Greetings Loyal Readers, and Friends of Wireless Messaging,

Happy Thanksgiving

I hope that all the readers here in the USA who celebrate Thanksgiving, had a wonderful day yesterday. This year, since I was only cooking for myself, I substituted a Rock Cornish Hen for a turkey.

This issue has several technical articles of interest to engineers, technicians, and amateur scientists. One of them refers to an SDR (Software Defined Radio) project that I worked on for over a year. It has been the most satisfying project that I have completed in my 50 years-plus in radio communications.

I refer all the requests that I receive for field engineering to Ira Wiesenfeld, P.E.

Ira has a unique approach to helping to support the newsletter. When he is in Southern Illinois, during his extensive travels, he takes me out to dinner and drops a one-hundred-dollar bill into my hand. I realize everyone can't do this, but it is always good to break bread with someone who really appreciates the effort that goes into putting out this newsletter each week.

Ira drives all over the country in a van full of tools, and high-tech-electronic test equipment. He installs, repairs, and optimizes paging and two-way radio systems for carriers, and public safety radio-system operators. I know of no one better.

If you haven't seen it for a while, my "public library for paging" is located here, or by clicking on the "Reference" button at the top of any newsletter. There are many articles here, written by the real experts in our industry. Topics covered included sales, marketing, and engineering.

Now on to more news and views.

Wireless Messaging News
Emergency Radio Communications Wireless Messaging Critical Messaging Telemetry Paging VoIP Wi-Fi WiMAX Location-Based Services	WIRELESS MESSAGING

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.

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 readers' 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.

Editorial Opinion pieces present the opinions of the author. They do not necessarily reflect the views of AAPC, its publisher, or its sponsors.

Brad Dye, Ron Mercer, Allan Angus, and Vic Jackson are friends and colleagues who work both together and independently, on wireline and wireless communications projects. Click here  for a summary of their qualifications and experience. They collaborate on consulting assignments, and share the work according to their individual expertise and their schedules.

If you would like to have information about advertising in this newsletter, please click here.

AAPC Vendor Spotlight

Unication continues to innovate and bring industry leading solutions to the paging marketplace. As the FCC mandated narrow banding for Private Land Mobile Spectrum looms only 24 short months away, Unication has developed a seamless migration solution with its new Legend+ Alpha numeric pager.

The Legend+ is designed to operate on 25 kHz channels and automatically adjust (i.e., no re-programming necessary) to narrowband 12.5 kHz environments. The key benefit of the Legend+ is, with the narrowband mandate looming, one can purchase the Legend+ today to either replace broken or for new. add-on, pagers and not worry about replacing it when the system is converted to narrowband.

Other benefits of the Legend+ are:

• It is compatible with the existing Unication Alpha pager programming HW and current Windows based SW version.
• Has the same User Interface as the Unication Elegant and Legend pagers.
• Has 16 Independent Addresses (64 Functional Addresses).
• A 2 year manufacturers warranty.

The Legend+ is just the beginning of a portfolio of new products Unication will be launching over the next year.

As a benefit to being an AAPC vendor member, we will gladly feature any product/information updates throughout the year in the newsletter.

Thank you for being an AAPC member.

Thanks to our Premier Vendor!

Prism Paging

Thanks to our Silver Vendors!

Method Link, LLC

Unication USA

Thanks to our Bronze Vendors!

• Commtech Wireless
• Critical Response Systems, Inc.
• Daviscomms (S) Pte. Ltd
• Digital Paging Company
• DX Radio Systems
• Hark Technologies
• InfoRad
• ISC Technologies
• Microspace Communications Corporation
• Onset Technology
• RF Demand Solutions
• Swissphone Telecom
• United Communications Corporation

Advertiser Index

hmce@bellsouth.net	Click to e-mail
http://www.h-mce.com	Paging Web Site
Joshua's Mission	Helping Wounded Marines Homepage
Joshua's Mission	Joshua's Mission Press Release

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NOTIFYall Group Text Messaging Service delivers your text message to an unlimited number of cell phones, pagers, PDAs, or e-mail on any service, anywhere, anytime!

PAGING & WIRELESS
NETWORK PLANNERS LLC
WIRELESS SPECIALISTS

www.pagingplanners.com
rmercer@pagingplanners.com

R.H. (Ron) Mercer Consultant 217 First Street South East Northport, NY 11731
Cell Phone: 631-786-9359

NEWS FLASH — SATELLITE FAILURES

• January 11, 1997—Telstar 401 suffers a short in the satellite circuitry—TOTAL LOSS May 19, 1998—Galaxy 4 control processor causes loss of fixed orbit—TOTAL LOSS September 19, 2003—Telstar 4 suffers loss of its primary power bus—TOTAL LOSS March 17, 2004—PAS-6 suffers loss of power—TOTAL LOSS
• January 14, 2005—Intelsat 804 suffers electrical power system anomaly—TOTAL LOSS

DON’T WAIT FOR THE NEXT SATELLITE OUTAGE

Allow us to uplink your paging data to two separate satellites for complete redundancy! CVC owns and operates two separate earth stations and specializes in uplink services for paging carriers. Join our list of satisfied uplink customers.

• Each earth station features hot standby redundancy UPS and Generator back-up Redundant TNPP Gateways On shelf spares for all critical components
• 24/7 staffing and support

For inquires please call or e-mail Stephan Suker at 800-696-6474 or steves@cvcpaging.com

Precise Frequency Locking for the RFSpace SDR radios

Dave Powis, G4HUP

The RFSpace SDR-IQ and SDR-14 are excellent wideband receivers, and can be used with SpectraVue, Winrad and Linrad SDR software. A new application, SDR Radio, should be available for them in the very near future. Both receivers have a simple hardware front end, which is basically an ADC, converting the RF to a data stream, connecting to the PC over USB. The significant difference between the two is that the

-14 is capable of converting and displaying the entire 30 MHz at once, whereas the –IQ can handle up to 190 kHz — the limitation seems to be more in the USB data handling rate rather than the front end hardware.

Whichever receiver you have, there may be applications where the internal clock is not precise enough — this is especially likely to be the case if you are trying to capture very narrow bandwidth sub-noise signals which require long term integration — as they are sub-noise level, there is no trace on the waterfall, or visible component on the spectrum for you to confirm that you have the frequency precisely tuned. Typically, some of the Deep Space Network signal reception requires this type of operation.

The standard internal reference is a 66.667 MHz oscillator — but fortunately, this is easily disabled in both variants, and an external signal can be fed in, in its place. An accurate 66.667 MHz signal can also be generated easily from a standard 10 MHz reference using Direct Frequency Synthesis. This is method of frequency generation which relies on multiplication, division and mixing, with no ‘locked loops’ to generate noise or go out of lock. It also has the advantage that the only oscillator is at 10 MHz, where high quality oscillators with low phase noise are readily available — producing a low-phase noise VHF oscillator is well beyond the capabilities, and test equipment, of most amateur electronics enthusiasts!

10 MHz Reference Oscillators

Suitable reference oscillators are readily available as complete GPS disciplined systems, such as the second-hand HP/Symmetricom Z3801A and other models, the Trimble Thunderbolt, the G3RUH GPSDO and many home/amateur produced variants, such as VE2ZAZ and the Brookes Shera design. Even if a full GPS-DO system is not practical or affordable, 10MHz reference OCXO’s are fairly easy to come by, and often of very good quality. Due to their ubiquity as reference sources, a lot of effort has been put in by manufacturers, and it makes good sense to take advantage of that!

A reasonable quality OXCO, running ‘stand alone’ (i.e. not automatically controlled by any reference such as GPS) will still make a very good reliable source. Ideally it should be left permanently running, and if checked and adjusted against a source such as WWV every month or so will settle down to be a very good accurate source. I strongly recommend using good old fashioned Lissajous figures as an easy to use method for the comparison process!

A 66.67 MHz DFS

Fig. 1 shows the block functions of a 66.67 MHz DFS. This will be used to explain the circuit operation.

Fig. 1 – Single loop DFS solution for 66.667MHz

The 10 MHz input is split into two – one side goes through the x7 VHF multiplier diode, up to 70 MHz. The other signal is divided by 3 to give 3.33 MHz – this is then low pass filtered to recover the sine wave, so that it can be mixed with the VHF signal. At the output of the mixer there will be both 66.67 and 73.33 MHz components present. An LC bandpass filter is used to select the wanted side frequency (in this case 66.67 MHz), and then a 3 stage VHF crystal ladder filter completes the ‘clean-up’.

Although crystals are quite expensive these days, a very economical solution is available by using miniature tubular resonator crystals. Having compared their performance with standard HC49/U crystals, it is definitely not as good – but the cost ratio is about 40 to 1 – you can accept some degradation in output spurii (approx 10 dB) for that benefit in this application!

Fig. 2 - Underside view of the completed 66.667 MHz DFS.
10 MHz input is to the right of the picture, and 66.667 MHz is on the left side.

Since the SDR radios use the signal directly to clock the DDS that runs the ADC timing, having spurii at -55 dBc is not such a significant issue as it would be were the output to be multiplied up as the LO for a microwave system — the normal application of DFS’s. For those applications I like to see the spurii better than -65 dBc.

In addition to the economy version crystal filter, there is another modification to the standard design needed for driving the SDR receiver — the output needs to be a square wave, and it must not exceed 3.3 v, since that is the Vcc used in the SDR boxes. A squarer circuit is used, based on 74AC logic, to convert the sine wave output at 66.67 MHz to a square waveform for the SDR-IQ. The circuit is due to David Smith, VK3HZ, and has a 74AC14 chip, powered from a 3V3 regulator. I had problems confirming that the output was indeed a square wave, since a single inverter will not drive a 50Ω load, so in my implementation I have paralleled three sections for the output — this is not required for the SDR drive, but did at least enable me to see the output correctly on a high speed 50Ω scope!

After building the prototype ‘dead-bug’ style (see Fig. 2), I initially used a small daughter board to hold these extra components inside the DFS, as shown in Fig. 3.

Fig. 3 – Close up of the Squarer circuit board inside the DFS 66.667 MHz

Blue lead to right is +5v DC, input and output signal leads to left.

Further experimentation has shown this to be an inappropriate location, as the daughter PCB is directly above the main regulators of the DFS, which run fairly hot. In high ambient temperatures the squarer function can become unreliable, causing the SDR to crash. Since there is no other convenient location within the DFS housing, I now recommend mounting the squarer outboard of the DFS in a small separate tinplate housing, which removes this weakness. An alternative is to mount a small fan on the DFS casing to create airflow through the box — see http://www.braddye.com/gps_do.html for an example of this approach.

Connecting the LO Signal into the SDR receivers

SDR-IQ
The SDR-IQ is easy to modify for permanent external LO injection — open up the box, and identify the locations R36, R37 and J6. With a blob of solder link the two sides of R36 location and do the same for R37. Connect the external signal to J6 on the PCB, using a miniature 50Ω coax. You will probably find it most convenient to mount a small RF connector (typically SMA or SMB) on the box wall, and cable into J6.

In my own unit I have also installed a small switch on the rear panel, as well as the SMA connector for the external LO signal, as in Figs. 4 and 5 below. This allows me to switch between internal and external LO operation, and thus allows the SDR to be used when there is no frequency locked LO available. Note that SpectraVue must be closed and restarted when changing from one LO source to the other.

Fig. 4 – Close up view of the LO switch installation in the SDR-IQ

Fig. 5 – View of SDR-IQ rear panel, showing LO switch and input connector

SDR-14
The process for the SDR-14 is slightly different, and rather easier, since it will accept a sine wave LO signal — see the instructions at http://g4hup.com/SDRlock.html

No changes are needed in the software for either receiver, since all we have done is stabilise the 66.667 MHz by frequency locking, not change it in any way.

In use there is no difference in operation — except that even for your most demanding applications you will have absolute confidence that your frequency setting is correct!

More information on this and other versions of the Flexible Direct Frequency Synthesiser can be found on my web-site at http://g4hup.com

Rural Groups Continue Push For USF Reform, ICC Relief

Representatives of four rural associations met last week with Steve Kolbeck of the Federal-State Joint Board on Separations to argue the rural case for universal service and intercarrier compensation reform. Whether the FCC considers these issues before year-end, clients should continue to press them, especially with the new Congress coming on board in January. We note that Rep. Lee Terry (R-Neb.) plans to move forward with the “Boucher-Terry USF Reform Bill,” despite Rick Boucher’s (D-Va.) failed reelection bid.

The National Exchange Carrier Association (NECA), National Telecommunications Cooperative Association (NTCA), Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO), and the Western Telecommunications Alliance (WTA) noted that their member companies are small rural carriers that serve remote and sparsely populated areas where there often is no business case for building and operating networks, absent universal service support. They said their members rely upon support from the universal service fund (USF) and intercarrier compensation (ICC) to recover the majority of their network deployment and operating costs.

Proposals to redirect this support to larger carriers’ un-served areas—or eliminate it altogether—will cause their rural networks to fail or suffer severe degradation, resulting in less, not more, broadband service for rural consumers and businesses, the associations said. They said history demonstrates that shifting from proven rate-of-return (RoR) cost recovery methods to price cap “incentive” regulation is likely to minimize, if not eliminate, incentives to expand and improve broadband networks in costly rural areas. They noted that reforms proposed in the National Broadband Plan (NBP), including the expectation that urban consumers will have 100 Mbps broadband in urban areas while limiting cost recovery for rural networks to 4 Mbps, risk creating and perpetuating a digital divide with serious negative consequences for rural consumers and rural economies.

To address these shortcomings and risks, the Rural Associations recommended that any USF and ICC reforms serve the following objectives:

1. ENSURE THAT SUFFICIENT UNIVERSAL SERVICE FUNDS ARE AVAILABLE

The FCC should take immediate steps to make the USF more sustainable and capable of truly achieving the NBP’s broadband goals.

a. Eliminate the Identical Support Rule for non-incumbent USF recipients.

b. Fund only one fixed and one mobile provider of last resort (POLR) in each geographic area.

c. Avoid arbitrary caps on the USF and expand the USF contribution base to provide the support necessary to do the job outlined by the NBP

2. APPROPRIATELY STRUCTURE THE NEW CONNECT AMERICA FUND (CAF)

After an appropriate transition period, replace the current USF mechanisms with a new CAF that includes appropriate provisions to ensure efficiency and accountability, while providing appropriate incentives for the construction and operation of the rural networks necessary to achieve the NBP’s goals. The CAF should recognize the legitimate differences between small rural carriers and larger carriers that serve both rural and urban markets.

a. Small Rural Carriers

i. Each CAF recipient would be required to act as the POLR throughout its service area and satisfy robust availability, affordability, and service quality obligations.

ii. The CAF would work in concert with RoR regulation to provide incentives for needed infrastructure investment, and support the actual cost of deploying and operating broadband-capable networks, subject to reasonable measures to ensure efficient operations.

iii. Carriers would be given the option to reduce intrastate access rates to interstate levels, with federal universal service support providing replacement cost support—subject to a reasonable local rate benchmark.

b. Larger Carriers

i. For larger POLRs that have not deployed broadband in rural portions of their service areas, the FCC should establish rules that ensure CAF support is appropriately tailored to enable such deployment in an efficient and accountable manner.

3. ENSURE THAT ALL AMERICANS HAVE ACCESS TO REASONABLY COMPARABLE BROADBAND SERVICES

To avoid the creation of a harmful “Digital Divide,” the FCC should focus on enabling POLRs to offer broadband services and rates that are reasonably comparable to those in urban areas, in accordance with Section 254(b)(3).

The associations said that small rural providers have made tremendous strides deploying broadband-capable networks throughout their service territories. Despite serving sparsely populated areas representing nearly 40% of the country’s land mass, these carriers have deployed at least DSL-capable broadband to over 92% of their subscribers as of 2009 (up from 79% in 2005). With long-standing commitments to their communities, these carriers have been gradually moving forward with investments in scalable network technologies that support today’s and tomorrow’s broadband-enabled applications and services. However, the job is far from complete in many places to reach the speeds and capabilities envisioned by the NBP, and the long-term availability and affordability of broadband in rural America needed to achieve desired adoption rates depends upon continuing sustainable support for investment and operations in hard-to-serve areas.

Unfortunately, the groups said, these investments and operations are at risk, and rural consumers and small businesses could suffer. While policymakers have indicated that affordable universal broadband should be a priority objective, certain NBP universal service fund (USF) reform proposals could have the unintended consequence of undermining this objective. Reforms focused primarily on reaching “unserved” areas fail to acknowledge that many areas have access to broadband today precisely because high-cost universal service funding continues to support those investments and operations. Such reform proposals also fail to recognize that many rural areas may appear “served” under current definitions of broadband, but not under the definitions contemplated by the NBP.

Proposals to redistribute USF funds not only run the risk of limiting future investment in broadband, but also present the very real prospect that existing investments in rural broadband infrastructure will become unsustainable. This means that fewer rural Americans might ultimately enjoy access to affordable high-speed broadband services as a result of reform, the associations said.

BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

FCC SEEKS COMMENT ON PROPOSED TECHNICAL RULES FOR TERRESTRIAL AND SATELLITE OPERATIONS IN 37.5-42.5 GHz BAND: The FCC seeks comment on proposed technical rules for the Fixed-Satellite Service (FSS) in the 37.5-42.5 GHz band. The purpose of this proceeding is to ensure that satellite operators in this band can share the band with terrestrial fixed microwave services without causing harmful interference. Comments in this WT Docket No. 07-293 and IB Docket No. 95-91 Notice of Proposed Rulemaking (NPRM) are due January 6, 2011, and reply comments are due February 7, 2011. The 37.5-42.5 GHz band is shared between FSS and terrestrial microwave operators on a primary basis. Under a regulatory plan known as “soft segmentation,” technical rules favor the widespread deployment of terrestrial microwave stations in the 37.5-40.0 GHz portion of the band and widespread deployment of consumer satellite earth stations in the 40.0-42.5 GHz portion of the band. The Third Notice proposes to complete the allocation of the entire 37.5-42.5 GHz band to terrestrial microwave and FSS by removing allocations to the Broadcasting Service and the Broadcasting-Satellite Service in the 42.0-42.5 GHz band and by adding an allocation for FSS on a primary basis in the 42.0-42.5 GHz band. In order to prevent harmful interference from FSS operators to terrestrial microwave and to radio-astronomy operations in the adjacent 42.5-43.5 GHz band, the Third Notice requests comment on coordination procedures for FSS operators and terrestrial microwave operators in the band and requests comment on what protection requirements will adequately protect radio-astronomy operations in the 42.5-43.5 GHz band. To allow FSS operators to boost power in the band to compensate for signal fading due to rain, while at the same time preventing harmful interference to terrestrial microwave stations from higher-power satellite transmissions, the Third Notice proposes to require FSS operators in the band to use measures other than boosting power to compensate for signal fading due to rain before boosting power, depending on the rain rate in various locations in the United States. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

FCC MAY MOVE FORWARD ON NET NEUTRALITY: The FCC may place “net neutrality” on the agenda for its December open meeting, according to various reports. The reports, in FierceWireless, Poltico, and the Financial Times, said FCC Chairman Julius Genachowski may put forward a proposal that is similar to the bill Rep. Henry Waxman put together before it failed to gain support in Congress earlier this fall. The FCC, however, has called all of the reports "speculation" and has not circulated its December agenda yet. However, according to a report in the Wall Street Journal, the FCC will unveil its agenda late Wednesday. House Republicans oppose net neutrality rules. Genachowski has said the FCC will move forward on net neutrality, and has criticized Google and Verizon for slowing down the process. Under Waxman's draft bill, which was introduced in late September, wireless Internet providers would not be able to block consumers from accessing lawful Internet websites, subject to reasonable network management. They also would not be able to block "lawful applications that compete with the provider's voice or video communications services in which the provider has an attributable interest, subject to reasonable network management." Further, wireless carriers would have to "disclose accurate and relevant information in plain language regarding the price, performance and network management practices" of service, "sufficient for consumers to make informed choices regarding use of such services and for content, application, service and device providers to develop and market new Internet offerings." BloostonLaw contacts: Hal Mordkofsky, Ben Dickens, Gerry Duffy, and John Prendergast.

NARUC ADOPTS TRAFFIC PUMPING, STIMULUS FUNDING RESOLUTIONS: The National Association of Regulatory Utility Commissioners (NARUC), at its recent annual meeting in Atlanta, adopted two telecommunications resolutions. First, NARUC acknowledged the need for the FCC to act quickly to address the issue of traffic pumping and not wait for the finalization of comprehensive intercarrier compensation reform; and support the FCC to move quickly in WC Docket 07-135 to issue a declaratory ruling on traffic pumping; and to consider further efforts to adopt interim rules to limit or prohibit similar schemes of inter-carrier compensation arbitrage as recommended in the National Broadband Plan. Disappointingly, the Telecommunications Committee did not include the issue of phantom traffic in the resolution; however, it was suggested by at least one delegate that the issue could be in a separate resolution at the February 2011 Winter Meeting. Second, NARUC urged Congress to assure the National Telecommunications and Information Administration (NTIA) and Rural Utilities Service (RUS) that they have adequate funds to continue oversight of the Broadband Technologies Opportunity Program (BTOP) and Broadband Initiatives Program (BIP) grant and loan awards, before the continuing resolution (CR) expires on December 3, 2010, either through a supplement to any successor CRs or by enactment of the FY 2011 budget. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

DINGELL QUESTIONS FCC’s AUTHORITY TO REGULATE MOBILE DATA ROAMING: Rep. John Dingell (D-Mich.) last week wrote the FCC to express his reservations that the Commission possesses the necessary statutory authority to regulate mobile data roaming. Data roaming refers to the extension of data connectivity in a location different from the location where the service is registered. Dingell said the FCC should consult with Congress to clarify its ability to do what it proposes and request appropriate authority under law. Noting that the Commission may adopt data roaming rules at its forthcoming December open meeting, Dingell said he had “grave doubts about the Commission’s statutory authority to classify broadband Internet access services as a telecommunications service, therefore subject to common carrier regulation under Title II of the [Communications] Act. I fear the legal underpinnings of the Commission’s proposal concerning mobile data roaming bear unfortunate analogy to those of its broadband access services proceeding. Similarly, just as Title II regulation of broadband access services may restrict the expansion of communications infrastructure in this country, so, too, may common carrier regulation of mobile data roaming.” BloostonLaw clients have filed comments with the FCC pointing out the need for a regulatory mandate that national carriers provide data roaming to small and rural carriers at reasonable rates. BloostonLaw contacts: Hal Mordkofsky, Ben Dickens, Gerry Duffy, and John Prendergast.

BLOOSTON RURAL CARRIERS FILE REPLY COMMENTS IN HAC PROCEEDING: A coalition of BloostonLaw commercial and private wireless licensees this week filed reply comments on the FCC’s proposed modifications to its wireless hearing aid compatibility (HAC) rules. Recent legislation has called for expansion of HAC requirements to cover advanced communications services (such as VoIP) and equipment. The Blooston Rural Carriers supported the Commission’s proposed extension of HAC to new services and technologies while recognizing that private carrier and internal use operations should remain exempt from HAC. The Blooston Rural Carriers also continued their fight against the prospect of HAC in-store testing and other requirements for independent retailers since this would have a harmful impact of small and rural service providers that rely on networks of independent retailers in order to compete with larger carriers. A Report and Order addressing these issues is expected in early 2011. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Cary Mitchell.

CHINESE COMPANY EXPECTS HUGE GROWTH IN 4G LTE NETWORKS: Reuters reports that China's Huawei Technologies says it expects to double the number of fourth-generation (4G) commercial networks it is building in 2011, meeting a need for more bandwidth to power devices, such as Apple's iPhone. The number of trial Long-Term Evolution (LTE) networks that Huawei was building was also expected to rise to 100 in 2011 from 70 this year, according to multiple press reports. The company is currently building 18 commercial LTE networks. Huawei also expected revenue from its LTE operations to contribute a significant percentage of total revenue by 2014. The LTE market was expected to grow to $6 billion by 2014, industry research firm Dell'Oro said, making it a lucrative growth area for Huawei and rivals such as Motorola Inc and Nokia Siemens Networks. Huawei indicated it was interested in partnering with companies in the United States.

WI-FI MAY POSE SECURITY THREAT TO AIRLINERS? According to the Atlanta Journal Constitution (AJC), Wi-Fi service may pose a security threat on board airliners. The question arose after Yemeni terrorists tried recently — and failed — to destroy two U.S.-bound cargo planes by stuffing printer cartridges full of explosives and then detonating the charges in flight. AJC reported that a British explosives consultant created a stir when he told New Scientist magazine that Wi-Fi is a "Pandora's box" for terrorists and that giving passengers Internet access "gives a bomber lots of options for contacting a device on an aircraft.” A number of airline workers, security professionals and technologists say they agree that Wi-Fi can create serious security risks. The Association of Flight Attendants, for example, has asked the government to ban Wi-Fi. AJC said the Yemeni bomb plot demonstrates one way Wi-Fi could facilitate terrorists. Wi-Fi and Internet-enabled calls could enable a terrorist to maneuver around the U.S. ban on the use of cell phones on airplanes and actually trigger a bomb. Banning Wi-Fi use completely or during high security-alert periods are two of several proposals the Department of Homeland Security is considering. TSA spokesman Greg Soule said DHS was “using the latest intelligence and state of the art technology to address ever-evolving threats.” While the Yemeni bombs contained cell phone components, they do did not appear to have been designed to detonate with a phone call but by cell phone alarm; that is, communication with the plane would not have been necessary to set off the bombs. But since the call-activated bomb is an established technique, terrorists could conceivably hide devices in checked luggage and then trigger them through an Internet-enabled call, AJC noted. The debate comes at a time when airlines are ramping up their marketing of Wi-Fi service to passengers. AirTran and Delta Air Lines, for example, have partnered with Google to offer free Wi-Fi aboard hundreds of their planes during the holidays. At Southwest Airlines, where Internet service is being installed on airplanes, a spokesman Chris Mainz said their broadband doesn't work that way. “Our Wi-Fi product will not enable cell phone-to-cell phone interaction and it blocks Voice over Internet Protocol,” he told AJC. Whether Voice over Internet Protocol (VoIP) can be completely restricted is not entirely certain. Aircell, the airline Internet company in Illinois that provides broadband to airlines including Delta, AirTran and American Airlines under the name Gogo, declined to be interviewed for the AJC story. But earlier this year, AJC said, Aircell released a statement saying it is “extremely difficult to stop every instance of VoIP.” Delta Air Lines declined to comment on its security practices. In opposing the use of cellphones on airplanes in the U.S., DHS, the FBI and the Department of Justice said in 2005 that they were concerned that terrorists or hijackers could use the phones to “facilitate a coordinated attack,” either with someone on the ground, on another airplane or even among people sitting in different sections of the same airplane.

SBA IDENTIFIES SMALL BUSINESS BROADBAND NEEDS AND GAPS: The Small Business Administration (SBA) recently published a report titled “The Impact of Broadband Speed and Price on Small Business,” which identifies small business broadband needs as well as differences between broadband availability, performance and price for urban and rural small businesses. This report is a result of a nationwide survey of 425 urban and rural small businesses conducted by Columbia Telecommunications Corp. combined with research about broadband markets in the U.S., Europe and Asia. Respondents indicated that high-speed broadband Internet is as essential to their business as other utilities such as water, sewer, or electricity. Although the survey finds that small businesses are embracing broadband, many are unsatisfied with the lack of choice in service providers, inadequate speeds and high prices. SBA also found that although rural and urban small businesses have similar broadband needs, there are some notable differences in terms of the speeds available to rural businesses and the prices for high speed service in rural areas. Small business broadband needs are expanding rapidly so business can utilize e-commerce, telecommuting, video-conferencing, data backup, security monitoring and many other innovative technologies. However, the demand for broadband speeds above 5 Mbps is outpacing availability, especially in rural areas. Not only will today’s broadband speeds be completely inadequate in the near future, but “this situation places small business in the U.S. at a competitive disadvantage against many businesses across the globe.” According to the survey results, one-quarter of the respondents need at least 10 Mbps and around one-third desired speeds of 50 Mbps or more—speeds that are difficult to find in most of the U.S. Rural small businesses were also more likely to switch to 100 Mbps and 1,000 Mbps broadband regardless of price, indicating that some businesses are desperate to have access to higher speeds. The SBA acknowledges that broadband has a significant impact on rural small businesses, but overall rural small businesses were less likely to have a website or use e-commerce tools than urban small businesses. The combination of limited provider and service offering choice plus insufficient speeds indicate that “the provider market has not fully responded to the rural small business customer market for service.” SBA provides eight recommendations to help the Internet marketplace meet the needs of small businesses. Recommendations include following through with National Broadband Plan regulatory and funding goals; continually increasing broadband speed and capacity; developing incentive programs focused on small businesses to improve broadband-related decision making and adoption; and making sure small businesses have ample access to information about broadband options, uses and benefits. Additionally, SBA suggests that small business needs should be considered in Universal Service reforms. Universal Service has traditionally focused on institutions (schools, libraries and health care) and residential service, but “the importance of small business in the daily lives of Americans and in the economic life of the nation cannot be underestimated.” SBA believes that small business-targeted funding could help reduce the rural/urban small business broadband gap. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

FCC To Review Its Tower Registration Program

To comply with its obligations under the National Environmental Policy Act (NEPA), the FCC is conducting a Programmatic Environmental Assessment (PEA) of its Antenna Structure Registration (ASR) program. The purpose of the PEA is to evaluate the potential environmental effects of the Commission’s ASR program. The Commission is undertaking the PEA in response to the determination of the U.S. Court of Appeals for the District of Columbia Circuit in American Bird Conservancy v. FCC that registered towers may have a significant environmental effect on migratory birds. In the course of the PEA, the Commission will consider alternatives to address potential environmental effects, and will determine whether a more extensive analysis, in the form of a programmatic Environmental Impact Statement, may be required under NEPA.

Under the ASR program, owners of antenna structures that are taller than 200 feet above ground level or that may interfere with the flight path of a nearby airport must register those structures with the FCC. The antenna structure owner must obtain painting and lighting specifications from the Federal Aviation Administration and include those specifications in its registration prior to construction. The ASR program allows the FCC to fulfill its statutory responsibility to require painting and lighting of antenna structures that may pose a hazard to air navigation.

The FCC will hold three scoping meetings for the public to provide input to the PEA process. The meetings will be open to the public; however, admittance will be limited to the seating available. Each scoping meeting will be comprised of an Information Session, a Presentation and a Formal Comment Period. Comment forms will be available, and may either be completed at the meeting, submitted through the PEA website, or mailed. Formal verbal comments will also be transcribed for public record by a stenographer at the meetings. PEA informational materials will be available at the meetings. Information gathered at the meetings will be used to prepare the PEA. The meetings are scheduled as follows:

On December 6, 2010, from 1:30pm until 4:30pm Eastern Time, at the FCC’s Meeting Room, 445 12th Street, SW, Washington, DC. Audio/video coverage of this meeting will be broadcast live with open captioning over the Internet from the FCC's web page at www.fcc.gov/live. The FCC’s webcast is free to the public. Those who watch the live video stream of the event may email event-related questions to livequestions@fcc.gov. Depending on the volume of questions and time constraints, FCC representatives will respond to as many questions as possible during the workshop.

On December 13, 2010, from 6:00pm until 8:30pm Pacific Time, at the Council Chambers, City of Chula Vista Civic Center, 276 Fourth Avenue, Chula Vista, California.

On December 15, 2010, from 6:00pm until 8:30pm Eastern Time, at the John F. Germany Public Library, 900 North Ashley Drive, Tampa, Florida.

Individuals requiring special assistance during a meeting should submit a request through the PEA website no later than two business days prior to the applicable meeting.

In addition to the scoping meetings, the Commission seeks written comments to assist it in preparing the PEA. Interested parties may file comments on or before January 14, 2011 in the WT Docket No. 08-61 and WT Docket No. 03-187 proceeding.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Richard Rubino, and Cary Mitchell.

FCC Announces Application Process For Certain 800 MHz Channels Let Go By Sprint

The FCC ‘s Public Safety and Homeland Security Bureau (PSHSB) has announced that on December 16, 2010, it will begin accepting applications for licensing of certain available channels in the 809.5-815/854.5-860 MHz (Channels 251-470) portion of the 800 MHz band that have been, or will be, relinquished by Sprint Nextel in certain National Public Safety Planning Advisory Committee (NPSPAC) regions. Applicants who receive licenses for channels vacated by Sprint must provide 60 days notice to Sprint before they activate a channel for testing or the commencement of operations.

In July 2004, the FCC ordered the reconfiguration of the 800 MHz band to eliminate interference to public safety and other land mobile communication systems operating in the band. As part of this plan, the Commission provided that spectrum vacated by Sprint in the Interleaved Band (809-815/854-860 MHz) would temporarily be made available for licensing exclusively to public safety and critical infrastructure industry (CII) entities. Specifically, the Commission ordered that, upon initiation of licensing, eligibility for the vacated interleaved band channels will be limited to public safety entities for the first three years after the opening of a filing window and to public safety and CII entities for the following two years. After five years, any remaining vacated channels will revert to their original frequency pools and be available for licensing to any eligible applicant.

The Interleaved Band channels are being made available for licensing and use by eligible public safety agencies in each NPSPAC region on a staged basis. After new licenses are granted, Sprint will vacate any channel on 60 days notice from the new licensee that it is ready to use the channel. The channels that will be newly available to public safety agencies are identified by region in Appendix A. In certain NPSPAC regions, all vacated Interleaved Band channels will be available. In other NPSPAC regions, Interleaved Band channels continue to be released in stages as follows:

• Stage 1: Sprint channels in the 809-809.5/854-854.5 MHz block of the Interleaved Band were made available in non-border NPSPAC regions. This stage was initiated on January 28, 2009 and applications for these channels may still be filed.
• Stage 2: Sprint channels in the 809.5-810.5/854.5-855.5 MHz block will be available in each region when 10% of channels in the former NPSPAC block (i.e., 12 channels) are clear in the NPSPAC region.
• Stage 3: Sprint channels in the 810.5-812/855.5-857 MHz block will be available in each region when 50% of channels in the former NPSPAC block (i.e., 60 channels) are clear in the NPSPAC region.
• Stage 4: Sprint channels in the 812-814/857-859 MHz block will be available in each region when 75% of channels in the former NPSPAC block (i.e., 90 channels) are clear in the NPSPAC region. Sprint will also make its channels in the 814-815/859-860 MHz block available if there is public safety demand for additional channels in the NPSPAC region.
• Stage 5: To the extent that channels in the 814-815/859-860 MHz block have not been made available in Stage 4, Sprint channels in this block will be available in each region when 90% of channels in the former NPSPAC block (i.e., 108 channels) are clear in the NPSPAC region.

To facilitate licensing of available channels, Sprint has cancelled or modified a number of its site-based and Economic Area (EA)-based licenses that include channels in the 809.5-815/854.5-860 MHz band (Channels 251-470) in certain regions. Currently, the amount of spectrum vacated by Sprint varies by NPSPAC region. The FCC is announcing that additional spectrum, up to Stage 5 in some regions, will be available for application beginning on December 16, 2010. For further information, please contact the firm.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Richard Rubino, and Gene Maliszewskyj.

FCC Seeks Comment On Thales’ 700 MHz Public Safety Waiver Request

The FCC seeks comment on the request for waiver filed by Thales Communications Inc. to permit it to manufacture and market its “Liberty Multiband Land Mobile Radio” for use by 700 MHz narrowband public safety licensees operating in the 775-776/805-806 MHz Guard Band.

The 775-776/805-806 MHz band segment was originally part of the 700 MHz public safety spectrum designated for narrowband use. In the 700 MHz Second Report and Order, the Commission reconfigured the 700 MHz public safety spectrum to create a broadband segment at 763-768/793-798 MHz, and consolidated 700 MHz narrowband channels at 769-775/799-805 MHz. As a result of the reconfiguration, the 775-776/805-806 MHz band was redesignated as guard band spectrum. However, the Commission allowed certain incumbent narrowband licensees to continue operating legacy equipment on the pre-consolidation narrowband frequencies, including 775-776/805-806 MHz, pending their eventual relocation to the new consolidated narrowband segment.

In its petition, Thales notes that licensees operating in the 775-776/805-806 MHz guard band are limited to using legacy equipment, and that equipment manufacturers are not able to certify new public safety equipment for use in this band. Thales contends that this prevents these licensees from “acquiring and deploying more effective, efficient, and appropriate multi-band equipment” while they remain in the 775-776/805-806 MHz guard band, which limits their ability to achieve interoperability. Thales contends that allowing these licensees access to multiband radios, such as the Thales Liberty Radio, would result in significant benefits, including more flexible deployment options, enhanced spectrum utilization and efficiency, improved interoperability, and lower costs. Accordingly, Thales requests waiver of Sections 2.106 and 90.531(b) of the Commission’s rules, and such other relief as may be necessary, to:

• Permit temporary extension of the authorized Part 90 frequencies specified on the Thales Equipment Authorization to include 775-776/805-806 MHz.
• Permit the Thales Liberty Radio to be marketed to, purchased by, and operated by public safety narrowband licensees that are currently authorized to operate in the 775-776/805-806 MHz band.

The FCC seeks comment on the Thales petition and encourages commenters to address any issues that they consider to be material to the FCC’s consideration of this petition. The FCC also seeks comment on whether the waiver relief sought by Thales, if granted, should be extended to equipment offered by other equipment manufacturers. Comments in this PS Docket No. 10-233 proceeding are due December 13, and replies are due December 28.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Richard Rubino, and Cary Mitchell.

FCC Grants D.C. Extension For 700 MHz Waiver Request

The FCC’s Public Safety and Homeland Security Bureau has granted the request for waiver by the District of Columbia for a 45-day extension to pay the administrative fee due to the Public Safety Spectrum Trust (PSST) under the budget previously approved by the Bureau for administration of the long term de facto spectrum leases in the 700 MHz public safety broadband spectrum.

On May 12, 2010, the Commission granted, with conditions, twenty-one waiver Petitions filed by public safety entities seeking early deployment of statewide or local public safety broadband networks in the 700 MHz public safety broadband spectrum (763-768 MHz and 793-798 MHz). The Commission found that the Petitioners generally met the standard for waiver of the Commission’s rules and that the public interest warranted allowing early deployment, so long as the conditions imposed by that order were met. Among other conditions, the Commission required that each Petitioner obtain a long term de facto spectrum lease from the PSST.

The Commission further required the PSST to submit for Bureau approval a budget for any proposed administrative fees to be paid by the Petitioners under the leases. On August 11, 2010, the Bureau approved the PSST’s proposed budget, finding the proposed $15,000 first year administrative fee to be reasonable. The Bureau appended the approved budget to the Budget Order, which included the notation that administrative fee payments would be due 60 days after the approval of a Petitioner’s lease. The Bureau approved the submitted leases on September 2, 2010.

On October 21, 2010, the District filed a request seeking a waiver of the 60-day deadline for submission of the administrative fee to the PSST. The District stated that while it was in the process of effectuating the payment, unforeseen administrative delays rendered it unable to make payment by November 1, 2010. The District “requests a waiver such that its payment of the fee within 45 days of November 1 (i.e., by December 15, 2010) be considered timely under FCC rules and the District’s lease with the PSST.” The District asserted that the requested delay is “minor,” and that the payment is already in process. The District stated that failure to grant the waiver would frustrate the goal of deploying broadband to protect public health and safety, and that such a minor delay was vastly outweighed by the benefits that the District’s Long Term Evolution (LTE) network will provide to the public.

In granting the waiver request, the FCC said that while the conditions imposed on the Petitioners, including those related to the administrative fee payments, cooperation with the PSST, working with the Emergency Response Interoperability Center (ERIC) and other related deadlines and reporting, were found necessary and appropriate to ensure that the Petitioners had sufficient planning and commitment to the deployment process. While the FCC found that the limited waiver requested by DC is warranted under the circumstances presented by the District, it encourages all Petitioners to proceed diligently with each of the conditions imposed by the Waiver Order to ensure timely progress and open collaboration with all stakeholders.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Richard Rubino, and Cary Mitchell.

PG&E Seeks Construction, Service Discontinuance Waivers To Build PLMR

The FCC’s Wireless Telecommunications Bureau (WTB) seeks comment on requests filed by Pacific Gas & Electric Company (PG&E) for extended construction periods and waivers of the rule prohibiting permanent discontinuance of operations, to permit implementation of a wide-area private land mobile radio (PLMR) system using Part 22 and Part 90 spectrum. Specifically, PG&E seeks an extended construction period, until June 30, 2013, for proposed new Part 90 trunked Industrial/Business Pool stations (radio service code YG) in California; and waivers of the permanent discontinuance rules to permit PG&E to discontinue operation until June 30, 2013 of existing Part 90 conventional and trunked Industrial/Business Pool stations (radio service codes IG and YG), Part 90 conventional and trunked commercial Industrial/Business Pool stations (radio service codes IK and YK), and Part 22 VHF/UHF Paging stations (radio service code CP), the licenses for which PG&E has acquired by assignment.

PG&E also seeks to modify the licenses for the IK and YK stations, and a waiver of the common carrier requirement with respect to the CP stations, to permit the stations to be used for PLMR operations. In addition, if the waivers are granted with respect to the pending applications, PG&E will file identical waiver requests with respect to other existing stations the licenses for which PG&E has acquired by assignment. PG&E also anticipates filing additional applications for new 90 trunked Industrial/Business Pool stations, or for modification of existing licenses, for which it also will request a June 30, 2013 construction deadline.

PG&E serves approximately 5.1 million electricity customers and 4.2 million natural gas customers across northern and central California. PG&E states that it plans to replace various existing radio systems with a single, integrated system that maximizes efficiency through trunking and frequency re-use, and provides functionality not available in PG&E’s legacy systems. The new integrated trunked radio network will consist of over one hundred repeater sites, and thousands of mobile and portable units. PG&E states that it will need to discontinue operation of the existing stations at issue for extended periods during implementation of the new network. The project plan calls for the proposed system to be implemented and funded in phases. While the proposed implementation plan contemplates completion of the project by the end of 2012, PG&E requests construction deadlines and authority to discontinue operations until June 30, 2013 to provide additional time in case of any unforeseen delay.

The comment cycle in this WT Docket No. 10-217 proceeding closes on November 22, but there are opportunities for ex parte presentations after that deadline.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

FCC Modifies PLMR License For Failure To Take Action

In an Order of Modification, the FCC modified the license of Fred Vetter for Private Land Mobile Radio (PLMR) Station WPVZ929 to replace frequency pair 810/855.6125 MHz with frequency pair 816/861.5125 MHz. The FCC took the action pursuant to an earlier order proposing to modify Vetter’s license.

Vetter is the licensee of PLMR Station WPVZ929 in Pemberville, Ohio, which is authorized to operate on frequency pair 810/855.6125 MHz. Under the provisions of the Commission’s 800 MHz rebanding proceeding, Vetter must retune Station WPVZ929 from frequency pair 810/855.6125 MHz to frequency pair 816/861.5125 MHz at Sprint Nextel’s expense. Pursuant to the terms of Commission’s 800 MHz Second Report and Order, and the Implementation Plan established by the 800 MHz Transition Administrator, Vetter was required to submit a cost estimate for this retuning by January 12, 2009.

In the 800 MHz Report and Order, the Commission charged all parties with a duty to act in good faith and warned parties that failure to act in good faith could result in license modification and involuntary relocation. Despite repeated urging on the part of the 800 MHz Transition Administrator, the FCC said Vetter failed to provide either the requisite cost estimate to Sprint Nextel or to request additional time to complete planning from the Public Safety and Homeland Security Bureau.

In an Order Proposing Modification (OPM) released July 30, 2010, the FCC proposed to modify Vetter’s license by replacing frequency pair 810/855.6125 MHz with frequency pair 816/861.5125 MHz. Vetter was afforded thirty days to protest the OPM.

Because Vetter failed to protest the proposed modification of his license within thirty days, the FCC said he is deemed to have consented to the proposed modification. Based on the record in this matter, the FCC said he is must modify the authorization for PLMR Station WPVZ929, as proposed in the OPM, and all costs associated with relocating to the new frequency pair must be borne by Vetter.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

FCC Extends Waiver For Garmin To Market GPS-Equipped Family Radios

The FCC has extended a waiver of the General Mobile Radio Service (GMRS) rules permitting Garmin International, Inc. (Garmin) to market GMRS transceivers with the capability of transmitting Global Positioning System (GPS) coordinates as non-voice data. In 2004, the Public Safety and Critical Infrastructure Division (PSCID), Wireless Telecommunications Bureau (WTB) granted Garmin a two-year conditional waiver of the Commission’s Rules, which has subsequently been extended multiple times. On September 22, 2010, Garmin requested a further extension. Garmin’s conditional waiver is now extended pending the outcome of a rulemaking proceeding on the issue, under the same terms and conditions as the initial waiver.

The Commission adopted rules establishing the future GMRS over fifty years ago as a short-distance two-way land mobile radio service available for communications that facilitate personal or business activities of licensees and their immediate family members. In 1988, the Commission amended the GMRS rules to provide flexibility to the individual user and limit eligibility for new GMRS licenses to individuals. In 1996, the Commission established the Family Radio Service (FRS) as a very short range, two-way voice personal radio service that provides an affordable and convenient means of communications among small groups of persons, including families, with minimal regulation. The FRS shares seven frequencies in the 462 MHz band with the GMRS and has seven channels that are offset from GMRS channels in the 467 MHz band.

In 2000, Garmin, a designer and manufacturer of consumer electronic devices, requested a waiver of the FRS rules to allow it to manufacture standard FRS voice communication radios incorporating an enhancement that would permit transmission of GPS location information. On September 29, 2000, the Bureau’s Public Safety and Private Wireless Division (PSPWD) granted Garmin a partial waiver of the Commission's Rules to allow it to manufacture and market transceivers capable of transmitting GPS location information on FRS channels. Under its waiver grant, PSPWD permitted Garmin to receive FCC certification of a FRS unit that would permit users to transmit GPS location information using emission type F2D in a digital data burst of not more than one second. Later that year, Garmin filed a petition for rulemaking seeking to amend the Commission’s Rules essentially to codify the terms of the waiver. In 2003, the Commission amended its rules to permit FRS transceivers to transmit GPS location information (including automatic responses to interrogation — polling — from other units) and user-generated text messages.

Garmin subsequently requested other waivers regarding improvements to its system, and these were granted, as noted above. In its current petition, Garmin seeks a further extension pending resolution of the 2003 Petition for Rulemaking. Garmin asserts that granting the extension would provide authority for Garmin to continue marketing equipment that has saved, and will continue to save, lives. Moreover, Garmin alleges that due to the efficiency of its non-voice data transmissions, it has not received any reports of harmful interference from the operation of its equipment.

The FCC granted an extension of the waiver permitting Garmin to manufacture and market GMRS transceivers capable of transmitting GPS location information on GMRS channels until the resolution of the 2003 Petition for Rulemaking in WT Docket No. 10-119, subject to all of the conditions for transmitting location data and text in the FRS and the following additional conditions and requirements set forth in the 2004 Order:

—Garmin must design the units it proposes to manufacture such that the mobile units capable of transmitting text and GPS location data have integrated (i.e., non-detachable) antennas.

—Garmin must design the units it proposes to manufacture such that transmission of text and GPS location data is limited to 462 MHz GMRS channels, as specified in Section 95.29(a) and (f), which channels are not repeater input frequencies.

—Garmin must design the units it proposes to manufacture such that transmission of text and GPS location data is limited to an authorized bandwidth of no more than 12.5 kHz.

—Garmin must design the units it proposes to manufacture such that a unit cannot automatically (i.e., without manual action or command) poll other units to determine their location based on GPS-derived location information.

—Grant of this waiver is subject to the resolution of Garmin’s pending petition for rulemaking, RM-10762.

—The FCC may immediately terminate the waiver if harmful interference is reported to the Commission.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

FCC Clarifies that Government Entities Applying for Industrial/Business Channels Must Still Meet Eligibility Requirements that Apply to Private Entities

The FCC has granted the informal petitions, filed by the Central Station Alarm Association (CSAA), to deny the applications filed by the Franklin Regional Council of Governments for new Industrial/Business Pool stations at various locations in Massachusetts.

In July 2010, Franklin filed the applications to operate on frequency 461.000 MHz at various locations in Massachusetts. Frequency 461.000 MHz is subject to Section 90.35(c)(66) of the Commission’s Rules, which states, “This frequency may be assigned only to persons rendering a central station commercial protection service, which is defined in paragraph (c)(63) of this section, within the service area of the radio station utilizing the frequency.” Section 90.35(c)(63) of the Commission’s Rules defines “a central station commercial protection service” as “an electrical protection and supervisory service rendered to the public from and by a central station accepted and certified by one or more of the recognized rating agencies, or the Underwriters Laboratories’ (UL), or Factory Mutual System.”

CSAA filed informal petitions to deny the applications. CSAA argues, inter alia, that Franklin does not meet the definition of central station commercial protection service because it does not use a certified central station, and it does not render alarm service to the public.

Franklin did not dispute that it does not meet the definition of central station commercial protection service. Instead, it argued that alarm frequencies may be used by other entities outside of certain specified urbanized areas, so it concludes that its proposed operations are permitted because they would be outside these urbanized areas. Franklin also argued that the Commission’s recent amendment of Section 90.35(a) of the Commission’s Rules to clarify that governmental entities are eligible for Industrial/Business Pool spectrum makes it eligible for the requested frequency.

The FCC disagreed with Franklin’s interpretations of Section 90.35. First, Section 90.35(c)(66) does not incorporate every provision of Section 90.35(c)(63); rather, the only part of Section 90.35(c)(63) that is incorporated into Section 90.35(c)(66) is the definition of central station commercial protection service. Therefore, a frequency that is subject to Section 90.35(c)(66) but not to Section 90.35(c)(63) — like frequency 461.000 MHz — is designated exclusively for central station commercial protection service operations nationwide, even outside the specified urbanized areas.

With respect to Section 90.35(a), the Commission only clarified that government entities that engage in commercial activities, like the operation of a utility or golf course, are eligible for Industrial/Business Pool spectrum on the same basis as private entities that engage in such activities. It did not relieve them of any eligibility requirements for particular Industrial/Business Pool frequencies.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Cary Mitchell.

FCC Denies Motorola Waiver Request At 450-470 MHz

The FCC has denied Motorola’s request for a blanket waiver of the required five megahertz separation between paired 450-470 MHz band base and mobile frequencies. The FCC noted that frequencies in the 450-470 MHz band can be assigned singly for simplex operations or in pairs for duplex operations, but paired frequencies must have a five megahertz separation. Low power systems authorized pursuant to Section 90.267 of the Commission’s Rules operate either with a 450-455 MHz base transmit frequency and a 455-460 MHz mobile transmit frequency five megahertz higher, or with a 460-465 MHz base transmit frequency and a 465-470 MHz mobile transmit frequency five megahertz higher.

Motorola sought a blanket waiver of the required separation for low power systems authorized pursuant to Section 90.267. It argued that a waiver would serve the public interest by promoting more effective utilization of spectrum, because it would facilitate the deployment of low power repeaters with non-standard separation to avoid the occurrence of intermodulation interference when multiple repeater cells are used within close proximity.

The FCC concluded that Motorola has not demonstrated that grant of a blanket waiver is warranted. The Commission said that Motorola’s proposals would increase the complexity of frequency coordination in the 450-470 MHz band. Motorola concedes that its proposed conditions would not completely eliminate the increased potential for interference. Also, Motorola has not addressed the detrimental effect on spectrum efficiency of forming one non-standard frequency pair from two standard frequency pairs. Finally, Motorola has not demonstrated that the occurrence of intermodulation interference when multiple repeater cells are used within close proximity is so common a problem that a blanket waiver is required.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

FCC Grants TA Waiver To NPSPAC Licensee in P.R.

The FCC has granted the 800 MHz Transition Administrator, LLC, (TA’s) request for a waiver of Section 90.621(b) of the Commission’s rules (co-channel spacing) in order to allow NPSPAC licensees in Puerto Rico to relocate to the “new” National Public Safety Planning Advisory Committee (NPSPAC) public safety band (806-809/851-854 MHz) as part of 800 MHz rebanding. The FCC said the waiver is necessary because Preferred Acquisitions, Inc. holds Economic Area (EA) licenses in the 806-809/851-854 MHz band in Puerto Rico.

The 800 MHz Third Report and Order established a new 800 MHz band plan for Puerto Rico, which requires that all non-NPSPAC incumbent licensees vacate the 806-809/851-854 MHz band segment so that NPSPAC licensees can relocate there. Preferred’s EA licenses are the only remaining non-NPSPAC licenses in that band segment, but Preferred has not constructed facilities in the band. Pursuant to the Commission’s rebanding orders, Preferred is required to vacate the 809-809/851-854 MHz band and has elected to relocate to the ESMR portion of the 800 MHz band. The TA has identified replacement frequencies in the ESMR band for Preferred’s future use. However, Preferred has not relocated to the ESMR band because the underlying status of its EA licenses is contingent on the outcome of two pending proceedings: an enforcement action against Preferred in which a proposed settlement is pending appeal, and a waiver request filed by Preferred for an extension of time to construct facilities.

The TA notes that five of the six NPSPAC licensees in Puerto Rico have negotiated their Frequency Reconfiguration Agreements (FRAs), which have been approved by the TA, and are ready to proceed with the reconfiguration of their radio systems. Absent a waiver, however, these NPSPAC licensees cannot relocate to the new NPSPAC band because doing so would result in their occupying spectrum that is still licensed to Preferred.

The FCC said the requested waiver is in the public interest because it will permit NPSPAC licensees to relocate to a band segment where they will be less susceptible to interference from ESMR and other cellular architecture stations, thus furthering the goal of 800 MHz band reconfiguration.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

BloostonLaw Licensees Oppose Proposal For Microwave “Auxiliary Stations”

BloostonLaw, on behalf of its clients that are existing and prospective licensees of point-to-point microwave radio stations, under Part 101 of the FCC’s Rules (the BloostonLaw Licensees), have opposed a portion of the Commission’s WT Docket No. 07-121 rulemaking proposal that seeks to allow the licensing of “auxiliary stations.”

While the BloostonLaw Licensees recognize the desirability for the Commission to review Part 101 to determine whether changes in the regulations can be made that will ensure sufficient microwave capacity for current and future demands for wireless backhaul, changes should not be made that will work to the disadvantage of existing licensees who will continue to rely on the availability of clean spectrum for fixed-station point-to-point requirements.

This proceeding has its genesis in a filing by Wireless Strategies, Inc. (WSI) in February of 2007. WSI had petitioned the Commission for a declaratory ruling that its proposed operations were consistent with the Commission’s Rules in Part 101 as then written. WSI’s proposal was to use lower gain antennas than are typically used in point-to-point operations that had sufficient side-lobe radiation to allow the main fixed station to communicate effectively with multiple fixed stations (now termed “auxiliary stations” by the FCC) situated all along the side lobes of the antenna – basically a point-to-multipoint operation. In effect, the licensee would be reusing its coordinated frequencies over a much larger area than in the typical point-to-point operation, thereby creating a quasi-geographic-area license.

WSI’s petition was roundly opposed by a major microwave frequency coordinator, several equipment manufacturers, an association of broadcast engineers, a major cellular carrier and others. The Commission’s Notice of Proposed Rulemaking and Notice of Inquiry (NPRM) in these proceedings denied the petition for a declaratory ruling, finding that WSI’s proposal is inconsistent with the plain wording of the Commission’s rules. Nevertheless, the Commission found that the concept was worthy of further consideration and instituted this proceeding to consider changes to Part 101 to allow operation as contemplated by WSI. While reserving judgment on the ultimate outcome, the Commission suggested certain changes to the Part 101 rules for the purpose of allaying the concerns that had been expressed by those opposing WSI’s petition.

The BloostonLaw Licensees recognize that there may be a shortage of spectrum for point-to-multipoint operations and that, in general, it is desirable to review the Commission’s rules periodically to determine whether changes can be made to accommodate innovative uses of radio without working to the disadvantage of licensees utilizing the radio spectrum for more traditional uses. Likewise, the BloostonLaw Licensees do not oppose the Commission’s rulemaking proposal solely with the idea that things that have worked well in the past should not be given a new look. Rather, the BloostonLaw Licensees remain unconvinced that WSI’s novel approach to licensing in Part 101, notwithstanding the safeguards proposed by the Commission, fit well within the parameters of Part 101 and would not result in harm to existing licensees or deplete the availability of clean spectrum in the future.

Microwave system designers and equipment manufacturers have done exhaustive engineering studies and have concluded that the proliferation of WSI’s mode of operation of point-to-multipoint systems cannot be accommodated under Part 101 without substantially increasing the potential for interference to existing point-to-point networks and exacerbating the shortage of spectrum in the future. Moreover, the public interest arguments put forth by WSI as justifying its mode of operation do not appear to be meritorious. Thus, WSI claims that when the Commission licenses point-to-point links, there are large areas in the vicinity that cannot be licensed to others because of interference concerns. WSI reasons that allowing auxiliary stations makes more efficient use of the frequency spectrum by allowing multiple stations to coexist in the vicinity. However, Comsearch has shown that this concept is not borne out by the facts. For example, Comsearch is on record as having established that in areas with high frequency density, such as Los Angeles, thousands of licensed point-to-point links are able to coexist in close proximity to each other on an interference-free basis under the current rules in Part 101. This is possible because the Commission’s current licensing scheme requires the use of minimum power and high-gain antennas with narrow beamwidths, thereby limiting side-lobe radiation. This allows for maximum utilization of the microwave frequency spectrum.

Under the licensing scheme now proposed by the Commission, would-be applicants such as WSI and its customers would have an incentive to apply for the maximum power permitted under the Commission’s rules and, with the proposed relaxation of the antenna performance standards, modulation and minimum path length requirements, the interference potential of stations thereby licensed may be expected to increase substantially. Although the Commission is proposing that auxiliary stations may not cause any increase in interference to other licensed services, this does not address how the proliferation of these auxiliary stations would deplete the availability of microwave spectrum for conventional point-to-point operations. The proposed rules therefore appear to promote inefficient utilization of the microwave frequency spectrum. Instead of stations with narrow RF propagation and clearly defined minimum interference potential, the microwave environment may be expected to degenerate into a sort of wide-area conglomeration of stations with inefficient antenna performance characteristics and poorly-defined interference parameters — tantamount to multiple quasi-geographic-area licenses.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.

NTIA Unveils Plans To Make More Spectrum Available For Broadband Service

The National Telecommunications and Information Administration (NTIA) is recommending that 115 MHz of spectrum be reallocated for wireless broadband service within the next five years. In late June, President Obama committed to make available 500 megahertz of Federal and nonfederal spectrum over the next 10 years.

In addition, the Commerce Department and NTIA have also established a plan and timetable for identifying spectrum that can be made available for wireless broadband over the next 10 years, working in collaboration with the FCC and other Federal government agencies.

NTIA released two complementary reports detailing the effort to nearly double commercial wireless spectrum: a Ten-Year Plan and Timetable, as well as a Fast Track Evaluation identifying the 115 megahertz of spectrum to be made available within five years.

NTIA developed the Ten-Year Plan and Timetable in response to the June 28, 2010 Presidential Memorandum that directed the Secretary of Commerce, working through NTIA, to collaborate with the FCC to make available a total of 500 megahertz of Federal and nonfederal spectrum over the next 10 years for mobile and fixed wireless broadband use. The 262-page report, An Assessment of the Near-Term Viability of Accommodating Wireless Broadband Systems in the 1675-1710 MHz, 1755-1780 MHz, 3500-3650 MHz, and 4200-4220 MHz, 4380-4400 MHz Bands, developed with input from other Federal agencies and the FCC, identifies 2,200 megahertz of spectrum for evaluation, the process for evaluating these candidate bands, and the steps necessary to make the selected spectrum available for wireless broadband services.

Of the 2,200 megahertz of candidate spectrum that the Ten-Year Plan and Timetable identify, 28 percent is allocated exclusively for Federal use at present, 35 percent is allocated exclusively for commercial use, and 37 percent is shared by Federal and commercial users. The 2,200 megahertz includes 280 megahertz of commercial spectrum that the FCC recommended in its National Broadband Plan be made available for mobile broadband use within five years.

In the Fast Track Evaluation report, NTIA examined four spectrum bands for potential reallocation within five years: 1) 1675-1710 MHz, 2) 1755-1780 MHz, 3) 3500-3650 MHz, and 4) 4200-4220 MHz and 4380-4400 MHz. The report recommends that various portions of these bands totaling 115 megahertz be made available for wireless broadband use within five years, contingent upon the allocation of resources for necessary reallocation activities.

Specifically, NTIA recommends reallocating 1695-1710 MHz, currently used for dissemination of severe weather information and alerts via satellites operated by Commerce's National Oceanic and Atmospheric Administration (NOAA), and 3550-3650 MHz, which would be shared with Department of Defense radar systems mainly on ships. NTIA recommends some geographic limitations on the availability of these bands to prevent harmful interference to government facilities in the 1695-1710 MHz band and to the proposed commercial services in the 3550-3650 MHz band.

Making the 1695-1710 MHz and 3550-3650 MHz band available for wireless broadband will require timely allocation of funding for affected Federal operations to engage in planning, and in some cases to make changes to their operations and redesign their equipment. For example, NOAA would need to redesign the next generation of geo-stationary meteorological satellites to move all communications below 1695 MHz or develop an alternate communications method which recognizes current reliability and availability requirements. Also, NOAA will need to redesign radio transmitters used on weather balloons and similar systems to use spectrum more efficiently to make room for satellite downlinks.

NTIA recommends further review of the 4200-4220 MHz and 4380 MHz bands, which are used worldwide for radio altimeters on aircraft. Due to the need for international regulatory action by the International Telecommunication Union and the International Civil Aviation Organization, these 40 megahertz of spectrum cannot be made available for broadband use in the United States before 2016. However, the U.S. Government will initiate the necessary action now to obtain international approvals for reallocating this spectrum by 2016.

The 1755-1780 MHz band is currently used by the Department of Defense, Federal law enforcement agencies, and other agencies for a variety of satellite, surveillance, aeronautical operations, fixed microwave and other operations. Given the number of Federal users in the band, the diversity of Federal uses, and the need to find replacement spectrum for operations that would have to be relocated from the band if it were to be made available for wireless broadband, NTIA could not complete a rigorous review of this band by October 2010. This band will continue to be a priority for analysis under the Plan and Timetable.

The FCC must conduct rulemakings in order to implement NTIA’s recommendations.

BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Cary Mitchell.

This newsletter is not intended to provide legal advice. Those interested in more information should contact the firm.

Intelligent Solutions for Paging & Wireless Data

WiPath manufactures a wide range of highly unique and innovative hardware and software solutions in paging and mobile data for:

• Emergency Mass Alert & Messaging Emergency Services Communications Utilities Job Management Telemetry and Remote Switching Fire House Automation
• Load Shedding and Electrical Services Control

PDT3000 Paging Data Terminal

• FLEX & POCSAG Built-in POCSAG encoder Huge capcode capacity Parallel, 2 serial ports, 4 relays
• Message & system monitoring

Paging Controlled Moving Message LED Displays

• Variety of sizes Indoor/outdoor
• Integrated paging receiver

PDR3000/PSR3000 Paging Data Receivers

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Specialized Paging Solutions

• Emergency Mass Alerting Remote telemetry switching & control Fire station automation PC interfacing and message management Paging software and customized solutions Message interception, filtering, redirection, printing & logging Cross band repeating, paging coverage infill, store and forward
• Alarm interfaces, satellite linking, IP transmitters, on-site systems

Mobile Data Terminals & Two Way Wireless  Solutions

Contact
Postal Address:	WiPath Communications LLC 4845 Dumbbarton Court Cumming, GA 30040
Street Address:	4845 Dumbbarton Court Cumming, GA 30040
Web site:	www.wipath.com CLICK
E-mail:	info@wipath.com CLICK
Phone:	770-844-6218
Fax:	770-844-6574
WiPath Communications

 SEE WEB FOR COMPLETE LIST:
www.preferredwireless.com/equipment CLICK HERE

Too Much To List • Call or E-Mail

Preferred Wireless Rick McMichael 888-429-4171 rickm@preferredwireless.com CLICK HERE www.preferredwireless.com/equipment OR HERE

TECHNICAL TUTORIAL

Gigahertz: One billion radio waves, or cycles per second.
1 GHz = 1,000 MHz = 1,000,000 kHz, = 1,000,000,000 Hz.

(SI=The International System of Units.)

Easy Solutions provides cost effective computer and wireless solutions at affordable prices. We can help in most any situation with your communications systems. We have many years of experience and a vast network of resources to support the industry, your system and an ever changing completive landscape.

Experts in Paging Infrastructure
Glenayre, Motorola, Unipage, etc.
Excellent Service Contracts
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Contracts for Glenayre and other Systems starting at $100
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Please see our web site for exciting solutions designed specifically for the Wireless Industry. We also maintain a diagnostic lab and provide important repair and replacement parts services for Motorola and Glenayre equipment. Call or e-mail us for more information.

Easy Solutions
3220 San Simeon Way
Plano, Texas 75023
Vaughan Bowden
Telephone: 972-898-1119
Website: www.EasySolutions4You.com CLICK
E-mail: vaughan@easysolutions4you.com

Wireless Communication Solutions

USB Paging Encoder

• Single channel up to eight zones
• Connects to Linux computer via USB
• Programmable timeouts and batch sizes
• Supports 2-tone, 5/6-tone, POCSAG 512/1200/2400, GOLAY
• Supports Tone Only, Voice, Numeric, and Alphanumeric
• PURC or direct connect
• Pictured version mounts in 5.25" drive bay
• Other mounting options available
• Available as a daughter board for our embedded Internet Paging Terminal (IPT)

Paging Data Receiver (PDR)

• Frequency agile - only one receiver to stock
• USB or RS-232 interface
• Two contact closures
• End-user programmable w/o requiring special hardware
• 16 capcodes
• POCSAG
• Eight contact closure version also available
• Product customization available

Other products

• Please see our web site for other products including Internet Messaging Gateways, Unified Messaging Servers, test equipment, and Paging Terminals.

Contact

Hark Technologies 717 Old Trolley Rd Ste 6 #163 Summerville, SC 29485

Tel: 843-821-6888

Fax: 843-821-6894

E-mail: sales@harktech.com CLICK HERE

Web: http://www.harktech.com CLICK HERE

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