Subject: [NEXTEL-1] Society of Broadcast Engineers (SBE) on Emergency Vehicle Signaling Service (RM-10836)

From: [email-masked]
Date: Fri, 13 Feb 2004 03:04:40 -0500

Society of Broadcast Engineers

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of Amendment of Parts 2 and 90
of the Commission's Rules to Provide for an
Emergency Vehicle Signaling Service

RM-10836

http://www.sbe.org/FCCLiaison/SBE.RM-10836.6.pdf

To: The Commission

Comments of the Society of Broadcast Engineers, Inc.

The Society of Broadcast Engineers, Incorporated (SBE),
the national association of broadcast engineers and technical
communications professionals, with more than 5,000 members
world wide, hereby respectfully submits its comments regarding
RM-10836, a Petition for Rulemaking filed by Alert Devices
International, Inc. (ADiCorp), proposing to create a Part 90
Emergency Vehicle Signaling Service (EVSS).

Pursuant to the Commission's January 9, 2004, Public Notice, requesting
comment on the ADiCorp petition by February 12, 2004, these SBE
comments are timely filed.

I. Fundamental Approach Is Flawed

1. The ADiCorp system is based on the premise that it is acceptable for
transmitters in
emergency vehicles to cause willful and intentional harmful interference to
the reception of AM
and FM broadcast signals by using blanket transmissions on all AM and FM
broadcast channels
to over-ride, or capture, the signals from AM and FM broadcast stations. No
matter how good
the perceived end, that end does not justify a flawed means. The system
proposed by ADiCorp
is deeply and fundamentally flawed, and would set a dangerous precedent for
further damage to
spectrum integrity.

2. It would further appear that the approach proposed by ADiCorp is in de
facto violation of
Sections 302(a) and 333 of the Communications Act of 1934, as amended by the
Telecommunications Act of 1996. Section 302(a) states:

The Commission may, consistent with the public interest, convenience, and
necessity, make reasonable regulations (1)
governing the interference potential of devices which in their operation are
capable of emitting radio frequency energy by
radiation, conduction, or other means in sufficient degree to cause harmful
interference to radio communications (bolding
and italics added).

Section 333 states:

No person shall willfully or maliciously interfere with or cause
interference to any radio communications of any station licensed or
authorized by or under this Act or operated by the United States Government.

The ADiCorp petition acknowledges Section 333 of the Communications Act, but
then goes on to argue that the plain language of
Section 333 would not apply to its proposed scheme because Section 333
supposedly only applies if the use of a jamming signal
is used solely to block the communications of others. SBE finds no such
provision in the plain language of Section 333.
Indeed, the language of Section 333 of the Communications Act precisely
applies to the ADiCorp proposal, in SBE's view.

3. Section 2.1 of the FCC Rules defines "harmful interference" as
Interference which endangers the function of a radionavigation
service or of other safety services or seriously degrades, obstructs, or
repeatedly interrupts a radiocommunication service operating
in accordance with these [International] Radio Regulations (RR) (bolding and
italics added). In SBE's opinion, the ADiCorp system,
if allowed, would exactly match the definition of "harmful interference."

4. The ADiCorp petition is paradoxical: On the one hand, it states that EVSS
would be secondary to broadcasting. Yet their system
is premised on the interruption of broadcast signals by an over-riding
co-channel signal. The meaning of "secondary" is that you
cannot cause interference to, and must accept interference from, the
"primary" service. This is the exact opposite of what ADiCorp
proposes.

II. Flaws in the ADiCorp Proposal

5. SBE sees the following conceptual and technical flaws in the ADiCorp
proposal:

5.1 ADiCorp presumes that most vehicles will have an audio system with an AM
or FM receiver and that the audio system will be
turned on and is being listened to at a reasonable level.

5.2 ADiCorp further presumes vehicles equipped with an audio system with an
AM or FM receiver is not being used in some other
mode, such as playing a CD or audio cassette, or tuned to an in-band
on-channel (IBOC) signal or to a satellite radio signal.

5.3 ADiCorp presumes that if tuned to an AM radio signal, the signal from an
EVSS transmitter won't simply cause unintelligible
heterodyned audio "squeals" rather than the capture (1) of the AM receiver's
audio. SBE is not aware of a "capture" effect for AM
radio receivers. Indeed, for this reason the FCC Rules require a more
rigorous protection ratio between co-channel AM signals
(26 dB) (2) than is required for co-channel FM signals (20 dB) (3). The
likelihood of audio squeals rather than "capture" is heightened
since ADiCorp proposes the use of "offset carriers"). (4) Audio squeals and
heterodynes will likely startle and distract a driver at
the very time when you do not want the driver to be distracted: When an
emergency vehicle is approaching.

5.4 ADiCorp presumes that if tuned to an FM broadcast signal, the receiving
radio will "capture" the ADiCorp FM signal. Whether
such a "capture" phenomena occurs will depend on whether the car radio
receiver uses a discriminator FM detector (which does
have a "capture" characteristic) or a slope-detection FM detector (which
does not have a "capture" characteristic).
Additionally, even if the car radio uses a discriminator detector, whether
"capture" occurs will depend upon whether FM signal strength
from the approaching emergency vehicle is sufficiently stronger than the
signal strength from the FM broadcast station being listened to.
It is not unusual for an FM broadcast station to have a signal strength of
100 dBu in a downtown area when its transmitter is located atop
a tall building in the downtown area of a city. Using a rule-of-thumb that
for a "foreign" FM signal to capture the reception of another FM
signal the foreign signal must be at least 10 dB stronger, SBE calculates
the 110 dBu contour of a 45 mW (-43.5 dBk) ADiCorp transmitter
to be a mere 4.7 meters (15 feet). (5) If the ADiCorp transmitting antenna
is at the rear of a large fire truck, the front of the fire truck would
have already arrived at the location of the vehicle it was trying to alert!

5.5 If one presumes a somewhat lower FM signal strength of 90 dBu for the FM
broadcast signal, the distance at which a 45 mW ERP
FM transmitter would create the required 10 dB stronger, or 100 dBu signal,
would be 14.8 meters (49 feet). For an emergency vehicle
traveling at 60 MPH, of 88 feet/second, this would give a warning time of
0.6 seconds; hardly very useful.
Even if one assumes the FCC minimum city grade signal strength of 70 dBu,
meaning an 80 dBu capture field strength, the distance from
a 45-mW ERP FM transmitter to the 80 dBu signal strength (based on free
space, which may not always be the case), is 148 meters (487
feet). At 60 MPH for an approaching emergency vehicle that's just 5.5
seconds of warning time, which might be enough to be useful. But,
how many FM broadcast station's place a far stronger strength over their
principal community? Most, SBE submits.

5.6 The ADiCorp petition presumes that interruption to the listeners of AM
and FM broadcasts will be only occasional, and that the
right-of-way spacing of a highway will guarantee that fixed radio receivers
will never be interfered with. SBE does not share this
optimistic view. First, it completely ignores the common situation of
multiple emergency vehicles responding to a major accident or
emergency, and the likelihood of a "witch's brew" of jamming signals. Radio
station listeners would be at risk of repeated interruptions
if they are in a heavily populated city where dozens if not scores of
responses by emergency vehicles happen every day; a "death by a
thousand knife cuts" scenario. Second, it ignores the reality that while
fixed radio receivers in locations adjacent to busy highways might
not receive a strong enough EVSS signal to obtain the "capture" effect that
ADiCorp assumes will occur, the distance at which harmful
interference to those fixed receivers can be caused is much greater. For
example, the Commission's NCEFM rules require a co-channel
protection ratio of 20 dB. For the same example signal strength of 100 dBu
for a local FM station, the interference criteria would be 80 dBu
(as opposed to the 110 dBu signal capture criteria). Applying the free space
formula gives the threat distance for a 45 mW FM ADiCorp
transmitter gives a threat distance of 148 meters (487 feet). This is likely
to exceed the right-of-way distance for many, if not most, highways.
In dense urban areas, many residential dwellings are less than 15.2 meters
(50 feet) from major arterial streets, intersections, and hospital
emergency room entrances.

5.7 And what of foreign language radio stations? It would appear that the
ADiCorp warning messages can only be generated in only one
language (presumably English), yet the proposed system would then override
foreign language radio broadcasts with an English language
warning. If one reasonably assumes that 1) a foreign language radio station
exists in a market because there are many residents there who
speak that language and 2) that some of those persons may have only partial,
or even no, understanding of English language broadcasts,
then it would be the height of presumptiveness to assume that an overriding,
English-only signal would be a good idea.

5.8 Perhaps the most dangerous flaw is that ADiCorp's premise may lull first
responders into a false sense of security that could lead to more,
not fewer, accidents. This danger would be based on the false assumption
that non-emergency vehicles will not only respond, but respond in
the correct manner.

5.9 There is also the reality that many mobile audio systems are listened to
at very high levels, and that program interruption could cause
damage to the system. Further, interruptions to fixed-location systems
operating a high levels could cause damage to high-frequency drivers
when there is heterodyning and the resultant clipping that would take place.

III. Other Vehicular-Based Services

6. And what of other vehicular-based radio or communication services that
similarly would have the potential to distract drivers from an approaching
emergency vehicle, such as IBOC, satellite radio, and cell phones? Would
ADiCorp next propose that IBOC, satellite radio, 800 MHz cellular,
and 1.9 GHz PCS jammers be added to emergency vehicles, as well? The premise
would be identical, and equally as flawed. Indeed, at Page 9, Footnote 3 of
its petition, ADiCorp suggests that it would want to capture digital IBOC
signals, as well.

IV. EAS Considerations

7. ADiCorp proposes that each and every EVSS-equipped emergency vehicle will
have a receiver that will monitor "primary EAS stations"
(plural) so as to ensure no EVSS transmissions commence during an EAS alert.
This raises at least two technical challenges, in SBE's view:

7.1. A local primary (LP) EAS station only exists for federal EAS messages;
i.e., the distribution of a presidential message, or Emergency Action
Notification (EAN). Virtually all of the work done by EAS is in the area of
state and local messages, and weather messaging, and suchmessages
are generally NOT delivered by just one particular broadcast station in a
given area. Thus, ADiCorp's concept that it only needs to monitor the LP
station is fundamentally flawed.

7.2. How can the ADiCorp technology protect an in-progress EAS message
(including Amber alerts), when the EAS tones that often, but not always,
precedes the message is the only part of the message that identifies the
subsequent audio as being an EAS message?

7.3 Will the EAS receivers in ADiCorp-equipped emergency vehicles always be
left on, even when the vehicle is parked and the ignition is off, to
ensure that any broadcast station transmitting EAS tones at the start of an
EAS or Amber alert will be properly detected? Will such vehicles always
be parked in areas where good radio reception can be assured?

7.4 Some broadcast stations do not precede local or state level EAS alerts
(including Amber alerts) with the EAS tones, because of the "annoyance
factor" and because transmitting the EAS tones is only mandatory for a
federal-level activation of EAS, the Required Weekly Test (RWT) or Required
Monthly Test (RMT). Thus, many broadcast stations voluntarily transmitting
state or local level emergency messages or Amber alerts without formal EAS
formatting would not even be recognized as EAS or Amber alerts by ADiCorp
system.

7.5 Further, not all life-safety emergency messages broadcast are EAS in
nature. The warning contained in an EAS message is generally considered to
be the first chapter of an unfolding lifesafety call-to-action story.
Conditions during an emergency can change for the worse in a split second.
Examples include:

7.5a EAS messages that ask those in danger to stand-by for detailed
evacuation information, take protective action, or even to do real-time
updates or add real-time support to an in-progress Amber alert.

7.5b An all-points bulletin looking for escaped prisoners who might be armed
and dangerous (as occurred in the state of Texas not too long ago).

7.5c Messages broadcast during a blackout where only the radio stations work
and people are in their cars or listening to portable radios for news and
information.

V. RM-9719 Parallels

8. In October 1999, SBE filed in opposition to a Petition for Rulemaking by
Federal Signal Corporation, RM-9719, asking the Commission to create a new
Emergency Data Radio Service ("ERDS") on FM Channel 200 (87.9 MHz). Like the
Federal Signal Corporation proposal, which made unsubstantiated claims such
as "ERDS could save thousands of lives and billions of dollars in
unnecessary health costs and property losses," the ADiCorp petition
similarly makes unsubstantiated claims.

9. Two other RM-9719 parallels are that of an annoyance factor, in the event
of ADICorpequipped emergency vehicles repeatedly arriving at a "magnet"
location, such as a big-city hospital emergency room, and a startle factor
for drivers intent on their main task of driving. When the program
interruption takes place, the driver may at first be startled, believing
that a malfunction of their radio is occurring. Then the driver may be
distracted while attempting to adjust or repair the vehicle's radio while in
motion. This distraction would occur at the very time when the driver's
attention is most needed: Upon the approach of an emergency vehicle at high
speed.

10. The "annoyance and confusion" factor would also apply to homeowners,
broadcast station main studios and control points, and to other people or
businesses who live, work or function near a main thoroughfare, arterial
highway, hospital, fire station or similar places where ADiCorp-enabled
vehicles would often travel and/or congregate. There is no need or excuse
for disrupting fixed receivers. Indeed, excessive use of the ADiCorp system
is likely to drive consumers from listening to AM or FM broadcasts to audio
services not repeatedly disrupted, such as satellite radio and CD players.
There may also be worsened neighborhood relations with police and other
emergency services if ADiCorp transmitters in police and other emergency
vehicles are synchronized with interference to radio reception.

11. SBE would also like to raise the issue of the countless service roads
that run parallel to freeways or major arteries, or the case of vehicles
traveling in the other direction of a divided highway. SBE submits that the
ADiCorp "broadcasts" (if they worked at all) would have the effect of
needlessly forcing many drivers to decide (and quickly) if they are really
in the way.

VI. Likelihood of Spurious Emissions

12. SBE also has the concern that ADiCorp transmitters would likely generate
out-of-band intermodulation products. SBE is assuming that ADiCorp would use
some sort of "comb" frequency generator feeding a broadband power amplifier
to generate its proposed FM and AM signals, as opposed to 200 separate FM
transmitters feeding a 200-port combiner, or 116 separate AM transmitters
feeding a 116-port combiner. If so, then when the public safety vehicle's
two-way system transmits there is the potential to generate spurious signals
in the aeronautical band, on other public safety or other land mobile
frequencies, and to the reception of TV Channel 6.

VII. Operation in Border Areas
13. As was the case for ERDS, the ADiCorp proposal raises Mexican and
Canadian considerations if ADiCorp transmitters were to operate in the
border areas. Even if the Commission decides it can address these problems
by establishing a keep-away zone within a specified distance of the Mexican
or Canadian borders, how would this be enforced for the large number of
mobile transmitters in public safety vehicles that ADiCorp envisions?

VIII. SBE Alternative

14. SBE believes that the concept of EVSS has merit; it's just that
ADiCorp's implementation of such a service is a terrible one and duplicates
that of others which have already been dismissed by the Commission for sound
technical reasons.6 Rather than attempting to jam AM and FM broadcast
signals, a much better approach would be for the Commission to designate a
narrow band public safety channel at 150, 450 or 800 MHz for EVSS, and then
to require, after some future date, that all vehicles sold in the United
States include an independent receiver that will monitor this frequency any
time that the vehicle's ignition is turned on. In the event a EVSS public
safety signal is detected, it would then trigger an in-dash icon and a
unique audio tone to alert the driving to an approaching emergency vehicle.
This would completely eliminate a plethora of issues of whether the vehicle
has an audio system, whether it is turned on, and whether it is in its AM or
FM receiver mode. It would also eliminate the issue of whether a low power
all-channels transmitter on an emergency vehicle really would be able to
"capture" regular radio reception with an intelligible message, or whether
such attempts would only create a nightmare of interference. Finally, such a
system would not run headlong into Sections 302(a) and 333 of the
Communications Act.
(6) For example, see the July 30, 2003, SBE comments opposing the WB9XTT
experimental STA of Safety
Cast Corporation (OET File Number 0183-EX-ST-2003.

IX. Summary

15. The entire premise of the ADiCorp system [that willful harmful
interference can be caused by one radio service (EVSS) to another radio
service (broadcasting)] is seriously flawed at both the conceptual and
technical levels. The FCC should not burden broadcasters with this intrusive
and potentially toxic experiment on the broadcast spectrum. However, while
the concept of EVSS is a logical and worthwhile endeavor, it must not be
implemented as proposed by ADiCorp, or as previously sought by Safety Cast.
The Commission should issue an NPRM based on the SBE alternative, which
proposes that a Part 90 land mobile VHF or UHF public safety frequency be
used for alerting drivers, with all vehicles equipped with an independent,
mandatory receiver that monitors the EVSS channel whenever the ignition is
on, triggering an unmistakable in-dash icon and independent audible alerting
mechanism rather than any attempt to interrupt the vehicle's audio system.

Respectfully submitted,
Society of Broadcast Engineers, Inc.

/s/ Ray Benedict, CSRE
SBE President

/s/ Dane E. Ericksen, P.E., CSRTE
Chairman, SBE FCC Liaison Committee

/s/ Christopher D. Imlay, Esq.
General Counsel
February 12, 2004
Booth, Freret, Imlay & Tepper
14356 Cape May Road
Silver Spring, Maryland 20904
301/384-5525

Footnotes:

1 "Capture" is a term used to describe a characteristic of FM (but not AM)
receivers, but only FM receivers
using discriminator detection rather than slope detection of the FM signal,
to receive, or "capture," the
stronger of two signals. When an FM receiver captures one signal over the
other, only the captured signal is
heard, and the non-captured signal is ignored.
2 See Section 73.37 of the FCC Rules.
3 See Section 73.215(a) of the FCC Rules.
4 ADiCorp petition, at Page 10,
5 Using the well known free space formula, EdBu = 102.8 - 20logDmi +
10logERPkw.
6 For example, see the July 30, 2003, SBE comments opposing the WB9XTT
experimental STA of Safety
Cast Corporation (OET File Number 0183-EX-ST-2003.

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