DRAFT. Before the FEDERAL COMMUNICATIONS COMMISSION. Washington, D.C ) ) ) ) ) ) ) ) ) Reply Comments of the

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1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C In the Matter of Unlicensed Operation in the TV Broadcast Bands Additional Spectrum for Unlicensed Devices Below 900 MHz and in the 3 GHz Band ET Docket No ET Docket No Reply Comments of the National Public Safety Telecommunications Council I. INTRODUCTION 1. The National Public Safety Telecommunications Council (NPSTC submits the following comments in response to the Commission s Notice of Proposed Rule Making (NPRM, ET (FCC , in the above-captioned proceeding. 2. With over 74,000 public safety organizations in the United States, it is critical to have a resource and an advocate for public safety telecommunications. That is the primary role of the National Public Safety Telecommunications Council. NPSTC is a federation of public safety associations that encourage and facilitate, through a collective voice, the implementation of Public Safety Wireless Advisory Committee (PSWAC and 700 MHz Public Safety National Coordination Committee (NCC recommendations. NPSTC 1

2 II. DRAFT explores emerging public safety telecommunications issues and technologies, and develops recommendations to appropriate governmental bodies to support the broad goals of promoting public safety telecommunications worldwide. Finally, NPSTC serves as a standing forum for the exchange of ideas and information regarding public safety telecommunications. NPSTC currently consists of the following thirteen organizations 1 : American Association of State Highway and Transportation Officials American Radio Relay League American Red Cross Association of Public-Safety Communications Officials-International Forestry Conservation Communications Association International Association of Chiefs of Police International Association of Emergency Managers International Association of Fire Chiefs International Association of Fish and Wildlife Agencies International Municipal Signal Association National Association of State Emergency Medical Services Directors National Association of State Telecommunications Directors National Association of State Foresters. PUBLIC SAFETY COMMUNICATIONS IN THE UHF-T BAND MUST BE PROTECTED FROM INTERFERENCE 3. While NPSTC is pleased to see the Commission promote more efficient use of unused TV channels, a few points in this proceeding give us cause for concern. We do not feel the protection afforded to land mobile radio (LMR users in the UHF-T band which is used by public safety for critical communications in a number of metropolitan areas throughout the country will be sufficient to prevent the occurrence of harmful interference. Metropolitan areas such as Los Angeles and New York City operate radio systems on TV channel NPSTC believes the only means by which unlicensed 1 A number of Federal agencies are affiliate members of NPSTC and active participants in its ongoing efforts. These include the Department of Agriculture, Department of Homeland Security (SAFECOM Program and Federal Emergency Management Agency, and Department of the Interior. 2 ET , MB , FCC 04-80, paragraph F. Amendments to Parts 2, 73, 74, and 90 of our Rules, page 10: (2 The use of the band MHz (TV channel 16 is limited to eligibles in the Public Safety Radio Pool in or near (i the Los Angeles 2

3 devices could be considered is if a new protection criterion were developed to compensate for increased spectrum usage resulting from both mobile and stationary unlicensed devices operating on co-channel assignments in the UHF T-Band. We question the effectiveness of the existing rules to protect public safety operations and believe more study is necessary before enacting the proposed rule. 4. The Association for Maximum Service Television (AMSTV in their June 21 request for clarification brought a number of important issues up that were not addressed to the level of detail a NPRM would require. Strictly speaking they were correct in their assertion that the NPRM did not specify maximum or minimum bandwidth, type of allowed modulation, number of concurrent channels to be used, or channelization for unlicensed devices 3. The MSTV is also correct in stating the need for clarification of what is deemed as other appropriate models when calculating the undesired unlicensed signal levels. We also believe the confusion over use of antenna height and height above average terrain (HAAT in calculating FCC (50, 50 must be clarified. If not resolved, these omissions individually or cumulatively could result in harmful interference not only to broadcasters but to licensed public safety services operating in the UHF-T band. Due to the critical nature of public safety communications we respectfully ask the Commission to provide clarification on the on this mater to protect licensed services and for the public good. 5. NPSTC agrees with the comments of Motorola submitted on July 21, 2004 asking the Commission not allow unlicensed devices to operate on TV channels which urbanized area; and (ii New York City; Nassau, Suffolk, and Westchester Counties in New York State; and Bergen County, New Jersey. 3 Association for Maximum Service Television (MSTV, June 21 filing pages 3, and

4 provide critical support to public safety communications in the UHF-T band 4. NPSTC also agrees with Motorola in questioning spectrum availability in major urban areas to support unlicensed devices channels NPSTC respectfully urges the Commission to prohibit the use of unlicensed devices on channels on the national level. III. THE COMMISSION MUST EMPLOY RULES TO ENSURE INTERFERENCE-FREE OPERATIONS TO USERS AND INCOMBANTS 6. NPSTC believes the Commission must include safeguards in the rules governing the deployment of unlicensed devices to prevent harmful interference to licensed services. If this is not accomplished we fear this plan will be unsuccessful. Matters involving shared operation as secondary users have never been attempted in such a grand scale. We urge the Commission to proceed cautiously since this initiative shows great promise to provide access to spectrum for many parties. We have a golden opportunity before stemming from the common goal of mitigating interference to see exciting technologies developed to make this plan come to fruition. 7. Within the aforementioned proceeding the Commission sought comment on the most efficient and effective method to control unlicensed devices 6. We have seen a number of good ideas presented that should be studied. One means is the use of transmitter power control (TPC 7. Transmitter output power should be regulated to what is ever necessary to close a radio link while still maintaining some grade of service (GoS. TPC will foster increased frequency reuse, and provide more use of spectrum of the airwaves and result 4 Motorola filing of July 21, 2004 page 8. 5 Ibid. page 8. 6 ET , Paragraph 24, page Ibid, Paragraph 27, page 14. 4

5 in less interference. NPSTC believes TPC should be incorporated in all equipment operating on vacant TV channels under this order and the rules originating therein. 8. The Commission considered the use of a control channel or beacon as a method for granting access to unused TV channels. The use of a beacon signal as a means to control unlicensed devices seems to be a simple and effective technique to deploy. NPSTC feels that global positioning system (GPS technology can compliment the control channel. GPS augmentation can be used to disable a device that travels beyond some designated operating range. The GPS could act as a fail safe means to shut down devices that have become errant. IV. THE RULES FOR UNLICENSED DEVICES USING VACANT TV CHANNELS MUST INCORPORATE SECURITY TO PREVENT HARMFUL INTERFERENCE 9. NPSTC applauds the Commission for taking up the issue of security for unlicensed devices on vacant TV channels. In addition NPSTC agrees with the Commission s proposal to not allow any party but a professional installer from making transmit channel or output power adjustments. NPSTC also concurs with the Commission requiring manufactures to take steps to ensure that only the software approved with a device can be loaded into a device, and prohibit a user from operating a device outside of approved parameters. NPSTC agrees with the use of proposed anti-tamper measures to prevent a device from operating. Lastly, NPSTC agrees that manufactures should be required to detail a device s security features in the application for equipment authorization. 5

6 V. THE COMMISSION SHOULD PROMOTE VOLUNTARY STANDARDS TO FACILITATE INTEROPERABILTY FOR PUBLIC SAFETY 10. One of the Commission sought comment was if there is a need for voluntary standards to facilitate sharing between unlicensed users in the TV bands 8. NPSTC feels that voluntary standards will be most beneficial to public safety. NPSTC believes standards based solutions will spur the public safety market place to develop technologies that will provide greater interoperability and competitive prices on products. Competition will also provide cost effective solutions over proprietary devices for capital starved public safety agencies. 11. NPSTC believes a partnership between industry and standards bodies is the best way to ensure innovation. The Commission should be involved as an advisor to facilitate ease of navigating through bureaucratic obstacles to getting products to the market place. The Commission can also play a beneficial role in guaranteeing that products will not be put into the field that are capable of producing harmful interference. VI. CONCLUSION 12. NPSTC commends the Commission for taking bold steps in advancing new technologies that promise to provide public safety with greater operational capabilities, facilitate interoperability in fighting crime, and protecting homeland security. The increased coverage afforded by the lower frequencies used by TV channels over typical wireless network devices in the microwave bands is far superior. Foliage penetration performance of lower frequencies will be beneficial to search and rescue (SAR teams. However, we must temper our exuberance since at the same time we feel the issue of interference protection must be ensured to provide protection to incumbent public safety service 6

7 sharing some of the same bands. We believe the measure of success by which this proceeding will be judged hinges upon the degree to which the rights of licensees are protected from harmful interference. NPSTC respectfully urges the Commission to prudently approach the deployment of unlicensed devices in vacant TV channels. Respectfully Submitted, NPSTC [INSERT WHO, WHAT, etc.] July 22, Ibid Paragraph 47, page 22. 7