FCC agenda out of sync with market

Lynchburg, Virginia

Dear Ted,
[Chairman Ted Dempsey
Implementation subcommittee, NCC]

After attending the recent Motorola consultant seminar, which you also attended, I then attended the APCO National Homeland Security seminar in Washington, D.C. I have come to the realization that what is going on in Docket 96-86 and the National Coordinating Committee is not meeting the national need. Things have changed and the FCC needs to recognize this and change course on the 700MHz band spectrum to support Homeland Security.

As things are and might be:

As you and I both learned at the same time, the APCO P25 standard is not a standard at all in the normal context. It is a vendor contracting infrastructure document. This arises out of the vendor option for three feature sets: mandatory, optional and value added. What this means is that the subscriber manufacturers are at the mercy of the infrastructure supplier. At this time one — Motorola.

Two other defects existing at this time are. First — the lack of console interface documents; thus console suppliers are locked and at the mercy of the infrastructure supplier. Second — there are no inter-system documents so that two adjacent systems have no assurance of being connected on an open standards basis.

The funding at the federal level is being directed toward APCO P25 systems directly. Redoing what was done in the past with fixed location frequencies with the results of the above is that what is evolving is an uncontrolled, unregulated monopoly, and hence what we are seeing is the APCO P25 system costs 22 percent to 55 percent above other comparable systems.

What then does the nation need?

The nation needs:

• The ability to float frequencies where they are needed (like cellular, PCS and Nextel).

• The separation of government infrastructure control from vendors to users.

• The ability to transport subscriber units nationwide, like cellular, PCS, and Nextel.

• Critical communications infrastructure not being used as a pawn in the political process.

• A purchasing/user organization on parity with vendors in technical management and control.

Reality:

• The national government networks are dynamic in evolution, implementation, and operation.

• Networking [interoperability] cannot be achieved by the way things were done in the past.

• Networking [interoperability] cannot be achieved utilizing static industry standards that take years if not decades to develop.

The solution:

• The frequency and infrastructure [not subscribers] needs to be under the auspice of national/regional structuring.

With my new enlightenment and the changes as a result of the events of Sept. 11, I cannot support the fixed static regional planning process.

A new and different methodology regulatory structure must be found for the good of the nation.
Frederick G. Griffin, P.E.
President

A rebuttal

Albany, New York

I am dismayed that your transmittal to “the world” contains sweeping generalities and only a few crumbs of factual information. I am sure that many would take issue with your broad stroke statements about what cannot be done for Interoperability on a nationwide basis.

It is true that the Console Interface and the Inter-RF SubSystem Interface (ISSI) are still works in progress. And, although you didn’t mention it, the Fixed Station Interface is also a work in progress. It may be relevant to understand that the direction of those standards development efforts was changed recently to become Internet Protocol based, which offers the potential for a more flexible, efficient, and robust network design.

You draw a broad brush picture of the Project 25 standards — as you refer to them. In point of fact, Project 25 is based on a definition of user needs embodied in a Statement of Requirements (SOR) document, which serves as the basis for the standards development effort of the Telecommunications Industry Association’s TR-8 Engineering Committee.

The SOR was developed from input by representatives of local, state and federal public safety entities. The resulting standards that have been developed follow an American National Standards Institute process and ultimately become ANSI standards.

The standards that have been incorporated in the 700 MHz rules of the FCC (47 CFR §90.548 and §90.553) for Interoperability are in fact ANSI standards. These required Standards for Interoperability define the most basic mode of operation — conventional common air interface, as opposed to trunked FDMA or TDMA, and include clear and encrypted voice, and data communication.

Numerous manufacturers offer products that meet these requirements in one or more frequency bands. Some offer subscriber equipment, some also offer fixed stations, and others offer complete systems. In some cases, proprietary equipment is offered for complete systems, which includes the capability to support the FCC required Interoperability Standards.

Technology is evolving at such a rapid pace, that one must realize it is essential to have some baseline common mode of digital communication for communication interoperability to take place at all. Under such circumstances, the traditional requirement for a Public Safety system requiring a “mature technology/product” is no longer feasible. A mature technology or product is an obsolete technology or product in these times. The best we can hope for is to have a uniform method of communication that we can automatically fall back to when we need Interoperability between disparate systems. We have that in the present FCC rules cited above.

With regard to Regional Planning, this system of local involvement in the planning process allows for the types of variation that are appropriate and desired by the Public Safety entities within their Region. The State Interoperability Executive Committees (SIECs) were formulated to provide a level of uniformity for plan development, operation and administration of Interoperability on a statewide basis. The suggestion has been put forward to allow the SIECs to have jurisdiction over all FCC-designated Interoperability channels. And, while the FC has not yet acted favorably on the NCC recommendation for uniform nomenclature to describe the FCC-designated Interoperability Channels, it is possible that the SIECs could each require such uniform nomenclature within their Statewide Interoperability Plans. It is unclear why the FCC is inconsistent in this matter, since they have no problem specifying uniform nomenclature for the Emergency Medical Service UHF “MED” channels in 47 CFR §90.20(d)(66)(i).

Clearly, the U.S. Department of Homeland Security should be an active participant in each of the 50 SIECs, and this will go a long way toward solving your perceived Interoperability concerns.

If your letter to the FCC, FTC and others was intended for the Federal marketplace, was it really appropriate to send this to the FCC and the NCC, which do not have jurisdiction over Federal radio communication matters?

I am sorry that I am not able to attend the NCC meetings this week, as I am sure this correspondence deserves significant discussion to bring out the issues with accuracy, clarity and specificity. Hopefully some of the issues I have addressed above will add to the enlightenment.
Robert F. Schlieman
Member of NCC
APCO Project 25 Steering Committee
Regional Planning Committees — 8, 30 and 55

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