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PSHSB Seeks Comment On Louisiana 700 MHz Narrowband Waiver Request

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Released: July 20, 2012


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 12-1170

Released: July 20, 2012




PS DOCKET 06-229

COMMENTS DUE: August 3, 2012

By this Public Notice, the Public Safety and Homeland Security Bureau (PSHSB) seeks comment
on a petition for waiver1 filed by the State of Louisiana (Louisiana) to operate the Louisiana Wireless
Information Network (LWIN) in the 700 MHz narrowband spectrum utilizing the current 12.5 kHz
channel efficiency through December 31, 2024. 2
Louisiana has developed LWIN to provide an interoperable public safety network in the state.
LWIN utilizes 700 MHz spectrum designated for narrowband use by public safety.3 Louisiana states that
LWIN “consists of 67,162 users making it the largest statewide radio system in the country.”4 The State
covers all of the costs associated with LWIN administration, maintenance and operation.5
In support of its Petition for Waiver, Louisiana argues that, “the purpose of the 6.25 kHz channel
mandate is to allow for a more efficient use of the 700 MHz spectrum dedicated to public safety.”6
Louisiana argues that, “LWIN is fully built and operational across the State of Louisiana and is already
using available spectrum to provide mission critical voice communications to its first responder
community.”7 Additionally, “the cost to build new radio systems for the reconfigured 700 MHz spectrum
is cost prohibitive and any new system in Louisiana within the last six years has been built to operate in
the VHF and UHF spectrum.”8 Louisiana further argues that, “while the 6.25 kHz channel efficiency

1 Petition for Waiver of Rules, State of Louisiana, PS Docket 06-229 (filed Jul. 3, 2012) (Louisiana Petition).
2 Previously, the State sought broader consideration of a change in the narrowbanding through a Petition for
Rulemaking. See Petition for Rulemaking of the State of Louisiana, RM-11577 (filed Oct. 5, 2009).
3 Louisiana Petition at 2.
4 Id.
5 Id.
6 Id. at 5.
7 Id.
8 Id.

mandate was intended to provide greater efficiency and access to spectrum, both aims have already been
achieved in Louisiana.”9
Louisiana states that, “with the 6.25 kHz channel efficiency mandate quickly approaching, local
municipalities are considering alternatives to providing mission critical voice communications to first
responders because the cost to replace their entire inventory of subscriber units in order to achieve
compliance with the Commission’s narrowbanding mandate is cost prohibitive.”10 Thus, “the practical
effect of the narrowbanding mandate is that the State’s largest homeland security region, Greater New
Orleans, may leave LWIN and build a separate, incompatible 800 MHz radio system.”11 Therefore, “the
public’s best interest would not be served as the ability of first responders from cross jurisdictional
boundaries to communicate during times of emergencies would be severely diminished.”12 Finally,
Louisiana asserts that “the cost of meeting the Commission’s mandate would exceed the total amount the
State spent to build LWIN and equip the first responder community with more than 67,000 subscriber
units,” and that the “State could not muster the funding necessary to implement the upgrades,” making
application of this rule unduly burdensome.13
By this Public Notice, we seek comment on Louisiana’s petition and announce the pleading cycle
during which comments and replies may be filed.
This proceeding will be treated as “permit but disclose” for purposes of the Commission’s ex
parte rules. See generally 47 C.F.R. §§ 1.1200-1.1216. As a result of the permit-but-disclose status of
this proceeding, ex parte presentations will be governed by the procedures set forth in Section 1.1206 of
the Commission’s rules applicable to non-restricted proceedings.14 Persons making ex parte presentations
must file a copy of any written presentation or a memorandum summarizing any oral presentation within
two business days after the presentation (unless a different deadline applicable to the Sunshine period
applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). Written ex parte presentations and memoranda summarizing oral ex parte
presentations, and all attachments thereto, must be filed through the electronic comment filing system
available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable
.pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules.
Parties may file comments on the Petition on or before

August 3, 2012

. Please place the docket

PS Docket 06-229

, on all filings. Comments may be filed using the Commission’s Electronic

9 Id. at 5-6.
10 Id. at 6.
11 Id.
12 Id.
13 See Louisiana Petition at 6; Louisiana Petition at 7.
14 47 C.F.R. § 1.1206.

Comment Filing System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR
24121 (1998).
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
Copies of the Petition and any subsequently filed documents in this matter are also available for
inspection in the Commission’s Reference Information Center:
445 12th Street, S.W., CY-Level
Washington, D.C. 20554
(202) 418-0270
For further information, contact: Aaron Garza, Policy and Licensing Division, Public Safety and
Homeland Security Bureau, at (202) 418-1175 or
Action by the Chief, Public Safety and Homeland Security Bureau.
– FCC –

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