April 2015 Inbox
Monday, April 27, 2015 | 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 edit@RRMediaGroup.com.

In response to “Lawmakers Question Effect on Public Safety of Closing 16 FCC Field Offices” from April 24


While serving as chief of telecommunications operations from 1987 – 2003 for the Federal Emergency Management Agency (FEMA), I often dealt with FCC field offices. The nature of the FCC support I requested included identifying, finding and shutting down stations that were interfering with emergency communications.

During the 1990s the commission embarked on a policy of replacing any retiring engineers with attorneys and effectively closed numerous field offices in major metro areas. This policy degraded the capability of the FCC to continue to provide critical support to the federal response plan and other national security/emergency preparedness missions.

When I served as frequency manager for the U.S. government during the 1996 Olympics in Atlanta, the local FCC field office was so understaffed that engineers had to be brought in from other field offices around the country to support me.

With the growth of wireless devices in this country since 1996, I think it’s unlikely the commission will be able to respond to critical public-safety problems in the timeframe they are suggesting. Perhaps their response will be nothing but a phone call.

The field offices and their personnel have an outstanding record of providing assistance where and when it is needed. Whether it be tracing down a cell phone used by a terrorist, shutting down a radio station interfering with ambulance-to-hospital communications, or shutting down a station that is interfering with the single remaining communications link to an island devastated by a hurricane, these engineers and technicians have proved their worth many times over.

I hope that our elected officials will see through this smoke and not allow the closing of these field offices.

Paul K. Reid Jr.
Vice President
Alpha Technical Services


Addressing the craziness of government stupidity, without an effective and protected communications infrastructure, we’re jeopardizing our local, state and national security.

Every year as more wireless product is added to our limited RF spectrum, the noise floor increases and issues arise from both intentional and unintentional sources. There are far more stupid people (the unintentional) out there than bad guys (the intentional), but it takes just one of either to bring a communications network to its knees.

For starters, just look at the various illegal RF devices marketed on Amazon or eBay — mainly imported and mislabeled from China and sold to these stupid and/or bad people.

I find it irresponsible to even think about cutting back the protection and management of one of our most important and vulnerable national resources. Too many tasks are accomplished wirelessly in our modern society, and with times the way they are, we should be going all out to protect our RF spectrum more now than any other time in history.

This is NOT the time to be thinking about cutting back on FCC agents in the field whose task is protecting something so important to our existence.

Kip Button

In response to “Tait Launches Online Education Program” from April 23


This initiative by Tait will be very educational, as well as beneficial for us smaller islands like Fiji. We will get all our techs to register and get updated on the RF technology and its advancement that we cannot ignore. Thanks Tait and RadioResource Media Group for the information.

James Kamsoo
Sky Technologies
Suva, Fiji

In response to “Mission-Critical Networks Face Increasing Cybersecurity Threats” from April 21


Enjoyed your article. Very well done. Please stay with the topic. Keeping supervisory control and data acquisition (SCADA) networks isolated from the Internet has been a long-term objective of critical infrastructure industries (CII) entities’ IT departments.

Douglas Jarrett
Keller and Heckman

In response to “LMCC Wants to Develop VHF Vehicular Repeater Frequency Coordination Procedures” from April 21


Public-safety systems have been needing VHF frequencies for vehicular repeater systems (VRS) for years. Absent usable frequencies, I suspect that many system owners (more likely, their shops) simply cheat and use a frequency at the very top or bottom of the VHF public-safety pool without benefit of proper licensing. System manufacturers cannot do that with integrity and are therefore unable to sell VHF VRSs when needed to satisfy a system customer’s needs.

David Cann
Senior Wireless Systems Engineer
EF Johnson Technologies

In response to “CII Groups Oppose Authorizing 173 MHz Channels for Vehicular Repeaters” from April 13


Here is another example for using the abandoned VHF TV channels in many parts of the country. Vehicle repeaters could operate on the channels between 174 MHz and 220 MHz, old channels 7 through 13 that have converted to UHF digital. There are still some operational television stations that use the VHF band, but that is now the exception.

In the Seattle area, there would be plenty of spectrum to use to establish the vehicle repeater channels that are desired. The broadband data companies more than likely would not want to use the spectrum for wireless devices because of the size of antennas required for optimum performance; likewise they would not like the lower VHF spectrum (channels 2 through 6) for the same reason. Monitoring the VHF television channels will show quite a bit of unused spectrum.

The frequency coordinators should evaluate this proposal and pressure the FCC to allow public-safety and business radio operations on VHF frequencies that were vacated with the transition to UHF digital transmissions. I do not think that there is a real interest to auction these frequencies to cellular or data companies. Otherwise, there would be significant use of these channels now.

Gerald Marsh
Peninsula Communications
Washington State

In response to “The Necessity of Private Network LTE” in the March 2015 print issue of MissionCritical Communications magazine


Reading your editorial in the March 2015 publication I have some additional observations and details that need to be considered in arriving at decisions related to the First Responder Network Authority (FirstNet) network.

It has been repeatedly shown that commercial networks routinely become overloaded and of limited value during major events or disasters. Many events each year demonstrate this result. The commercial networks only recently started working toward prioritized access for certain data customers. The new regulations treating Internet service providers (ISPs) as Title 2 utilities will likely limit commercial carriers’ abilities to prioritize certain end data users over others.

From the inception of FirstNet it has been envisioned to include prioritization and preemption capabilities. The Long Term Evolution (LTE) standard includes the ability to prioritize traffic and support multiple levels of quality of service (QoS). The Public Safety Research Communications (PSCR) program has been exploring these capabilities and testing how FirstNet may deploy priority and preemption capabilities.

The use of priority and preemption capabilities is envisioned to fulfill several requirements. It is envisioned to assure incident commanders have the access and flexibility needed to assure critical information is delivered to the responders participating in major events or disasters. It is envisioned to allow prioritization of both users and applications within areas where system overloading occurs. Priority and preemption are also envisioned to allow the excess capacity of the FirstNet network to be used to help support the network’s capital expenses (capex), operational expenses (opex) and life cycle refresh. With functional priority and preemption capabilities public safety receives the benefits of a private network while having the potential to partner with a commercial carrier to speed deployment, broaden coverage and increase capacity while remaining financially viable. The finer details of priority, preemption and security must be established to meet public safety’s needs. Once those details are in place, many different potential partnerships become viable with commercial carriers.

As public safety users and communications specialists, we have not had access to the information that FirstNet has collected from carriers in the request for information (RFI) process. We can research technologies and apply our knowledge of available capabilities to guess at some of the possibilities. We know that the carriers are all using software-defined radios (SDR) that are frequency agile and capable of supporting multiple bands. We know that carriers are likely going to have to replace LTE infrastructure hardware in their migration to the new releases of LTE. Release 8 – 9 equipment is not likely to be capable of software-only upgrades to later LTE releases.

Multiple LTE vendors have indicated that they can produce new radio access network equipment capable of simultaneously supporting band class 14 from the same eNodeBs as the commercial equipment. In some cases, the same antennas and feeds may even be able to be used. Vendors have indicated that the band class 14 traffic for public safety can be isolated into separated backhaul assuring the backhaul does not become a bottleneck with public traffic. The public safety band class 14 traffic would be routed to the FirstNet core or available Internet as needed.

Research into the lease/use agreements between carriers and the tower holding companies they sold to may also be interesting. It is my understanding that in many cases the carrier that constructed the site retains access and use of the site for their purposes with no additional fees as a condition of the sale. The tower holding company that purchased the site charges other potential users for access to the site. If this understanding is correct, it is unclear if a carrier partnering with public safety for band class 14 deployments, would incur any additional expense for tower use. It may require legal review of the sale contracts to have an understanding of the expenses or savings that may be possible working with a carrier for tower access.

LTE data connectivity needs to be evaluated by capacity as much as by coverage. The need for capacity to support multiple users and their applications in the cell edges will normally require a network with many more sites then our LMR systems. The capacity gains are obtained with smaller cells and frequency reuse. Many of our LMR systems are designed with high sites for wide-area coverage rather than the lower cellular sites selected to minimize frequency reuse interference.

Public safety’s need for capacity at major events, incidents and disasters will require construction of the network to support capacities way beyond what would normally be used on a daily basis. If this capacity is not included in the design phase, the level of needed availability for critical incidents will not exist even with prioritization abilities. The extra capacity designed for critical incidents would have immense value to carriers or other partners when the capacity is not needed for public safety.

The $7 billion allocated by Congress for construction of FirstNet is by all estimates inadequate for the scope of public-safety expectations. In most cases the existing LMR infrastructure is not appropriately located or dense enough for the needed capacities of the FirstNet data network. All of the carriers have need for additional capacity. The recent Advanced Wireless Service 3 (AWS-3) auction displays the value of spectrum for additional capacity.

The carriers’ ability to enter an agreement with FirstNet and add band class 14 in their equipment replacement is a low-cost way for them to gain additional capacity. It is also a much less expensive approach for FirstNet deployment than separate individual equipment deployments. This approach minimizes or avoids much of the permitting requirements.

Partnering with a carrier placing band class 14 capabilities on its equipment also puts the public-safety infrastructure equipment on the same refresh cycle as the carrier’s equipment. With the rapid advances in LTE releases and technology, a three- to five-year hardware refresh cycle has to be anticipated. Software refreshes have to be anticipated every year to 18 months. Even with critical infrastructure, federal and public-safety users, it is questioned if there would be adequate revenue to support this refresh rate. If the infrastructure is not maintained to current releases, interoperability with commercial networks is likely to deteriorate. User devices would also become more specialized and not commodity products. FirstNet will have to plan for a refresh rate that is consistent with the cellular industry. Including band class 14 in one or more carrier’s radio access networks (RANs) would put the refresh cycle on that carrier’s schedule.

FirstNet has access to the information from the carriers on what they are willing to do and consider based on the RFI. As users, we need to recognize some of the efficiencies that may be possible by partnering with carriers. We need to trust FirstNet to look at all the available options and select the choice that will serve us best. It is a concern that the FirstNet request for proposals (RFP) will be written before significant information is collected from the states for FirstNet’s evaluation.

Individuals and organizations are encouraged to participate in the reviews of the draft RFP that FirstNet will release to assure that adequate consideration is given to the resources and needs of the different states. We are all aware that public safety will expect coverage, capacity and reliability beyond what commercial carriers provide. Partnering with one or more commercial carriers may be the best solution to obtaining the greatest capacities for a starting point. The public-safety resources held by state and local government may allow expansion of the cellular RAN footprint or capacity.

A pilot project such as the FIS Alpine World Ski Championship demonstrating LTE band class 14 priority and preemption capabilities would be significant. Demonstrating these capabilities on an overloaded test network would make many users more comfortable with the concept of partnering with a commercial carrier for the infrastructure. PSCR will provide details of the research it has accomplished this last year related to priority and preemption at its annual workshop June 3 – 5 in San Diego.

I am a deputy sheriff in a rural eastern Washington county with 31 years of full-time law enforcement experience. I have volunteer firefighting, EMS and search-and-rescue experience. I am an amateur radio operator and have supported communications elements within my agency for several years. I have participated with the National Institute of Justice (NIJ) Technical Working Group for Communications and participate at the state level for communications planning. I have participated with the National Public Safety Telecommunications Council (NPSTC) on the statement of requirements (SOR) for push to talk (PTT) for LTE requirements.

Jon Melvin

In response to “FCC Requests Comment on 9-1-1 Obligation for Non-Service-Initialized Devices” from April 2


As a 9-1-1 dispatcher, I would support deactivation of these devices. We almost never get legitimate calls from these phones.

Kim Balmer

In response to “FCC to Consider 3 GHz Spectrum Sharing at April Open Meeting” from March 30


Oh oh! Here we go again — desperately seeking another place to put yet another Citizens Radio (CB) service. Let's see, we currently have the following:

1. 27 MHz Double Sideband (DSB) full carrier there with the FCC rules firmly ignored. 2. 151 MHz low-power narrowband FM, again a lot of the rules are ignored there.
3. Family Radio Service (FRS). Most of the users think it’s a poor man’s cellphone! Now, there’s a real thrill.
4. Finally General Mobile Radio Service (GMRS), enough said.
Aren’t there already enough places to put lids? Having a new CB microwave band: This is a bad idea ranking right up there with placing a container of Limburger cheese on a hot stove and leaving it there. This proposal makes just as much sense and stinks just as bad.

Maybe not though. If it ends up being another CB radio service, maybe they should make sure that all the microwave transceivers come with a “magic screwdriver” so the end users can work on their own radios and improve them right out of operation.

No, we don't need another CB service, especially at microwave frequencies. There are enough frequencies available there to keep an awful lot of CBers busy.

With tongue firmly in cheek, I remain.

John Cartwright, WA8LGM, WQTZ773
North Olmsted, Ohio

Click here for the February/March 2015 Inbox.
Click here for the January 2015 Inbox.
Click here for the December 2014 Inbox.


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