Subject: [NEXTEL-1] Commentary 4Mobility - The FCC Spectrum Policy Task Force Report - 12 November 2002

From: Marcel <[email-masked]>
Date: Tue, 12 Nov 2002 20:20:06 -0500

The FCC Spectrum Policy Task Force Report

I have a sinking feeling in my stomach. I have read the press releases concerning the U.S.
FCC Spectrum Policy Task Force and I can't help but think that there could be some real
problems ahead for all who rely on wireless communications. The press releases are full of
statements such as "After finding that some U.S. spectrum bands are heavily used, while
others are used little or not at all, the task force determined that considering time, in
addition to frequency, power and space, would lead to more efficient use of the spectrum
resource." "The task force also recommended the creation of a quantitative standard for
acceptable interference that would provide both greater certainty for licensees and
greater access for specific uses." "FCC policy should be flexible enough so that companies
could be free to use the spectrum in response to new technologies and customer
demographics," and "Our policies must focus on what consumers want and what technology can
delivernot on old models of command and control regulatory intervention."

Why does this concern me? It takes me back to my days as a Motorola employee handling the
County of Los Angeles account. I worked with the LA County Communications department, the
Sheriff's Department and the Fire Department. The two emergency services agencies had more
than 4,000 mobile radios, 2,500 handhelds and 78 radio towers to cover the County.

During my tenure with Motorola I was involved with the County in trying to obtain
additional radio channels for both departments. The FCC came to town to listen to the
channels that were already in use to determine whether they were being used effectively.
The FCC monitoring indicated that the Sheriff's Department was only handling about 60
instead of the recommended 100 vehicles per channel, and that the Fire Department's
channels were lightly used.

These "findings" were based on a single FCC monitoring point set up for a few hours a day
at various locations within the County. No FCC personnel visited either dispatch center,
nor did they monitor the channels on a Friday or Saturday night. They based their channel
loading on mid-day, week-day activity--Federal employees don't work on weekends or
holidays. (On the fourth of July in LA County it is not unusual for a paramedic rescue
squad to be re-routed three or four times, and most of the squads never even made it back
to their fire stations during their shift.)

It was no big surprise when recommendations were published: Both agencies had enough
channels to handle their operations and the FCC did not see any need for LA County to be
given the new channels it had requested. After a more than three year battle with the FCC,
LA County (and the City of LA) did prevail and additional spectrum was assigned to them. I
fear that similar situations with the new policy.

Anyone listening to police channels for San Jose, Santa Cruz and San Francisco during the
day will come to the conclusion that these channels are lightly used. There are periods of
quiet with no dispatches, no activity. The same goes for the fire, PG&E and amateur radio
channels. I hope that when the new policies are drawn up it is understood spectrum usage
cannot be based on "normal" operations. There must be sufficient spectrum to handle peak
periods of activity and major disasters.

In 1989 when the Loma Prieta earthquake hit our area, police and fire systems were
overburdened. Amateur radio operators were called in to take some of the traffic off of
the emergency channels. Ham radio operators are also used to move traffic off fire
channels and to provide coordination between agencies that are not able to communicate
directly with each other.

I am concerned that people who have not experienced radio congestion during times of major
events and/or disasters will be making decisions based on their perceptions of "normal"
wireless communications usage. Wireless systems are designed and built for times when
channel loading is heavy. How do you figure the "time" factor in evaluating spectrum
usage? An air conditioning contractor uses his radio channel only lightly during the
winter but come the first major heat wave he needs it clear and available.

Railroads have a lot a spectrum that is "lightly" used to send and receive data as well as
voice traffic. Some of this data controls the signals that keep trains from crashing into
each other and some data tracks the locations of trains. The military has a LOT of
spectrum that is hardly used. I have listened to military channels for a long time in this
area and never heard any traffic. Should channels be taken from these groups and assigned
to a plumber for his fleet of trucks on a secondary basis?

Lots of folks will be putting in their two cents as this new FCC spectrum policy unfolds
and the FCC will have its job cut out for it. Everyone feels that their use of the
airwaves should be given more consideration than others. I wouldn't want the job of
resolving all of the issues that need to be addressed as we move forward.

I am concerned that the people who will be working on this new spectrum policy have never
ridden in a police car on a Friday night, have never been in a paramedic rescue unit on a
Saturday night and have never listened to the electric companies' radio channels during a
major storm. Will these folks understand how important it is to have reliable
communications in times of emergencies and that communications can be the difference
between life and death?

                                     Andrew M. Seybold