December 2009 Inbox
Tuesday, January 12, 2010 | Comments
Following are comments we’ve received from readers about recent online news and articles. If you’d like to comment on an article, e-mail
It ain’t gonna happen. Two of the petitions (North Dakota and New York) are from Canadian border states. When the FCC reconfigured the 700 MHz band for the previous auction, they threw away the existing agreement with Canada on what is now the U.S. public-safety broadband spectrum. Just look at the international agreement that is still on the books. The Canadians still consider part of the public-safety broadband allocation to be TV channels, and they haven’t decided what to do with another big chunk of it. Yes, there is an agreement on the 700 MHz narrowband allocation, but the broadband allocation … sorry, no.
And it’s not going to be easy to get an agreement. All the talk is how the public-safety system will be a Long Term Evolution (LTE) system using up the full 5 megahertz of public-safety broadband spectrum. So how do you share spectrum when you use it all? It’s going to be interesting resolving that little issue. The Canadians aren’t real anxious to reconfigure their band plan; at least they don’t seem to be. So until the State Department can sit down and work out an arrangement on spectrum use in the border areas — and there are a lot of states that are partially in the border area — forget about any waivers for border states. And do you think the State Department will even think about sitting down with the Canadians until the D block situation is resolved?
Maybe New York can convince the FCC that its waiver request is only for the populous downstate areas of New York, but I doubt it. North Dakota — as long as it wants to use the narrowband allocation for its broadband system, you can consider its petition on permanent hold.
And if you think the Canadian border situation is difficult, the Mexican border situation will be much worse. It’s going to take years; just look at where 800 MHz rebanding is in the border states.
While I’m on a rant, let me talk about the Public Safety Spectrum Trust (PSST). The PSST doesn’t have any money. To get money, they want to lease spectrum to those agencies wanting to build broadband systems. They also want those agencies to pay for rebanding any 700 MHz narrowband systems in their operational area before they can build a broadband system. And the whole point of the first D block auction was to take the financial load off the public-safety agencies. Is this madness or what? The FCC needs to rethink the whole PSST.
The public-safety broadband issue will still be being argued long into the future. In the meantime, CTIA will keep telling the FCC that carriers need more spectrum, any spectrum, and there’s all that public-safety spectrum that could be freed if the FCC would only make public-safety use commercial systems.
Al Nowakowski
Communications Engineer
State of Michigan

In response to “One Last Night On Call: A Christmas Story” from Dec. 22
Leonard Koehnen has written another great story! This one is truly a tribute to our emergency-services workers, the police, fire, EMS and support folks — especially the radio service technicians and facilities management folks who keep our radios working.
Thank you again for another great Christmas story!
Larry Louree
Apopka, Fla.

In response to “Proposed Legislation to Fund Engineers at FCC” from Dec. 16
The pointy haired manager in Dilbert just became a FCC commissioner.
Donald M. Balsamo
Lead Comm Tech Support
Riverside County Information Technology (RCIT)
County of Riverside, Calif.

I have no difficulty understanding why Motorola would want an accredited standards body to oversee TETRA deployment in North America given its dominance over the Project 25 (P25) standards body, literally handing them dominance in the P25 market.
Bob’s Mobile Radio
It’s about time! It would appear that the radio bully of North America is about to be defeated. The cost of public-safety radio communications has just been given the green light to drop to half price, and now my tax dollars will finally get the value they always should have. When Motorola’s problems on the consumer side are considered with this recent chain of events, I’m guessing this wouldn’t be the time to buy Motorola stock.
Radio freedom at last!
Scott Adams
Adams Electronics
Wixom, Mich.

Obviously, the BVS device depends on contraband cell phones being turned on and in use to detect them. I really don’t think that’s the normal state of those devices. More than likely, the phones are taken out of hiding and used at opportune times when guards aren’t likely to be nearby or monitoring for cell-phone activity. Then there is the issue of training guards to use a directional antenna to find the phone; and I suspect that by the time the guard gets close to a contraband phone, his presence is known and the phone is switched off and hidden.
So while the BVS device may be marginally useful, it’s obviously not a complete answer to the contraband cell phones in jails issue.
Al Nowakowski
Communications Engineer
State of Michigan

It is a long overdue need for the United States. Finally, a standard that actually is a standard, giving multiple vendors the chance to bid on projects. Not the case with Project 25 (P25).
Rick Nielson
Bay Electronics

With regard to the EWA recommendation for case-by-case waivers for narrowbanding deadlines, I agree not only with the extensions for the Jan. 1, 2011 deadline, but also for the Jan. 1, 2013 deadline. Although I feel the vast majority of the municipalities are making an effort to meet the deadlines, there are real funding issues to be dealt with… particularly with smaller municipalities, which have older, non-narrowband capable LMR equipment.
Funding help is out there in the form of various grants to help with the public-safety side of the house; however, for the most part, these grants bypass the various utilities, such as water, sewer and streets. In the majority of these cases, the cost of replacing utilities’ LMR equipment must fall onto the various departments. Because of the tight funding in all areas, the option of a mass LMR replacement is out of the question, as is going without communications. An extension would allow these utilities to upgrade their LMR equipment through normal attrition and spread the cost out over five to seven years depending on the equipment.
Due diligence must be conducted on these “case-by-case” waivers to verify that everyone applying for a waiver has a plan for implementation in place at the very least. They shouldn’t be handed out just because someone filled out the paperwork. I don’t feel this will solve or eliminate all the problems associated with the migration to narrowband; however, it should reduce them. As with the conversion of TV from analog to digital, there will still be some out there who bury their heads in the sand until it’s too late.
John Larribeau
Communications Systems Technician
Spokane (Wash.) City Radio Shop

The FCC is seeking comment on a petition for rulemaking filed by the state of Louisiana asking that the 6.25-kilohertz efficiency deadlines in the 700 MHz band be deferred until Dec. 31, 2024, from Dec. 31, 2016.
Louisiana has three points in its argument:
• No equipment employing 6.25-kilohertz efficiencies is available in the 700 MHz band;
• Equipment purchased now will be obsolete at the end of 2016, severely reducing its normal lifespan; and
• Purchasing radios with a regulatory limited lifespan is fiscally imprudent.
This is a great example of how disconnected the FCC remains from public safety. Louisiana’s three points have merit throughout the entire United States. Further, there has been no reality-based testing of 6.25-kilohertz in how it will affect public safety and their ability to communicate.
Paul Roberts
Boise Fire Department

In response to “State of the Industry” from September
I just picked up my September issue of MissionCritical Communications and found an interesting comment in the State of the Industry interview regarding narrowbanding. The comments by Fredrick Smith (coincidentally the last lines of the article) were: Why can’t we simply turn down our deviation? Why do we need to re-coordinate? I am paraphrasing his actual response but that is the essence of his statement, and it is actually a large understatement.
I am a land mobile dealer and represent the Vermont State Firefighters’ Association with respect to communications issues. In 2007, I raised the same questions and with help from Dana Shaffer I filed an application, which requested a waiver of the coordination requirement. After two years of wrangling and pressure from our congressional delegation, the waiver was granted in March 2009. The commission’s comments regarding the waiver were that it found no reason to believe that such a change posed a threat of interference. In a somewhat bizarre move the FCC also chose to grant the waiver and require other licensees to request an individual waiver to achieve the same end rather than issue a blanket waiver or change the rule to remove the coordination requirement. Government at its best.
It’s significant to note that the comments filed by the Association of Public-Safety Communications Officials (APCO) International regarding the waiver ignored the limited scope of our requested change — moving from a 25-kilohertz emission designator to a 12.5-kilohertz one — and danced around the issues of applicants making other changes and keeping the database up to date. If the Universal Licensing System (ULS) was modified to allow a licensee to file a simple narrower emission designator change form with specific and restricted options that wouldn’t be an issue, and the database would be updated instantly.
The commission is clearly dragging its feet on this issue. When I first contacted them years ago they put up all sorts of speed bumps including that our treaty with Canada would preclude waiving coordination. They were unhappy when I asked them to whom I should forward my communications with the State Department regarding that treaty. When the request for public comment was posted, I received a number of e-mails and faxes from industry organizations and telecom law firms supporting our initiative.
I firmly believe that APCO and a small number of other organizations, which have a significant fiduciary interest in leaving the coordination requirement intact, are lobbying hard against our common sense efforts. How that position benefits the interests of public-safety agencies, which they claim to represent, is questionable at best.
The requirement to re-coordinate a license to comply with the narrowbanding order is clearly an unfunded mandate, which is costing the licensees and the taxpayer millions of dollars unnecessarily. Even with APCO’s new discount prices for such a change, it is still a travesty. Simple math tells us that with the FCC’s estimate of 1.1 million licenses affected by the narrowbanding order, $100 million will be wasted. This assumes that every licensee gets the $100 per call sign deal and each licensee has only one call sign.
I am somewhat disappointed that the trade press has not pursued this issue. The commission is requiring action with a looming deadline but they have managed to avoid taking responsibility for reducing the cost of this migration by eliminating an unnecessary expenditure.
Your editorial in that issue starts out “The FCC wants your help.” The question for the commission is: Why are we paying coordination fees that you have acknowledged to be unnecessary? Perhaps if the FCC would like our help they should consider reciprocating. One hand washes the other.
Ron Kumetz
Falcon Communications 

Click here for the November 2009 Inbox.
Click here for the October 2009 Inbox.
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