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Regulatory Overview Some people will tell you that APCO-25 is the regulatory standard for mandatory compliance with new FCC narrow band rules. That isn't exactly correct.......  You've heard the rumors. All public safety agencies must purchase APCO-25 type narrow band 2-way radios to receive federal funds because the Department of Homeland Security (DHS) guidelines state that all new radio purchases SHOULD be APCO-25 compliant. Now, let's deal with a few facts and definitions for the REAL answer! First, let's make a few corrections. The compliancy issue is based on a standard developed by SAFECOM. This is kind of like an internal advisory group to DHS. Perhaps a few definitions may be in order at this time. Let's start with the mission of SAFECOM.
SAFECOM
The following is quoted directly from SAFECOM's mission statement. SAFECOM adheres to a bottom-up approach, which means the program relies heavily on local and state emergency response practitioners for input and guidance as it works to define and implement solutions for the interoperability challenge.
As a practitioner-driven program, SAFECOM has developed a governance structure that facilitates the input of local and state emergency response practitioners. Through the Program’s Executive Committee (EC) and Emergency Response Council (ERC), the emergency response community and local, tribal, state, and Federal policy makers provide strategic input to the SAFECOM Program.
The SAFECOM standard, if we understand it correctly is currently based on two factors. The first being that the technical standard developed by APCO (more about this later), generally known as P25 will be the preferred digital interoperable communications standard in the USA. A large number of countries (at least those that have developed a standard) tend to favor a technology known as TETRA. Even in the USA, there are lesser cost digital alternatives that are actually superior in some regards to P25 for those that plan to build a new system or upgrade and existing system. However, if the user intends to MIGRATE from analog to digital, P25 is the best choice.
The second factor relating to the SAFECOM standard is a recommendation that all statewide systems be based on operation in the 700 MHz band. That is all well and good except for two limiting factors. First, the are a very limited number of potential suppliers, all of which currently offer only high tier expensive radios. Second, and of more importance, is the fact that frequencies will not be available until 2009 when TV broadcasters are scheduled to vacate the band proposed to be used. Lastly, there are a number of competing plans for management of the 700 MHz band when the aforementioned details have been resolved. The bottom line is that the recommendation to use P25 700 MHz as a "standard" is an objective that simply cannot be met at this time.
It is our understanding that the Department of Commerce (DOC), not DHS will have the ultimate responsibility for distribution of funding for interoperable communications. DOC has the option of agreeing or disagreeing with SAFECOM proposed standards - an issue as yet, unaddressed. For now, let's get familiar with the terms used in the definition of the proposed standards.
The Associated Public-Safety Communications Officials (APCO)
Originally an association of police communications technicians, APCO has grown into a PRIVATE ORGANIZATION that provides a number of services relating to government communications. Notably, APCO is one of several frequency coordinators responsible for coordinating frequency assignments before an application is filed with the Federal Communications Commission (FCC). APCO also has a technical standards group responsible for planning the future needs of police (and more recently public-safety) users. It was through this group that a standard for advanced narrow band communications was developed. This standard is known as APCO Project 25, APCO-25, or simply P25. In essence, APCO-25 defines a standard for migrating from the current bandwidth of 25 kHz to a reduced bandwidth of 12.5 kHz (this is known as narrow band) using TDMA digital technology in Phase 1 and FDMA in Phase 2 (at least two years away from 2007). The FCC requires all radios to operate on 6.25 kHz channels by 2018 and all radios built in the USA to be capable of operating at 6.25 kHz after January 1, 2011. On the assumption that analog radios will not operate efficiently at 6.25 kHz (ultra narrow band), the APCO-25 project defined a new radio standard that would allow APCO-25 radios to operate on 12.5 kHz in either an analog or digital mode as well as 6.25 kHz digital only mode using FDMA technology. The Phase 2 operational standard for 6.25 kHz will include backwards compatibility with Phase 1 digital as well as analog operating modes. It should be again noted that APCO is NOT a government agency and has no regulatory authority over any user - either public safety or private. APCO-25 is simply an evolving standard that has been endorsed by a number of manufacturers and users.
The Federal Communications Commission (FCC)
The FCC was established and is governed by the CONGRESS of the United States under the authority of the Legislative branch. The FCC has been given ALL AUTHORITY over the operation of ALL communications including broadcast media, wireless communications of all types of radios INCLUDING Public Safety communications. It is the FCC that determines the technical operating standards for communications equipment in the United States and no other Branch of government - PERIOD! It is the FCC that is responsible for long term frequency planning and the implementation of narrow band technology below 512 MHz. in two phases. Phase One requires that all communications devices used in the United States below 512 MHz. be capable of operating on frequencies not exceeding a bandwidth of 12.5 kHz. This is commonly known as the narrowband standard. Until 2013 (maybe), public safety users may continue to use 25 (wide band) kHz equipment. Phase 2, which becomes mandatory (maybe) in 2018 would require radios capable of operating at 6.25 kHz. To say there is a great deal of confusion relating to these new standards would be a gross understatement! Both the first and second phases assume radios capable of operating in either an analog or digital mode with automatic detection and selection of the incoming signal(this is known as Mixed Mode operation). Currently, the alternate MotoTRBO digital system and first generation FDMA 6.25 KHz digital systems do NOT have this capability. The new IDAS multi-mode 6.25 kHz system by ICOM has simultaneous analog and digital communications capability
Much of the confusion relates to pressure on the FCC by special interest groups. For example, the FCC wanted TV Broadcasters to vacate the 700 MHz band (Channels 60-70) for reassignment to public safety users. The broadcasters made no effort to comply and continued to be granted extensions to continue operations through 2008.. The result is that 700 MHz frequencies cannot be assigned in most areas of the US. Then, there is the spectrum swap crafted by Sprint/Nextel whereby Nextel would give up 800 MHz frequencies (which allegedly cause interference to public safety users in the 800 MHz band) and move to the more desirable (for Nextel) 1900 MHz band. No one seems to know when, if ever this will happen. In the meantime, the FCC has focused most of their attention on frequency bands below 512 MHz where they have attempted to implement the new narrow band standards. To say that there has been much opposition would again be a gross understatement. But, confusion or not - It is the FCC that is responsible for equipment technical standards, not anyone else including DHS.
The Department of Homeland Security (DHS)
A cabinet level agency, set up under the authority of the EXECUTIVE branch of our government. There are two other branches of equal power - Judicial, and Legislative. Legislative MAKES laws, Judicial INTERPRETS law, and Executive ENFORCES law. It is important to remember the differing responsibilities of each branch and that fact that no branch has the authority to usurp the authority of another REGARDLESS OF THE SITUATION! Our Constitution guarantees an equal balance of power for obvious reasons. DHS states that any radios funded by DHS SHOULD be APCO-25 compliant. To meet this loosely worded requirement, any radio purchased with DHS funding would comply if it is capable of operating in the 12.5 kHz mode. It does NOT have to be digital and it does NOT have to operate at 6.25 kHz and it does NOT have to operate at 700 MHz as proposed by SAFECOM. The perceived intent as that DHS funded radios should have digital capability, but because of the confusion associated with the wording, DHS grants have been granted for non-digital radios operating at 12.5 kHz.
The Department of the Interior (DOI)
The DOI, among other things is responsible for taking care of federal lands through a subordinate agency known as the Bureau of Land Management. In this capacity, the DOI has a close working relationship with the US Fire Administration, who in turn works closely through the Federal Emergency Management Agency (FEMA). DOI through another subordinate agency, the US Forest Service works closely with State, County, and local fire departments - both paid and volunteer. It is important to note that DOI is NOT subordinate to DHS, or any other cabinet level agency or Department. DOI needs coordinated communications with State, County, and local firefighters for the protection of federal lands. DOI has some input into the standards applicable to FEMA grants, mainly dealing with the ability to communicate with DOI personnel using a commonly accepted standard. At this time, the ONLY requirement is the ability to communicate at 12.5 KHz (narrow band) using ANALOG radios. OPTIONALLY, a user can communicate with DOI using 12.5 kHz radios operating in the digital mode, utilizing radios capable of operating in both an analog and digital format. See previous comments. In the digital operating mode, a U.S. Government user agency may require high level encryption, either DES (Digital Encryption System) or AES (Advanced Encryption System) as part of a requirement for FIPS (Federal Information Protocol System) compliance.
As an item of note, many US government agencies such as the US Forest Service are purchasing digital APCO-25 compliant radios at this time - not a result of a mandate by another agency, but more for reasons of economic practicality. It is safe to say that at some point, all users will have to be 12.5 kHz digital compliant. Rather than purchasing 12.5 kHz analog radios for current use, the Forest Service chose to skip the interim step and purchase digital compatible equipment. That makes sense if the funds are available to purchase radios that typically cost four times more than an analog equivalent capable of operating at 12.5 kHz.
M/A-COM, Motorola, etc.
All major manufacturers including BK/Relm E.F. Johnson, ICOM, Kenwood, Midland, Relm and Thales have acknowledged the APCO-25 standard but to our knowledge, none of them has developed P25 trunking capability. As you may know, trunking is the concept of pooling a group of frequencies for dynamic assignment as required. For the past 25 years, we have been told that trunking is the key to high efficiency utilization of frequencies, yet we are not offered this capability utilizing APCO-25 compliant equipment. There are a number of reasons for this apparent oversight, but the main one is the lack of a standard P25 trucking system protocol.
Both Motorola and M/A-Com offer digital trunking systems that are NOT compatible with APCO-25. If you want the trunking capability, you must use equipment incorporating their proprietary protocols. The fact is that no manufacturer really wants a totally open standard. That would be totally contrary to a competitive and profitable marketplace. Those who are waiting for a universal standard that reduce all manufacturers to a common technical standard will have a very long wait.
Summing it all up - So what do you do? The fact is that 12.5 KHz equipment is readily available in analog, analog upgradeable to P25, and P25 digital equipment with backwards compatibility to analog 25 or 12.5 kHz at reasonable cost. Purchase of a 12.5 kHz capable radio today meets FCC requirements from which DHS has scripted their loosely worded requirement for "should" be APCO-25 compatible. Forget about any short term planning in the 700 and 800 MHz bands for now. There are too many issues still up in the air.
Utilization of P25 digital equipment will assure interoperability with federal agencies and other P25 users. It is a great choice to consider for those who are planning a gradual phase out of older equipment. 6.25 kHz FDMA equipment such as the IDAS system by ICOM or the MotoTRBO TDMA system are obviously compliant with FCC requirements, although special consideration is required by public safety users.
We hope this information has been useful and to the best of our knowledge, it is correct at the time of publication. For additional information, we encourage you to do your own research and not take verbal or written representations by anyone (including us) as being factual. Check it out for yourself. We've given you our opinion and we encourage you to develop your own conclusions through additional research.
*Digital base stations generally provide equal if not better range than 25 kHz analog stations.
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