August 2013 Inbox
Friday, August 16, 2013 | Comments

Following are comments we’ve received from readers about recent online and print news and articles. If you’d like to comment on an article, email


In response to “EWA, USMSS Say PMRS Shouldn’t Comply with CPNI Requirements” from Aug. 28


It needs to be noted that the Enterprise Wireless Alliance (EWA) request isn't necessary. As an operator of non-interconnected community shared repeaters, a couple of years ago it was suggested to us by another operator of similar systems, that we should file such a notification with the FCC, so we did. This occurred after operating those systems for more than 20 years and never having filed such a notification before.

However, when we filed, we apparently mistakenly left out an attachment that the FCC thought critical to the filing. This extra task the FCC thought I needed to provide caused me to re-read the rules, including the FCC's own Advisory DA-10-91. All of our repeaters are licensed as in the private LMR (PLMR) service and none have the "interconnected" box checked. Already quite fully stated in the “frequently asked questions" that followed the advisory, the FCC said that customer proprietary network information (CPNI) consideration is only for "telecommunications" carriers. We noted that we have nothing whatsoever to do with anything "tele.” Rather, we are a radio communications carrier.

The FCC gives examples such as local exchange carriers and commercial mobile radio service (CMRS) providers. We are not licensed that way. When we received the notice of apparent liability (NAL) like 500 or 600 others in February 2009, we answered within the 30-day window, noting the above observations and indicating that if the FCC let the NAL stand, we would demand a hearing in front of an administrative law judge.

We heard nothing back from the FCC. Then in July 2011, we received order DA 11-1142, that stated the FCC agreed with our arguments and that no forfeiture penalties should apply.

Keep in mind that anyone contacted by the FCC about anything has 30 days to reply, but it took 28 months for the FCC to reply to us. Clearly the FCC does not play by the same rules that we are forced to play by.

DA 11-1142 included a list of companies that were affected by this admission of mistake. There are 13 licensees on that list. It makes one wonder what happened to all those other 500 or so licensees. Did they pay up rather than fight the erroneous NAL? Did they go out of business because of the size of the NAL (ours was $4,000)?

Scott Adams
Adams Electronics
Wixom, Mich.



In response to “30-Month 800 MHz Rebanding on Mexican Border Begins Aug. 23” from Aug. 16


With the exception of Cameron County, most of the South Texas public-safety departments have asked for an extension to the Aug. 23 date.

Enrique Flores, P.E
CES Network Services



In response to “NICE Systems Secures Houston Ship Channel” from Aug. 20


In the late 1960s while working as a Motorola industrial sales representative I was asked by the Motorola government sales group to assist them and to design a system in response to safety concerns expressed by the U.S. Coast Guard for ship, tug and barge traffic in the Houston ship channel in all weather conditions. It seems that my old technology ideas, in the early development stage of the computer, have finally been applied using today’s technological advancements. I have long hoped to see this system at work to improve safety and now to also provide a response to the heightened probabilities of threats from a variety of extremist groups.

Ron Smith
Communications & Emergency Products
Stafford, Texas



In response to “California Reports Sharp Decline in Wireless 9-1-1 Call Accuracy” from Aug. 13


Maybe no one has noticed how the wireless carriers’ service voice quality has been over the last few years. Maybe you as a customer have never seen cellular service radio technicians at any of the cell sites, but I do take notice. I travel around the country and have to use a cell phone in my work daily. If the cellular service coverage is poor, my phone doesn’t work well, and I have a hard time trying to understand what the person on the other end of the call is saying.

We as wireless users are starting to get use to this type of poor service that has been provided by the carrier you use. Some carriers are better than others for the quality and coverage area that they provide.

But when you make a call to 9-1-1, you expect that it will go through. You expect that the 9-1-1 call center can pinpoint your location through the technology that the FCC has required the cellular carriers to provide. However, as time has passed, this location ability seems to be going in the other direction. Instead of getting better, it seems as if this location ability is slipping. Now the big question is presented as to why this seems to be happening.

This technology to locate a wireless caller’s location by the carriers has been around since about 2000. I used to work for a cellular carrier and was involved in the process. You would think that since then some 12 or more years have passed, the ability to provide a wireless caller’s location would have been refined. You would think that since then, technology would have improved the ability to have the wireless carriers to provide better accuracy to the 9-1-1 centers.

These 9-1-1 centers can only go by the information that is displayed on their screens. This information comes from the electronic location information that the carriers obtain from their cell site equipment. So guess what, if the information is going downhill, and the technology is improving, where would you look? I wouldn’t be all that hot to point the finger at just the cell site equipment. It may have a role to play here, but take a moment to consider a few more possibilities.

The cellular competition has become competitive. To keep the customers, these carriers are lowering the monthly charges. The plans they force customers to sign are restricting the wireless users. To cut cost and stay in the black, the money has to come from expenditures someplace. Those areas include cost of the infrastructure, maintenance of the cellular system, labor and the cost of the cell phones.

Maybe the FCC should start looking into the actual skill level of the technicians that are used to maintain the cellular system. I can vouch to the quality of the radio technicians that I run into that work on the public-safety radio systems is not what it use to be some 10 years ago. The owners of the radio shops that hire the radio technicians might not want to say much about the quality of people they can find to work for them. But the truth is out there. The skill level of many technicians I have worked along side of out in the field is not as good as back a number of years ago. Not sure if this is due to many radio shops no longer spend much time training these new technicians. It might be a lack of good mentors to work in the field alongside these new radio technicians. It might be due to the managers pressing the radio technicians to get more done in less time.

The FCC might have its work cut out for it in pressing a cellular carrier for the reason for reduced position accuracy. But they do have the clout to make the carriers toe the line. We will have to sit back and see where this all ends up after the smoke clears.

Note: These are not the thoughts and position of the company I work for, but are mine alone.

Jim Szalajeski
Radio Systems Engineer
Sytech Corp.
Alexandria, Va.



In response to “The Effects of Non-P25 Digital Systems on Interoperability” from July 17


Well said John. Be sure to add that it is not only dealers but also manufacturers that are selling non-Project 25 (P25) digital systems to public safety. Another soapbox to get on is the proprietary encryption that many vendors have added to true “P25” equipment. True interoperability is being muddied by greed.

Ann Rita Ditmore
General Manager
Central Communications and Electronics
Knoxville, Tenn.


Click here for the July 2013 Inbox.
Click here for the June 2013 Inbox.
Click here for the May 2013 Inbox.




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