In comments to the FCC regarding modified 700 MHz narrowband channel rules for Project 25 (P25) Compliance Assessment Program (CAP) compliance and vehicular repeater systems (VRS), public-safety associations offered continued support for P25 CAP and VRS, and Motorola Solutions filed a petition for partial reconsideration.LMR History Lessons, Reminders and Questions for FirstNet
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The comments are in response to an August FCC order and further notice of proposed rulemaking (FNPRM).
Motorola Solutions said the FCC should delay implementation of its modified P25 CAP rules, which require P25 CAP compliance or the equivalent to be completed after equipment certification but prior to the marketing or sale of that equipment. The FCC said the new P25 CAP rules will ensure that potential users will have the benefit of CAP testing or the equivalent and compliance with P25 interoperability standards without disadvantaging radio manufacturers.
Motorola Solutions said the FCC should either postpone or suspend enforcement of this new rule until complementary proposals affecting Section 90.548 are addressed in a future order. The company also said Office of Management and Budget (OMB) approval is required before the P25 CAP revisions can become effective.
“Motorola Solutions continues to have concerns about how this program, originally designed to be performed voluntarily, can be implemented within the FCC’s rules without impeding innovation,” the vendor said in separate comments filed before the petition for partial reconsideration.
Earlier this year, the P25 CAP advisory panel (AP) submitted 15 features sets and capabilities that should be tested. Some of the 15 feature sets don’t yet have CAP tests or are not yet in the P25 standards. The National Public Safety Telecommunications Council (NPSTC) said only the feature sets that are in the P25 standard and have associated CAP tests should be included in FCC rules.
In its comments, the Association of Public-Safety Communications Officials (APCO) International said codifying baseline feature sets and the FCC’s recent action to require CAP compliance or the equivalent prior to the marketing or sale of equipment will substantially promote interoperability. APCO believes that manufacturers should be required to demonstrate interoperability with respect to any additional features offered for public-safety agencies to use in mutual-aid situations. Further, interoperability requirements should not be limited to just voice; the FCC should encourage appropriate testing for features such as packet data, location information, encryption management and other capabilities offered on P25 devices.
“APCO defers to the P25 CAP AP on the most efficient process to ensure that while manufacturers are able to innovate and add new features for devices, they quickly become interoperable with other devices that subsequently offer common features,” APCO’s comments said.
The Telecommunications Industry Association (TIA) said the FCC’s new P25 CAP rules contain inaccuracies and include areas not covered by P25 CAP, and TIA provided recommendations and changes.
The FCC added the 700 MHz reserve channels to the general use pool so they could be available for VRS use. The addition of the reserve channels to the general use pool brought them within the scope of Section 90.537 of the commission’s rules, which requires all 700 MHz systems using six or more general use or state license channels to be trunked. Virginia requested a waiver of the trunking requirement, and the FCC requested comment about rule changes to allow VRS operation at 700 MHz.
Motorola Solutions supports allowing low-power (5 watts or less), mobile-only operations on more than five channels per license without requiring trunking technology on the 700 MHz general use or state license channels.
APCO supports amending the trunking rules to allow VRS. “There is significant demand for VRS in 700 MHz, and APCO is unaware of options for trunked VRS equipment or trunking VRS operations,” its comments said. “… VRS are typically associated with a single user vehicle or multiple users centered on a single scene of activity. Thus, trunking is not necessary for 700 MHz VRS equipment.”
NPSTC recommended additional steps to enable the deployment of VRS to support public safety. The FCC should provide states and regional planning committees (RPCs) with greater flexibility in deciding what operational restrictions are needed for VRS on the 700 MHz narrowband general use channels within its region, as long as the current LMR technical rules are maintained to help minimize interference and promote interoperability.
RPC 20 submitted comments regarding VRS, supporting the extended use of spectrum for VRS conventional operations.
Motorola Petition for Clarification
In August, the FCC also requested comment on a recommendation by Motorola Solutions to clarify Sections 90.547 and 90.548 of its rules to the effect that 700 MHz radios must be capable of being programmed to operate on the designated interoperability channels.
NPSTC said there is concern that the request could inadvertently impact data operations because the P25 data standard is only 9.6 kilobits per second (kbps), whereas a number of LMR data systems operate at faster data rates. “Further discussion is needed on the Motorola request for clarification,” the NPSTC comments said.
APCO said there should not be additional software, firmware, hardware or technology changes required. APCO also believes that the FCC’s rules do not require that every radio have every interoperability channel programmed into it and available to the user. APCO would not, however, support an interpretation of the rules such that all operations on 700 MHz narrowband channels would have to conform to the standards described in Section 90.548.
The comments and petition for partial reconsideration are here.
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