I JUN - 1 2005 1
1 FCC-MAILROOM [
Office of the Secreky
Federal Communications Commission
Washington, DC 20554
445 12m St., sw
SBOCKET FILE COPY ORIGINAL
WT Docket NO. 96-
comments
To: The Commission
The employees of Hi-Desert Communications wants to advise the FCC of a number of
concerns it has about the proposal to require radios using only the 700 MHZ wideband general
use channels to be capable of operating on the interoperable channels as well. Although we
support interoperability, we do not believe this specific requirement is reasonable or necessary.
It is of even greater concern because of the FCC's decision to adopt the SAM standard for all
700 h4Hz wideband equipment.
Here are some of the reasons we think the proposal is a bad idea:
At earlier stages of this proceeding, the FCC correctly decided that public safety users are
entitled to some discretion in how they design and operate their systems. We all have certain
unique operating requirements depending on factors such as whether we are in urban or rural
areas, the types of communications we intend to handle, and the fresuency with which we need
to coordinate with other organizations. The FCC's active role in encouraging interoperability is
welcome, particularly for voice communications where everyone will be using a common
language. However, we had planned on and need the option of operating radios on the wideband
general use channels to meet our specific wideband data applications. Forcing us to have SAM
capability in those radios certainly will make that difficult and may make it impossible.
One major issue is that SAMenabled equipment is not available today; it isn't clear when it will
be. That means that all wideband deployment, and even wideband planning, will have to be put
on hold for the time being. It took the FCC and the industry a long time and a lot of effort to get
access to this 700 MHZ spectrum. We want to use it as soon as possible.
Another concan is that this additional requirement will increase the cost of 700 MHz wideband
equipment by some as yet unknown amount. It also is expected to require more infrastructure to
get the same coverage. That may not be an issue in urban areas where public safety users
already use multiple sites. It will have a major cost impact on rural systems if they have to build
additional sites just to make the equipment meet a standard for a use they don't anticipate
activating.
No. of Co ies rec'd 4
LY AECBE