Subject: [NEXTEL-1] Coveting Thy Neighbor's Spectrum

From: [email-masked]
Date: Wed, 22 Oct 2003 00:56:06 -0400

Coveting Thy Neighbor's Spectrum

Over the past few years at the FCC and in the wireless communications field, the
word "convergence" has gained a foothold within policy linguistics. Lobbyists use
"convergence" to demonstrate to the Commission that one group or licensee can
fulfill the needs of several other groups through a new service or device. The
simple truth is everyone wants everyone else's spectrum to supply more customers
with a conglomeration of services; or put another way, we want whatever our
neighbor has.

In the recent past, several proposals have been brought to the Commission seeking
our spectrum. First, commercial carriers took a stab at the private land mobile
community by saying that commercial wireless (i.e. cellular phones) can satisfy
business needs. In fact, I have heard a large trade association for major carriers
state just that in front of the Commerce Committee staff on Capitol Hill.
Fortunately, others in the room understood and publicly stated that private
wireless services must have reliability well beyond that of an everyday cellular
network to accommodate the daily needs of virtually all American business sectors.
The same continues to hold true when commercial carriers offer push-to-talk
services or priority access. The built-in reliability inherent in custom tailored
private wireless systems cannot be supplanted by a glorified speed dial or special
access to an overwhelmed network.  

Even more recently, personal radio gurus have sought industrial/business channels
for unlicensed operation. 
One petition would have integrated the Family Radio Service (FRS), the General
Mobile Radio Service (GMRS) and the Multi-Use Radio Service (MURS) with certain
industrial/business channels. The Commission rightfully denied the Petition
stating that the FRS, GMRS and MURS services were intended for personal use by the
general public, while industrial/business channels are intended to support
business use.  Our private land mobile radio systems are indeed too important to
jeopardize by permitting personal communications on a sporadic, unlicensed basis.
Picture a crew drilling for oil on a coastline hearing family communications
instead of a "stop" command. Imagine airline communications being interrupted by a
traveling family trying to find each other at a specific gate. 

While these examples may be slight exaggerations, these are legitimate, and
potentially harmful, consequences of mixing these services.  The point is: it is
imperative that the integrity of true industrial/business operations be
maintained. Yes, common carrier-provided push-to-talk and priority access could be
worthwhile in certain situations . . . for commercial, less-than-critical
communications. Yes, personal radio services offer a valuable communications tool
for families, friends and the general public on group outings. But none of these
services seeking private land mobile spectrum provide the essential reliability
and instantaneous communications necessary to support America's economic backbone.
Simply stated, convergence of commercial or personal radio with critical private
land mobile applications would fall short of meeting the interest of the public
and industry. Until spectrum seekers can boast such reliability and security, we
will continue to vigilantly ward off these entities as they covet our vital,
overly congested spectrum.

Jeremy Denton Director, Government Affairs

http://www.ita-relay.com/magazine/October2003/RegUP.pdf 

OCTOBER 2003

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