Subject: [NEXTEL-1] The Debate On Heats Up On The 4.9 GHz Band For Wireless Broadband Public Safety Use

From: [email-masked]
Date: Wed, 30 Jul 2003 17:21:53 -0400

Before the
                        Federal Communications Commission
                              Washington, D.C. 20554
                                 In the Matter of
                        The 4.9 GHz Band Transferred from
                              Federal Government Use
                                To: The Commission

WT Docket No. 00-32

PETITION FOR RECONSIDERATION
OF THE NATIONAL PUBLIC SAFETY TELECOMMUNICATIONS COUNCIL

The National Public Safety Telecommunications Council (“NPSTC”) hereby
respectfully submits the following Petition for Reconsideration in response to the

Commission’s Memorandum Opinion and Order and Third Report and Order, FCC 03-
99 (released May 2, 2003) (“Report and Order”), in the above-captioned proceeding.

With over 74,000 public safety organizations in the United States, it is critical
to
have a resource and an advocate for public safety telecommunications. That is the
primary role of the National Public Safety Telecommunications Council. NPSTC is a
federation of public safety associations that encourage and facilitate, through a
collective
voice, the implementation of Public Safety Wireless Advisory Committee (PSWAC) and

700 MHz Public Safety National Coordination Committee (NCC) recommendations.
NPSTC explores emerging public safety telecommunications issues and technologies,
and develops recommendations to appropriate governmental bodies to support the
broad
goals of promoting public safety telecommunications worldwide. Finally, NPSTC
serves
as a standing forum for the exchange of ideas and information regarding public
safety
telecommunications. NPSTC currently consists of the following thirteen
organizations:1

American Association of State Highway and Transportation Officials
American Radio Relay League
American Red Cross
Association of Public-Safety Communications Officials-International
Forestry Conservation Communications Association
International Association of Chiefs of Police
International Association of Emergency Managers
International Association of Fire Chiefs
International Association of Fish and Wildlife Agencies
International Municipal Signal Association
National Association of State Emergency Medical Services Directors
National Association of State Telecommunications Directors
National Association of State Foresters

I. INTRODUCTION AND SUMMARY

1. For well over a decade, public safety agencies have urged the Commission to
allocate additional public safety spectrum to ease life-threatening frequency
congestion,
enhance interoperability, and facilitate implementation of new public safety
communications technologies. Congress responded by requiring that 24 MHz be
reallocated for public safety services from the upper UHF television band, though
that
spectrum remains blocked by television stations in most major metropolitan areas.
The
Commission followed this initial reallocation of 24 MHz with the reallocation of
50 MHz
in the 4.9 GHz band for wireless broadband public safety use as part of this
current
proceeding, with the 3rd Report and Order released on May 2, 2003.

2. The Commission’s Report and Order takes important steps in addressing
longstanding
public safety spectrum requirements. Many of the service rules adopted in the
Report and Order are well developed and consistent with the needs of public safety

agencies. However, as described below, some of the most critical parts of the
Report and
Order were wrongly decided and, unless changed, will significantly impact the
ability of
public safety agencies to utilize the 4.9 GHz band quickly, effectively,
efficiently and at
minimum cost. Specifically, these three actions are:

A. Adoption of an unnecessarily restrictive emission mask that will add
significantly
to the cost of equipment, forming another niche market for public safety, and
potentially cause a significant delay in the introduction of equipment;

B. Providing of a totally unregulated technology arena within an open licensing
system that will potentially lead to technology conflicts within common coverage
areas of licensees to the point that interference renders the band useless, while
at
the same time severely hindering interoperability; and
C. Failure to adopt mandatory regional planning and a conflict resolution process
for
disputes arising between licensees, and within and between Regional Planning
Committees (RPCs).

3. The Commission must reconsider its decision by adopting industry-recognized
emission masks, developing a clear path toward identification and adoption of a
technology standard for general and interoperability use within the 4.9 GHz band,
and
requiring mandatory regional planning, along with adopting clear rules for use by
licensees, RPCs and potentially other conflict resolution bodies to resolve issues
around
implementation of systems in the 4.9 GHz band.

http://www.apco911.org/frequency/documents/WT00-32NPSTCReconPetition.pdf