Subject: [NEXTEL-1] 450 MHz Refarming Logistics

From: [email-masked]
Date: Fri, 21 Nov 2003 09:22:45 -0500

-------- Original Message --------
From: "Dennis Kline" <[email-masked]>
Subject: 450 MHz Refarming Logistics

Has anyone seen anything official from the FCC on the mechanics of re-
licensing an existing station to comply with 450 MHz refarming ?

Under normal circumstances, a station modification would be 
submitted, which would include frequency re-coordination.  If we have 
to re-coordinate every existing license that is migrating from 
wideband to narrow band, there is going to be a big back log with the 
coordinators as well as the FCC, not to mention the coordination 
costs involved.

I have not seen anything from the FCC on how they intend to handle 
this migration.  Anyone else heard anything?

Dennis

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---

From: [email-masked]
Date: Fri, 21 Nov 2003 09:26:02 -0500

-------- Original Message --------
From: [email-masked]
Subject: Re: 450 MHz Refarming Logistics

There is no requirement that existing licensees with 25 kHz licenses 
"skinny-up" until 2008 for non-public safety, and 2013 for public safety.  Thus,
as 
licensees begin using narrowband equipment, they can make their licensing 
changes as those "upgrades" (I use that word sarcastically) happen.  Therefore,
we 
don't expect to see some massive backlog of these types of applications.

In contrast, those wishing to file applications for new or significantly 
modified wideband authorization need to get their applications in as soon as 
possible, well ahead of the January 17, 2004 deadline, in order to give 
coordinators as much time as possible to process those applications.  This will
be a more 
significant problem on the public safety side, where coordinators already 
take a very long time to coordinate applications, but less so on the non-public 
safety side, where coordinators presently are pretty current.  This presumes, 
of course, that the FCC elects not to extend that deadline.

Alan S. Tilles, Esquire
Shulman, Rogers, Gandal, Pordy & Ecker, P.A.
11921 Rockville Pike, Third Floor
Rockville, Maryland 20852
www.shulmanrogers.com

In a message dated 11/21/2003 8:58:29 AM Eastern Standard Time, 
[email-masked] writes:
Has anyone seen anything official from the FCC on the mechanics of re-
licensing an existing station to comply with 450 MHz refarming ?

---

From: [email-masked]
Date: Fri, 21 Nov 2003 15:05:05 -0500

-------- Original Message --------
From: [email-masked]
Subject: Re:  450 MHz Refarming Logistics

As much as the desire was there, it just wasn't practical with the existing 
high power channels because of the patchwork of incumbancy.  It would have been 
a nightmare to move people around and around and around.  Would have been a 
beautiful thing if we were dealing with virgin spectrum, but with hundreds of 
users on every frequency everywhere, it wasn't realistic.

In contrast, we tried to do that on the former offset frequencies when the 
rules were changed.  Specifically, we tried to set aside a group of channels 
for: (1) high power (i.e. wide area operation); (2) "middle power" (20 watts ERP 
for campus-type use); (3) low power (6 watt ERP) non-voice systems; and (4) 
itinerant use.  While it took a while (is that redundant?) to get that in place, 
that finally became a reality in March of this year.  Of course, the true 
benefits of that won't happen until (and unless) the requirement for all 
licensees to go to 12.5 (other than paging) happens.

Alan

In a message dated 11/21/2003 2:25:09 PM Eastern Standard Time, 
[email-masked] writes:
It is a shame the FCC is not recognizing the efficiencies that are/could be
gained below 512 mHz with trunking.

I do not understand why the 450 band could not be segregated with a portion
for job site and plant systems, and the rest for UHF trunking, on an
exclusive basis, yielding the same benefits as at 800 mHz.

The industry has not done a very good job of promoting to the FCC the use
of trunking at 450 mHz, and as a result the band is a dumping ground for
incompatible users.

Rik Rasmussen

---

From: [email-masked]
Date: Fri, 21 Nov 2003 14:54:40 -0500

-------- Original Message --------
From: [email-masked]
Subject: Re:  450 MHz Refarming Logistics

You just don't ask the right people, Todd.  On February 25, 2003, the FCC's 
narrowbanding order said as reprinted below.

Alan

"First, we note that there is a consensus among the commenters, including 
AMTA, that any change in spectrum efficiency requirements should be limited to 
frequency bands below 800 MHz, i.e., “refarmed” bands.  We agree.  The
“refarmed
” bands at 150-174 MHz and 421-512 MHz are licensed on a shared basis.  By 
contrast,  the 800 MHz and 900 MHz bands are licensed on an exclusive basis.  A 
licensee operating in a shared use environment does not necessarily directly 
accrue the benefits of its own investment in narrowband technology.  Even if 
that licensee chooses more efficient equipment, other users in the band may not. 
 Moreover, any spectrum efficiency gains may be realized by others sharing 
the spectrum, or by new applicants who gain access to the shared spectrum, 
rather than by the licensee choosing to use more efficient technology.  Such 
dependency and resulting investment disincentives for any licensee to become
more 
efficient are not manifest in the bands above 800 MHz where channels are 
exclusive, rather than shared.  The current certification rules apply to use of 
channels in the 150-174 MHz and 421-512 MHz bands and do not extend to channels 
above 512 MHz.  As the Commission indicated in the Refarming NOI, the rules 
governing spectrum above 800 MHz already contain incentives designed to foster
the 
research and development of advanced, spectrum-efficient techniques.  For 
example, PCIA contends that trunked 800 MHz operations already efficiently use 
spectrum.  In that connection, we note that the Refarming NOI cites trunking as 
an efficiency that is encouraged in the 800 MHz band.  Additionally, there are 
regulatory and operational distinctions between operations above 800 MHz band 
and those below 800 MHz band.43  For example, licensees in 800 MHz and 900 MHz 
bands are permitted to utilize non-standard bandwidths, subject to 
interference standards.  We agree with these commenters and the reasons offered
above 
for excluding operations above 512 MHz, and will limit any new requirements to 
operations in the Refarming bands -- 150-174 MHz and 421-512 MHz."

In a message dated 11/21/2003 12:01:05 PM Eastern Standard Time, 
[email-masked] writes:
Jim:

I asked that question at the infamous summit meeting in Baltimore, Feb 19th,
2002.  I got 80 blank looks.

Todd Ellis

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:52:14 -0500

-------- Original Message --------
From: "[email-masked]" <[email-masked]>
Subject: Re:  450 MHz Refarming Logistics

Low band suffers from the "skip" problem. In sun spot peak activity years,
local systems can be rendered almost useless because of signals propogating
in from thousands of miles away. I would think low band might make a good
place to put scada and other short burst type communications that could
resend the data when conditions require. Any use of live voice, analaog or
digital, on low band will suffer from "network Congestion" during periods
of interference.

As far as VHF (high band 150 -160) goes, the ability to use this band
effectively for exclusive trunking is weak due to the longer propagation
making system spacing so great that frequency re-use is not as efficient as
at UHF. In our on location here in Durham, NC our old VHF fire frequency
(only used for paging volunteers since we moved comms to 800) is blown away
some days by signals from as far away as Norfolk, Va.

Realigning bands is not new to the FCC. The 220 band has been aligned, also
the process currently underway with UHF TV is an example.

The proposal now being considered for 800 MHz is similar to what I believe
should be done at UHF.

One problem at UHF will be the need for stepped up enforcement due to the
proliferation of unlicensed equipment.

UHF Trunking is the only decent alternative to CMRS left. In its current
condition it is not a good investment for a sysytem operator due to
difficulty obtaining exclusive frequencies.

Rik Rasmussen

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:52:46 -0500

-------- Original Message --------
From: [email-masked]
Subject: Re: 450 MHz Refarming Logistics

In a message dated 11/24/2003 9:03:12 AM Eastern Standard Time, 
[email-masked] writes:
The proposal now being considered for 800 MHz is similar to what I believe
should be done at UHF.
As much as I would love this, I just don't see how it's practical, given the 
sheer number of licensees, most of whom haven't a clue about the FCC or the 
process.  It makes 800 MHz look like a cakewalk.  We've got enough problems just 
getting people to go 12.5 kHz at UHF (the PS folks want to wait until each 
and every one of them is retired).  Heck, we started the proceeding 13 years 
ago, and we're STILL not done!  I also agree on stepped up enforcement in the 
band, and the audit was helpful in recovering a lot of licenses.  That is 
probably a more realistic goal.

Alan

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:54:37 -0500

-------- Original Message --------
From: "[email-masked]" <[email-masked]>
Subject: Re: 450 MHz Refarming Logistics

This will sound crazy to many I know even before I finish typing my
thoughts.

In the amateur service, the FCC recognizes local coordinating groups to
coordinate and arbitrate frequencies for repeaters.

In Public Safety 700 and 800 Mhz local committees have established
frequency use plans.

I believe the industry could establish local groups who would be familiar
with local users and would then provide pre-coordination recommendations
for the "official" coordinators.

The local volunteer coordinators could provide a level of user education,
and arbitration. Over time, campus, site and plant systems would be
migrated to a segment set aside for their use. Then existing trunked and
shared systems would be realigned over a period of time so as to not place
a financial hardship on small operators.

Just as the HF marine bands migrated from a.m. to s.s.b. years ago, we
could eventually make the UHF band a useful spectrum resource.

Or, we could leave it like it is, assuring more users become frustrated and
migrate to CMRS systems. (Maybe that IS the current plan.)

Rik Rasmussen

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:53:56 -0500

-------- Original Message --------
From: "Maples, Dave" <[email-masked]>
Subject: RE:  450 MHz Refarming Logistics

Rik: The comments on VHF low and high are good, but I wonder the following:

a. Do the increased efficiencies from trunking offset the longer spacing for
frequency reuse at VHF highband, particularly in the Midwestern states where the
population density is very low?  The question assumes we are using trunking
technologies woven around FM or P25 at most...nothing more sophisticated.
 
b. Does packetized voice make lowband more useful?  Would frequency-hopping or
ALE make it more useful?  Would combining packetization with hopping or ALE make
it more useful still?
 
c. Would similar technologies make VHF highband more useful, e.g. allow shorter
spacings?

Just some thoughts, for what they are worth, but as Jack often says, I could
definitely be wrong here.
 
Dave Maples

-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Monday, November 24, 2003 9:01 AM
Subject: Re:  450 MHz Refarming Logistics

Rik Rasmussen

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:55:28 -0500

-------- Original Message --------
From: "[email-masked]" <[email-masked]>
Subject: RE:  450 MHz Refarming Logistics

a. Local pre-coordination committes could decide that local conditions make
VHF a better choice for an applicant than UHF and could recommend a
coordination approval. I agree that is some areas VHF is a better choice.

b. Digitized and packeted voice is still live and if you have tried
streaming radio stations on the internet you have probably seen how network
congestion can put holes in the audio. They use UDP and don't recover the
missing holes because of trying keep up with the stream. Low band would be
much worse. However, low band might be a good place to put all those
surveyors and golf courses and their GPS transmitters.

c. VHF will benefit from the move to narrow band and it would be great if
these recoordinations could focus on a repeater band plan and include a
plan for simplex systems.

Rik Rasmussen

---

From: [email-masked]
Date: Mon, 24 Nov 2003 11:36:41 -0500

-------- Original Message --------
From: "Maples, Dave" <[email-masked]>
Subject: RE:  450 MHz Refarming Logistics

Rik: I couldn't agree more.  
 
I'd also extend that thinking to VHF highband.  It seems to me that if the
nonsensical frequency allocation at highband were adjusted to something more
modern the industry as a whole could reap some significant benefits.
 
The planning at highband was done in the days when receivers couldn't tune more
than a little bit at best because the old Sensicon A strip pipes had to be
tweaked, and the PAs had to be dipped and peaked in order not to toast the final
PA tubes.  Not applicable now...most modern equipment can tune at least from
150-162 MHz without a major effort, and I can imagine that if the band were
rationalized the antenna mfrs would come up with a tradeoff to allow the
antennas to tune over that range with minimal difficulty (pay a 1 to 1.5 dB loss
in efficiency in return for fairly low SWR across the band for mobile
antennas).  
 
If we add to this the possible reclaiming of licenses currently held but not in
use, I wonder how much spectrum we could free up at highband?  Much?  A little? 
Would it be enough?
 
The costs of rearrangement and reclamation would be significant, but in the end
I think it would be worth it to the industry and to the public.  It doesn't
serve anyone's interests for the spectrum to be as confused as it is.  Perhaps
if someone laid out a business case for this and showed it to the FCC, they'd
get interested.
 
A side note: What about lowband?  Nobody is ever going to want it for portables,
because antennas are completely inefficient, but what kind of mobile and fixed
services could be accomodated on lowband channels that are licensed but haven't
been used in years because folks just didn't want to bother any more?  Here's an
interesting thought: Use lowband channels to interconnect highband trunking
sites.  The interconnects could be digitized (if I could run 8 TDMA slots in a
50 kHz channel and retain good fidelity, how's that for efficiency?).  Whale of
a lot cheaper than microwave, methinks, especially out in the boonies.
 
Maybe none of my ideas make sense, but I sure think that Rik's plan is the way
to proceed.  
 
Dave Maples

---

From: [email-masked]
Date: Mon, 24 Nov 2003 17:23:36 -0500

-------- Original Message --------
From: "Rik Rasmussen" <[email-masked]>
Subject: RE: 450 MHz Refarming Logistics

My comment was actually meant to be more aimed at the issue of promotoing
trunking at UHF. That is where the industry has not well represented itself.
Trunking has been shown to use spectrum efficiently. The fact that there is
no focus on making it more possible to implement is I believe more a
reflection of the low cost of licensing and coordination.

One day, a Senator is going to ask the chairman to focus on squeezing
revenue from this spectrum, and then it will all be over for private LMR.

While it has technically been allowed, the management of the UHF spectrum
has made the reality of UHF trunking all but impossible in many areas.

Much spectrum is being wasted because of fast food drive up windows,
portables in retail locations, radios is plants and job sites, all tying up
frequencies that, if efficiently coordinated and licensed, would allow many
users to receive excellent service in the form of UHF trunking.

I remember the days and issues of the past that you mention, but I believe
the pendelum has swung too far in the other direction. No one is looking at
the overall use of the UHF spectrum and seeing that those licensed on many
frequencies could often be sharing frequencies in a small portion of the
band with each other peacfully on small site systems, leaving the rest of
the band for the wide area systems.

It is discouraging when a coordinator drops a mall security on top of a
system serving many users over a wide area. Just because it fits on paper,
doesn't mean it works out here in the real world.

FIT has a good reputation, but anyone who has been in this business for a
few years knows the horror stories that have been created by some
coordinators. PCIA almost single handedly brought the LMR industry to an end
with poor coordinations. I see they are now focused on wrecking the tower
industry.

Rik Rasmussen

-----Original Message-----
From: Kenton E. Sturdevant [mailto:[email-masked]]
Sent: Monday, November 24, 2003 3:33 PM
Subject: Re:  450 MHz Refarming Logistics

"hrasmussen@n..."
<hrasmussen@n...> wrote:
SNIP--- "I am also dismayed that the groups that claim to represent
the
industry have not put more focus on this issue. Again, I think it is
because they see so little $$ in it."

Rik Rasmussen
----------------
Rick.

Actually, the industry groups have tried this.  Forgive me if I get my
dates wrong but up until about 12-15 years ago Both MRFAC and UTC had
exactly what you are talking about, volunteer regional coordinators.
I can't speak to the economics of their having either single or
multiple coordinators, but logistically it was often a nightmare when
we other coordinators had to seek concurrences from multiple
regional/state/local coordinators in various services (radio signals
don't know political/geoigraphic borders.)  The FCC passed the
"coordinators" docket and insisted each coordinator have a "single
point of contact."  APCO took this to mean everything filter through
their offices but keep the regional advisors, the affected industrial
coordinators dropped their regional offices.  Refarming also placed
additional burdens on coordinators that just seem to be best handled
by having a central point for cordination.  And, yes, much of it has
to do with the cost of running a coordination orginization.

Considering the current discussion: FIT is always willing to listen
and consider the local shop/dealer/vendor input on what they feel is
the best available channel for their client.  We always have.  We
really appreciate that discussion and input and make the best attempt
to go along with the recommendation, however in a lot of cases, the
vendor was unaware of the some specific rule or another, or a pending
new co or adjacent channel applicant that blew the oportunity.  But, I
would rather have that information from you and hold those discussions
than to ignore what you feel is best for your customer.

Kenton

Forest Industries Telecommunications