Subject: [NEXTEL-1] The South Carolina Statewide 800 MHz Trunking Advisory Committee has serious concerns with the Consensus Plan

From: [email-masked]
Date: Wed, 15 Oct 2003 01:07:36 -0400

S.C. STATEWIDE 800 MHz TRUNKING
                                ADVISORY COMMITTEE

                                 Freddie Thompson
                                     Chairman
                                Spartanburg County

                                    Nick Babin
                                  Vice Chairman
                            SC Dept. of Public Safety

                                   Ken Harrell
                                Dorchester County

                                    Mike Horne
                                Greenville City PD

                                  Doug Connelly
                            SC Dept. of Public Safety

                                    Chris Cady
                               Aiken Electric Coop

                                   Steve Davis
                                      SCE &G

                                    Neil Ellis
                                 Lexington County

                                   Joyce Outlaw
                                     SC DHEC

                                  Elaine Johnson
                            SC Dept. of Public Safety

                                   Oscie Brown
                                      SCE&G

                                  Mike Sonefeld
                                 Irmo Fire Dept.

                                     Luke Pye
                                 Spartanburg EMS

                                   Vandy Waller
                                      SC DNR

                                   Gary Hewett
                             Augusta-Richmond County

                                   Daniel Lane
                                 Richland County

                                    Rich Hines
                              Columbia Police Dept.

                                  George Crouch
                              Contract Administrator

October 14, 2003

Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
236 Massachusetts Avenue, N.E.
Suite 110
Washington, DC 20002

Re:  FCC 800 MHz Realignment Proceedings (WT Docket No. 02-55)

Dear Ms. Dortch:

The  South  Carolina  Statewide  800  MHz  Trunking  Advisory Committee ("Advisory
Committee") has serious concerns with the proposed Consensus Plan currently
being  considered  by  the  FCC.  The  Advisory  Committee  urges  the Commission
to  not  adopt  this  plan  without  further  detailed  investigation.  The
Advisory Committee feels that it would be premature to adopt this plan without
additional  guarantees  from  NEXTEL,  consideration  of  other  options  and  a
full review of the impact/disruption to large statewide public safety 800 systems.
We would ask the FCC to remember that national organizations do not represent all
of their members concerns, that many of the agencies supporting the Consensus Plan
do not operate 800 MHz systems and are not directly impacted by this plan. The
Advisory  Committee  supports  a  national  approach  to  address  the
interference problem, but believes a blend of solutions including the Balanced
Approach Plan is  a  better  solution  for  South  Carolina.s  Statewide  Shared
800  MHz  Radio System.

The  Advisory  Committee  assists  the  State  of  South  Carolina  and
Motorola  with  the  management  and  oversight  of  the  South  Carolina  Shared
Statewide 800 MHz Trunked Radio System and mobile data system, known as the
Palmetto  800  Shared  Trunked  Network.  Advisory  Committee  members  are
elected by the system users and represent all areas of system users (Law
enforcement, Fire, EMS, power utilities and government). This system is a unique
partnership made up of public safety and power utilities eligible who utilize both

ILT  and  public  safety  licenses.  The  Palmetto  800  Shared  System  is  one
of  the
largest  systems  in  the  country,  and  its  users  are  directly  impacted  by
the
Consensus Plan. The Palmetto 800 system currently includes over 61 transmitter
sites  serving  South  Carolina  and  Augusta-Richmond,  Georgia.  The  system
supports  over  20,000  active  ID.s  representing  23  state  agencies,  165
local
governments/agencies, 7 power utility providers, 3 federal agencies and 5 special

Currently the users of the Palmetto 800 Shared System are not experiencing
specific areas of interference from
cellular vendors. The potential impact and disruption to the Palmetto 800 Shared
System from rebanding would
be  sizeable.  The  lack  of  details  about  replacement  frequencies  in  the
interleave  band  makes  it  very  hard  to
determine  the  exact  retune  cost  for  the  Palmetto  800  Shared  System.
The  estimated  retune  cost  is  between
$3,000,000 and  $6,000,000. At least 2 complete retunes of all sites and radios
would be required for the Palmetto
800 Shared System. Several years ago the Palmetto 800 Shared System was upgraded,
this upgrade required all of
the system radios to be reprogrammed. The coordination required to gather and
retune all 20,000 plus radios from
across the state is monumental. It requires hundreds of man hours from public
safety responders to deliver, pick-
up and redistribute radios, time that may not be reimbursable and pulls them away
from their primary jobs. To
date no one has guaranteed that the interleave replacement frequencies to be
provided by NEXTEL will have the
same 70 mile contours (non-short spaced), ERP.s and antenna heights. Changes in
these frequency parameters can
create  interference we do  not  have  today  and  reduce  system  and
in-building  coverage  endangering  the  lives  of
public safety responders.

Consensus Plan Concerns:

Equal  Frequency  Replacement  Is  Not  Guaranteed  .  The  plan  does  not
guarantee  that  replacement frequencies for public safety or other licensees in
the interleave band (non-NSPAC) will have the same 70 mile contours between
licensed transmitters, ERP and antenna heights. For this plan to be considered by
public  safety, a demonstrated  plan  must  be produced  to  ensure  that  all
public  safety  licenses  and  other licenses shared with public safety are
provided with replacement frequencies that are equal or better than their
existing  frequencies.  A  state  by  state  national  study should be conducted
prior to any FCC action being taken.

Funding  Is  Not  Guaranteed  .  NEXTEL.s  plan  to  fund  the  project  through
a  Limited  Partnership jeopardized completion of the project. The spectrum NEXTEL
is asking for has been estimated at over 4.5 billion dollars. To be fair to all
cellular vendors the FCC should implement a process to guarantee the funds for
rebanding and ensure that the full value of the spectrum has been compensated
for.  No  Plan  In  Place  If  Funding  Exceeds  Projected  Cost  .  If  the  FCC
secures  the  full  value  of  the spectrum  NEXTEL  is  requesting  additional
funds  will  be  available  if  cost  exceed  the  projections.  The plan
currently  provides  for  regions  to  be  retuned  only  if  the  funding  is
available.  Would  those  regions who were not retuned if funds ran out doomed to
interference when NEXTEL reactivates their interleave frequencies in the 851 to
861 band.

Funding By Reimbursement Only . For many  statewide  systems we are talking about
millions  of  up front dollars the states must provide to fund the retuning. The
reimbursement process and timelines are yet  to  be  developed.  The  FCC  should
require  an  up-front  funding  plan  to  protect  state  and  local government
budgets. Reimbursements for unexpected cost should have a timeline specified for
payment.

Relocation  Coordination  Committee  (.RCC.)  Management  .  The  RCC  should  be
under  the  direct
control of the FCC and have financial audit authority.

Plan Does Not Prioritize Statewide Systems - The rebanding priority plan only
looks a population or interference  and  does  not  factor  in  investment  in
statewide  systems  and  systems  servicing  multiple NSPAC regions. Population
should not be the deciding factor in rebanding priorities.

All Cellular Type Systems Should Be Relocated Out Of The 851 to 861 Band . Low
site cellular type
systems in the interleave band are either creating interference or they are not.
To implement a nationwide rebanding plan that already considers exempting some
companies who utilize cellular technologies is not a nationwide plan. To prevent
future interference the FCC should consider prohibiting the development or use of
cellular type and low site technologies in the proposed 851 to 861 band.
Consideration  For  Additional  Spectrum  .  To  ensure  sufficient  spectrum
for  public  safety,  the  FCC should consider at least 2 MHz of additional
spectrum (861 . 863) be added to the interleave spectrum.  Based on a value
determined by the FCC for  the 1.9 GHz spectrum NEXTEL would receive, the FCC
should consider exchanging additional available spectrum for public safety. The
spectrum created could be set aside for public safety to support statewide or wide
area shared radio systems and interoperability.

The  Advisory Committee  supports  the  FCC  in  its  efforts  to  develop  a
national  strategy  to  address  the
interference problems. However let us not forget that many  of  the  public
safety radio systems were operational
and  servicing  areas  prior  to  NEXTEL  and  other  cellular systems. While
NEXTEL  and  other  providers  may  be
operating  legally,  the  recent  changes  in  their  system  design  and
antenna  configurations  created  many  of  the
interference problems. If the tables were turned and public safety was knocking
cellular providers, who provided service prior to the existence the public safety
system, off the air would the burden of correcting the problem still fall on
cellular companies or would they demand public safety to correct the problem they
created?

In  summation  the  FCC  must  ensure  that  adequate  funding  will  be
available  to  complete  the  plan,  that
plenty  of  equal  spectrum  is  available,  additional  spectrum  will  be
available,  that  replacement  channels  in  the
interleave band will have the same ERP.s and contours, adequate value is received
for the spectrum, determine the true national extent of this severe cellular
interference and that no other options exist before the FCC moves forward with
consideration of this plan.

Respectfully submitted,
Freddie Thompson, Chairman
P.O.Box 5666
Spartanburg, S.C. 29304-5666
(864) 596-2050, ext. 105

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515284464