Subject: [NEXTEL-1] Congressional Testimony Of Mr. Stephen L Carrico Director Communications and Business Development Wisconsin Public Service Corporation

From: [email-masked]
Date: Fri, 13 Jun 2003 11:55:33 -0400

Congressional Testimony Of
Mr. Stephen L Carrico
Director Communications and Business Development Wisconsin Public
Service Corporation
P.O. Box 19001
Green Bay, WI, 54307-9001

Mr. Chairman and honorable members of the Subcommittee:

I am Stephen Carrico, Director of Communications and Business
Development for Wisconsin Public Service Corporation, representing the
United Telecom Council. I am a former UTC Chairman of the Board and
currently serve as Chair of UTC's Homeland Security Steering Committee.
I thank you for the opportunity to appear before you today to discuss
issues of vital concern to all emergency responders.

For 55 years, UTC has been the voice of electrical, gas and water utilities
in matters relating to their voice and data telecommunications. UTC's
several hundred critical infrastructure members range in size from
multi-state organizations such as American Electric Power in the Midwest
and Entergy in the South, to municipally owned utilities and co-ops
operating in cities, towns and rural areas throughout the country. All of
these companies own, maintain and operate mission-critical
communications systems. Most importantly for purposes of this hearing,
these include two-way land mobile radio systems on which we all rely for
both routine and emergency communications.

Critical Infrastructure Communications Affect Homeland Security All
critical infrastructure industries are becoming increasingly dependent on
information management and private internal communications systems to
control and maintain their operations. A 2002 study by the National
Telecommunications and Information Administration (NTIA), entitled,
"Current and Future Use of Spectrum by the Energy, Water and Railroad
Industries," makes very clear the extent of this dependency to meet
essential operational, management and control functions. In fact, the
physical components of the energy and water production, supply and
delivery networks can be wholly intact but rendered virtually useless
through control or incapacitation of these internal communications
systems.

An article in the Washington Post a year ago noted that Al Qaeda
operatives spent time on sites that offer software and programming
instructions for the distributed control systems (or DCS) and supervisory
control and data acquisition (known as SCADA) systems that run power,
water, transport and communications grids in the U.S. - so, too, should
this aspect of critical infrastructure protection receive your serious
consideration.

All parties concerned with homeland security agree that one of the most
important considerations is the availability of reliable communications for
emergency responders. In this regard, there are three important issues
which need to be addressed: 1) The critical players that require such
communications include not only the first responders from the public
safety community, but also the critical infrastructure enterprises such as
power and water utilities which must provide a first line of defense; 2) We
must ensure effective and interoperable communications between the
communities of public safety responders and critical infrastructure
enterprises; and 3) Government oversight of the communications facilities
and services relied upon by public safety and critical infrastructure, which
is now shared between the FCC and NTIA, must be streamlined to ensure
effective protection from interference as well as interoperability.

Emergency Responder Communications It is understood that the local
and state police and fire personnel are among the first responders to an
emergency, as well as emergency health care workers. But critical
infrastructure employees - the emergency utility workers - are often
overlooked as vital to any emergency response. Along with protecting life,
the first order of business following a manmade or natural disaster is the
restoration of essential public services, including water (to fight fires and
ensure clean and safe supplies), gas and electricity (to restore heat, light
and energy generation capabilities). These are the first services that must
be brought back on line, so these workers are among the first personnel
on the scene.

Case in point: as soon as the magnitude of the 9/11 disaster became
apparent, more than 1900 Consolidated Edison emergency workers were
dispatched to Ground Zero to assist critical service restoration efforts and
provide emergency communications capabilities to others on the scene.
ConEd's two-way land mobile radio system was among the only
communications available and was widely used during the first few hours
following the collapse of the Twin Towers.

In a more recent and more common example: so far this year, Consumers
Energy of Michigan has been called on to respond to two major storms.
On Thursday, April 3rd, an ice storm swept across Michigan's lower
peninsula. Through the following day, a total of 425,000 customers were
without power. Over 10,500 "wire down" calls were received. All available
Consumers Energy crews and available contractors were put into the field,
along with over 125 electric line crews from neighboring utilities.

On Sunday, May 11th through Monday May 12th, strong winds in excess
of 50 miles per hour hit Lower Michigan. Electric service to 101,000
customers was disrupted. Over 2,200 reports of down wires were received
and resolved.

Responding to these storms required massive communication resources.
All work was coordinated via the Consumers Energy 800 MHz trunked
radio system. Only by having a reliable, private two-way radio system is
Consumers Energy able to adequately respond to such emergencies.

Critical infrastructure entities use the same kind of radio equipment as
Public Safety agencies, and as fellow emergency responders, we
understand their communications needs better than any other industry.
The most important aspect of our radio systems is reliability -- utilities
build their systems for 24-7 and "five 9s" operation. The job of an electric
lineman until recently was considered the most dangerous in the nation -
these crews rely on their radios just as police and fire personnel do. And
one element of reliability beyond that of traditional public safety: our
radios must work, wherever our crews go, when the power is out.

During any kind of manmade or natural disaster, you will see police, fire,
utility and other emergency personnel on the scene at the same time.
Any discussion of emergency interoperability must include critical
infrastructure if the United States is to have an effective system. The
White House has recognized this fact and has urged UTC's inclusion in
energy, water and telecommunications sector work on Homeland
Security.

Local Efforts Toward Interoperability Congress recognized the importance
of our systems in 1997, when you included utilities, pipelines and other
critical infrastructure among "public safety radio services:" those private
systems that provide support to such vital systems that entities operating
them should have access to spectrum without obtaining it via auction.
Since then, critical infrastructure has not sought access to existing public
safety spectrum; however, the FCC has not made a separate allocation to
non-public safety private wireless since 1985. Therefore, UTC and its
members have looked for opportunities to bolster interoperability among
all emergency responders by other means. The most effective means on a
local basis has been through shared radio systems, and there are dozens
of these throughout the country. Many of them have been built by utilities,
because we often can get the system funded and into operation faster
than public safety agencies. And - we build our systems so they work
when the power is out.

Just a few examples of shared systems: Gainesville, Florida, where
Gainesville Regional Utilities has built and maintains a non-profit, shared
800 MHz system. Local public safety agencies use this system as
low-cost subscribers. There are many municipalities, as throughout the
Philadelphia metro area, where local utilities and public safety agencies
share a common radio system owned by the local government.

In Mississippi, Alabama, Georgia and the Florida Gulf Coast, Southern
Company has built a commercial 800 MHz system to utility standards,
making it attractive to thousands of public safety users, as well. A system
like Southern's is the only form of commercial system appropriate for
mission-critical communications, since utilities must have complete
coverage of their service territories, as well as guaranteed reliability at all
times. No consumer-oriented commercial wireless provider can afford to
offer service to this standard, nor do commercial systems continue to
function during power outages of any duration.

However, these shared systems are only local attempts to solve
interoperability problems, and the United States needs a nationwide
solution so that all emergency responders can communicate with each
other. We offer our expertise to help reach this vital goal.

Critical Infrastructure Has No Dedicated Spectrum Unlike traditional public
safety, the critical infrastructure industries have no designated spectrum
for their own use, and we suffer from increasing congestion and
interference on the bands we share with millions of other non-public safety
private wireless users. We have requested a small, exclusive allocation of
six to ten megahertz, on which we propose to construct a nationwide
system. This system would be interoperable among the multiple utilities
that always respond to regional emergencies, and would be made
available to traditional public safety, federal agencies and others through
additional equipment, or as part of a network of networks.

While it is understood that spectrum is a scarce resource, homeland
security initiatives should consider an exclusive allocation of spectrum to
critical infrastructure for the establishment of a nationwide emergency
communications network. This would achieve three objectives: 1)
economies of scale would drive down the cost of equipment; 2) efficient
spectrum use would dictate the use of this spectrum on a day-to-day
basis for critical infrastructure operations support, while entities would be
responsible for maintaining the emergency network; and 3) emergency
response capability would be served by all response agencies having
immediate access to fully operational communications equipment, priority
access and a fully interoperable network when the need arose. A very
good home for this system would be on the 700 MHz band, on spectrum
adjacent to the 24 MHz allocated to public safety. UTC includes an
overview of this proposal in our written statement.

Thus, in answer to the subcommittee's question of whether public safety
has enough interference-free spectrum for interoperability, this segment of
"public safety radio services" does not, and emergency responders as a
whole will not be interoperable without critical infrastructure. However, we
are ready and willing to help all parties reach this goal.

The FCC's 800 MHz Proceeding Hundreds of mission-critical utility radio
systems are operated on the 800 MHz private land mobile radio (PLMR)
frequency band. Such systems are of varying age and technological
sophistication, from analog conventional use to advanced digital systems
that incorporate voice and data transmissions. Several utilities are
deploying such advanced systems across wide areas, with expectations
of using them for, not only routine and emergency field communications in
support of service and power restoration, but also for key telemetry
systems that actually control the nation's power and water infrastructures.
Because of the ability to use frequencies exclusively within a licensed
area, coupled with the variety of equipment manufactured, the 800 MHz
band is probably the most important PLMR band currently available for
critical infrastructure communications, especially for entities seeking to
deploy more advanced technology.

800 MHz interference is not only a public safety problem. Many UTC
members operating on this band also have suffered interference, almost
exclusively from Nextel's system. Prime examples are Union Electric in
the St. Louis, MO area and Consumer's Energy in Michigan, which have
had to resolve a number of interference problems; they have done so
through use of engineering solutions such as those found in the "Best
Practices" guide.

However, interference resolution alone is not enough. UTC is a leading
member of the 800 MHz User Coalition, which has submitted an
alternative position to Nextel's. More than 30 parties, including several
trade associations, individual critical infrastructure entities, small
commercial carriers, the cellular industry and some public safety
agencies, have already signed on to the Coalition document, filed on May
29, 2003, and more are added daily. Statements by Nextel and its
supporters that its "consensus" plan is supported by a vast majority of
affected licensees are simply untrue.

The User Coalition stresses that interference to all user systems must be
resolved, at the cost of the interfering licensee - and that future
interference must be prevented through improved engineering practices,
as well as regulatory flexibility that enables "channel swaps" and shared
systems. Mandatory rebanding is an inefficient, overly expensive and
ultimately, ineffective solution, since interference would still be present at
the end of the process. Moreover, rebanding to "separate" compatible
systems from incompatible ones only freezes a moment in time: these
systems are not static, and migration to better technology will change the
landscape again within a few years.

However, in spite of FCC policy directions in favor of better spectrum
efficiency, less detailed regulation and market-based solutions, the Nextel
plan would require a massive, four-year (at the minimum) reshuffling of the
entire band placing all licensees in restricted space, and resulting in only
Nextel being able to deploy advanced technology and better spectrum
efficiency. To many utilities already building digital wide-area systems for
themselves and their communities, this is unacceptable. UTC and dozens
of our member companies have opposed the Nextel plan consistently, as
have many public safety agencies. Such restrictions only scratch the
surface of the User Coalition parties' concerns about the Nextel
"consensus" plan: there are serious questions about the FCC's authority
to implement the plan, and challenges are likely should it be adopted.
This band is too important to all its users; the solution for interference
must be one that keeps it fit for the future of all of those that depend upon
it.

ATTACHMENT A

PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION IN
806-824/851-869 MHz BAND

I.    Procedures to Identify and Avoid Incidences of Interference in the
806-824/851-869 MHz band.

Any licensee wishing to install a new antenna in the 851-869 MHz band at
height of less than 30 meters AGL ("low-site transmitters") shall notify co-
and adjacent channel licensees within the protected service contour (via
filing at the FCC in ULS or an alternative database) and appropriate
frequency coordinators 30 days in advance of the installation of the site
providing the following information:

Licensee Name
Point of Contact-Information: Name, address, telephone
number, and e mail address for technical person knowledgeable
about site.
Site Coordinates
Certification: The licensee shall certify that it has performed an
engineering analysis pursuant to generally accepted industry
practices and has determined that its operation of that site is not
predicted to cause co-channel or adjacent channel interference
to other licensees in the 806-824/851-869 MHz Band within
service areas that overlap a 5,000 foot radius around its
transmitter site.

II. Procedures to Address Identified Interference Problems

A 806-824/851-869 MHz licensee receiving interference will immediately
notify any suspected interfering low-site system operator or operators of
the problem by:

Posting the interference complaint to an e-mail address to be
established and operated jointly by the licensees of low-site
systems in this band.

The Complainant shall identify:

Specific geographic location where interference is occurring,
FCC license information for the Complainant's system,
Point of Contact Information for the Complainant's system.

All licensees receiving notice of complaint via the website shall respond
within two business days and shall confirm whether they have systems
operating within 5,000 feet of alleged site of interference.

On-site analysis: The Complainant shall contact the potentially
responsible contributors to the interference to arrange for an on-site
analysis to take place within five business days (or later at the discretion
of the complaining entity). The Complainant and all potential contributors
shall support the analysis effort.

Mitigation steps:

When the analysis shows that one or more of the suspected
interfering operators are actually interfering with the system in
question, the contributors to the interference shall correct the
interference per industry-standard mitigation techniques. The
resolution of the interference shall be documented and copies
provided to each contributor and the complaining licensee.
If mitigation of interference at a site requires that contributors
make changes that can be easily reversed or substantially
modified (e.g., changing of transmitter frequencies to avoid
intermodulation ("IM") product formation on a particular
frequency, or a reduction in on-street power), then the
contributor making the change shall continue to coordinate both
with the other contributors and the complaining entity before
making further changes to the site.
If the analysis finds that interference is caused by something
other than the equipment belonging to potential contributor
system operators (e.g., a bi-directional amplifier ("BDA")
installed by a third party, or "receiver-generated" IM
interference), the owner of the equipment shall be responsible
for mitigating the interference. The participants in the on-site
analysis shall be responsible for notifying the equipment owner
of this finding.

The Complainant shall have a duty to cooperate in the implementation of
the most cost-effective solution.

If an agreement between the parties is not reached within 60 calendar
days after receipt of the written notice of interference, any affected party
may submit the matter to the FCC for resolution. The FCC shall order
appropriate steps to resolve interference in the most efficient manner,
including by such means as specifying the transmitter power, antenna
height or frequency, or requiring other changes in operation or equipment
to correct the problem.

ATTACHMENT B

TECHNICAL RULE MODIFICATIONS

The following technical rules, in addition to the requirement, described
above, that interfering licensees correct their interference, should be
adopted as part of the effort to resolve interference through improved
mitigation techniques. The FCC should:

Require licensees in the 800 MHz band to comply with the
procedures outlined in Attachment A, ie: · Notify co- and
adjacent channel licensees within the protected service contour
(via filing at the FCC in ULS) and appropriate authorized
800/900 MHz frequency coordinators 30 days in advance of
initiating transmissions from a new "low site transmitter". ·
Respond to interference complaints within two business days
and resolve interference expeditiously through industry-standard
mitigation techniques.
Require Licensees in the 806-824/851-869 MHz band to
calculate percentage degradation for land mobile systems by
using the TSB-88 algorithm. While the TSB-88 algorithm was
developed to address interference issues associated with land
mobile refarming, the methodology could be used at 800 MHz
to evaluate co-channel and adjacent-channel systems.
Implementing the use of TSB-88 could address potential
interference from digital operations on channels directly adjacent
to proposed facilities. Frequency coordinators in the band must
decide on mileage criteria that would necessitate evaluation of
adjacent-channel facilities. Absent a current recommendation
from 800 MHz frequency coordinators, a 70-mile radius is
proposed.
Codify or amend the regulations as necessary to allow for
external filtering and other added equipment to be used to
reduce or eliminate interference.
Adopt the "APCO Best Practices" recommendation to require
that user receiver equipment in the 806-824/851-869 MHz
band provide a minimum 75 dB intermodulation specification.
Require licensees of "low-site" systems in the 806-824/851-869
MHz band to limit the ERP of base stations with an antenna
height of 30 meters or less above ground to 100 watts/25 kHz
channel. · "Low sites" may be defined similarly to the "cellular"
definition offered by the Consensus Plan, i.e.: sites: 1) that are
included within a system with five or more overlapping sites with
handoff capability; 2) with twenty or more operating
frequencies; and 3) with antennas at a height of up to 30 meters
above ground.
All base station operations in the 806-824/851-869 MHz band
should be subject to a single rules section concerning emission
restrictions. The requirements of 47 CFR 90.543 - Emissions
limitations, including the ACCP Tables addressing adjacent
channel and OOBE levels (excepting subparagraph (e)) for 12.5
kHz or wider operations, should, at an appropriate future date,
replace the current rules sections dealing with emission masks
for various portions of the band, modified as necessary to
accommodate bandwidths currently not included in the ACCP
Tables. To implement this standard, 47 CFR 90.691- Emission
mask for EA-based systems, and 47 CFR 90.669 - Emission
limits for MTA licensees, should be modified to conform to the
above standard. This, coupled with ERP restrictions, would
significantly reduce the possibility of interference between and to
noise-limited systems operating in the vicinity of low sites.
The combination of low-site ERP restrictions, the adoption of
the ACCP attenuation requirements of 47 CFR 90.543, and the
use of TSB-88 for adjacent channel separation, coupled with
the removal of eligibility barriers to permit "frequency swapping"
and other measures to allow operators to reduce or eliminate
interference, will eliminate the need for the creation of a "guard
band" as described in the PWC Plan, Appendix F, Section
4.1.2. As has been stated previously, the "sliding scale" of
protection for frequencies in the proposed guard band might not
significantly impact low-power campus systems, but would have
a devastating impact on wide-area users currently licensed and
operating in the proposed guard band, as well as the many
non-public safety incumbent systems that would be required to
retune to the 859-861 MHz portion of the band under the PWC
proposal.
Establish adjacent channel spacing standards for use in
coordinating non-EA channels, to facilitate the ability of
frequency coordinators to review the spacing of channels
adjacent to the frequency under consideration, as well as the
co-channel spacing, during the coordination process.
Any interference that should remain after the implementation of
the above measures could be resolved through "Enhanced Best
Practices" measures such as careful design or redesign of
antenna systems, filters, and other non-transmitter-specific
remedies. Under this proposal, manufacturers would be able to
produce equipment usable across the entire band, maintaining
economies of scale, encouraging manufacturer involvement and
innovation and benefiting the 800 MHz market in general.
Motorola, for example, is testing the use of switchable
attenuators in portable receivers to reduce the strength of signals
entering the receiver in strong signal areas that would otherwise
result in non-linear operation of the low noise amplifier and
mixer, creating intermodulation interference.
Motorola is also testing software-controlled tunable filters in
their portable receivers that retune the filter based on received
signal strength, allowing the portable to operate correctly in the
presence of strong CMRS signals. Further, Motorola has
written that "All of the deployed dual-band XTS 2500 and XTS
5000 model radios (which began shipping in 4th quarter 2001)
are physically capable of implementing this solution, but will
require additional software.

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