Comments Mixed on IMSA’s 6.25-kHz Equipment Certification Waiver Request
Tuesday, November 22, 2016 | Comments

In comments filed with the FCC, the Government Wireless and Technology Association (GWTCA) and Icom America oppose an International Municipal Signal Association (IMSA) waiver request, but three other commenters agree with the request.

In September, the FCC requested comment on IMSA’s waiver request regarding the FCC’s rule that it no longer accepts applications for certification of Part 90 equipment in the 150 – 174 MHz and 450 – 512 MHz bands that cannot operate in a 6.25-kilohertz mode or with equivalent efficiency.

IMSA said that the implementation of the 6.25-kilohertz capability requirement should be delayed until Jan. 1, 2020, at which time the commission should reassess the decision.

GWTCA said IMSA's concerns are speculative. “Since implementation of the requirement, radios available in the band with 6.25-kilohertz capability have proliferated, without an increase in cost,” GWTCA said in its filing. “Further, there is no rationale for requiring a single 6.25-kilohertz standard. Doing so would disenfranchise tens of thousands of users, which have chosen one of the two dominant 6.25-kilohertz transmission technologies, with absolutely no benefit to users.”

NXDN two-way radio supplier Icom agreed. “Since implementation of the requirement, radios available in the bands requiring 6.25-kilohertz capability have proliferated, without much increase in cost derived from further advances in technology and natural market competition,” Icom said.

However, radio manufacturer Ritron said it supports delaying implementation of the requirement that applications for certification of Part 90 equipment in the VHF and UHF bands demonstrate 6.25-kilohertz capability or equivalent efficiency. “An indefinite date as determined by the market would be most warranted, but in lieu of that, a delay at least until the 2020 date proposed by the petitioner is justified,” Ritron said.

The National Ski Patrol System (NSP), a primarily volunteer membership group that provides rescue and medical services for the nation’s winter sports areas, said the FCC’s existing rule requiring both digital and analog operation is problematic for several reasons. First, there are multiple incompatible digital protocols, and ski patrollers need to communicate with a variety of first responders. In addition, NSP said dual-band analog and Project 25 (P25) equipment is expensive.

Manufacturer Powerwerx said the new 6.25-kilohertz requirement forces volunteer fire departments, search and rescue, ski patrol and other first responders to buy expensive digital radios that cost from $2,000 to more than $5,000 per radio without resources to pay for them.

“Postponing and granting a waiver for the implementation of the new 6.25-kilohertz digital standard for three to five years would allow the newer digital radio technology to become more mainstream and come down in price so that it may become more affordable in the future for the smaller rural, first responders,” Powerwerx comments said.

All the comments and reply comments are here.

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On 11/30/16, Leon van der Linde said:
We must look at the facts. 6 25 kilohertz is more efficient than 12 5 kilohertz. Project 25 (P25) and Digital Mobile Radio (DMR) are very old technology in a world where technology advances at a lightning speed. Certain countries are forcing their governments and associated organizations, including emergency communications, to move to digital. It is sad that P25 moved from FDMA to TDMA. The FDMA technology could be implemented at 6 25 kilohertz. That would result in more efficient spectrum usage. The NXDN radios are way more affordable than P25, and the protocol is mission critical. We have proven it locally where we deployed it with mission-critical organizations.
I think they should start looking at the more modern technology and move on — not stay in the past.


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