Subject: [NEXTEL-1] 800 MHz User Coalition- PUBLIC SAFETY LICENSEES WHO HAVE EXPRESSED RESERVATIONS ABOUT THE “CONSENSUS PLAN”

From: [email-masked]
Date: Wed, 25 Jun 2003 02:14:12 -0400

PUBLIC SAFETY LICENSEES WHO HAVE EXPRESSED RESERVATIONS
ABOUT THE “CONSENSUS PLAN”

State of Arizona
“This is a very difficult, time consuming, and expensive option, which may or may
not fully resolve the problem due to the wideband nature of today’s 800 MHz radio
receivers.”(May 3 Comments - 2)

City of Baltimore, Maryland

“Baltimore City continues to believe that the Plan is premature and cannot be
adopted in its current form, because the scope of the interference problem has not
been sufficiently investigated, and the cause has not been accurately enough
determined, to justify the adoption of a remedy as drastic as band realignment.”
(Feb. 10 Comments - 1)

“The Commission cannot accept the Plan in its current form for several reasons:
(1) the plan’s funding mechanism is lacking and does not explain how Public Safety
systems will be retuned without interruption; (2) the Plan does not establish that
retuned parties will be protected from future interference; (3) the proposed
forced migration policies are against public policy and without legal basis; and
(4) the Plan does not adequately protect the interests of Public Safety licensees
and does not recognize the it is a matter of life and death that Public Safety
operations not be interrupted during the realignment process.” (2)
Baltimore County Office of Information Technology

“Forcing State, Local, or City Governments to relocate their system frequencies
would not only create the possibilities of these vital systems having to be
modified at costs far beyond the 500 million so stated by Nextel, but could create
additional interference and interoperability problems as the 821-824 MHz systems
are brought into the 806 MHz range.” (April 12 Comments - 5)

“It is the Baltimore County’s contention that modifying all of these systems in
the time frame mentioned by Nextel would lead to unprecedented hardships on the
regional committees and governmental entities if done without a full understanding
of the associated problems.” (5)

Bergen County Police Department

“The remedies proposed by the parties and discussed by the Commission are stop-gap
measures that themselves will lead to future interference environments.” (May 6
Comments - 5)

“Bergen County urges the Commission to go much beyond the range of issues
surrounding the 800 MHz band and move public safety to a new environment.
Specifically, the potential presented by the scheduled auction of fertile spectrum
at 700-800 MHz, combined with those frequencies already allocated to public safety
in the band, is an opportunity that if let pass, will not return.” (7)

“The Commission’s discussion, however, in the context of the Nextel proposal,
attempts to delineate the myriad of costs related to relocation, equipment,
engineering, technical and legal. Such delineation will only stifle the
relocation. There is not adequate funding across public safety community to absorb
any cost.” (7)

Office of Chief Technology Officer, Government of the District of Columbia

“It is important to note that the view and comments of this coalition
[Nextel/Joint Commenters] may not directly represent the views and wishes of
Public Safety operating entities in this proceeding.” (Aug. 7 Reply Comments - 4)

Department of Information Technology, Fairfax County, Virginia

“Nextel must correct interference caused by Nextel stations to public safety
communications and other LMRS licensees operating in the 800 MHz LMRS bands and
bear all associated costs.” (April 30 Comments - 4)

“Fairfax County believes that many cases of 800 MHz CMRS interference to public
safety licensees can be corrected on a case by case basis by using good
engineering practice and proven interference mitigation techniques.” (21)
“The Nextel proposal and other similar band restructuring plans will take a long
time to implement with no guarantee of complete success. Nextel has a
responsibility to correct cases of interference to public safety communications
caused by Nextel stations.” (21)

City of Fort Lauderdale

“The FCC’s suggestion that the interference caused by interleaving can be solved
by removing pubic safety from the interleaved spectrum addresses only one small
part of the problem. . . . The majority of the interference problems would not be
addressed by this proposal.” (May 3 Comments - 4)

City of Gainesville

“We at the Gainesville Police Department are very concerned with the current
developments regarding the Nextel White Paper and the subsequent NPRM by the FCC.”
(April 29 Comments - 1)
“The interference problems created by CMRS and Cellular deployments can be solved
with proper engineering and technical solutions.” (1)

“We do not believe that any plan that proposes that public safety and service
vacate NPSPAC spectrum would be desirable. . . . Our dispatch centers would lose
most of their console capabilities during the transition and, due to a loss of
resources, our system would be severely impaired if an emergency event or disaster
occurred during this transitional period.” (2)

State of Hawaii

“It would be against the public interest to adopt any plan to reconfigure the 800
MHz frequency band that would cause the rechannelization of existing public safety
radio systems.” (May 1 Comments - 1)

“The ICSD rejects outright the suggestion that $500 million represents a
significant portion of the expenses necessary to relocate the current 1320 public
safety and NPSPAC licensees that use the 800 MHz band. . . . Cost and liability
should be borne by the commercial entities that benefit from the change.” (1)

“Immediate steps must be taken to eliminate interference to public safety
communications systems that is now occurring.” (1)
Lake County Chiefs of Police Association

“We strongly disagree with any plan that includes communication disruptions.”
(Feb. 13 Comments - 1)
“A planned disruption in public safety communications would open the door to those
that wish to inflict terror in our communities.” (1)

County of Maui

“Solutions must be technical and field deployable for public safety interest only,
and not economically or politically motivated for CMRS users such as Nextel.” (May
6 Comments - 3)

“Actual costs are unknown, but certainly it will require much more than $500
million to implement changes. In Maui County’s case, radio equipment will require
software updates, hardware modification, and a high probability of complete
replacement of certain equipment.” (4)

“Who will be responsible if during, or as a result of relocation, someone were to
be injured or killed due to a lack of communications?” (7)

Michigan State Police Communications Division

“Any plan to correct the current situation must be implemented in a timely
manner.” (May 6 Comments - 1)
“Relocation could also include the acquisition of additional equipment that would
be used to provide continuous service during the transition. The total cost of
relocation must be funded, and those responsible for the interference should
shoulder the burden of that cost.” (2)

City of Newport News

“The City would like to request that the FCC not impose relocations on Public
Safety license holders.” (May 4 Comments - 1)
“I do not believe the burden and cost of relocation should be placed on the Public
Safety community and ultimately the public. Instead, the burden should be borne by
Nextel Communications.” (1)

NYC Transit Authority

“The Consensus Plan does not address the problem of interference from low site SMR
providers, such as Nextel, and develops an approach designed to remove them to an
area of the spectrum where it is expected that they will not interfere with public
safety providers. No assurances, however, are given that once the relocation
occurs, future interference from entities using similar technologies will not
cause additional interference problems.” (September 20 Comments - 2)
“The Consensus Plan . . . does not identify what is surely to be a shortfall of
funds given the number and magnitude of the moves anticipated. No government
entity should be required to absorb the anticipated multi-million costs for this
move. Adequate provisions need to be made in the final order specifying the source
of these funds.” (3)

City of Philadelphia

“No public safety entity should be left at risk of non-reimbursement for curing a
situation caused by commercial users of spectrum.” (Feb. 10 Comments - 2)

“Any final relocation plan adopted by the Commission should clearly provide that
public safety agencies are entitled to full reimbursement for both the direct and
indirect costs of relocation, including expenses for planning and design,
modifications to existing equipment and software, replacement equipment and
software . . reprogramming radio and base stations, expert engineering and
technical assistance, and all necessarily incurred costs for managing the
changeover, including, in particular, police and fire officer overtime . . .” (2)

Portland, Oregon

“The initial solution is for the CMRS providers to recognize the role they play in
this problem and that their involvement and cooperation are necessary components
of the solution.” (May 6 Comments - 8)

Moving all public safety systems into a narrower band will create intra- and
inter-system frequency coordination problems.” (8)

“This process is not affordable through conventional funding mechanisms available
to local government, such as bond measures.” (9)

“The band realignment approach would not resolve the interference problems
currently being experienced by the Portland mobile data system.” (9)

Public Safety Improvement Coalition

“The larger problem is the trade of Nextel relocation funds for new Nextel
spectrum. The potential inadequacy of those funds may be, even at this late hour,
a reason to break a link that is under serious attack from Nextel’s competitors.”
(Feb. 10 Comments - i)

“The implementation of the Consensus Parties’ Plan would be in a few private hands
and sorely lacking in public oversight.” (i)
“PSIC members are also united in the views that (a) if forced to relocate or
retune, public safety systems should be fully compensated for the total costs,
direct and indirect, of their prudently chosen modifications; (b) choices among
more interference-resistant receivers for public safety and increased signal
levels for public safety systems, on the one hand, and reduced out-of-band
emissions and diminished signal levels for commercial systems, on the other hand,
should be fairly balanced. Public safety should not have to foot the lion’s share
of the bill by purchasing super-tough receivers or adding multiple antennas.” (May
6 Comments - 3)

City and County of San Diego

“APCO and other responsible frequency coordinators should explain precisely how
the CP plan will work. Our analysis says it will not.” (Feb. 10 Comments - i)

“The Supplement’s answer is unsatisfactory: That no relocation or retuning need
begin without a demonstration of money in hand to cover the costs. This only
avoids an unfunded liability; it does not address the public safety interference
problems that have caused the need to relocate and retune in the first place.”
(ii)

Commonwealth of Virginia

“The Commonwealth would be overly burdened with relocation. First, with whom would
we be competing with for replacement spectrum? Also, would our replacement
spectrum be an identical channel allocation or spectrum image of our former
spectrum? Who would pay for the engineering studies on equipment and spectrum
availability? Should a special coordinator be allowed to coordinate state
assignments, allocated by NPSPSC? Additionally, there would be background
disruptions and impacts that would affect our state colleges, institutions and
agencies. If interference is being caused to a COV entity, the interferer should
assume the responsibility.” (May 6 Comments - 4)

“A 500 million dollar funding limit may not be practical or reasonable for any
practical or comprehensive solution.” (5)
Washington State Interoperability Executive Committee

“The Consensus Plan has yet to address relocation and interoperability in any
proceedings with Canada.” (Sept. 23 Comments - 2)

“There are significantly more costs involved than the actual expenses, which are
greater than the $500 million that Nextel has agreed to hold in escrow for
relocation. There are also inherent operational costs to implement relocations for
both public and private organizations.” (2)

Washington State Interoperability Executive Committee

“The Consensus Plan has yet to address relocation and interoperability in any
proceedings with Canada.” (Sept. 23 Comments - 2)

“There are significantly more costs involved than the actual expenses, which are
greater than the $500 million that Nextel has agreed to hold in escrow for
relocation. There are also inherent operational costs to implement relocations for
both public and private organizations.” (2)

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514282235

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