further Questions or Comments? About anything we have discussed today Ba lon ey

  37. In case you want to hear more from me My Contact Info Bob Speidel, Esq. Again, Remember I do not provide Legal Representation to TE Mgr, Government Affairs - Regulatory Policy M/A-COM, Inc. (434) 455-9465 (434) 455-6712 (fax) speidelbo@tycoelectronics.com I have business cards with me so you don’t need to copy this down, just ask me for a card

  38. That’s all from me, Folks! Thank you for your patience and your attention! Let’s Eat!

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