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The Wireless Messaging News

Here is a bad report on a new emergency paging system in Marine City, Michigan. Before we point any fingers or jump to conclusions as to why it is not working right, let me remind you that there are many factors in a paging system that contribute to performance.

• The transmitters
• The antennas
• The adjustment of the transmitter(s) frequency, phase, and amplitude
• The design and programing of the pagers
• The location of the transmitter sites

(Just to name a few.)

TheStreet Downgrades Spok Holdings, Inc. from a “B-” to a “C” May 30th, 2017

Our friend Rex Lee has written another excellent article about smartphone security that was published in Mission Critical Communications this month.

“ Is Your Smartphone Secure ?”

Now on to more news and views.

Wayne County, Illinois

Emergency Radio Communications Wireless Messaging Critical Messaging Two-way Radio Technology Telemetry Science Paging Wi-Fi

Wireless Messaging

This doesn't mean that nothing is ever published here that mentions a US political party—it just means that the editorial policy of this newsletter is to remain neutral on all political issues. We don't take sides.

A new issue of the Wireless Messaging Newsletter is 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 web. 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 Messaging 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 Messaging 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.

I spend the whole week searching the Internet for news that I think may be of interest to you — so you won’t have to. This newsletter is an aggregator — a service that aggregates news from other news sources. You can help our community by sharing any interesting news that you find.

Editorial Opinion pieces present only the opinions of the author. They do not necessarily reflect the views of any of advertisers or supporters. This newsletter is independent of any trade association. I don't intend to hurt anyone's feelings, but I do freely express my opinions.

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Back To Paging

Still The Most Reliable Protocol For Wireless Messaging!

If you are reading this, your potential customers are reading it as well. Please click here to find out about our advertising options.

Advertiser Index

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MARS (Mobile Alert Response System)

• Paging Protocol Monitoring and Wireless Sensor Monitoring (Inovonics and Bluetooth LE)
• Improves Mobile Response Team Productivity using Smartphone App
• Low-Latency Alerts using Pagers, Smartphones, Browsers, and Digital Displays
• Automated E-mail Based Alert Response and System Status Reports
• Linux Based Embedded System with Ethernet and USB Ports
• Browser Based Configuration
• Mobile Resident Call and Wandering Resident Tracking with Bluetooth Beacons
• SMTP and SIP Inputs and XMPP Output in Development

STG (SIP to TAP Gateway)

• Monitors Rauland Nurse Call SIP Protocol
• Outputs TAP protocol to Ethernet and Serial Port Paging Systems
• Linux Based Embedded System
  
• Browser Based Configuration

A Problem

The Motorola Nucleus II Paging Base Station is a great paging transmitter. The Nucleus I, however, had some problems.

One of the best features of this product was its modular construction. Most of the Nucleus' component parts were in plug-in modules that were field replaceable making maintenance much easier.

One issue was (and still is) that two of the modules had to always be kept together. They are called the “matched pair.”

Motorola used some tricks to keep people in the field from trying to match unmatched pairs, and force them to send SCM and Exciter modules back to the factory for calibrating them with precision laboratory equipment.

The serial numbers have to match in the Nucleus programing software or you can't transmit [in simulcast mode] . Specifically the 4-level alignment ID parameter contained in the SCM has to match the Exciter ID parameter.

Even if someone could modify the programing software to “fudge” these parameters, that would not let them use unmatched modules effectively without recalibrating them to exact factory specifications.

So now that there is no longer a Motorola factory laboratory to send them to, what do we do?

I hope someone can help us resolve this serious problem for users of the Nucleus paging transmitter.

Please let me know if you can help. [ click here ]

[Thanks to Tom Harger Chief Engineer at Contact Wireless for the correction above in red. ]

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.

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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.

BlackBerry shares rocket on bullish analyst note

• Shares of BlackBerry are up 10 percent.
• The pop follows a bullish note from Citron that says BlackBerry will play a key role in autonomous cars and the internet of things.
• Citron also says BlackBerry is a perfect takeover target.

Todd Haselton | @robotodd Thursday, 1 Jun 2017 | 10:45 AM ET

Shares of BlackBerry spiked 10 percent on Thursday after a note from Citron Research setting a 24-month price target of $20 per share.

The noted short seller sees new life in BlackBerry as an internet-of-things provider and a key player in the autonomous car market.

Citron is bullish on BlackBerry's QNX operating system, which it says is a "potential game changer in autonomous driving." It names QNX's customers, which include Audi, Bentley, BMW, Buick, Chevrolet, Chrysler, Ford, Hyundai, Honda, Toyota, Volkswagen and more. Citron compared BlackBerry with Nvidia noting that the two companies are participating in markets with plenty of growth potential.

The firm addressed the bear case, in which BlackBerry's QNX technology may be quickly outclassed by tech titans such as Apple and Google , which are also investing in autonomous car technology. "Citron believes if anything this validates BlackBerry's position and makes it ripe as an acquisition target for countless suitors," it said. "Qualcomm recently purchased NXP for its exposure in Automotive, Internet of Things, security and Networking."

Citron said it's also bullish on BlackBerry because of its potential to have a big role in the internet of things, particularly as a company known for its security. Internet of things devices have a long history of being insecure, and BlackBerry is working to change that.

Kansas City

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e*Message Wireless Information Services Europe

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Incyte Capital Holdings LLC
Dallas, Texas

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Montreal, Quebec

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Communication Specialists

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Cook Paging

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MethodLink

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Citipage Ltd.
Edmonton, Alberta

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Repair and Refurbishment Services

Product Support Services, Inc.

511 South Royal Lane
Coppell, Texas 75019
(972) 462-3970 Ext. 261
sales@pssirl.com
www.pssirl.com

PSSI is the industry leader in reverse logistics, our services include depot repair, product returns management, RMA and RTV management, product audit, test, refurbishment, re-kitting and value recovery.

When a Failure to Communicate is Not an Option ^®

New Product Release

InfoRad Inc
800-228-8998 x31
216-531-1313 x31
sales@inforad.com
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Announcing InfoRad Wireless Pro Messenger Gateway

InfoRad Wireless Pro Messenger desktop messaging software provides connectivity to InfoRad's cloud based Messaging Gateway to send text messages to cell phones, pagers, or other wireless devices i.e. IOT & M2M. 100% network reliability with 99.7% of messages delivered in 30 seconds.

InfoRad Wireless Pro Messenger  software messages through the  InfoRad Messaging Gateway  which eliminates the need to obtain a special account with each carrier for enterprise level messaging over the Internet and / or using unreliable email-to-text messaging. Additionally, the InfoRad Messaging Gateway provides other messaging enhancements such as text to voice, and response options.  Message delivery reliability is 99.7 % in 30 seconds along with redundant network support. The InfoRad Wireless Pro Messenger desktop software license is free.  Message bundles are purchased in advance and never expire.  

Contact InfoRad sales today or click on the following link to register your request for your FREE copy of InfoRad Wireless Pro Messenger Software which includes a FREE 30-day / 1000 message bundle trial of the InfoRad Messaging Gateway:

http://www.inforad.com/InfoRadGatewayRequest.html

On receipt of your request you will receive an email with  a download link for InfoRad Wireless Pro Messenger software and your InfoRad Messaging Gateway Account setup information.

Current InfoRad customers of other products may also request a FREE 30-day / 1000 message bundle trial of the InfoRad Messaging Gateway (requires product version v10.4.2).

About InfoRad Inc.
Since 1983, InfoRad, Inc. has been developing and integrating wireless messaging technology, serving a broad range of wireless users in public safety, medical, industrial, and commercial markets. With continued advances in Smartphones, tablets, text pagers and infrastructure technology (IOT & M2M), InfoRad has maintained a leadership role in the industry. By designing and incorporating new features, providing first class support, and being customer focused, the more than one-half million InfoRad users continue to benefit from our software and system solutions that are robust, cost effective and state-of-the-art.

Specialists in sales and service of equipment from these leading manufacturers, as well as other two-way radio and paging products:

	Motorola SOLUTIONS
	Motorola MOBILITY

False Alarms

Bill Mahon describes a decade of inaccurate emergency communications on campuses and provides advice on how to avoid these situations going forward.

By Bill Mahon May 22, 2017

Colleges and universities across the United States are spending tens of millions dollars to create and operate emergency communications systems. Yet as officials at the University of Texas at Austin discovered recently during a deadly knife attack on the campus, students have their own informal system for communicating in an emergency.

As is usual in such emergencies, students in Texas pushed out warnings much faster than campus officials. Also as usual, that information was often inaccurate.

Or consider the recent incident at Colgate University . A student reported seeing a man with a gun enter a campus building. Following the same protocol that exists on many American campuses, an emergency alert was issued to thousands of people. And then another, this one reporting an active shooter and calling for a campus lockdown. As expected, panic ensued.

In reality, the alleged gunman was actually a student carrying a glue gun for a class project. The fact the student was black raises a whole other set of issues for the campus.

Even in situations where an institution generates a digital message to thousands of smartphones within minutes of an actual campus attack, like the one last November at Ohio State University, it can be too late. Ohio State pushed out a Buckeye Alert message just five minutes after that knife attack began on Nov. 28. By then, a campus police officer had already shot the assailant to death. Although the danger was over, the message still generated panic.

We have trained a digital generation to expect instant information on Facebook Live, Snapchat and Twitter. If accurate details are not available, people without accurate information quickly step in to fill the void.

Many of our students are so digitally adept they have thousands of followers on their campus and around the world. But while they may have a powerful $700 smartphone, they do not have training in journalism or emergency management.

Inaccurate distribution of emergency information by students on college campuses has been going on for more than a decade. On the evening of Dec. 13, 2007, no shooting occurred on Penn State’s University Park campus. No shooting at all. Tens of thousands of students and employees and visitors were all safe.

That’s exactly when all hell broke loose.

Campus police and the county 911 emergency center were overwhelmed with panicked callers. Armed officers were dispatched around the campus. Frightened students locked themselves in their rooms on and off campus. Some called their parents for reassurance that everything would be OK. Breathless news reporters called PR staff members at home wanting to know why a SWAT team rushed inside one of the residence halls.

Worried callers wanted to know about the gunman in Atherton Residence Hall. Some called about the gunman in the library. Others wanted to know about the student union building, and more called about a sighting of the elusive gunman a block off the campus.

The more police responded, the more the frantic calls increased.

After a few hours, it became clear that there was no gunman.

During those chaotic hours, I called police. I called administrators. I called my staff. But I resisted the idea of sending out an official text alert that a possible gunman was roaming campus. Years of experience as a police reporter and as a communications professional told me this emergency did not sound right.

If I made the wrong decision, people could die. I pictured myself sitting before a congressional committee a few months later testifying why I hesitated to push the send button on my BlackBerry with a message that might have saved lives. How would I face angry, grieving parents?

Up until that evening I believed, as vice president of university relations, that I oversaw one of the largest text alert systems in the country. I was shocked to discover students had their own system. And while the university could quickly communicate accurate information to 50,000 people, the students could reach one another, parents and news media just as easily with information nobody had vetted for accuracy.

What started out a few hours earlier that day as a well-meaning public warning from the local, off-campus police department about a suspected murderer spotted a few miles from campus at a motel on Atherton Street morphed into rumors among students of the alleged gunman being on the campus in Atherton Hall. And a bunch of other places.

That’s when police phone lines went crazy. Really, really crazy.

The next morning I visited the campus police station and listened to a recording of the calls that dozens of people, some nearly hysterical, made the night before. It was a classic, modern-day exercise in mass hysteria.

And, at that moment, I realized I did not have the biggest, most complete communications system on the campus. The students had a far bigger one. And unfortunately, they had absolutely no checks or balances on the claims they were sharing with one another.

When I arrived at the office the next day, I received a call from an angry woman. She rang me from London to tell me how stupid I was for not sending out emergency text alerts the night before.

She was the parent of a student who locked herself in her off-campus apartment during the fake crisis. She barricaded the door and, for more than an hour, talked with her mother 3,000 miles away for comfort.

I told the woman the only information I could have shared by text alert for a couple hours the night before was that police were receiving multiple reports about a dangerous gunman all over campus and downtown. I felt in my gut the information was wrong, but it was just my gut. Using the best information we had at the time would have put an official stamp on further panic and confusion.

She believed, after listening to the terror in her daughter’s voice, the best course of action was to issue a series of text alerts with information about each of the sightings and that, by the end of the night, it would all be resolved. A kind of digital three-act drama told in a frantic series of 160-character text messages — all of them inaccurate except the final one.

But if I had given the all clear without facts, it could have been a bigger disaster if gunmen were actually roaming four different campus buildings.

I still think the imperfect but correct call was to not send a series of confusing, inaccurate text alerts throughout the evening as the rumors expanded in size and locations on student social media and text-message systems. The news media were already converging on the campus, and we didn’t need to attract more coverage and further hype the confusion.

In hindsight, I will say good luck and Godspeed to all the campus police and communications staff members who have to manage these situations in the future. There are many more possible wrong decisions in a crisis than there are right decisions. Indeed, with the growing number of mass shootings in our country and the expansion of civilian guns on campuses, the opportunity for mistakes has never been bigger.

In the clarity of the next day, everyone seems to know how they would handle a crisis more effectively. Just keep in mind that, in the best of scenarios, the official text-alert system will need a few minutes to distribute any information. And as we’ve seen in recent mass shootings around the country, the initial reports are often inaccurate.

The public’s informal text-communications system can jump into action immediately. Nobody will later need to apologize or be held accountable for passing on inaccurate information to a couple friends who then pass it on to 10,000 other friends.

What the police at Penn State a decade later still refer to as the “Invasion of Atherton Hall” taught me that, no matter how sophisticated official communications systems may be, the unofficial ones can have a bigger impact. In fact, long before the invention of Facebook, Twitter and text messaging, a quote sometimes attributed to Mark Twain appeared: “A lie can travel halfway around the world while the truth is putting on its shoes.”

Recommendations

So what, if anything, can institutions do? Accuracy in an emergency may always be a challenge, but they can take some steps to minimize the confusion:

• Teach students to ask themselves if the source of an emergency warning can be trusted. Campus police? Yes. That guy you met standing next to the keg at the illegal frat party Friday night? Maybe … but maybe not.
• Clean up any problem with emergency alert mistakes. They happen often. During a training session in February at the University of North Carolina at Wilmington, a false warning message circulated campus-wide: “University Police have received a report of shots fired on main campus. Immediately take shelter in a secure location away from windows, secure any doors and wait for the all-clear message. Emergency personnel are responding.” Students ran for shelter and panicked, but it was a mistake.
• Campus officials need to get it right every time. If you are going to invest millions in an emergency alert system, make sure it works and works fast -- and that people trust it.
• Consider creating a continuing public-service campaign aimed at training students and staff to post information to a campus safety message board that is continuously monitored — one digital location among hundreds that probably already exist that someone with authority can monitor and immediately and publicly respond when students and others post information that may not be accurate. Such a system allows for a digital conversation in real time with those who are panicked, upset or misinformed. If your university-branded Facebook page or Twitter feed already has a huge following, that may be the place for everyone to meet online.

Bio

Bill Mahon is the former vice president of university relations at Penn State, where he now teaches strategic communications in the College of Communications. He is a partner of University RepProtect, a suite of readiness services offered by public relations firm Ketchum.

Disaster-Proven Paging for Public Safety

Paging system designs in the United States typically use a voice radio-style infrastructure. These systems are primarily designed for outdoor mobile coverage with modest indoor coverage. Before Narrowbanding, coverage wasn’t good, but what they have now is not acceptable! The high power, high tower approach also makes the system vulnerable. If one base station fails, a large area loses their paging service immediately!

Almost every technology went from analog to digital except fire paging. So it’s time to think about digital paging! The Disaster-Proven Paging Solution (DiCal) from Swissphone offers improved coverage, higher reliability and flexibility beyond anything that traditional analog or digital paging systems can provide. 

Swissphone is the No. 1 supplier for digital paging solutions worldwide. The Swiss company has built paging networks for public safety organizations all over the world. Swissphone has more than 1 million pagers in the field running for years and years due to their renowned high quality.

DiCal is the digital paging system developed and manufactured by Swissphone. It is designed to meet the specific needs of public safety organizations. Fire and EMS rely on these types of networks to improve incident response time. DiCal systems are designed and engineered to provide maximum indoor paging coverage across an entire county. In a disaster situation, when one or several connections in a simulcast solution are disrupted or interrupted, the radio network automatically switches to fall back operating mode. Full functionality is preserved at all times. This new system is the next level of what we know as “Simulcast Paging” here in the U.S.

Swissphone offers high-quality pagers, very robust and waterproof. Swissphone offers the best sensitivity in the industry, and battery autonomy of up to three months. First responder may choose between a smart s.QUAD pager, which is able to connect with a smartphone and the Hurricane DUO pager, the only digital pager who offers text-to-voice functionality.

Bluetooth technology makes it possible to connect the s.QUAD with a compatible smartphone, and ultimately with various s.ONE software solutions from Swissphone. Thanks to Bluetooth pairing, the s.QUAD combines the reliability of an independent paging system with the benefits of commercial cellular network. Dispatched team members can respond back to the call, directly from the pager. The alert message is sent to the pager via paging and cellular at the same time. This hybrid solution makes the alert faster and more secure. Paging ensures alerting even if the commercial network fails or is overloaded.

Swissphone sets new standards in paging:

Paging Network

• It’s much faster to send individual and stacked pages digitally than with analog voice.
• If you want better indoor coverage, you put sites closer together at lower heights.
• A self-healing system that also remains reliable in various disaster situations.
• Place base station where you need them, without the usage of an expensive backhaul network.
• Protect victim confidentiality and prevent unauthorized use of public safety communications, with integrated encryption service.

Pager

• Reliable message reception, thanks to the best sensitivity in the industry.
• Ruggedized and waterproof, IP67 and 6 1/2-feet drop test-certified products.
• Battery autonomy of up to three months, with a standard AA battery.
• Bluetooth enables the new s.QUAD pager to respond back to the dispatch center or fire chief.

Dispatching:

• Two-way CAD interfaces will make dispatching much easier.
• The new s.ONE solution enables the dispatcher or fire chiefs to view the availability of relief forces.
• A graphical screen shows how many of the dispatched team members have responded to the call.

Swissphone provides a proven solution at an affordable cost. Do you want to learn more?
Visit: www.swissphone.com or call 800-596-1914.

OneLogin Password Manager Breach Enabled by Stolen AWS Cloud Keys

By: Sean Michael Kerner | June 02, 2017

NEW ANALYSIS: Online password manager service suffers a data breach after an attacker is able to get access to the company's cloud services.

Online password manager service OneLogin reported on May 31 that it was the victim of a data breach that exposed its users and their data to risk.

Initially the company provided few details, other than disclosing the fact that there was an unauthorized access to OneLogin customer data. Late on June 1, the company provided more details, revealing that attackers had infiltrated OneLogin's cloud backend and had unfettered access for seven hours prior to being detected.

OneLogin is using Amazon Web Services (AWS) as its cloud provider and at approximately 2 am PST on May 31, a hacker was somehow able to use OneLogin's AWS credentials. OneLogin's AWS keys were used by the attacker from a smaller, unidentified service provider in the U.S, that was able to create new virtual server instances to get visibility and perform reconnaissance into OneLogin's operations.

"OneLogin staff was alerted of unusual database activity around 9 am PST and within minutes shut down the affected instance as well as the AWS keys that were used to create it," Alvaro Hoyos,Chief Information Security Officer at OneLogin wrote in a blog post. "The threat actor was able to access database tables that contain information about users, apps, and various types of keys."

Hoyos added that it's also possible the attacker was able to get the information needed to also be able to decrypt user data.

This isn't the first time OneLogin has reported a data breach. In August 2016 the company reported a breach in the company's Secure Notes service. In that incident the root cause was identified as a bug in the platform that enabled attackers to view notes before they were encrypted.

Possible Threat Vectors

At this point, it's unclear how the attacker was able to get access to OneLogin's AWS credentials or why it took the company seven hours to detect the unauthorized access.

There are a number of potential vectors by which an attacker could have breached OneLogin's security. In many attacks, some form of directed, spear-phishing email is often found to be a root cause. In such a scenario, an attacker sends a fake phishing email to a privileged account holder and then gets the victim to click or log into a service, which then steals the user's credentials.

With AWS in particular though, there are other potential threat vectors that can place unsuspecting organizations at risk. An April 2017 study from security vendor Threat Stack, found that 73 percent of AWS users were leaving the Secure SHell (SSH) service open to the public internet on their cloud instances. SSH is commonly used to remotely administer a server instance.

The Threat Stack study also found that not all AWS users were using Amazon's CloudTrail auditing service in all zones. CloudTrail can be used by organizations to identify potentially unauthorized access and account anomalies. However the attacker was able to get access to OneLogin's AWS credentials, the bottom line is the attack should serve as a wake up call for all organizations to revisit and harden their cloud access credentials and monitoring policies.

Friday, June 2, 2017	Volume 5 | Issue 108

FCC, OSHA Release Tower Climber Safety Guide

UPDATE The FCC and OSHA released a new Tower Climber Safety guide. Access the 29-page document here .

“As more Americans use mobile devices to call, text and stream content, the safety of workers who maintain and construct communications towers is more critical than ever,” said FCC Chairman Ajit Pai and Assistant Deputy Secretary for Labor for Occupational Safety and Health Dorothy Dougherty in a joint statement. “Every day, communications tower workers face potential hazards that can be deadly if not performed safely, and dozens of fatalities have occurred over the past few years. Every tower climber death is preventable.”

The agencies have hosted workshops with input from industry stakeholders to identify and establish accepted practices for performing communication towers work securely. This document is a collection of the best practices gathered from those workshops and from talks that continued afterwards.

OSHA and the FCC note in the guide that when carriers own their own towers and directly employ the employees who build and maintain the towers and the equipment on them, the carriers have the ability and incentive to ensure safe practices. But typically the relationship is more complicated:

 

• Towers are often owned by separate corporations (not carriers, generally), and are built by contractors;
• Carriers often contract with “turfing vendors” for equipment installation and maintenance;
• Turfing vendors may hire other contractors to perform work who may sub-contract tower work to even smaller employers.

“As a result, carriers and tower owners may not know who is performing work for them, or when work is being performed,” according to the guide, leaving responsibility for employee safety split into several layers.

Additionally, tower work is physically demanding and requires employees to spend long periods of time away from home; hence, job tenure tends to be short and turnover tends to be high, according to OSHA and the FCC. In light of these circumstances, ensuring employee safety requires accountability and diligence throughout the contracting process, from the carrier to the individual employee performing the work. Issues such as employer and employee participation and hazard identification, assessment and control are covered. So too, are program evaluation and improvement and communication on multi-employer workplaces.

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

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

SEE WEB FOR COMPLETE LIST:

www.preferredwireless.com/equipment

Rick McMichael
Preferred Wireless, Inc.
Telephone: 888-429-4171
(If you are calling from outside of the USA, please use: 314-575-8425)
rickm@preferredwireless.com

Selected portions [sometimes more — sometimes less] of the BloostonLaw Telecom Update and/or the BloostonLaw Private Users Update — newsletters from the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP — are reproduced in this section of The Wireless Messaging News with the firm’s permission. Contact information is included at the end of the newsletter.

FCC Form 481 Due July 3

In approximately one month, all eligible telecommunications carriers (ETCs) must report the information required by Section 54.313, which includes outage, unfulfilled service request, and complaint data, broken out separately for voice and broadband services; information on the ETC’s holding company, operating companies, ETC affiliates and any branding in response to section 54.313(a)(8); its CAF-ICC certification, if applicable; its financial information, if a privately held rate-of-return carrier; and its satellite backhaul certification, if applicable. Form 481 must not only be filed with USAC, but also with the FCC and the relevant state commission and tribal authority, as appropriate. Although USAC indicates that it treats the filing as confidential, filers must seek confidential treatment separately with the FCC and the relevant state commission and tribal authority if confidential treatment is desired.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Sal Taillefer.

Headlines

Battle Continues over Mobility Fund Phase II Rules

On April 26, Blooston Rural Carriers filed a Petition for Reconsideration of the Mobility Fund Phase II Order, raising a number of issues.

Oppositions were filed by Verizon and the Rural Wireless Association (RWA). Specifically, Verizon opposed the Petitions that urged the FCC to reconsider its 5 Mbps cut-off for Mobility Fund Phase II (MF-II) eligibility. According to Verizon, increasing the threshold would cause MF-II support to go to areas that “are already wellserved by unsubsidized 4G LTE service…” RWA opposed T-Mobile‘s Petition requesting that the FCC reduce the 10/1 service requirement (which is separate from the 5/1 eligibility threshold), arguing that MF-II will support mobile broadband in rural areas for a decade, and speed requirements must therefore be forward-looking. RWA also opposed CTIA’s proposal to require a one-time coverage data collection from all carriers in lieu of using Form 477 data, and a challenge process based thereon. RWA argued that the proposal was unnecessarily overbroad, inefficient, and would delay MF-II implementation.

Replies were filed by by NTCA, T-Mobile, RWA, the Competitive Carriers Association (CCA), Panhandle Telephone Cooperative and Pine Belt Cellular, and a group of wireless carriers including U.S. Cellular, Appalachian Wireless, Pioneer Cellular, Viaero Wireless, Nex-Tech Wireless LLC, and Smith Bagley, Inc. (Rural Wireless Carriers).

NTCA and CCA filed general reply comments supporting reconsideration of certain issues, including issues raised in the Blooston petition. NTCA supported reconsideration of (a) the FCC’s decision to use a 5 Mbps download threshold for MF-II eligibility; (b) its Letter of Credit requirements; (c) its decision to require collocation for all towers in MF-II funded areas; and (d) whether service offered by a provider collocated on a tower built by a recipient of universal service support is actually “unsubsidized” competition. CCA supported reconsideration of the MF-II budget; letter of credit requirements; and disbursement methodology of MF-II funding.

RWA, separately, and Panhandle Telephone and Pine Belt Cellular, jointly, replied to the opposition of Verizon. RWA argued that Verizon’s assertion that 5 Mbps was within reasonable range of urban speeds is contradicted by the record. Panhandle and Pine Belt similarly argued against Verizon’s assertion that 5 Mbps was within reasonable range of urban speeds. They also argued that no party opposed the request to allow areas served by only one unsubsidized LTE network technology for reliable voice service to be remain eligible for MF-II support.

BloostonLaw Contacts: John Prendergast and Sal Taillefer.

FCC Extends Comment Deadline for Wireless Infrastructure NPRM and NOI

On May 26, the FCC issued an Order granting the Joint Motion filed by CTIA, Competitive Carriers Association, and the Wireless Infrastructure Association (Petitioners) on May 24, 2017, and extending the deadlines for filing comments and reply comments in response to the Wireless Infrastructure NPRM/NOI (WT Docket No. 17-79). Comments are now due June 15, and reply comments are now due July 17. According to the Order, granting the Petition will harmonize the pleading cycle of the above captioned proceeding with the pleading cycle established for the Wireline NPRM, NOI, and RFC (in WC Docket No. 17-84).

As we reported in a previous edition of the BloostonLaw Telecom Update, the FCC seeks comment in the FNPRM and NOI on (i) streamlining state and local review; (ii) reexamining National Environmental Policy Act and National Historic Preservation Act review; and (iii) the implementation of Sections 253(a) and 332(c)(7) of the Communications Act, which prohibit State or local regulations that have the effect of prohibiting the provision of telecommunications and the preservation of State and local governments’ authority over decisions regarding the placement, construction, and modification of personal wireless service facilities.

BloostonLaw Contacts: John Prendergast.

Law & Regulation

FCC Releases FY2017 Regulatory Fee Notice of Proposed Rule Making

The FCC has issued its annual Notice of Proposed Rulemaking and Order in connection with the collection of annual regulatory fees for Fiscal Year 2015. Comments on the FCC’s proposals will be due June 22, 2017 and Reply Comments will be due July 7, 2017.

Notably, the FCC has made three proposals that will be of interest to several of our clients: (a) raising the de minimis threshold from $500.00 to $1,000, (b) developing some sort of a de minimis threshold for the private land mobile, microwave and rural radiotelephone services and (c) eliminating the fee for CMRS Messaging and any other similarly situated service where the FCC is not engaged in regulatory activity aside from the processing of licensing applications.

This year, the FCC has proposed to collect $356,710,992 in regulatory fees, which is down from last fiscal year’s figure of $384,012,497 in regulatory fees.

De Minimis Exemption

Two years ago, the FCC increased the threshold for the de minimis from $10.00 for all fees owed by a regulatee to $500.00. On further review, the FCC is seeking comment on its proposal to increase the de minimis amount from $500.00 to $1,000.00 in order to improve the cost effectiveness of the commission’s collection of regulatory fees and provide regulatory fee relief to smaller entities, particularly those that have little Commission oversite or regulation. In this regard, the Commission notes that smaller entities with limited funds are less likely to be able to budget for the annual regulatory fees on a timely basis and therefore, could incur late fees and consequently utilize more Commission resources for fee collection. The Commission tentatively concludes that the benefits of collecting such small payments is outweighed by the administrative burden on small regulatees and the Commission’s operational costs associated with the processing and collection of these fees. In this regard, the Commission also notes that payors with gross fees between $500.00 and $1,000.00 account for less than one percent of all regulatory fee payments.

Because this exemption can be changed from time-to-time, it is important that regulates review their regulatory fee obligation annually in order to determine if the fee due for that year will exceed the threshold. We also recommend that those clients claiming an exemption under the de minimis rule affirmatively file a letter with the Commission in order to avoid being red-lighted for non-payment of the regulatory fee.

The Commission is also seeking comment on whether it should include multi-year wireless licenses in the de minimis threshold. If the Commission were to adopt this proposal, should it be based upon the aggregate fee or the number of licenses, frequencies or paths held by the licensee? As part of this proposal, the Commission is also seeking comment as to whether or not this proposal would be too administratively burdensome.

Proposed Regulatory Fee Schedule for FY2016

For FY2016, the FCC is proposing to increase regulatory fees for some of the fee categories while reducing the fee for others. A list of relevant fee categories is listed below:

Elimination of Regulatory Fee Categories

The FCC is seeking comment on eliminating regulatory fee categories, such as CMRS Messaging (Paging), which account for a very small amount of regulatory fee payments. In particular, the Commission is requesting that commenters discuss other changes to the regulatory fee framework that would facilitate the goal of ensuring that regulatory fees are administrable and sustainable. For example, are there categories of regulatory fee payors that now have very little Commission oversight or regulation, apart from the application process for which a separate fee is paid? In this regard, the FCC is seeking comment on whether regulatory fees have been adopted for other categories in the past where there is now a clear case to conclude that the fee is no longer “reasonably related to the benefits provided to the payer of the fee by the Commission’s regulatory activities. . . .”

Direct Broadcast Satellite (DBS)

Two years ago, the FCC adopted its proposal to establish a regulatory fee for Direct Broadcast Satellite (DBS) as a subcategory in the CATV and IPTV categories. Based upon the FCC’s experience it has proposed a fee increase for this subcategory from $.27 to $.38 per subscriber per year. This proposed fee includes a base amount of $.36 and a proportional adjustment of $.02 per subscriber due to the increase in the Commission’s budget for moving expenses. In using this fee structure, the FCC has previously noted that it is important to note that DBS service providers wear two hats — multichannel video programming distributors (MVPDs) as regulated by the Media Bureau and users of geostationary space stations that are used to provide one-way subscription video service to consumers — which is regulated by the International Bureau. In order to properly allocate costs, the FCC subjects DBS providers to two regulatory fees in order to recover the relevant costs associated with each operating bureau.

International Bearer Circuits

The FCC requires facilities based common carriers to pay regulatory fees for terrestrial and satellite International Bearer Circuits (IBCs) that are active as of December 31 of the prior year for the provision of service to an end-user or resale carrier. In FY2015, the FCC asked all facilities based common carriers to review their reporting processes in order to ensure that all common carrier IBCs used by the facilities based carrier or their affiliates were properly accounted for. As part of this process, the FCC is now reviewing the processes for reporting IBCs in order to ensure that all carriers report IBCs in a consistent manner. The FCC is seeking comment on how to make its fee assessment more efficient, equitable and less burdensome, the Commission is seeking comment on adopting a flat, per-provider fee similar to how we treat submarine cable regulatory fees, with a tiered regulatory fee methodology for terrestrial IBCs based on capacity. Similar to the regulatory fee treatment of submarine cable IBCs, under this proposal, terrestrial and satellite IBCs would be treated the same regardless of whether they are offered on a common-carrier or non-common-carrier basis. The Commission is also seeking comment on this proposal and how to divide the terrestrial IBCs into categories based on capacity.

Reallocation of FTEs

Inasmuch as the FCC’s regulatory fees are based upon full-time equivalents (FTEs) associated with the regulation of particular activities, the FCC periodically reviews whether or not adjustments should be made based upon staffing and work function. For this year, the FCC is proposing to reallocate FTEs associated with both the Universal Service Fund and administration of Numbering Resources in order to better reflect the actual uses of personnel throughout the Commission on particular types of regulation. As a result, the FCC has proposed to reallocate the 38 FTEs associated with the non-high cost programs of the Universal Service Fund as indirect and four of the Wireline Competition Bureau FTEs that work on numbering issues to the Wireless Telecommunications Bureau as direct FTEs for regulatory fee purposes.

Other Reforms

The FCC is also seeking comment on ways to further improve its regulatory fee collection process in order to make it less burdensome for all entities. In particular, it is seeking comment on ways that it can better communicate with smaller entities, such as mass emails rather than United States mail, and if so, whether it should require a current email address for all regulatory fee payors.

Payment of Regulatory Fees via Credit Card

We remind our clients that effective June 1, 2015, the US Treasury adopted new rules concerning credit card payments. Under these new rules, the maximum amount that can be charged on a credit card for a particular debt is $24,999.99 (which is reduced from $49,999.99). As a result of this change, charges of more than $24,999.99 will be rejected. It is important to note that this limit applies to both single payments and bundled payments of more than one invoice. Additionally, multiple transactions to a single agency in one day will be added together and treated as a single transaction for purposes of this rule. US Treasury has also indicated that debtors may not split payments into more than one payment by using the same or multiple credit card accounts or by spreading the payments over multiple days.

Clients wishing to make payments that exceed $24,999.99 have several options, such as: Visa or MasterCard debit cards, Automated Clearing House (ACH) debits from a bank account, and wire transfers. Like last year, payment by check is no longer an option .

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Issues Violation Warnings to Local Governments for Violations of Preservation Rules

On May 22, 2017, the FCC’s Public Safety and Homeland Security Bureau warned Marion County, South Carolina, Pinellas County, Florida, and Madison County, Indiana that each locality had failed to comply with the FCC’s rules implementing the National Environmental Policy Act of 1969 (NEPA) and other federal statutes as well as the related antenna structure registration and licensing rules, including the requirement that applicants provide truthful and accurate statements in their applications.

Regulatory Requirements

The FCC’s Rules require an applicant to consider, prior to initiating construction or deployment, whether the proposed facility may have a significant effect on the environment. If it appears that there could be a significant effect, the applicant is required to prepare an Environmental Assessment (EA) and submit the EA with its application in accordance with the FCC’s Rules.

In particular, an applicant is required to prepare an EA if the proposed facility will meet any of a number of criteria specified in the FCC’s rules, including, e.g.: construction that may affect properties listed or eligible for listing in the National Register of Historic Places, impact Native American sites or that is located in a flood plain. If an EA is required, construction may not commence until the FCC has completed its environmental assessment. The FCC’s Antenna Structure Registration (ASR) rules place a separate obligation on an applicant to submit an EA with the ASR application if an EA is required under the Commission’s environmental rules. Finally, if a wireless facility that could have a significant environmental impact is to be constructed, the application is automatically considered to be a “major action”, requiring prior FCC approval before construction can start.

Marion County’s Conduct

The FCC found that Marion County failed to comply with the FCC’s environmental, ASR and licensing regulations. In particular, Marion County submitted an ASR application for a proposed site at Mullins, South Carolina wherein it certified that the proposed antenna structure would not have a significant environmental impact. The FCC found that this certification was made before Marion County had completed the required process for engaging federally recognized Tribal Nations and before it had submitted a complete Memorandum of Agreement to mitigate any adverse effects that the tower would have on historic properties. Additionally, even though the County was required to file an EA and obtain a Finding of No Significant Impact (FONSI) prior to receiving its ASR and commencing construction due to the potential for an adverse effect on historic properties, Marion County proceeded with the construction of its 300-foot antenna tower and began operations even before it submitted its EA and obtained the required FONSI. As a result, the County incorrectly certified that (a) it had completed its environmental review, (b) that the tower did not require an EA and (c) that the project would not have a significant environmental effect.

Pinellas County’s Conduct

With respect to Pinellas County, the FCC noted that the County had submitted five applications to register public safety radio towers during 2015-16 which included a certification that the towers would not have a significant environmental impact. The towers were constructed and radio operations commenced at the tower sites before Pinellas County had completed the required environmental and historic preservation reviews. Additionally, two towers were constructed in flood plains without conducting the required EAs or receiving the necessary FONSI from the FCC to proceed with tower construction.

The FCC stated further that because Pinellas County uses the towers for public safety communications that are subject to licensing under Part 90 of its rules, the construction and operation of radio facilities on those towers likewise constituted a major modification of its license, which required prior FCC approval.

Madison County’s Conduct

In 2015 – 2016, Marion County constructed a public safety radio tower near Pendleton, Indiana before allowing the Indiana Division of Historic Preservation and Archaeology (SHPO) or the Eastern Shawnee Tribe of Oklahoma (Eastern Shawnee Tribe) to complete their review for adverse effects on historic properties at the site. Although the Eastern Shawnee Tribe ultimately determined that there were no historic properties of cultural significance that would likely be impacted, the Tribal Historic Preservation Officer (THPO) noted that relevant and necessary information ( i.e., that construction had already been commenced) was not provided when the archeological report was submitted to the THPO for review. In this regard, the FCC noted that the pre-grant construction compromised the SHPO and THPO evaluation process.

As with Marion and Pinellas Counties, Madison County also certified on its Form 854 Antenna Structure Registration that the proposed tower would not have a significant environmental impact and that all statements were “true, complete, correct and made in good faith.”

Conclusion

It is important to note that the FCC’s environmental rules apply regardless of whether the proposed tower is located on private property or government-owned property, and whether the use does or does not include commercial licensees. Simply put, the FCC’s environmental rules are triggered by the proposed construction and its potential impact on the environment.

In issuing these warning letters, the FCC made clear that any future violations would result in further enforcement action, including monetary penalties. It is also critically important that each application includes a warning that WILLFUL FALSE STATEMENTS MADE ON THIS FORM OR ANY ATTACHMENTS ARE PUNISHALBE BY FINE AND/OR IMPRISONMENT . . . AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT.”

As we have previously indicated, our office has published a tower compliance manual, which is designed to assist you in avoiding these sorts of pitfalls. Please contact our office if you would like to obtain a manual.

BloostonLaw Contacts: John Prendergast and Richard Rubino

Industry

New York City Urges Immediate Improvements to Wireless Emergency Alert System

Last week and in response to a Petition for Reconsideration filed by CTIA, the City of New York’s Emergency Management Department and Department of Information Technology and Telecommunications (the City) met with the FCC in order to urge the Commission to modernize the capabilities of its Wireless Emergency Alert System (WEA) without delay. The City is very sensitive to this issue — having just recently utilized the WEA immediately following the September bombing in Manhattan’s Chelsea neighborhood.

The City pointed out that the current WEA system is antiquated, in that it is limited to 90 characters and does not allow for the inclusion of photographs and embedded URL links. Following the Chelsea bombing, the WEA system was utilized three times order to put out city-wide messages requesting public assistance in locating the suspected bomber. The City stated that “due to the limitations of the WEA system, that citywide message was unable to include a photograph and/or link to a photograph of the alleged perpetrator. Instead, our message directed consumers to see media for pic.”

Following the use of the WEA system, the City commissioned a study on the effectiveness of the WEA system. In the study, it found that “while 89% of survey respondents found our use of the WEA system to be appropriate, only 45% of respondents indicated that they subsequently sought out the photograph via other media sources.” The City concluded that “the inclusion of a specific link would likely have increased the number of consumers who viewed the photograph and, thus increased the chances that a consumer would have recognized the suspect. Given today’s threat environment and the limitations of the WEA system, it is absolutely critical that alert originators have the ability to include URLs that direct consumers to additional information during an emergency.”

While CTIA asserted in its Petition that the inclusion of URLs in WEA messages would lead to network congestion, the City claimed that CTIA’s assertions were not supported in the record and that the website failures it pointed to were, in any event, beyond the control of Commercial Mobile Service Providers (CMSPs).

The City also reiterated its position that embedded references should be included on all devices, and not just smartphones that are Internet capable. In particular, the City stated that “it would be inequitable for a consumer’s decision to purchase a feature phone over a smart phone (which may be related to the relative price) to limit the amount and type of information that the consumer receives in a WEA message.” The City continued that while a feature phone might not have Internet access, the consumer would still be in a position to enter the URL into another internet-capable device.

Finally, the City urged the Commission not to delay the implementation of Spanish language alerts beyond the two years already established by the Commission in its Report and Order. Rather than delaying implementation of the requirement, the City urged the Commission to allow alert originators to determine how best to implement the Spanish-language alerting for their jurisdiction.

Deadlines

MAY 31: FCC FORM 395, EMPLOYMENT REPORT. Common carriers, including wireless carriers, with 16 or more full-time employees must file their annual Common Carrier Employment Reports (FCC Form 395) by May 31. This report tracks carrier compliance with rules requiring recruitment of minority employees. Further, the FCC requires all common carriers to report any employment discrimination complaints they received during the past year. That information is also due on May 31. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report. Clients who would like assistance in filing Form 395 should contact the firm.

BloostonLaw Contacts: Richard Rubino.

JULY 3: FCC FORM 481 (CARRIER ANNUAL REPORTING DATA COLLECTION FORM). All eligible telecommunications carriers (ETCs) must report the information required by Section 54.313, which includes outage, unfulfilled service request, and complaint data, broken out separately for voice and broadband services, information on the ETC’s holding company, operating companies, ETC affiliates and any branding in response to section 54.313(a)(8); its CAF-ICC certification, if applicable; its financial information, if a privately held rate-of-return carrier; and its satellite backhaul certification, if applicable. Form 481 must not only be filed with USAC, but also with the FCC and the relevant state commission and tribal authority, as appropriate. Although USAC treats the filing as confidential, filers must seek confidential treatment separately with the FCC and the relevant state commission and tribal authority if confidential treatment is desired.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Sal Taillefer.

JULY 3: MOBILITY FUND PHASE I ANNUAL REPORT. Winning bidders in Auction 901 that are authorized to receive Mobility Fund Phase I support are required to submit to the FCC an annual report each year on July 1 for the five years following authorization. This year, July 1 falls on a Saturday; therefore, the report is due July 3. Each annual report must be submitted to the Office of the Secretary of the FCC, clearly referencing WT Docket No. 10-208; the Universal Service Administrator; and the relevant state commissions, relevant authority in a U.S. Territory, or Tribal governments, as appropriate. The information and certifications required to be included in the annual report are described in Section 54.1009 of the FCC’s rules.

BloostonLaw Contacts: John Prendergast and Sal Taillefer.

JULY 31: FCC FORM 507, UNIVERSAL SERVICE QUARTERLY LINE COUNT UPDATE. Line count updates are required to recalculate a carrier's per line universal service support, and is filed with the Universal Service Administrative Company (USAC). This information must be submitted on July 31 each year by all rate-of-return incumbent carriers, and on a quarterly basis if a competitive eligible telecommunications carrier (CETC) has initiated service in the rate-of-return incumbent carrier’s service area and reported line count data to USAC in the rate-of-return incumbent carrier’s service area, in order for the incumbent carrier to be eligible to receive Interstate Common Line Support (ICLS). This quarterly filing is due July 31 and covers lines served as of December 31, 2013. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2014); December 30 (for lines served as of June 30, 2014), and March 31, 2015, for lines served as of September 30, 2014).

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

JULY 31: CARRIER IDENTIFICATION CODE (CIC) REPORTS. Carrier Identification Code (CIC) Reports must be filed by the last business day of July (this year, July 31). These reports are required of all carriers who have been assigned a CIC code by NANPA. Failure to file could result in an effort by NANPA to reclaim it, although according to the Guidelines this process is initiated with a letter from NANPA regarding the apparent non-use of the CIC code. The assignee can then respond with an explanation. (Guidelines Section 6.2). The CIC Reporting Requirement is included in the CIC Assignment Guidelines, produced by ATIS. According to section 1.4 of that document: At the direction of the NANPA, the access providers and the entities who are assigned CICs will be requested to provide access and usage information to the NANPA, on a semiannual basis to ensure effective management of the CIC resource. (Holders of codes may respond to the request at their own election). Access provider and entity reports shall be submitted to NANPA no later than January 31 for the period ending December 31, and no later than July 31 for the period ending June 30. It is also referenced in the NANPA Technical Requirements Document, which states at 7.18.6: CIC holders shall provide a usage report to the NANPA per the industry CIC guidelines … The NAS shall be capable of accepting CIC usage reports per guideline requirements on January 31 for the period ending December 31 and no later than July 31 for the period ending June 30. These reports may also be mailed and accepted by the NANPA in paper form. Finally, according to the NANPA website, if no local exchange carrier reports access or usage for a given CIC, NANPA is obliged to reclaim it. The semiannual utilization and access reporting mechanism is described at length in the guidelines.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

Calendar At-A-Glance

May
May 31 – FCC Form 395 (Annual Employment Report) is due.
May 31 – Comments on Short Form Tariff Review Plans are due.

June
Jun. 1 – Deadline to increase local residential rates above $18 to avoid reductions in support.
Jun. 2 – Deadline for CMRS to certify compliance with E911 location requirements.
Jun. 7 – Reply comments on Short Form Tariff Review Plans are due.
Jun. 7 – Reply comments on State of Mobile Wireless Competition Report are due.
Jun. 8 – Reply comments are due on Broadband-Enabled Healthcare Public Notice.
Jun. 12 – Comments are due on VRS User Equipment Profile FNPRM.
Jun. 15 – Comments are due on Wireless Broadband Infrastructure proceeding.
Jun. 15 – Comments are due on Wireline Broadband Infrastructure proceeding.
Jun. 16 – 15-Day Tariff Filings are due.
Jun. 16 – Comments are due on Speed Disclosure Petition for Declaratory Ruling.
Jun. 23 – Petitions regarding 15-Day Tariff Filings are due.
Jun. 26 – Reply comments are due on remaining VRS FNPRM sections.
Jun. 26 – 7-Day Tariff Filings are due.
Jun. 27 – Replies to Petitions regarding 15-Day Tariff Filings are due.
Jun. 29 – Petitions regarding 7-Day Tariff Filings are due (NOON EST).
Jun. 30 – Replies to Petitions regarding 7-Day Tariff Filings are due (NOON EST).

July
Jul. 3 – FCC Form 481 is due.
Jul. 3 – Mobility Fund Phase I Recipient Reports are due.
Jul 3. – Comments are due on Robocall Blocking proceeding.
Jul 3. – Reply comments are due on Speed Disclosure Petition for Declaratory Ruling.
Jul. 11 – Reply comments are due on VRS User Equipment Profile FNPRM.
Jul. 17 – Reply comments are due on Wireless Broadband Infrastructure proceeding.
Jul. 17 – Reply comments are due on Wireline Broadband Infrastructure proceeding.
Jul. 17 – Comments are due on Broadband Title I Reclassification NPRM.
Jul. 31 – FCC Form 507 (Universal Service Quarterly Line Count Update) is due.
Jul. 31 – Carrier Identification Code (CIC) Report is due.
Jul. 31 – International Traffic Data Report is due.
Jul. 31 – Reply comments are due on Robocall Blocking proceeding.

August
Aug. 16 – Reply comments are due on Broadband Title I Reclassification NPRM.

ALERT — Fraudulent Tower Ownership Change ASR Applications Filed

In connection with an inquiry, the FCC’s staff has notified our office that a Company appears to have filed fraudulent applications with the FCC in order to change the ownership information in the FCC’s Antenna Structure Registration (ASR) database. While the FCC’s grant of the ownership change application in and of itself will not result in an actual change in the ownership of the antenna structure, they will at a minimum create confusion and may interfere with a sale of the towers or the legitimate owner. Therefore, we want our clients to be aware that these sorts of applications have been filed and granted by the FCC and that there is an active investigation on-going at the FCC.

Please notify our office as soon as possible should you become aware that the ownership information for any of your antenna structures has been changed in the FCC’s ASR database without your permission.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Issues Violation Warnings to Local Governments for Violations of Environmental and Historic Preservation Rules — Threatens Fines

On May 22, 2017, the FCC’s Public Safety and Homeland Security Bureau warned Marion County, South Carolina, Pinellas County, Florida, and Madison County, Indiana that each locality had failed to comply with the FCC’s rules implementing the National Environmental Policy Act of 1969 (NEPA) and other federal statutes as well as the related antenna structure registration and licensing rules, including the requirement that applicants provide truthful and accurate statements in their applications.

Regulatory Requirements

The FCC’s Rules require an applicant to consider, prior to initiating construction or deployment, whether the proposed facility may have a significant effect on the environment. If it appears that there could be a significant effect, the applicant is required to prepare an Environmental Assessment (EA) and submit the EA with its application in accordance with the FCC’s Rules.

In particular, an applicant is required to prepare an EA if the proposed facility will meet any of a number of criteria specified in the FCC’s rules, including, e.g.: construction that may affect properties listed or eligible for listing in the National Register of Historic Places, impact Native American sites or that is located in a flood plain. If an EA is required, construction may not commence until the FCC has completed its environmental assessment. The FCC’s Antenna Structure Registration (ASR) rules place a separate obligation on an applicant to submit an EA with the ASR application, if an EA is required under the Commission’s environmental rules. Finally, if a wireless facility that could have a significant environmental impact is to be constructed, the application is automatically considered to be a “major action”, requiring prior FCC approval before construction can start.

Marion County’s Conduct

The FCC found that Marion County failed to comply with the FCC’s environmental, ASR and licensing regulations. In particular, Marion County submitted an ASR application for a proposed site at Mullins, South Carolina wherein it certified that the proposed antenna structure would not have a significant environmental impact. The FCC found that this certification was made before Marion County had run the proposal by the relevant Tribal Nations and before it had submitted a complete Memorandum of Agreement to mitigate any adverse effects that the tower would have on historic properties. Additionally, even though the County was required to file an EA and obtain a Finding of No Significant Impact (FONSI) prior to receiving its ASR and commencing construction due to the potential for adverse effect on historic properties, Marion County proceeded with the construction of its 300-foot antenna tower and began operations even before it submitted its EA and obtained the required FONSI. As a result, the County incorrectly certified that (a) it had completed its environmental review, (b) that the tower did not require an EA and (c) that the project would not have a significant environmental effect.

Pinellas County’s Conduct

The FCC noted that Pinellas County had submitted five applications to register public safety radio towers during 2015-16 which included a certification that the towers would not have a significant environmental impact. The towers were constructed and radio operations commenced at the tower sites before Pinellas County had completed the required environmental and historic preservation reviews. Additionally, two towers were constructed in flood plains without conducting the required EAs or receiving the necessary FONSI from the FCC to proceed with tower construction.

The FCC stated further that because Pinellas County uses the towers for public safety communications that are subject to licensing under Part 90 of its rules, the construction and operation of radio facilities on those towers likewise constituted a major modification of its license, which required prior FCC approval.

Madison County’s Conduct

In 2015 – 2016, Marion County constructed a public safety radio tower near Pendleton, Indiana before allowing the Indiana Division of Historic Preservation and Archaeology (SHPO) or the Eastern Shawnee Tribe of Oklahoma (Eastern Shawnee Tribe) to complete their review for adverse effects on historic properties at the site. Although the Eastern Shawnee Tribe ultimately determined that there were no historic properties of cultural significance that would likely be impacted, the Tribal Historic Preservation Officer (THPO) noted that relevant and necessary information ( i.e., that construction had already been commenced) was not provided when the archeological report was submitted to the THPO for review. In this regard, the FCC noted that the pre-grant construction compromised the SHPO and THPO evaluation process.

As with Marion and Pinellas Counties, Madison County also certified on its Form 854 Antenna Structure Registration that the proposed tower would not have a significant environmental impact and that all statements were “true, complete, correct and made in good faith.”

Conclusion

It is important to note that the FCC’s environmental rules apply regardless of whether the proposed tower is located on private property or government-owned property, and whether the use does or does not include commercial licensees. Simply put, the FCC’s environmental rules are triggered by the proposed construction and its potential impact on the environment.

In issuing these warning letters, the FCC made clear that any future violations would result in further enforcement action, including monetary penalties. It is also important that each application includes a warning that “WILLFUL FALSE STATEMENTS MADE ON THIS FORM OR ANY ATTACHMENTS ARE PUNISHALBE BY FINE AND/OR IMPRISONMENT . . . AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT.”

As we have previously indicated, our office has published a tower compliance manual, which is designed to assist you in avoiding these sorts of pitfalls. Please contact our office if you would like to obtain a manual.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Seeks Comment on Request for Waiver by Washington County, Oregon to Use 800 MHz Business Channels

The FCC’s Public Safety and Homeland Security Bureau is seeking comment on a request for waiver filed by Washington County, Oregon to license through inter-category sharing two 800 MHz channels from the Business/Industrial/Land Transportation (B/ILT) Pool for use at the Gales Peak site. Comments are due June 9, 2017 and Reply Comments are due June 23, 2017.

In support of its request, Washington County stated that its 800 MHz trunked radio system provides mobile radio coverage to 18 police and fire agencies within Washington County, and has expanded service to include 94 agencies from Clackamas County and the City of Newberg. It currently serves over 7,000 units generating more than 14 million push-to-talk transmissions per year. Because the area served by the system consists of “extremely rugged terrain,” the County determined that it would be necessary to increase the number of base stations from 21 to 48 and to increase the number of channels from 71 to 140. Washington County asserts that once the system upgrade is completed, the public safety communications system will provide “better in-building portable radio coverage mainly for school security” as well as expanded coverage to rural areas such as the Mt. Hood Timberline recreational ski area.

Washington County further states that there are not enough public safety or vacated frequencies available for licensing at the Gales Peak site to add six channels. Therefore, in addition to two Public Safety Pool channels, a General Category channel, and a Sprint-vacated channel, Washington County has applied for B/ILT Pool base transmit frequencies 854.7625 MHz and 855.8125 MHz. Additionally, the County seeks to license paired mobile transmit frequencies 809.7625 MHz and 810.8125 MHz for use by associated mobile units operating within a thirty-two kilometer radius of the Gales Peak site.

Pursuant to the Commission’s Rules, channels from the Business/Industrial Land Transportation Pool are reserved for use by entities performing business/industrial related activities. Since Washington County is proposing to utilize the channels for public safety communications, it is not eligible for licensing in its own right. None-the-less, the FCC’s rules permit an entity to license a channel outside its frequency pool category through inter-category sharing if it can demonstrate that no channels within its pool category (in this case, Public Safety) are available.

While Washington County is able to demonstrate that there is not sufficient public safety spectrum to meet its communications needs, the FCC has a long-standing 20 year plus freeze on inter-category sharing for spectrum in the 800 MHz band. Therefore, the County will require a waiver of the freeze, which is being supported not only by APCO, the FCC-certified coordinator of Public Safety Pool Channels, but also by the Utilities Technology Council (UTC), the FCC certified coordinator for B/ILT channels.

Any office client interested in supporting or opposing this waiver request should contact our office.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Rewrites Part 95 Personal Communications Rules

The FCC has adopted a Report and Order which culminates a seven year effort to modernize the Part 95 Personal Radio Services Rules and eliminate outdated requirements.

The Part 95 rules cover 11 different Personal Radio Services (PRS), including the Family Radio Service (FRS), Multi-Use radio Service (MURS), Medical Device Radio-communications Service (MedRadio), Wireless Medical Telemetry Service (WMTS) and the venerable General Mobile Radio Service (GMRS) and Citizens Band Radio Service (CB). PRS devices generally use low-power transmitters that communicate using shared spectrum. For the most part, communications under these rules are authorized by operation of rule rather than by the issuance of an individual license for each user.

The FCC’s rewrite is intended to simplify and update Part 95 in order to reflect technological advances and changes in the way the various Personal Radio Services are used today. The Commission believes that its revisions will eliminate certain regulatory burdens that have been placed on the public and equipment manufacturers. Additionally, the FCC is prohibiting the inclusion of voice obscuring features that could hinder emergency communications in the PRS equipment that is designed to be used on shared channels, and prohibiting the use of the term “Personal Locator Beacon” and “PLB” to market any rescue beacon device that does not meet the FCC’s technical standards.

Notable reforms include:

• GMRS/FRS Reform: Increase the number of channels for both the GMRS and FRS, expand digital capabilities of the GMRS and increase the power/range for certain FRS channels in order to meet consumer demands for longer range communications.
• CB Reform: The CB Rules have been updated in order to eliminate requirements that are no longer needed, including labeling requirements and a limit on the use of channels when conditions allow long-range communications. Additionally, the FCC clarified that hands-free devices may be used with CB radios.
• Overall Rule Reform: Outdated and unnecessary rules have been removed. Additionally, the FCC is revising other rules in order to reduce potential for confusion. Further, the rules are being reorganized and streamlined in order to make them easier to understand by using a “plain language format”.
• The revisions to Part 95 shall be effective 30 days following publication in the Federal Register.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC Steps Up Enforcement of Technical Rules

As shown by two recent cases out of Honolulu, Hawaii and other cases described in this month’s issue, the FCC’s statement at last month’s LMCC Annual Meeting is clear — greater scrutiny is being given to ensure that licensees operate their stations in accordance with the terms of the license authorizations issued by the FCC.

The two cases coming out of Hawaii provide an illustration of what not to do. In Anderson Communications, Inc. (ACI), ACI was authorized to operate with a bandwidth of either 4 kHz or 6 kHz, the maximum permitted under Rule Section 90.35(c)(33). In response to a complaint of harmful interference from an adjacent channel licensee, the FCC determined that ACI was operating with 10 kHz bandwidth — thereby causing harmful interference to the adjacent channel licensee.

In the second case, Utility Mapping Service, Inc. (UMS) continued to operate its station even though it failed to renew its license for station WQFS506. A complaint of interference from a co-channel licensee caused the FCC to investigate UMS’s operation. In reviewing the station’s operation, the field agents from the Enforcement Bureau determined that UMS (a) continued to operate station WPRY213 even though it allowed the license to expire in September 2016, (b) utilized a continuous carrier on a shared channel, thereby preventing access to the channel by co-channel licensees, (c) failed to monitor the frequency before transmitting in order to prevent harmful interference and (d) failed to transmit the call sign identification as required by the FCC’s Rules.

As indicated last month, the FCC takes enforcement of its technical rules seriously, in order to minimize the potential for harmful interference. In those circumstances where interference arises, the FCC first expects licensees to attempt to resolve the matter among themselves. We recommend that that you contact our office promptly if you find in a situation where (a) there is an interference issue or (b) your station is not in compliance with your license or FCC rules.

BloostonLaw Contacts: John Prendergast and Richard Rubino

Chairman Pai Proposes Blue Alerts for EAS

On May 19, FCC Chairman Ajit Pai issued a Press Release announcing a proposal to add a “Blue Alert” option to the Emergency Alert System (EAS), which would be used by authorities in states across the country to notify the public through television and radio of threats to law enforcement and to help apprehend dangerous suspects.

According to the Press Release, Blue Alerts can be used to warn the public when there is actionable information related to a law enforcement officer who is missing, seriously injured or killed in the line of duty, or when there is an imminent credible threat to an officer. Some states have individual Blue Alert programs that use various methods to issue warnings. The Chairman’s proposal would build on these efforts through the development of a nationwide framework that states can adopt.

“As we have learned from the very successful AMBER Alert initiative for recovering missing children, an informed public can play a vital role in assisting law enforcement,” Chairman Pai said. “By expanding the Emergency Alert System to better support Blue Alerts, we could build on that success — and help protect those in law enforcement who risk their lives each day to protect us.”

The Commission will consider an NPRM at its June 22nd Open Meeting.

BloostonLaw Contacts: John Prendergast, Cary Mitchell and Richard Rubino.

FCC Proposes $144K Fine for Operation Without Low-Power TV License

On May 12, the FCC’s Enforcement Bureau proposed a $144,344 fine against Vearl Pennington and Michael Williamson for operating an unlicensed low-power television station in Morehead, Kentucky. An FCC investigation found that these individuals continued to operate well after the FCC license for their station was cancelled following failure to file a renewal. The proposed fine is the maximum allowed for ongoing violations of the Communications Act, which the FCC indicated is justified by the individuals’ continued operation of the station for years despite repeated warnings that they were in violation of the law.

Specifically, an FCC Press Release indicates that Mr. Pennington failed to renew his license in 1998. In 2004, the FCC’s Media Bureau canceled the license for DW10BM for non-renewal and failure to respond to an FCC inquiry. Mr. Pennington, joined by Mr. Williamson, continued to operate the station despite their lack of FCC-issued license.

After an unrelated FCC filing by another entity referenced the continued operation of DW10BM, the FCC’s Media Bureau informed the Enforcement Bureau, which investigated through its Atlanta Field Office and found that the unlicensed station was indeed operating on channel 10 in Morehead.

FCC agents met with Messrs. Pennington and Williamson during the investigation and warned both individuals that their unlicensed broadcasts violated FCC rules and the Communications Act. The station was instructed to cease operation, warned of possible enforcement actions, and issued an on-scene Notice of Unlicensed Radio Operation. Despite these warnings, the men continued to operate the station.

BloostonLaw Contacts: John Prendergast and Richard Rubino.

FCC Issues Several Violation Notices for Unlicensed Operation and Signal Jamming

Over the past month, the Enforcement Bureau’s regional offices have issued numerous violation notices for unlicensed operation. Most of the notices were issued to individuals for the operation of Pirate Radio stations in the FM bands while one notice was issued due to an interference complaint from Dallas County, Texas’s consolidated 911 communications center.

As we have previously reported in the past, the FCC takes an extremely dim view of persons or entities that willfully operate unlicensed stations or otherwise operate their radio facilities in consistent with the terms of their radio licenses. In many cases, there are pirate radio stations, which are stations operating in the FM broadcast band without a license from the FCC. Because the FCC strictly controls the allocation of FM broadcast channels, these pirate radio stations have the potential to cause harmful interference to other licensed users, including broadcasters and public safety entities.

In the Dallas County case, Mr. Pike admitted to the FCC’s field agents that he had been operating a signal jammer in the VHF band, a transmitting device that does not comply with the FCC’s Rules. In this regard, Section 333 of the Communications Act (the Act) prohibits willful or malicious interference with any radio communications of any station licensed or authorized by or under the Act or operated by the United States Government. Additionally, Section 2.803 of the Commission’s rules prohibits the manufacture, importation, marketing, sale or operation of devices deliberately designed to jam or disrupt wireless communications. During his interview with the FCC field agents, Mr. Pike surrendered his radio signal jammers.

The operation of radio signal jammers can have dire consequences for public safety. Depending upon the affected bands, members of the public could lose the ability to utilize cell phones and other wireless devices in the event of an emergency — and therefore be blocked from making a 911 call. Likewise, signal jammers can also block mobile two-way communications, such as those utilized by police, fire and EMS as well as communications that are essential for critical infrastructure and business operations.

BloostonLaw Contacts: John Prendergast and Richard Rubino

AFX Agrees to $90K Consent Decree for Marketing Unauthorized Radio Frequency Devices

AFX, Inc. has entered into a consent decree under which it will pay a $90,000 civil penalty for marketing radio frequency devices that had not been approved by the FCC and caused harmful interference to AM/FM broadcast reception.

AFX is a manufacturer and distributor of lighting fixtures that are used in residential and commercial applications. The FCC received complaints that AFX’s “NLL Series” under cabinet LED light fixtures were causing interference to AM/FM broadcast transmissions. Under the FCC’s Rules, the light fixtures in question are considered “unintentional radiators” and must therefore comply with the FCC’s equipment authorization procedures and relevant technical rules. The FCC was able to determine that prior to the issuance of the LOI, the LED light fixtures had not been tested and authorized under the Commission’s equipment authorization procedures prior to marketing and distribution. Further, the FCC noted that AFX continued to market the light fixtures during a five month period after the receipt of the FCC’s LOI into the matter apparently so that AFX could minimize any financial harm to the Company.

In addition to the $90,000 civil penalty, AFX must also create a compliance plan, which includes:

• Development of operating procedures applicable to all covered employees in order to ensure compliance with the FCC’s equipment authorization rules.
• Creation of a compliance manual which shall be distributed to all covered employees
• Compliance training for all covered employees that covers Equipment Authorization and Marketing Rules and the operating procedures discussed above.

In addition to the compliance plan, AFX is required to self-report any violations with the FCC’s Equipment Authorization and Marketing Rules as well as any violations of the terms of its consent decree. Finally, AFX will be required to make periodic reports to the FCC over the next three years.

This case illustrates the importance of ensuring that any equipment that is capable of being an intentional radiator or unintentional radiator of RF energy is tested and approved by the FCC before it is imported, marketed or sold in the United States. The equipment authorization rules are designed to ensure that equipment does not cause harmful interference to other licensed or protected operations.

BloostonLaw Contacts: John Prendergast and Richard Rubino

FCC CIO Issues Statement on Denial of Service Attacks on FCC’s Electronic Comment Filing System

On May 8, FCC Chief Information Officer Dr. David Bray issued a statement that the cause of delays experienced by consumers recently trying to file comments on the FCC’s Electronic Comment Filing System (ECFS) was “multiple distributed denial-of-service attacks (DDoS).” Mr. Bray said, “These were deliberate attempts by external actors to bombard the FCC’s comment system with a high amount of traffic to our commercial cloud host. These actors were not attempting to file comments themselves; rather they made it difficult for legitimate commenters to access and file with the FCC. While the comment system remained up and running the entire time, these DDoS events tied up the servers and prevented them from responding to people attempting to submit comments. We have worked with our commercial partners to address this situation and will continue to monitor developments going forward.”

Multiple news sources have observed that the reported DDoS attacks reportedly began shortly after late night host John Oliver called on viewers to visit a website that would redirect them to the correct page on the FCC site to leave their comments, leading some to wonder whether it was really another inundation of pro-net neutrality commenters, or something more nefarious.

BloostonLaw Contacts: Ben Dickens and Sal Taillefer.

New York City Urges Immediate Improvements to Wireless Emergency Alert System

Last week and in response to a Petition for Reconsideration filed by CTIA, the City of New York’s Emergency Management Department and Department of Information Technology and Telecommunications (the City) met with the FCC’s in order to urge the Commission to modernize the capabilities of its Wireless Emergency Alert System (WEA) without delay. The City is very sensitive to this issue — having just recently utilized the WEA immediately following the September bombing in Manhattan’s Chelsea neighborhood.

The City pointed out that the current WEA system is antiquated, in that it is limited to 90 characters and does not allow for the inclusion of photographs and embedded URL links. Following the Chelsea bombing, the WEA system was utilized three times order to put out city-wide messages requesting public assistance in locating the suspected bomber. The City stated that “due to the limitations of the WEA system, that citywide message was unable to include a photograph and/or link to a photograph of the alleged perpetrator. Instead, our message directed consumers to “see media for pic.”

Following the use of the WEA system, the City commissioned a study on the effectiveness of the WEA system. In the study, it found that “while 89% of survey respondents found our use of the WEA system to be appropriate, only 45% of respondents indicated that they subsequently sought out the photograph via other media sources.” The City concluded that “the inclusion of a specific link would likely have increased the number of consumers who viewed the photograph and, thus increased the chances that a consumer would have recognized the suspect. Given today’s threat environment and the limitations of the WEA system, it is absolutely critical that alert originators have the ability to include URLs that direct consumers to additional information during an emergency.”

While CTIA asserted in its Petition that the inclusion of URLs in WEA messages would lead to network congestion, the City claimed that CTIA’s assertions were not supported in the record and that the website failures it pointed to were, in any event, beyond the control of Commercial Mobile Service Providers (CMSPs).

The City also reiterated its position that embedded references should be included on all devices, and not just smartphones that are Internet capable. In particular, the City stated that “it would be inequitable for a consumer’s decision to purchase a feature phone over a smart phone (which may be related to the relative price) to limit the amount and type of information that the consumer receives in a WEA message.” The City continued that while a feature phone might not have Internet access, the consumer would still be in a position to enter the URL into another internet-capable device.

Finally, the City urged the Commission not to delay the implementation of Spanish language alerts beyond the two years already established by the Commission in its Report and Order. Rather than delaying implementation of the requirement, the City urged the Commission to allow alert originators to determine how best to implement the Spanish-language alerting for their jurisdiction.

BloostonLaw Contacts: John Prendergast, Cary Mitchell and Richard Rubino

Buildout of Nationwide First Responder Broadband Network Could Drive Amateur Radio Emergency Service (ARES) Changes

The ARRL Letter for June 1, 2017

The First Responder Network Authority ( FirstNet ) — a nationwide wireless broadband network for first responders — could change the complexion of how the Amateur Radio Emergency Service® (ARES®) functions to support communication for responders during disasters and emergencies. As an independent authority within the US Department of Commerce's National Telecommunication and Information Administration ( NTIA ), FirstNet's mission is to build out, deploy, and operate an interoperable nationwide broadband network dedicated to first responders. Ralph Haller, N4RH, the chairman of the National Public Safety Telecommunications Council ( NPSTC ), told ARRL that the advent of FirstNet "will likely be as significant as when public safety first began using radio."

"The nationwide network will be hardened, so that it will be more likely that many of today's public safety systems remain operational in emergencies," Haller said, pointing out that Amateur Radio should not expect to have access to FirstNet. He cautioned, "The endurance of Amateur Radio systems in disasters has been a big selling point in the past for incorporating amateur operators in emergency plans, but perhaps not so much in the future."

NPSTC is a federation of organizations that work toward improving public safety communication and interoperability, and ARRL has a seat on NPSTC's Governing Board. Haller predicted that Amateur Radio's role in emergencies will not disappear. "There is no substitute for eyes and ears on the ground in an emergency," he said, adding that radio amateurs "can and should continue to play an important part" in supporting emergency communication.

"Amateur operators can continue to provide valuable information to emergency operations centers in the recovery phase of disasters," he said. "Whether that intelligence gathering is reporting on storm clouds, power outages, or road closures, amateurs can help provide critical, real-time information about conditions over a vast area. While first responders are treating the injured or protecting life and property, the amateur community can concentrate on assessing the overall picture."

On March 30, FirstNet and the Commerce Department announced a 25-year partnership with AT&T as the primary contractor to make FirstNet a reality. "The ability to communicate seamlessly across jurisdictions is critical for law enforcement, fire, and emergency medical services (EMS) when securing large events or responding to emergencies and disasters," a Commerce Department news release said. "In those instances, networks can become overloaded and inaccessible, limiting responders' use of vital communication technologies, such as smartphones and applications dedicated to public safety services."

Public safety agencies already use commercial wireless networks, such as AT&T and Verizon, to supplement their own radio systems and networks, although such communication is not point to point. FirstNet is initially targeted primarily to provide video and data, with mission-critical voice communication at least a decade away. EMS is likely to become a heavy user of the network, which will employ voice command functions a la Siri or Alexa.

"Be sure the public safety organizations never forget how valuable the amateurs are!"
NPSTC Chairman Ralph Haller, N4RH

Inevitably there will be coverage gaps, and the development of "deployables" is critical. These devices can expand the network to areas it doesn't cover but where it may be needed for a specific incident. Deployables could include satellites — Inmarsat is a member of the AT&T team. Network security and encryption is a high priority. The Military Auxiliary Radio System (MARS) now uses encryption on its data nets.

While images in the form of digital Amateur Radio television (DATV) and a plethora of digital modes are available to ARES, FirstNet could nudge ARES to more quickly adopt a similar approach. A new generation of radio amateurs steeped in data, image, and video technology is likely to drive ARES to think beyond analog.

Haller advised that the Amateur Radio community should continue to work closely with public safety organizations at all levels to assure that they remain a part of emergency plans.

"The hype about broadband should not result in amateurs inadvertently being swept under the rug," Haller stressed. "Be sure the public safety organizations never forget how valuable the amateurs are!"

FirstNet will use spectrum at 700 MHz — no immediate threat to Amateur Radio allocations, although there is no guarantee that this won't change as the network approaches the shift to 5th generation (5G) technology. Amateur Radio has access to significant spectrum above 700 MHz.

The expectation is that within a couple of years, a nationwide "core" network will be ready to roll out, and the first public safety users will be on board. Some regional networks have been set up for proof-of-concept purposes and to work out wrinkles.  — Thanks to Mike Corey, KI1U, and Ralph Haller, N4RH

Brad Dye, Ron Mercer, Allan Angus, Vic Jackson, and Ira Wiesenfeld 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. Each one has unique abilities. We would be happy to help you with a project, and maybe save you some time and money.

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Telephone: 631-786-9359
www.wirelessplanners.com
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