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FRIDAY - FEBRUARY 10, 2006 - ISSUE NO. 199

Dear friends of Wireless Messaging,

Finally . . . we got noticed. The FCC has published my most recent comments to the Hurricane Katrina Independent Panel, on their web site—here: http://www.fcc.gov/eb/hkip/PubCom/bdye.pdf

The FCC has issued a PUBLIC NOTICE that I have reproduced on page two of this issue:

“NOTICE OF PROCEDURES FOR APPLYING TO MAKE ORAL PRESENTATIONS AT THE NEXT MEETING OF THE FEDERAL COMMUNICATIONS COMMISSION’S INDEPENDENT PANEL REVIEWING THE IMPACT OF HURRICANE KATRINA ON COMMUNICATIONS NETWORKS”

Interested persons who wish to provide oral presentations at the Independent Panel’s next meeting should submit a request. . . Requests must be received by the Designated Federal Officer no later than February 17, 2006.

Please see page two for the details of how to request five or ten minutes of time to make a presentation during the Panel's next meeting.

THE END OF AN ERA
Western Union discontinued all Telegram services last month. More details on page two. While I imagine there is a compelling business case to do so, never-the-less, it is sad. I get my hair cut in the same office here is this little town where the Western Union telegraph office used to be. I learned the Morse code myself here over fifty years ago. Early telegraph operators used the American Morse Code, while radio operators used the International Morse Code. They are quire different.

The photo below shows the type of device that I used to learn to send the Morse code. I was never very proficient at sending, but I could receive the code at 30 words per minute. That qualified me for second chair in my Navy radio school class. The guy in the first chair (KØLUZ) was twice as fast as I was. He was a musician from Iowa and sounded like a Teletype machine when he sent the code. Although I graduated with high honors, my buddy Joe Norris, who today is chief engineer at radio station WMUU in Greenville, SC, beat me academically by getting the highest score that anyone had ever obtained all the way back to World War II. It seems like yesterday, but it was 45 years ago.

Did you know that a good Morse code operator can recognize someone by just listening to the code the same way you would recognize the voice of someone you know?

morse code key

During the years between WW I and the Korean War the US Army Signal Corps designated many of their telegraph (or Morse code) keys with a "J" prefix followed by a number. The known numbers range from J-1 to J-51. All of these keys are considered collectible, and many of the WW II models are still in everyday use by Amateur Radio (Ham) Operators. One of the most popular of the "J" keys is the J-38. (above) [source]

morse
Samuel F. B. Morse

The message, "What hath God wrought?" sent later by "Morse Code" from the old Supreme Court chamber in the United States Capitol to his partner in Baltimore, officially opened the completed line of May 24, 1844. Morse allowed Annie Ellsworth, the young daughter of a friend, to choose the words of the message, and she selected a verse from Numbers XXIII, 23: "What hath God wrought?", which was recorded onto paper tape. Morse's early system produced a paper copy with raised dots and dashes, which were translated later by an operator. [source]

morse keyWell, please excuse me for reminiscing, but radio communications was my favorite thing until I discovered girls.

This big item this week (in both senses of the word "big" e.g. large and important) is the official USA Mobility document filed at the FCC two weeks ago, commenting on the FCC's plans to modernize the Emergency Alert System (EAS). Let's hope that this—coming from the company that has approximately 60% of the total US subscriber paging market—gains some traction. Remember there are two separate issues at the FCC that we are concerned with right now—EAS and the Hurricane Katrina Independent Panel. Be sure to read the USA Mobility comments that follow.

Oh yes . . . and please don't miss this special recognition of WaveWare Technologies in the column to your right. right arrow

Now on to more news and views.

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Wireless Messaging Newsletter
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  • Wi-Fi
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  • Wi-MAX
  • Telemetry
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WIRELESS
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MESSAGING

This is my weekly newsletter about Wireless Messaging. You are receiving this because you have either communicated with me in the past about a wireless topic, or your address was included in another e-mail that I received on the same subject. This is not a SPAM. If you have received this message in error, or you are not interested in these topics, please click here, then click on "send" and you will be promptly removed from the mailing list with my apology.

iland internet sulutions This newsletter is brought to you by the generous support of our advertisers and the courtesy of iland Internet Solutions Corporation. For more information about the web-hosting services available from iland Internet Solutions Corporation, please click on their logo to the left.

A new issue of The Wireless Messaging Newsletter gets posted on the web each week. A notification goes out by e-mail to subscribers on most Fridays around noon central US time. The notification message has a link to the actual newsletter on the Internet. That way it doesn't fill up your incoming e-mail account.

There is no charge for subscription and there are no membership restrictions. Readers are a very select group of wireless industry professionals, and include the senior managers of many of the world's major Paging and Wireless Data companies. There is an even mix of operations managers, marketing people, and engineers—so I try to include items of interest to all three groups. It's all about staying up-to-date with business trends and technology. I regularly get reader's comments, so this newsletter has become a community forum for the Paging, and Wireless Data communities. You are welcome to contribute your ideas and opinions. Unless otherwise requested, all correspondence addressed to me is subject to publication in the newsletter and on my web site. I am very careful to protect the anonymity of those who request it.

NOTE: This newsletter is best viewed at screen resolutions of 800x600 (good) or 1024x768 (better). Any current revision of web browser should work fine. Please notify me of any problems with viewing. This site is compliant with XHTML 1.0 transitional coding for easy access from wireless devices. (XML 1.0/ISO 8859-1.)


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MORE PAGES
There are three main pages in the newsletter now. In the top right-hand corner of this page you will see: “Page 1
 2 3.” This indicates that you are on page one and that you can click on either the “2” or the “3” (because they are underlined) to go to those respective pages. When you are on page two you will see: Page 1 2 3” and when you are on page three you will see:  Page 1 2 3.” Also, at the end of page one there is a link to page two, and at the end of page two, there is a link to page three.



A Paging company in New England has openings for experienced RF technicians or engineers. Glenayre Switch experience a plus. Please contact me if you know of anyone who might be interested and qualified.


 

waveware

This is a special recognition of WaveWare Technologies in Dallas, Texas. This company, under the able management of Curtis Rock, is one of the leading suppliers of Wireless Messaging equipment in the USA. If you want to see some really cool equipment for "on-premise paging" please click on their logo and check out their web site. I particularly like their "Message Centers" that are Alphanumeric LED Displays, which scroll messages sent to them over public or private paging systems. Browse around their site and let me know what you think.

Let's try an experiment. As a special favor to me, would you take a look at their web site and then call them on the telephone and say that you saw them mentioned here in the newsletter? I would appreciate it very much. Several advertisers have told me that they are getting good responses from their ads here in the newsletter. It will be interesting to see how many responses we get from this special recognition.

WaveWare Technologies recently sent in a generous donation to help keep the newsletter going. You can too by clicking on the DONATE button above.


AMERICAN ASSOCIATION OF PAGING CARRIERS

aapc logo AAPC Bulletin
www.pagingcarriers.org • 866-301-2272
The Voice of US Paging Carriers

It’s never too early to start planning.

Register today at www.pagingcarriers.org

AAPC Wireless Forum
May 31-June 2, 2006
Marriott Resort at Grande Dunes
Myrtle Beach, South Carolina
www.pagingcarriers.org

Have you renewed your AAPC membership? The association is continuing to work to advance the visibility of the paging industry.

Invoices for 2006 membership fees were sent via e-mail. If you would like a hard copy sent or did not receive yours, please contact Linda at info@pagingcarriers.org.


Thanks to the Gold Vendors!
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PRISM Paging
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Recurrent Software Solutions, Inc.

Thanks to the Silver Vendor!
isc technologies
ISC Technologies, Inc.

Thanks to our Bronze Vendors!
  • BLP Components, Ltd.
  • Canyon Ridge Communications, Inc.
  • Commtech Wireless
  • Critical Response Systems, Inc.
  • Global Technical Engineering Solutions (GTES)
  • Hark Systems, Inc.
  • Motorola Inc.
  • Minilec Service, Inc.
  • Trace Technologies LLC
  • Unication USA
  • United Communications Corporation
  • VCP International
  • Zetron, Inc.
Linda M. Hoover
AAPC Executive Director
441 N. Crestwood Drive
Wilmington, NC 28405
Tel: 866-301-2272
E-mail: info@pagingcarriers.org
Web: www.pagingcarriers.org

AAPC Regulatory Affairs Office
Suite 250
2154 Wisconsin Avenue, NW
Washington, DC 20007-2280
Tel: 202-223-3772
Fax: 202-315-3587

AAPC BULLETIN

FEATURED ADVERTISERS SUPPORTING THE NEWSLETTER

Advertiser Index

AAPC—American Association of Paging Carriers  Minilec Service, Inc.
Advanced RF Communications   Multitone Electronics
Advantra International  Northeast Paging
Aquis Communications, Inc.  NotePage Inc.
Ayrewave Corporation  Outr.net
Bay Star Communications  Ira Wiesenfeld
CONTEL Costa Rica  Preferred Wireless
CPR Technology  Prism Paging
CVC Paging   Product Support Services
Daniels Electronics  Ron Mercer
Daviscomms USA  
EMMA—European Mobile Messaging Association  Sun Telecom International
eRF Wireless  Texas Association of Paging Services
Global Fax Network Services TH Communications
GTES LLC  UCOM Paging
Hark Systems  Unication USA
Heartland Communications  USA Mobility, Systems Application Division
HMCE, Inc. WiPath Communications
InfoRad, Inc.  Zetron Inc.

AQUIS COMMUNICATIONS, INC.

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USA Mobility provides customized wireless solutions for enterprises with complex messaging needs, offering:

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Communications solutions that meet the critical messaging needs of:

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IRM Unified Wireless Communications Engine

irm logo Originally developed to meet the high-volume and critical messaging needs of hospitals, the IRM (Integrated Resource Management) system from USA Mobility seamlessly integrates all wireless communications into a single system. By combining multiple wireless platforms with internal data sources such as directories and scheduling software, an IRM allows you to operate a reliable, efficient, and cost-effective messaging system.

CONTACT US TODAY for your customers
. . . to learn more about our full suite of wireless integration products. Together we can help your customers improve their productivity while maximizing oversight and control.

Nancy Green, VP Systems Applications Division 972-801-0448.

www.usamobility.com/systems


INFORAD Wireless Office

Wireless Messaging Software

InfoRad® Wireless Office (Windows 95, 98, ME, NT, 2000, XP) is designed for the professional who needs full-featured wireless messaging capabilities. Features include enhanced user interface,  message log with search function, scheduled Paging,  group and individual message addresses, TAPI Smart™, multiple protocol SMS communication compatibility. AlphaCare™ support services available. With a 32-bit architecture, InfoRad Wireless Office is designed for compatibility with Windows 95/98/ME/NT/2000/XP. For more information on InfoRad Wireless Messaging software, and a free demo, please click on the logo.

InfoRad logo  left arrow CLICK HERE


InfoRad Wireless Office

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Newsletter repair prices—starting at:

  • $6.50 labor for numeric or alphanumeric pagers
  • $12.00 labor for 2-way pagers
  • $19.50 labor for cellular phones

**Special pricing on cellular and pager refurbishment**

motorola logo Motorola Authorized Service Center for Paging and Cellular.

Ask for Special Newsletter Pricing.

Please call: (800) 222-6075 ext. 306 for pricing.


Contact
E-mail: info@minilec.com left arrow CLICK HERE
Minilec Service, Inc.
Suite A
9207 Deering Ave.
Chatsworth, CA 91311
Minilec Service



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  • January 11, 1997—Telstar 401 suffers a short in the satellite circuitry—TOTAL LOSS
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  • September 19, 2003—Telstar 4 suffers loss of its primary power bus—TOTAL LOSS
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WIRELESS MESSAGING NEWS

Before the
Federal Communications Commission
Washington, D.C. 20554

  ) 
In the matter of ) 
  ) 
Review of the Emergency Alert System ) EB Docket No. 04-296

COMMENTS OF USA MOBILITY, INC.

USA Mobility, Inc. (“USA Mobility”) respectfully submits these comments in response to the Commission’s Further Notice of Proposed Rulemaking in the above-captioned docket regarding the proposed expansion of the Emergency Alert System (“EAS”).1

INTRODUCTION AND SUMMARY

USA Mobility strongly supports the Commission’s interest in developing a more comprehensive EAS that is capable of meeting the communications challenges associated with a broad range of emergency situations. In particular, USA Mobility agrees with the Commission that the expanded EAS should encompass wireless services in addition to broadcast, cable, and DBS services. As the nation’s leading provider of paging services, USA Mobility, in addition to its mass market consumer and business services, provides mission-critical text-messaging services to police officers, firefighters, emergency medical teams, and related personnel in a broad range of crisis situations. USA Mobility appreciates the opportunity to comment based on its significant experience assisting with emergency communications and looks forward to working with the Commission on the expansion of the vitally important EAS program.

As discussed below, the increasingly central role of wireless communications in the daily lives of Americans makes the inclusion of wireless services essential to the success of an expanded EAS. Paging services, in particular, offer unique attributes that are ideally suited to emergency communications. Paging networks provide redundant, reliable, and cost-effective communications capabilities that have made pagers a preferred device among many first responders.

In light of the Commission’s objective of ensuring broad and redundant transmission of critical emergency information, USA Mobility believes that participation in the new EAS should be mandatory for all communications providers. The existing system—which allows participation by providers of wireless services on a voluntary basis—has not produced the type of industry-wide participation or the level of cooperation among industry participants and government agencies that are necessary to achieve the Commission’s objectives.

Finally, the expanded EAS should be grounded in the principles of interoperability and coordination. The system should be designed so that all providers receive emergency information in a form that can be readily passed on to their customers. Governmental authorities at all levels should be able to utilize the same infrastructure to harmonize their response to emergencies and to avoid placing unnecessary burdens on service providers.

BACKGROUND

USA Mobility is the leading provider of traditional one-way and advanced two-way paging services in the United States. Paging was one of the nation’s earliest means of wireless telecommunications, and paging network infrastructure has become well-established across the country. While the mass market for paging services has declined rapidly in recent years (as most consumers have migrated to mobile phone services), USA Mobility continues to play an important role in providing cost-effective and highly reliable text-messaging solutions to government agencies and commercial enterprises, including in particular the health care sector. For example, during Hurricane Katrina, police officers, firefighters, hospital workers, and government officials were able to use USA Mobility pagers to communicate when land lines and cell phones were not in service.

USA Mobility was formed in late 2004 by the merger of Arch Wireless, Inc. and Metrocall Holdings, Inc., then the nation’s two largest independent paging and wireless messaging companies.2 As a result of the merger, USA Mobility is able to offer paging and wireless messaging services throughout an expansive coverage area. Indeed, the company operates the largest traditional one-way paging network within the United States, reaching more than 90 percent of the U.S. population. The company’s two-way wireless data network is also the largest in the nation. USA Mobility offers wireless messaging to over 1,000 cities in the United States, including the country’s 100 largest markets, and serves more than 80 percent of Fortune 1000 companies. As of September 30, 2005, USA Mobility provided service to over 5.1 million messaging devices.

USA Mobility operates a network consisting of approximately 15,000 narrowband PCS base-station transmitters, which are controlled by satellites. The transmitter antennas, which are often located 300 feet off the ground, simulcast high-powered signals of up to 3,500 watts effective radiating power (“ERP”) from multiple towers.3 Transmitters receive signals directly via satellite instead of through the wireline infrastructure, making them far less vulnerable than mobile phone services to hurricanes, earthquakes, and other sources of outages. For example, after Hurricane Katrina, USA Mobility was able to restore messaging service within two days in the geographic areas hardest hit by the storm, while most wireline and wireless providers took much longer to restore service.

As the industry leader in wireless paging and messaging services, USA Mobility is an ideal candidate to participate in an expanded EAS and looks forward to working with representatives of other industry segments and the Commission to assist with the development of the new system.

DISCUSSION

I. THE COMMISSION SHOULD ESTABLISH AN EXPANDED NATIONAL ALERT SYSTEM THAT INCLUDES PAGING SERVICE PROVIDERS AND OTHER WIRELESS CARRIERS.

USA Mobility supports the Commission’s interest in developing “a more comprehensive system” that provides emergency alerts through multiple communications channels.4 The inclusion of wireless services generally, and paging services in particular, is an essential step towards meeting this goal.

A. Inclusion of Wireless Services Is Necessary to Ensure Broad and Redundant Transmission of Emergency Alerts.

Recent crises—including most notably Hurricane Katrina—have highlighted the importance of relaying critical emergency alerts through multiple channels. In such situations, it is imperative that emergency information be available to first responders, other government officials, and the public at large. Providing alerts to the television and radio audience—as the existing EAS aims to do—may reach a significant percentage of the population, but that approach also inevitably fails to provide critical information to many citizens, including officials charged with responding to a crisis. As the FNPRM notes, “[w]ireless products are becoming an equal to television and radio as an avenue to reach the American public quickly and efficiently.”5 Indeed, as of December 2004, nearly 185 million Americans—including the vast majority of all adults—subscribed to mobile telephone services,6 and another 8.5 million Americans subscribed to paging services.7 In light of such prevalence, the expanded EAS should include wireless services as a central component, and the Commission should design the system architecture and common protocols with this future in mind.

The mobility associated with today’s wireless devices also makes them an essential part of an expanded EAS. In any emergency—especially one involving evacuation plans—people will be on the move, making their mobile wireless devices the best, and perhaps only, way for them to receive alerts and other communications. Expanding the EAS to include mobile wireless devices thus will address one of the critical shortcomings of the existing system: consumers often are far from a television or radio when emergency messages are broadcast.

In any event, regardless of which device (a television, radio, mobile wireless device, or something else) provides the best chance of reaching a particular consumer, the Commission fortunately need not choose among them in designing an expanded EAS. Rather, as the FNPRM recognizes, ensuring “built-in redundancy features and use [of] a variety of communications media” will allow officials to “reach large numbers of people simultaneously.”8 By including wireless services in the expanded EAS, the Commission will create a layered web of “safety nets,” so that if one platform fails, another will fill the void.

B. Paging Service Providers Will Play an Important Role in an Effective Expanded EAS.

While wireless services generally will represent an important component of an expanded EAS, the system would be sorely lacking without the participation of paging services in particular. The unique network characteristics of paging systems and their extensive use by first responders, medical personnel, and government agencies make paging ideal for inclusion in an expanded EAS.

First, paging services offer extremely broad geographic coverage. USA Mobility alone employs 16,000 transmitters to cover over 90 percent of the U.S. population, including the nation’s 100 largest cities. Part of the reason for this broad coverage from relatively few towers is that paging systems transmit signals from a much higher elevation than cellular and broadband PCS providers—approximately 300 feet for paging transmitters, compared to approximately 90 feet for cellular and broadband PCS transmitters. Moreover, paging transmitters emit an extremely powerful signal of 3,500 watts ERP (as compared to an average signal of 100 watts ERP for cellular and broadband PCS communications). The combination of high-elevation and high-power transmissions enables paging signals to better cover rural areas and irregular terrain than their cellular counterparts and to deliver better in-building reception and transmission.

Paging systems are also inherently redundant. The Commission has noted that the expanded emergency alert system “should have built-in redundancy features.9 Paging systems can further this goal even apart from participating alongside other technology platforms, because messages are simulcast from multiple towers to each device. Thus, unlike other wireless services, the failure of one tower will not necessarily cut off communication to all users who are serviced by that tower.

Moreover, paging systems are well-suited for participation in the expanded EAS because they remain highly reliable in emergency conditions. Unlike cell phones and PDAs, paging devices typically run on a single AA battery and have a long battery life. The devices are not affected by a loss of electrical power, as there is no need to recharge them.

Just as importantly, paging networks tend to be more resilient (in light of their reliance on simulcasting) and quicker to recover than other communications networks. As noted above, paging networks consist of stand-alone towers that use satellites for backhaul, and are thus independent of the traditional wireline infrastructure. In a weather-related crisis or terrorist attack, the wireline network may be directly disabled or overloaded by high volume usage. The public cellular and broadband PCS network would likewise be affected. On September 11, 2001, for example, the percentage of blocked cellular calls exceeded 75% in New York City and 50% in Washington, D.C.10 The failure of traditional voice communications networks to deal effectively with the tragedies of September 11 underscores the benefits of two-way paging in an emergency. According to one expert, two-way paging “should be considered a primary or backup system to improve real-time communication among emergency personnel during critical periods when voice communication is not practical or fails.”11 Indeed, the aftermath of Hurricane Katrina powerfully illustrated the reliability of paging systems in a crisis situation. By retaining broad network coverage during the storm and restoring coverage quickly afterward—the paging network was fully operational within two days in the geographic areas hardest hit by the storm, while most wireline and wireless providers required far longer to restore full service—USA Mobility demonstrated its ability to provide reliable and resilient messaging capabilities in the face of the most destructive of catastrophes.

Paging systems also offer the important benefit of cost effectiveness compared to other text-messaging technologies. Standard paging devices can be purchased more far cheaply than cellular phones or PDAs. This disparity in cost continues to make pagers an attractive option for employers and government agencies that need basic messaging capabilities but wish to avoid paying for the voice capabilities offered by cell phones and many integrated PDA/phone combinations. The cost savings also appeal to low-income consumers who cannot afford more expensive wireless communications services. Including paging services in the expanded EAS thus will enable the Commission to ensure the broadest possible dissemination of emergency messages to these wireless users.

Finally, the widespread use of paging systems by first responders, health care workers, and other government agencies makes a strong case for their inclusion in the expanded EAS. Police officers, firefighters, and other first responders rely on paging systems to receive critical emergency information, using their pagers as either their primary or back-up communications devices. Doctors, nurses, emergency medical technicians, and other medical personnel often use the paging network as their primary means of wireless communication. State and local government agencies are also significant users of paging services. Thus, key personnel in any emergency response situation already are likely to rely on paging services to receive critical information. By integrating paging systems into the expanded EAS, the Commission will promote improved coordination and more effective communication among such critical personnel.

In short, paging systems continue to be relied upon to transmit emergency information to more people in hard-to-reach areas than other communications services. The Commission should take advantage of the broad geographic coverage and high transmitting power of paging systems by including paging services in the expanded EAS.

C. The Commission Has Ample Authority to Establish an Expanded EAS and Should Play a Lead Role in Its Development and Oversight.

As the Order accompanying the FNPRM recognizes, the Commission has ample authority to regulate emergency alerts and warnings.12 The Commission is the sole agency with broad authority over all major communications services, so it is ideally situated to oversee a comprehensive national EAS. Historically, the Commission has filled this role with its oversight of the Emergency Broadcast System and later the EAS. The development of an expanded EAS should be seen as a natural continuation of the Commission’s traditional role.

In developing an expanded EAS, the Commission should work closely with other federal agencies that have overlapping jurisdiction and experience, including the Federal Emergency Management Agency (“FEMA”) and the National Weather Service (“NWS”). FEMA and NWS, among other federal agencies, have made important contributions to the development of a comprehensive national alert system. State and local governments also will play an integral role in the development, testing, and implementation of new systems. Thus, while the Commission should play a lead role in issuing the requisite mandates and convening working groups (as discussed further below), it should coordinate closely with its sister agencies at the federal and state levels. Such broad and inclusive participation will be essential to the success of an expanded EAS.

II. PARTICIPATION IN EXPANDED EAS SHOULD BE MANDATORY FOR PROVIDERS OF WIRELESS SERVICES.

The Commission should make the expanded EAS mandatory for providers of commercial mobile radio services.13 As shown above, CMRS providers now play a major role in meeting society’s communications needs, and mobile wireless technology is ideally suited to the transmission of emergency messages. Yet, only a mandatory regime can ensure the necessary commitment of resources and coordination among wireless carriers, the governmental entities providing alert messages, and other key parties.

Making participation in an expanded EAS voluntary for wireless service providers would likely replicate the status quo: few, if any, would participate. Entities not subject to EAS mandates already can participate in the system voluntarily.14 A principal reason that CMRS carriers seldom if ever volunteer to receive alert messages is that the existing rules are overwhelmingly geared toward broadcasters.

Participation by paging providers and other wireless carriers will be efficient and productive only if the new system is designed with such participants in mind. Specifically, USA Mobility seeks to participate in an expanded EAS based on the critical assumption that alert messages will be transmitted via an efficient system architecture and in an appropriate format that does not require service providers to replace existing network equipment or require consumers to replace existing devices. Such an efficient system will require a significant up-front investment of resources by industry and government, working together to ensure that all participating technologies are accommodated. It is unreasonable to expect the necessary degree of engagement and investment absent mandatory participation. If service providers believe that competitors will gain advantage by avoiding the costs associated with participation, a race to the bottom will result and the Commission’s goals will be undermined.

Mandatory participation also is justified by the need to ensure that all consumers will benefit from an expanded EAS. A consumer’s ability to receive critical alert messages should not depend on the service provider’s unilateral decision to avoid participation in the national EAS. While it is possible that, over time, market forces would spur widespread participation, the stakes are too high to wait until such market incentives develop or to risk the possibility that they will not. The only way for the Commission to ensure uniform availability to emergency information is to make participation in an expanded EAS mandatory for CMRS providers.15

III. THE EXPANDED EAS SHOULD BE DESIGNED TO FACILITATE INTEROPERABILITY AND COORDINATION AMONG ALL RELEVANT PARTIES.

In response to the Commission’s inquiries regarding system design,16 USA Mobility proposes that the Commission should be guided by the principles of interoperability and coordination and should establish a working group to develop inclusive technical standards.

A. The Expanded EAS Should Ensure Interoperability Among Differing
Communications Platforms.

The FNPRM seeks comment on a range of potential system architectures, including point-to-multipoint distribution of alert messages (possibly incorporating satellite transmission) as well as common messaging protocols.17 USA Mobility believes that a satellite-based point-to-multipoint system employing a common messaging protocol appears sensible. But such details should be subordinate to the overarching need to ensure that, whatever design is selected, service providers will be able to receive emergency alerts in a form that enables seamless redistribution to their customers. In other words, the Commission should ensure that the expanded EAS promotes the maximum degree of interoperability so that technical barriers do not stand in the way of a more robust and redundant national alert system.

To further this goal, the Commission should convene a technical working group made up of leading industry representatives from all relevant sectors and public officials from the Commission, FEMA, and NWS, as well as state and local governments.18 Bringing together key stakeholders will enable the working group to devise a system architecture and messaging protocol(s) that account for the needs of the entities that will be charged with disseminating alerts to the public. The working group should be given an accelerated timetable. The Commission later could seek comment on the recommendations issued by the working group. By contrast, developing technical standards through a notice-and-comment rulemaking proceeding alone would make it very difficult to anticipate and resolve the challenges associated with incorporating a wide array of different technical platforms into the EAS.

B. Federal, State and Local Authorities Should Utilize the Same Infrastructure and Protocols.

Development and operation of the expanded EAS should be based on close coordination among federal, state, and local governmental authorities.19 From hurricanes to chemical spills to school shootings, most emergencies occur at the state or local level. Even emergencies of a national scope, such as the terrorist attacks of September 11, deeply affect states and municipalities. With this in mind, USA Mobility applauds the Commission’s recognition of the “vital connection between state and local alert and warning and Federal efforts to mitigate disasters.”20 Moreover, USA Mobility supports the proposal that state governors should have “the ability to utilize EAS facilities in order to disseminate potentially life-saving information.”21

Increased involvement of state and local officials should be accompanied by concerted efforts to avoid imposing duplicative obligations on service providers. As long as state- and local-initiated alerts employ the same protocols and standards as the national alert system, service providers will not bear unreasonable burdens in disseminating additional alert messages. It will be essential to ensure that state and local officials do not rely on distinct system architectures or face different technical requirements, because subjecting service providers to a patchwork of inconsistent obligations would inevitably undermine the effectiveness of an integrated national alert system. State and local participation in the expanded EAS should be contingent on compliance by those political subdivisions with the national standards adopted by the Commission, based on the vital interest in operational uniformity.

C. The Commission Should Not Consider Adopting Performance Standards Until Well After the New System Is Implemented.

The expanded EAS will include service providers that have never before participated in a national emergency alert and warning system. Any discussion of government-imposed performance standards—regarding such matters as the length of time it takes to transmit a particular message or the accuracy of the message—is therefore premature.22 There is no reason to presume that performance will be inadequate or require significant governmental oversight. In particular, if the Commission establishes a working group that designs technical standards with the full range of participating providers in mind, the likelihood of strong performance will be high. Moreover, the prospect of performance mandates—and the associated burdens they entail—will chill service providers’ incentives to support an expanded EAS, thereby jeopardizing the important objectives at stake. USA Mobility accordingly urges the Commission to remain focused on the immediate goal of developing a successful, workable EAS and to refrain from considering performance standards until the new system is fully implemented.

CONCLUSION

For the foregoing reasons, the Commission should include wireless providers generally and paging systems in particular in its expanded EAS on a mandatory basis. The expanded EAS should employ a system that is interoperable among various providers and is coordinated for uniformity at the federal, state, and local levels. The Commission should refrain from considering performance mandates until well after it implements the expanded system.

 

Respectfully submitted,


/s/ Matthew A. Brill

Scott B. Tollefsen
General Counsel and Secretary
USA MOBILITY, INC.
6677 Richmond Highway
Alexandria, Virginia 22306
(703) 718-6608

January 24, 2006

Matthew A. Brill
Samuel Logan
LATHAM & WATKINS
555 11th Street, N.W.
Suite 1000
Washington, D.C. 20004-1304
(202) 637-2200

Counsel for USA Mobility, Inc.


1 Review of the Emergency Alert System, First Report and Order and Further Notice of Proposed Rulemaking, EB Docket No. 04-296 (rel. Nov. 10, 2005) (“FNPRM”).
2 Both companies are now operated as subsidiaries of USA Mobility.
3 By contrast, a traditional cellular system utilizes a single tower in a given area, and the towers are only about 90 feet high, transmitting a relatively weak signal of 100 watts ERP.
4 FNPRM § 61.
5
Id. § 69.
6 Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of Competitive Market Conditions With Respect to Commercial Mobile Services, Tenth Report, WT Docket No. 05-71, FCC 05-173, § 161 (rel. Sept. 26, 2005).
7 Id. § 166. With the rise of data-ready cellular phones and networked personal data assistants, the number of pagers is on the decline among the general population. However, pagers remain popular in niche markets such as first responders, medical personnel, service-driven businesses, and other sectors needing reliable basic data service at low cost.
8 FNPRM § 62.
9 Id.
10 Cellular Telecommunications & Internet Association, report to the Network Reliability Interoperability Council: “Network Impact and Recovery Efforts—September 11, 2001,” 1-2 (Oct. 23, 2001), quoted in Peter Kapsales, Wireless Messaging for Homeland Security: Using Narrowband PCS for Improved Communication During Emergencies, 2 (March 2004), available at http://www.homelanddefense.org/journal/Articles/Kapsales.html.
11 Kapsales, Wireless Messaging, at 1.
12 See Order § 5 (citing 47 U.S.C. §§ 151, 154(i), 154(o), 303(r), 606); see FNPRM § 63 (seeking comment on the Commission’s statutory authority and the role in should play in creating a new alert system).
13 See FNPRM § 63.
14 See 47 C.F.R. § 11.11(e).
15 USA Mobility recognizes that participation in the expanded EAS may be impracticable for very small providers. In such cases, exemptions for providers meeting a de minimis threshold are appropriate.
16 See FNPRM §§ 65-81.
17 Id. §§ 66-67.
18 Cf. Warning, Alert, and Response Network Act, S. 1753, 109th Cong., 1st Sess. (2005) (calling for establishment of a working group including representatives of federal government agencies, state and local governments, and communications service providers to establish guidelines for the technical capabilities and requirements of a national alert system).
19 See FNPRM § 73.
20 Id.
21 Id.
22 Id. § 72.

 


FEATURED ADVERTISERS SUPPORTING THE NEWSLETTER


GTES LLC

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GTES Corporate
Russ Allen
2736 Stein Hill Lane
Custer, WA 98240
Tel: 360-366-3888
Cell: 360-820-3888
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GTES Sales
Brooks Marsden
340 Bethany Bend
Alpharetta, GA 30004
Tel: 770-754-1666
Cell: 404-518-6632
brooks.marsden@gtesinc.com

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www.sherlocgps.com

GTES has recently made the strategic decision to expanding its development activities to include wireless location technologies; a market that researchers forecast could reach $3.6 billion by 2010. In support of this new strategic direction, GTES has developed SHERLOC™ a complete one-stop wireless location service, providing the flexibility of being protocol neutral and network agnostic. Targeted at business customers who need to track their high-value shipments or better manage their service or delivery fleets, SHERLOC™ is a hosted application that combines configuration flexibility with ease of use.

GTES is offering SHERLOC™ services both directly and through authorized resellers. If your company has an interest in finding out how location services can enhance your revenue stream, and has the contacts and expertise to make you successful in the location marketplace, please contact us for further information at www.sherlocgps.com and select “Reseller Opportunities,” or call us at 770-754-1666 for more information.


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GTES is the only Glenayre authorized software support provider in the Paging industry. With over 200 years of combined experience in Glenayre hardware and software support, GTES offers the industry the most professional support and engineering development staff available.


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Hark Technologies

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Wireless Communication Solutions


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ISI-LX Internet Serial Interface with Protocol Conversion


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IPG Internet Paging Gateway


  • No Moving Parts Such as Hard Drives or Fans to Fail
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PageTrack


  • Inexpensive method of automating your paging monitoring
  • Uses standard paging receiver
  • Available in 152-158 POCSAG or 929 FLEX (call for others)

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Omega Unified Messaging Server


  • Full Featured Internet Messaging Gateway
  • TAP Concentrator and TNPP Routing Functions w/TNPP over Internet
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  • Full Featured, Easy-to-use Voice/Fax/Numeric Mail Interface
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  • Optional Hot-swap Hard Drives and Power Supplies Available

Please see our web site for even more products designed specifically for Personal Messaging carriers. For example, the Omega Messaging Gateway and Email Throttling Gateway (anti-spam).


Contact
Hark Technologies
2675 Lake Park Drive
N. Charleston, SC 29406
Tel: +1 843-764-1560
Fax: +1 843-764-3692
E-mail: sales@harksystems.com left arrow CLICK
Web: http://www.harksystems.com left arrow CLICK
Hark Technologies


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Turn-key RF System Products, Engineering & Technical Services

  • Conventional Single Site and Wide Area Simulcast System Configurations
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Call (217) 653-8200 Fred Pakosta or Jim Neves (660) 341-0304 for your Project Requirements!
E-mail: sales@AdvancedRF.biz
301 Oak St., Suite 2-46A, Quincy, IL 62301

arrowPaging & Two-Way Radio Service Centrearrow
  • Supplier of Motorola and Unication
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Contact us to find out more:
Tel: +44 (0)2380 666 333
e-mail: enquiries@thcomms.co.uk
Web: www.thcomms.co.uk

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Unication USA

Unication’s

Paging

Products

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The Paging Industry expects quality, reliable, and high performance paging products.

We at Unication have listened and delivered.

  • One-Way Pagers
    • Alpha Elite and Alpha Gold—Our top of the line FLEX™ / POCSAG, 4-line alphanumeric pagers with an identical user interface and comparable RF performance to the Motorola Elite and Gold pagers.
    • NP88—Our newest numeric FLEX / POCSAG pager with the best backlight in the Industry.
  • Two-Way ReFLEX™ Advanced Messaging Pagers
    • Partner—A refreshed version of Motorola’s T900 Classic.
    • e80—A fully licensed version of the former PerComm e80.
  • Telemetry
    • We offer RF and decoding solutions.
alpha elitealpha goldnumeric

About Unication Co., Ltd.

  • A Taiwan company founded in 1992 with extensive experience designing and manufacturing paging and broadband products.
  • An ODM to major telecommunications companies.
  • More than 300 associates worldwide with Engineering Design Centers in Taipei, China and Vancouver, BC.  The engineering team has years of experience in wireless systems, embedded SW, RF design and protocols for infrastructure and pagers.
  • Our Accelerated Life Testing facility ensures the highest quality of products for our customers.
  • Fully licensed by Motorola for product design technology and the FLEX Family of Protocols.
  • Sales and Engineering support office in Arlington, Texas.
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  Contact Information

  Kirk Alland
  Unication USA
  1901 E. Lamar Blvd
  Arlington, TX 76006
  (817) 926-6771
  kirk@unication.com

Unication USA

Prism Paging

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Prism Message Gateway Systems
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Contact
Prism Paging
300 Colonial Center Parkway,
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Roswell, Georgia 30076 USA
Telephone: 678-353-3366
Internet: www.prismpaging.com left CLICK HERE
E-mail: info@prismpaging.com left arrow CLICK HERE
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See the Prism Paging video

Streaming Video from the
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eRF Wireless
Paging Hardware
End-to-End Solutions for Wireless Personal Communications and Messaging Productsbase stations
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Exceptional quality. Unmatched sales and service support.

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As a worldwide supplier of telecommunications equipment eRF Wireless designs, manufactures and markets transmitters, receivers, controllers, software and other equipment used in personal communications systems, as well as radio and telephone systems. eRF Wireless also provides service and support for its products, as well as consulting and research development on a contract basis.

If you'd like a single-source provider that's committed to competitive prices and fast delivery, call us today at 1-800-538-9050 or visit our web site at:
www.erfwireless.com left arrow CLICK HERE

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Multitone Electronics
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Multitone North America Inc.
2300 M Street NW
Suite 800
Washington, DC 20037
Tel: (202) 973-2827
Fax: (202) 293-3083

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Launches...

NEW state-of-the-art PowerPage 750 with Advanced Reliability offering Digital Voice Storage Technology and a range of other exciting new features and benefits...

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Multitone also has a range of PowerPage & FuturePhone Wireless Communication Solutions to suit your individual communication needs.

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wherify

FOR IMMEDIATE RELEASE

WHERIFY SECURES UP TO $35 MILLION IN FUNDING

Wherify Gears up to Deliver Family Communications and GPS Child Safety Services—

REDWOOD SHORES, Calif. (February 9, 2006)—Wherify Wireless, Inc. (OTCBB:WFYW), a leading developer of wireless location products and services, today announced the Company has secured a package of equity financing where the Company can access up to $35 million of common stock equity over a two-year period, subject to effective stock registration and other terms of the agreement, from Dutchess Private Equities LP. For full details of the agreement, please refer to Wherify’s 8K filing with the SEC. Wherify will utilize the funds for accelerating marketing efforts and expanding global operations toward the upcoming launch of its Wherifone® GPS Locator Phone, assisted-GPS technology platforms, and continued product development.

The Wherifone is the world’s smallest GSM/Enhanced-GPS Locator Phone and provides a totally unique and affordable way for families with pre-teens, seniors, mobile workers, or those with special medical needs, to stay connected and in contact with each other. As well as two-way voice calling, the Wherifone features Enhanced-GPS location technology that lets it be located in lightly obstructed areas, such as many types of wood frame buildings and vehicles, and under dense foliage. The Wherifone gives a child or adult carrying it a new level of security knowing they can stay connected to friends, family and colleagues, and request an emergency response at the touch of a button.

“This equity financing is an important component of our overall financial strategy and provides us access to the capital necessary to continue our innovation and leadership position in the GPS location, family safety and communications markets,” said Timothy Neher, chief executive officer, Wherify Wireless. “We are excited to see that our Company has received such a strong vote of confidence as we prepare to launch our services worldwide.”

About The Wherifone
The Wherifone provides affordable peace-of-mind to the modern mobile family. The slim, small and lightweight Tri-Band GSM cell phone (900/1800/1900 and 850/1800/1900) weighs under 70 grams and features incoming and outgoing calling, five programmable buttons for one touch dialing, a headset jack, and a backlit LCD display. The absence of a traditional dial pad helps parents and caregivers manage the expense of out-going calls, and provides ease-of-use. As well as two-way voice calling, the Wherifone features Enhanced-GPS location technology that lets it be located in lightly obstructed areas, such as many types of wood frame buildings and vehicles, and under dense foliage. The cell phone is supported by a Location Service Center, which can be accessed 24 X 7, by telephone or the Internet to locate and plot a device’s position on both street maps and aerial photographs.

  • PRE-TEENS: The Wherifone is a great “First Phone” for pre-teens. The small, compact design is a perfect fit for kids, and comes in a variety of great colors that will make them the envy of the neighborhood. The phone’s five pre-programmable buttons let kids stay in touch with close family and friends, or summon help with one-touch dialing—while letting parents manage outbound call costs. The Wherifone’s Enhanced GPS location technology also lets parents, caregivers and safety officials quickly locate a child in need of help, bringing peace-of-mind and added safety to the mobile family.
  • SENIORS: The Wherifone makes an ideal “Companion Phone” for seniors on the go or with special needs. With simple one-touch dialing through five pre-programmed buttons, seniors can easily stay in touch with friends and family while having the ability to call for help at the push of a button. Not only can seniors use the Wherifone GPS location phone themselves to summon aid right to their location, but loved-ones and care-givers can contact the Wherify Global Location Service Center, or use the secure Wherify website, to identify senior’s location at anytime of day or night.
  • SMALL BUSINESSES: The Wherifone can be used by small businesses as a mobile “Work Phone” to manage and communicate with mobile workers, to manage the location of small fleets of trucks or delivery vehicles, and to coordinate dispatch destinations with drivers. The preprogrammed one-touch dialing buttons also help the small business owner manage communications expenses. The absence of a traditional dial pad prevents workers from using the Wherifone for personal calls and incurring unauthorized expenses, while at the same time insuring they can make necessary calls to up to five pre-defined locations.

About Wherify Wireless, Inc
Wherify Wireless, Inc. (WFYW:OTCBB) is a leading developer of patented wireless location products and services for family safety, communications, and law enforcement. The company’s portfolio of intellectual property includes its proprietary integration of the US Government’s Global Positioning System (GPS) and wireless communication technologies; its patented back-end location service; the Wherifone™ GPS locator phone which provides real-time location information and lets families with pre-teens, seniors, or those with special needs, stay connected and in contact with each other; and its FACES® industry-leading facial composite technology, which is currently being used by thousands of public safety agencies worldwide. Founded in 1998, the company is located in Redwood Shores, California. Please visit http://www.wherifywireless.com for more information.

Note Regarding Forward Looking Statements
This press release includes forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Any statements that are not statements of historical fact (including statements containing the words "believes," "plans," "anticipates," "expects," "estimates" and similar expressions) should be considered to be forward-looking statements. There are a number of factors that could cause actual results or events to differ materially from those indicated by such forward-looking statements, including general conditions in the relevant industries and markets, the impact of competitive products, intellectual property issues and the other factors described in Wherify's periodic filings with the SEC. The company disclaims any intention or obligation to update any forward-looking statements as a result of developments occurring after the date of this press release.

# # #

Contact:

Wherify
Joe Noel
Wherify Investor Relations
Tel: 1.650.551.5231
jnoel@wherify.com

and

John Cunningham
Director of Communications
Wherify Wireless
Tel: 1.650.551.5271
jcunningham@wherify.com

Source: Wherify Wireless


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