Federal Communications Commission
Washington, D.C. 20554
February 12, 2015
DA 15-201
FCC 14-172
Small Entity Compliance Guide
Proposed Amendments to the Service Rules Governing Public Safety 
Narrowband Operations in the 769-775/799-805 MHz Bands
PS Docket No. 13-87, PS Docket No. 06-229, WT Docket No. 96-86, RM-11433, and 
RM-11577
This Guide is prepared in accordance with the requirements of 
Section 212 of the Small Business Regulatory Enforcement 
Fairness Act of 1996.  It is intended to help small entities—small 
businesses, small organizations (non-profits), and small 
governmental jurisdictions—to comply with the new rule/s 
adopted in the above-referenced FCC rulemaking docket/s.  This 
Guide is not intended to replace the rule/s and, therefore, final 
authority rests solely with the rule/s.  Although we have attempted 
to cover all parts of the rule/s that might be especially important to 
small entities, the coverage may not be exhaustive.  As a result, in 
any civil or administrative action against a small entity for a 
violation of a rule or rules, the content of the Small Entity 
Compliance Guide may be considered only as evidence of the 
reasonableness or appropriateness of proposed fines, penalties or 
damages.  This Guide may not apply in a particular situation 
based upon the circumstances, and the FCC retains the discretion 
to adopt approaches on a case-by-case basis that may differ from 
this Guide, where appropriate.  Any decisions regarding a 
particular small entity will be based on the statute and regulations.  
Interested parties are free to file comments regarding this Guide 
and the appropriateness of its application to a particular situation; 
the FCC will consider whether the recommendations or 
interpretations in the Guide are appropriate in that situation. The 
FCC may decide to revise this Guide without public notice to 
reflect changes in the FCC’s approach to implementing a rule, or 
to clarify or update the text of the Guide.  Direct your comments 
and recommendations, or calls for further assistance, to the FCC’s 
Consumer Center:
1-888-CALL-FCC  (1-888-225-5322)
 TTY: 1-888-TELL-FCC  (1-888-835-5322)
Fax: 202-418-0232
Background.
On October 24, 2014, the Federal Communications Commission (Commission) released a 
Report and Order in the foregoing dockets.  The Report and Order implements certain 
changes to the rules governing the 700 MHz public safety narrowband spectrum (769-
775/799-805 MHz). The Report and Order eliminates the requirement for narrowbanding 
of the spectrum by December 2016, which will enable licensees to extend the life of 
existing systems and will provide public safety with greater flexibility in determining the 
optimal future use of the band.  In addition, the Report and Order revises and updates the 
technical rules for the band to enhance interoperability and open up certain channels to 
new uses, and releases reserve spectrum to provide additional capacity, particularly for 
licensees relocating to the 700 MHz band from the T-Band.  These rule changes will 
enhance the ability of public safety licensees to use this spectrum to protect the safety of 
life and property. 
Compliance Requirements.
In formulating rule changes in the Report and Order, the Commission sought to
promote efficient use of the 700 MHz public safety narrowband spectrum while reducing 
economic burdens on Public Safety Radio Licensees.  Absent these rule changes, Public 
Safety Radio Licensees would be subject to unnecessary economic burdens and 
restrictions.  The Report and Order adopts a rule that will entail reporting, recordkeeping, 
and/or third-party consultation (e.g., modifying requirements for certain equipment 
certification applications; requiring regional planning committee concurrence to license 
the reallocated reserve channels; requiring state concurrence to license the air-ground 
channels). The rule changes become effective on January 2, 2015, except for the 
foregoing new or modified information collection requirements in 47 C.F.R. §§ 
2.1033(c)(20), 90.531(b)(2) and 90.531(b)(7), that require approval by OMB, which will 
become effective after such approval, on the effective date specified in a future notice by 
the Commission.
Deadline for Narrowbanding Transition to 6.25 Kilohertz Technology
The Report and Order eliminates the December 31, 2016 deadline for 700 MHz 
public safety narrowband licensees to transition to 6.25 kHz bandwidth technology and 
the December 31, 2014 interim deadline for the cessation of marketing, manufacture, or 
import of 700 MHz narrowband equipment not capable of operating at 6.25 kilohertz 
efficiency.  Elimination of the 2016 deadline relieves public safety licensees of the 
economic burden associated with having to replace currently operating communications 
systems prior to the end of their life-cycle.  Elimination of the 2014 deadline allows for 
the development of industry standards for 6.25 kHz technology which will allow 
equipment manufacturers to develop equipment designed for interoperability among 
equipment of all manufacturers as opposed to equipment that can only communicate with 
a limited number of vendors’ equipment. 
Air-Ground Channels Replace Secondary Trunking Channels  
The Report and Order re-designates the secondary trunking channels for air-
ground communications to be used by low altitude aircraft and related ground based 
stations.  The Report and Order concludes there is a need to designate specific channels 
in the band for use by low-altitude aircraft and that secondary trunking channels are no 
longer used for their original purpose.  Thus, public safety licensees benefit from this rule 
change because channels in the band which previously remained fallow become available 
for the increasingly important function of allowing aircraft responding to emergencies to 
interoperate with public safety officials on the ground.
The Report and Order re-designates the Secondary Trunking Channels to support 
Air-Ground communications subject to State administration.  The Report and Order
assigns responsibility for coordinating these channels to the states.  As a result, each 
applicant for Air-Ground spectrum will need to coordinate its application with the State.
Voice Communications on Data Interoperability Channels
The Report and Order permits voice communications on a secondary basis on the 
upper two of the four 6.25 kilohertz channel pairs previously reserved for data-only 
interoperability.  This rule change benefits public safety licensees by providing them the 
flexibility to use additional channels for voice interoperability in jurisdictions that only 
have limited if any demand for data interoperability.
Reserve Channels
The Report and Order designates all twenty-four 12.5 kilohertz bandwidth 
Reserve Channel pairs for General Use subject to Regional Planning Committee regional 
plans.  The Reserve Channels had been held in reserve to address public safety’s 
developing needs.  To further Congress’ goal to facilitate relocation of public safety 
incumbents in the 470-512 MHz band, the Report and Order provides priority access to 
all twenty-four 12.5 kilohertz channel pairs for T-Band relocation in the urban areas 
specified in Section 90.303 of the Commission’s rules.  Outside the urban areas specified 
in Section 90.303, the Report and Order permits dedication of up to eight 12.5 kilohertz 
channel pairs for temporary deployable trunked use and the rest for General Use, 
including low power vehicular repeater operation.  This approach affords public safety 
agencies with flexibility in operation on the former Reserve Channels while also avoiding 
undue economic burdens.   
To date, only 47 out of 55 regions have obtained approval for their 700 MHz 
plans.  As a result, the Report and Order directs these 47 700 MHz Regional Planning 
Committees that have obtained approval for their regional plans to modify their plans to 
reflect the new 700 MHz narrowband General Use (formerly Reserve) spectrum 
allocation adopted in this Report and Order.  Each applicant for General Use (formerly 
Reserve) Spectrum will need to coordinate its application with the relevant Regional 
Planning Committee(s).  T-Band incumbents filing applications for the former Reserve 
channels must also demonstrate a commitment to return an equal amount of T-Band 
spectrum.
Compliance with Interoperability Technical Standards
Section 90.548 of the Commission’s rules requires any radio designed to operate 
on the 700 MHz narrowband interoperability channels to conform to the ANSI 102 
Project 25 technical standards.  The Report and Order reduces the burden on equipment 
manufacturers by according them a presumption of conformity with these standards if 
they submit equipment for certification under the Project 25 Compliance Assessment 
Program (CAP).  
CAP is a program that establishes an independent compliance assessment process 
to ensure that communications equipment conforms to Project 25 standards and is 
interoperable across vendors.  The purpose of this rule is to enhance interoperability and 
provide assurance to licensees that their equipment is interoperable across vendors 
regardless of which vendor they choose.  Thus, the Report and Order establishes the 
presumption that CAP conformity is sufficient to show compliance with Section 90.548.  
Alternatively, a manufacturer may submit a document describing how it determined 
compliance with Section 90.548 and that its equipment is interoperable across vendors.  
ACP Requirements for Class B Signal Boosters
The Report and Order exempts Class A and Class B signal boosters from the 
Adjacent Channel Power (ACP) limits of Section 90.543(a) when such units are 
simultaneously retransmitting multiple signals.  In lieu of the ACP limits, the Report and 
Order applies the emission limit listed in Section 90.543(c) to such signal boosters 
operating in this manner.  Wireless communications equipment manufacturers that 
produce suchsignal boosters benefit from this exemption because they will be able to 
continue manufacturing and marketing signal boosters capable of operating on 700 MHz 
public safety narrowband spectrum.  Public safety licensees benefit from this exemption 
because they will continue to have access to signal boosters capable of providing in-
building RF coverage in this band.  Absent this exemption, public safety licensees may 
have been unable to find solutions for deficiencies in in-building RF coverage.  
Narrowband Power Limits
The Report and Order converts all power limits from transmitter output power
(TPO) to effective radiated power (ERP) and consolidates all power limits into a more 
comprehensive Section 90.541, deleting Section 90.545.  Public safety licensees benefit 
from this change in power characterization because all power limits will now be in terms 
of ERP which more accurately defines the actual operating power of the radio.     
User Access to Interoperability Channels
The Report and Order clarifies that Commission rules require only that radios be 
capable of being programmed to operate on all of the interoperability channels, but do not 
require that every radio have every interoperability channel programmed into it and 
available to the user.  This approach affords public safety flexibility in programming 
radios while avoiding undue economic burdens.  This rule change eliminates an 
ambiguity in the rules and reduces the compliance requirements on public safety 
licensees.
Analog Operation on the Interoperability Channels
The Report and Order revises Section 90.535 to make clear that  users may not 
operate their mobile and portable equipment in analog mode on the interoperability 
channels, even as a secondary mode.  In reaching this decision, the Report and Order
concludes that allowing two modulation modes on a channel reserved for interoperable 
voice communications would seriously impair interoperability.
Internet Link.
A copy of the Report and Order is available at 
http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db1024/FCC-14-
172A1.pdf