March 2011 Inbox
March 14, 2011
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
Regarding the D block reallocation for voice (eventually), the only question I have is: Will the current Project 25 (P25) software-defined radios be capable of a Flash update or other means to handle 758 – 763 MHz?
Joel N. Marcott
RCIT Communications Technician II
Riverside County, Calif.
In response to “FCC Active in Narrowbanding Education," by Ralph A. Haller from the March 2011 issue, Page 10
I just received my March 2011 issue of MissionCritical Communications. I want to thank you for brightening my day. The article by Ralph Haller concerning FCC narrowbanding was entertaining and at some points comical. My favorite sentence was, “Even with all the FCC's efforts, it appears that many licensees have no clue that narrowbanding is required.” To that I reply, what efforts?
I am a two-way radio dealer in the Indianapolis metro area. I have been aware of narrowbanding for many years because I earn my living in the business. I can guarantee you that most, not many, licensees have no clue about narrowbanding. I am appalled that the FCC requires end users of frequencies to be licensed, and then when it changes the rules, the FCC refuses to communicate those changes to the licensees. I don’t know anyone on the dealer or end-user level who has ever received or even seen any communications from the FCC regarding narrowbanding. The truth is the FCC is poor at communicating with the people they wish to control.
Haller spoke in his article about a public notice done in December 2010. Where was this public notice posted? I have a news flash for the FCC: Most people who use radios and are licensees have a life, and it doesn’t revolve around waiting for public notices from a government agency. If the FCC expects compliance, it must communicate directly with license holders. Expecting equipment manufacturers and their dealer networks to disseminate this information is an abdication of the FCC's responsibility and isn’t working. It isn’t fair to the licensee to change the rules and not tell them. After all, the FCC does have all their names and addresses.
Also in the same issue, James Barnett Jr. was quoted as saying, “Licensees shouldn't expect an extension or individual waivers.” Now I am just a small business man from the hinterland, but I don’t believe the FCC has the manpower to process all the amended license requests required to meet their deadline, even if everyone started filing their amended licenses today. This “drop-dead” date will be extended as it has so many times in the past.
Author’s Response: I certainly understand Mr. Harper's frustration. Most private land mobile licensees, unlike broadcasters, use radio in their businesses, not as their businesses. Most probably don’t know that the FCC has a website because they have no need to know. Other than the granting of the radio license, the FCC does nothing to make a business more profitable or a local governmental entity operate more efficiently. I have often referred to land mobile radios as tools, like hammers and saws. It’s unlikely that most people check the websites of hammer manufacturers for updated information.
But most federal agencies don’t deal one-on-one to get information out. The Consumer Product Safety Commission has never communicated with me about some unsafe product that I may own. They, like the FCC, rely on their public notices, the media and the sales chain to get the word out. The system isn’t perfect, but as with all laws, ignorance of the law is no excuse.
FCC’s Response: We have a new webpage and have conducted numerous outreach efforts, including hosting workshops, appearing at conferences to speak on the issue and entertaining inquiries daily from lawmakers and the public on the issue. We continue to work to increase the awareness of public safety and government representatives about the compliance deadline for narrowbanding Jan. 1, 2013.
There is a wealth of information on our website that interested parties can access, and we encourage public-safety and government officials to use these pages to their benefit:
We also have an email box, email@example.com
, to which the public can email questions and concerns. We have staff on hand to handle public phone inquiries. Currently staff handles about 50 – 60 calls each month on the issue.
Correct me if I am wrong, but didn't Sprint Nextel purchase 800 MHz spectrum at auction? $700 million comes to mind. What makes you think they will give it back to public safety or other commercial users for free because they own the spectrum? Seems to me if you own it, you own it.
Perhaps they could sell spectrum to public safety. I can’t imagine a police department, fire department or EMS paying millions of dollars just for a license to operate on a radio channel without receiving any actual radio equipment. Police, fire and EMS can obtain a radio station license now by basically filing. Why would they pay millions of dollars for something they can obtain by just filing?
I can remember when Nextel was buying licenses for six or seven figures. Nextel spent, by your figures, $5 billion for public-safety reconfiguration. Are they now going to give up what they have already paid for and invested heavily in? The problem with the FCC selling spectrum is that once you've sold it, they own it and it's gone. You do not get it back.
W. Rick Duel, PE, W9XB
My article was asking questions about the future, not suggesting an outcome. But, to the question of what happens to the spectrum, Section 90.631(f) of the FCC rules states, “An SMR licensee with facilities that have discontinued operations for 90 continuous days is presumed to have permanently discontinued operations, unless the licensee notifies the Commission otherwise, using FCC Form 601, prior to the end of the 90-day period and provides a date on which operation will resume, which date must not be in excess of 30 additional days.”
Thus, it would seem that 90 (or perhaps 120) days after the system is shut down, the FCC will consider Sprint Nextel to have discontinued operations, and the licenses will cancel automatically in accordance with the provisions of Section 90.157(a) of the FCC rules. Even if the fixed transmitters remain in place, Section 90.631(f) also requires that service be provided to at least two associated mobile units (per channel).
Alternatively, one might argue that the above rules do not apply to geographic licensees. Section 90.685 does apply to geographic licensees and requires coverage of two-thirds of the population in each geographic area (or an ill-defined substantial service requirement). If no service is being provided, it would be difficult to show compliance with that rule. The real question is whether a licensee can hold onto idle spectrum just because they paid money in an auction?
It is a bad idea to have the output of the tactical channel (TAC) repeaters be CSQ because you open up the operating radios to every kind of noise that can be put into intermodulation, skip tunneling or any other noise problem that you can think of. Pick a standard tone and go with it. Anyone operating CSQ can pick it up and anyone with the PL can enjoy a quieter operation.
We are engaged in a similar discussion with our spectrum regulator, Industry Canada, in which they are interpreting the regulation extremely narrowly to allow inclusion of only the primary first responders and seemingly ignoring the important roles that support agencies play in the protection of life and property in cases of many emergency incidents. An example that immediately comes to mind is the snow plow that might be called to assist an ambulance to reach a citizen in distress during a severe storm. This flies directly in the face of the need for interoperability among and between agencies.
Further exacerbating the situation in Canada is that the decisionmaking on which parties are eligible to use 700 MHz has been decentralized to the various regional offices, and their decisions aren’t consistent from one office to the next. Unfortunately, the bureaucrats involved seem not to recognize that the modern trunked radio systems that will be using the 700 MHz spectrum are capable of assigning various priorities of service to different agencies. At least in Canada, it is typically the provinces that are making the huge capital investments in interoperable systems, and they aren’t going to short-change their primary responders in terms of system access and capacity. At the same time, they are going to insist on including all of their public-safety and public-service agencies, as well as appropriate nongovernmental organizations, for reasons of interoperability and economy.
We will be watching the development of this case closely.
Terry S. Canning, CET, CRSP
Emergency Communications Coordinator
Public Safety and Field Communications
Shubenacadie, Nova Scotia, Canada
Pubic safety/security departments in public museums and other public spaces should be included. Our security department’s primary mission is life safety and property protection. We are a quasi-governmental agency. At one time we were completely government, but in an effort to cut public spending, our facility and the collections are owned by government, but it’s run by a non-profit entity. Our security department has the important mission of protecting the safety of visitors, staff and property.
I see no reason why we should be excluded — especially since Rep. King’s proposal would steal our radio frequencies that we use right out from under us to be auctioned off to the highest bidder. Frankly that proposal is terrible. Too many users of the 420 – 470 MHz bands are either government, public safety, ham radio operators or businesses. Nothing was included in King’s proposal for all these users.
Electronic Systems Engineer
Milwaukee (Wis.) Public Museum
The 30 megahertz that amateur radio uses (420 – 450 MHz) would not be missed. Amateur radio is an important, critical resource during a major incident. A main band that amateur radio operators use during an emergency is the 420 – 450 MHz band. This band must stay as a resource for emergency amateur radio operators and not reallocated or auctioned for commercial use.
Thank you for the opportunity to express my opinion on keeping the amateur radio UHF band for amateur use.
Henry Russell, KC0NAJ
Deputy Radio Amateur Civil Emergency Service (RACES) Officer
El Paso County Sheriff's Office
Colorado Springs, Colo.
It’s unfortunate that government officials can propose such a bill to remove the users from UHF frequencies with a stroke of a pen. It’s an incredibly uninformed proposal in that respect, especially without the technical criteria and the impacts being included. They didn’t do their homework!
Not all of us have the luxury of flat geography and use 450 MHz (or 150 MHz) because of its propagation characteristics and the fewer sites needed ($$) compared with the 700/800 MHz frequencies. I hope some common sense, other than dollars, finds its way into a revision to this bill. This bill reminds me of the movie “The Towering Inferno,” and the final comment from the fire chief (Steve McQueen) when he says that someday they will include “us” in the design and prevent another disaster. Many of us need the UHF frequencies for a multitude of reasons. We all don't need bells and whistles and radios that only engineers can operate, nor a radio that is dependent on venerable infrastructure to communicate. Besides, who will fund all this, both initial and reoccurring expenses?
Russell V. Whittaker Jr.
Communications Systems Specialist
Dutchess County, N.Y., Emergency Response
The federal government is expecting a windfall of money from trying to recover the entire UHF and later the VHF bands from public-safety agencies. Who is going to pay for all the radio equipment that will need to be replaced? Public-safety agencies don't have any money to spare. As a matter of fact, there are many agencies that have just gone out and bought new radio equipment and installed trunked systems on these frequencies. They were following the guidelines set forth by the FCC.
Now we are looking at another mandated migration to the 700 MHz band. This is not a good move. Many of the agencies are on the VHF and UHF bands because the region they are in makes these bands the most economical to operate in. Going to the 700 MHz band would require a large number of new additional radio tower sites just to provide the radio coverage they have now.
How can Congress think this move from the VHF and UHF bands by any public-safety agency can be a justified act? Maybe if they slow down and start talking to agencies using these frequencies, they would understand this isn’t a good move for the federal government to consider. It would be a different story if the government were going to pay for the migration. But to mandate an unfunded move is similar to trying to change the country's health plan that was recently tried.
Who's going to win here? It surely won't be the end public-safety user. Will the federal government be able to come up with a plan for this before H.R. bill 607 is enacted? We can only hope that the people trying to push this bill through can have their ears and eyes opened up and understand the ramifications of what this bill will do to the country's communications.
This bill will even cause problems for many of the new federal government's radio network systems that have recently been installed at many of the installations around the country. Who do you think is going to pay for the replacement of all these military installations and federal agencies that are in the 420 to 440 MHz frequencies? Most of these systems were just installed over the last two years. Somehow, I think this is going to be a big waste of taxpayer money to try and move these systems again.
This is a poorly thought out bill by the supporters. I am all for progress and finding money for the federal government. But somehow this bill is going in the wrong direction. I don't see anyone coming close to a win on this. Let’s make sure that everyone makes their voices heard. There are few whom this bill will not affect in a negative way to their pocketbook.
We here at York County (Pa.) Department of Emergency Services are extremely concerned over even the remote possibility of having to “give back” this radio spectrum in which we just recently completed a $36 million radio system upgrade. The upgrade was for all of our county public-safety providers totaling in excess of 4,200 individual police, fire, EMS and local EMA entities to migrate field users who were operating on four different and disparate radio bands, such as FM low band (30 – 50 MHz), VHF (145 – 155 MHz) and UHF (450 – 460 MHz) to one new 500 – 512 MHz digital trunked radio system.
York County was forced to apply for this specific radio spectrum because there was no other available radio spectrum available for us to successfully apply given our close geographic proximity to the greater Philadelphia and Baltimore-Washington metropolitan areas.
To now tell us that we may be in a position within the next eight to 10 years to have to completely redo our entire radio system is outrageous. Quite frankly, the citizens and end users who now have a significant amount of dollars invested in this new technology, which for the first time in more than four decades brings everyone on one radio platform with true interoperability, would be enraged, and rightfully so.
York County will strongly oppose this initiative and offer any level of support necessary to prevent this concept from getting off the ground.
Eric A. Bistline
York County (Pa.) Department of Emergency Services
The attempt to force small communities to migrate to the 700 – 800 MHz is ridiculous. Many small communities will be cut off, or have limited communications if this move is forced upon the public-safety community. Our community isn’t financially able to make this switch even with an eight-year notice. We are barely able to afford the equipment we have now.
Emergency Management Agency (EMA)
Houston County, Tenn.
As an amateur radio operator and a public-safety official, I also have a hard time giving up the 420 – 440 MHz band. I understand that a large portion of the communications infrastructure that serves the amateurs depends on this band of frequencies. In fact, a local amateur radio group uses frequencies in the 430 MHz portion of that band, while constantly being available to render support in our rural communities.
Since public-safety assistance is a primary goal of the amateur radio service, it seems counter-productive to take a full 20 megahertz of spectrum away, while still expecting to receive the same high-quality support that we have come to rely on.
Senior Telecommunications Specialist
Washington State Department of Natural Resources (DNR)
I think it's impossible (though admittedly cheaper) to build a single network that is as resilient as a linked set of separate networks. It may be necessary because of cost, but the "we can engineer for every possibility" hubris often doesn't stand up to reality.
The Titanic didn't need more lifeboats because it was unsinkable. The Challenger didn't need to delay launching in the cold because the o-rings were designed to handle the conditions. The nuclear power plants on the northeast coast of Japan had backup power on site, so what could go wrong?
Resilience is inefficient and more expensive, but somewhat less expensive than consequences of a "brittle failure curve" taking systems to zero in a "black swan" event. Systems that are loosely coupled and severable fail more slowly in steps, not in a single resounding thud.
And we've not even talked about supervisory control and data acquisition (SCADA) networks like StuxNet and insider access to digital backbones.
I doubt anyone waiting on emergency services to save their family thinks to themself, “I sure hope the responders are using the cheapest communications gear they could get.” I wish them the best getting this right.
What better place to keep watch on surroundings. With fire stations being located in strategic areas makes good sense. The sales person should go nationally with proposals for all. I would like to know more. Is this person available to share what this takes to set up a municipality for service?
City of Kokomo, Ind.
Reminds me a bit of Hurricane Katrina when everybody took credit for providing mission-critical communications. The truth is a number of communications networks held up. Ambulance communications, for example, were unaffected. TeamTalk — New Zealand's public access mobile radio (PAMR) provider — was unaffected, and a number of wireless Internet suppliers’ services were undamaged.
One of the features of the Chistchurch quakes is that everyone has knuckled down and focused on saving lives; few organizations have chosen to play politics with the situation.
I am surprised to read that Tait and Motorola played an important role in supplying radios and their accessories, but failed to mention that Icom New Zealand and Icom Australia played just an important role. It proves that there is a favoritism given to certain brands, which I deplore.
You will probably never publish my comments, but I wanted to prove to you that you must be impartial in your articles and not give favors to certain brands and leave others out.
Motorola isn't mentioned in the article. The suppliers mentioned are Tait and MiMOMax Wireless, both of which are headquartered in Christchurch, New Zealand. The main reason for citing the vendors in the article was the location of their headquarters in the city of the earthquake, no other reason. RadioResource International
prides itself on objective and fair coverage of all mobile radio suppliers. Please forward any additional information about emergency communications in the aftermath of the devastating earthquakes in New Zealand and Japan, and we will publish the information. Our e-mail address is editor@RRMediaGroup.com
I’m writing you on behalf of the legions of amateur radio operators in America and the important role they play in disaster and emergency communications. Ham radio operators perform important services as it relates to response to earthquakes, floods, wild fires, missing children and Alzheimer’s patients, and local functions such as marathons and bike races. As volunteers, amateur radio operators donate their time and invest considerable personal expenses and resources to equip their vehicles, homes and portable systems to enable them to be ready at a moment’s notice to respond to these types of emergencies.
As public service agencies transfer their older legacy radio systems to newer, more advanced public service radio systems, there exists an opportunity to reuse and re-purpose the older, obsolesced radio hardware and systems. Because on the surplus market the values of older radios, repeaters and tower systems are miniscule at best, would it not be a better use of these systems to donate them to the local amateur radio organizations to help them improve the technologies that they have?
For private system providers there could potentially be a tax write off. For municipal cities, counties and federal users, the transfer of these systems could be shown as a good use and function to better local emergency response capabilities. If we could spearhead a program to alert radio suppliers and municipalities of the need to help amateur radio operators improve their systems, it could be a win-win situation for everyone.
I’m certain all of this used, outdated and obsolete equipment could be put to a great use across America. I would offer my time to work with the American Radio Relay League (ARRL) to find new homes for this gear.
Public Information Officer
Santa Cruz County (Calif.) Amateur Radio Club
Santa Cruz County Amateur Emergency Radio Services
I’m particularly interested in the statement at the end about “issues” with simulcast systems. We are in the beginning stages of building a simulcast public-safety radio system here and I am already seeing issues arise. Do you know or is there anyone you can direct me to who has specific knowledge of the issues that other agencies are having with simulcast? Any help you can provide would be appreciated.
Klickitat County Sheriff's Office
Search & Rescue Coordinator