Subject: [NEXTEL-1] FCC agenda out of sync with market

From: [email-masked]
Date: Sat, 30 Aug 2003 11:25:53 -0400

FCC agenda out of sync with market
Mobile Radio Technology, Aug 1, 2003
Lynchburg, Virginia
Dear Ted,[Chairman Ted DempseyImplementation subcommittee, NCC]

After attending the recent Motorola consultant seminar, which you also attended, I
then attended the APCO National Homeland Security seminar in Washington, D.C. I
have come to the realization that what is going on in Docket 96-86 and the
National Coordinating Committee is not meeting the national need. Things have
changed and the FCC needs to recognize this and change course on the 700MHz band
spectrum to support Homeland Security.
As things are and might be:

As you and I both learned at the same time, the APCO P25 standard is not a
standard at all in the normal context. It is a vendor contracting infrastructure
document. This arises out of the vendor option for three feature sets: mandatory,
optional and value added. What this means is that the subscriber manufacturers are
at the mercy of the infrastructure supplier. At this time one —Motorola.

Two other defects existing at this time are. First — the lack of console interface
documents; thus console suppliers are locked and at the mercy of the
infrastructure supplier. Second — there are no inter-system documents so that two
adjacent systems have no assurance of being connected on an open standards basis.

The funding at the federal level is being directed toward APCO P25 systems
directly. Redoing what was done in the past with fixed location frequencies with
the results of the above is that what is evolving is an uncontrolled, unregulated
monopoly, and hence what we are seeing is the APCO P25 system costs 22 percent to
55 percent above other comparable systems.
What then does the nation need?

The nation needs:

The ability to float frequencies where they are needed (like cellular, PCS and
Nextel).
The separation of government infrastructure control from vendors to users.
The ability to transport subscriber units nationwide, like cellular, PCS, and
Nextel.
Critical communications infrastructure not being used as a pawn in the political
process.
A purchasing/user organization on parity with vendors in technical management and
control.

Reality:
The national government networks are dynamic in evolution, implementation, and
operation.
Networking [interoperability] cannot be achieved by the way things were done in
the past.
Networking [interoperability] cannot be achieved utilizing static industry
standards that take years if not decades to develop.

The solution:

The frequency and infrastructure [not subscribers] needs to be under the auspice
of national/regional structuring.
With my new enlightenment and the changes as a result of the events of Sept. 11, I
cannot support the fixed static regional planning process.

A new and different methodology regulatory structure must be found for the good of
the nation.Frederick G. Griffin,
P.E.President

A rebuttal

Albany, New York

I am dismayed that your transmittal to “the world” contains sweeping generalities
and only a few crumbs of factual information. I am sure that many would take issue
with your broad stroke statements about what cannot be done for Interoperability
on a nationwide basis.

It is true that the Console Interface and the Inter-RF SubSystem Interface (ISSI)
are still works in progress. And, although you didn't mention it, the Fixed
Station Interface is also a work in progress. It may be relevant to understand
that the direction of those standards development efforts was changed recently to
become Internet Protocol based, which offers the potential for a more flexible,
efficient, and robust network design.

You draw a broad brush picture of the Project 25 standards — as you refer to them.
In point of fact, Project 25 is based on a definition of user needs embodied in a
Statement of Requirements (SOR) document, which serves as the basis for the
standards development effort of the Telecommunications Industry Association's TR-8
Engineering Committee.

The SOR was developed from input by representatives of local, state and federal
public safety entities. The resulting standards that have been developed follow an
American National Standards Institute process and ultimately become ANSI
standards.
The standards that have been incorporated in the 700 MHz rules of the FCC (47 CFR
§90.548 and §90.553) for Interoperability are in fact ANSI standards. These
required Standards for Interoperability define the most basic mode of operation —
conventional common air interface, as opposed to trunked FDMA or TDMA, and include
clear and encrypted voice, and data communication.

Numerous manufacturers offer products that meet these requirements in one or more
frequency bands. Some offer subscriber equipment, some also offer fixed stations,
and others offer complete systems. In some cases, proprietary equipment is offered
for complete systems, which includes the capability to support the FCC required
Interoperability Standards.

Technology is evolving at such a rapid pace, that one must realize it is essential
to have some baseline common mode of digital communication for communication
interoperability to take place at all. Under such circumstances, the traditional
requirement for a Public Safety system requiring a “mature technology/product” is
no longer feasible. A mature technology or product is an obsolete technology or
product in these times. The best we can hope for is to have a uniform method of
communication that we can automatically fall back to when we need Interoperability
between disparate systems. We have that in the present FCC rules cited above.

With regard to Regional Planning, this system of local involvement in the planning
process allows for the types of variation that are appropriate and desired by the
Public Safety entities within their Region. The State Interoperability Executive
Committees (SIECs) were formulated to provide a level of uniformity for plan
development, operation and administration of Interoperability on a statewide
basis. The suggestion has been put forward to allow the SIECs to have jurisdiction
over all FCC-designated Interoperability channels. And, while the FC has not yet
acted favorably on the NCC recommendation for uniform nomenclature to describe the
FCC-designated Interoperability Channels, it is possible that the SIECs could each
require such uniform nomenclature within their Statewide Interoperability Plans.
It is unclear why the FCC is inconsistent in this matter, since they have no
problem specifying uniform nomenclature for the Emergency Medical Service UHF
“MED” channels in 47 CFR §90.20(d)(66)(i).

Clearly, the U.S. Department of Homeland Security should be an active participant
in each of the 50 SIECs, and this will go a long way toward solving your perceived
Interoperability concerns.

If your letter to the FCC, FTC and others was intended for the Federal
marketplace, was it really appropriate to send this to the FCC and the NCC, which
do not have jurisdiction over Federal radio communication matters?

I am sorry that I am not able to attend the NCC meetings this week, as I am sure
this correspondence deserves significant
discussion to bring out the issues with accuracy, clarity and specificity.
Hopefully some of the issues I have addressed above will add to the
enlightenment.Robert F. SchliemanMember of NCCAPCO Project 25 Steering
CommitteeRegional Planning
Committees — 8, 30 and 55

http://iwce-mrt.com/ar/radio_fcc_agenda_sync/index.htm

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