Editor’s Note: Portions of this article will be submitted to the Federal Communications Commission in a White Paper by the Industrial Telecommunications Association.
I have been reading Fred Day’s book, “Policies and Practices in the Regulation of Private Radio Communications Systems,” lately. My favorite chapter is the one on “Development of the Private Radio Services,” because it is a fascinating evolution that shows government reacting to fulfill companies’ needs for internally owned and operated systems. On the other hand, it is a tale of how the FCC developed today’s rather bizarre web of radio services.
After almost two-and-a-half years, the spectrum refarming proceeding is scheduled to be completed in the FCC’s May open meeting. As part of refarming, the FCC proposed consolidating the 19 radio services in the UHF and VHF private wireless spectrum. ITA has taken a strong stand in favor of radio service consolidation. In this article, I will paraphrase some of the contents of Fred’s book and explain how it has shaped my beliefs in favor of radio service consolidation.
Soon after its birth in 1934, the FCC recognized seven private land mobile services: emergency service (public-safety related), geophysical service, agriculture aviation, private coastal, experimental, fixed private and temporary service.
Through the years, citizens went to the government with their private radio needs and received allocations for different radio services on different pieces of spectrum.
In 1937, the FCC added four radio services: police, forestry, mobile press and motion picture. In 1945, spectrum in the 25-44 MHz and 108 MHz-30 GHz bands was allocated to a number of radio services, including forestry and conservation, and utilities. At the end of 1945, the FCC converted the railroad radio service from an experimental to an official service. Frequencies in the 72-76 MHz band, in 1946, were allocated to the urban transit, power and petroleum radio services, among others. In 1949, the FCC implemented rules governing the industrial radio services. One of those services was the special industrial radio service, which covered agriculture, heavy construction, fuel-oil delivery and specialized services to the petroleum industry. That same year, the FCC created the land transportation radio services.
In the late 1940s and 1950s, the FCC began to allocate spectrum in the 150-174 MHz, 450-470 MHz and the 470-512 MHz bands to these and other radio services. In 1958, while modifying channel spacing in the 450-470 MHz band, the commission established the manufacturers radio service, telephone maintenance radio service and business radio service.
This synopsis provides some idea of how the current plethora of radio services came about. All in all, through the years, six separate radio services were devoted to public-safety groups, including local government, police, fire, highway maintenance, forestry conservation and special emergency. Nine different radio services were created to serve industrial radio needs, such as power, petroleum, forest products, motion picture, relay press, special industrial, business, manufacturers and telephone maintenance.
Land transportation now sports four distinct radio services: motor carrier, railroad, taxicab and automobile emergency.
New private wireless era
In 1974, the FCC moved away from the multiple-radio service approach and allocated spectrum in the 800 MHz band on the basis of technology. A total of 200 channel pairs were allocated for trunked systems and 100 channel pairs were slated for conventional systems. In 1978, the FCC allocated another 50 channel pairs for conventional systems. The 200 channel pairs are now the specialized mobile radio allocation in the upper portion of the 800 MHz band. And the 150 conventional channel pairs are now known as the general category frequencies.
In 1982, the commission adopted the pool approach. The agency allocated 250 channel pairs for either trunked or convention use, with 80 channel pairs designated for SMR use, 70 channel pairs for public-safety use, 50 channel pairs for industrial/land transportation use and 50 channel pairs for business use. Intercategory-sharing rules were instituted to allow an entity from one radio pool to access frequencies in another pool if all of the frequencies in the applicant’s home pool in the desired area are already assigned. This policy serves to correct spectrum-use anomalies between the radio pools and is a self-correcting mechanism.
A similar pool approach was also implemented in the private allocation in the 900 MHz band.
Refarming setting new stage
In 1992, the FCC proposed sweeping changes in the private land mobile radio services rules. The industry received a plan to introduce digital technologies in the 421-430 MHz, 450-470 MHz and 470-512 MHz bands. The channels in the 72-76 MHz and 150-174 MHz bands would be similarly impacted. Along with increasing spectrum efficiency, the commission suggested the current regulations be streamlined. The FCC asked the industry if the current structure of 19 radio services should be consolidated.
The radio service decisions the FCC made during the last 60 years have become dated.
ITA, the Council of Independent Communication Suppliers (CICS) and the Telephone Maintenance Frequency Advisory Committee (TELFAC) could not be more in agreement. The radio service decisions the FCC made during the last 60 years have become dated. For example, when the railroad radio service was allocated 91 channels in the 150 MHz band in 1949, there were 131 railroads nationwide. ITA, CICS and TELFAC have recommended the FCC use four pools: private industrial, specialized mobile radio, business/general category and public safety.
Spectrum allocation inequities
The evolution of industry has resulted in inequities in the spectrum allocated to the private wireless radio services. In its Notice of Proposed Rule Making, the commission noted it had studied usage across the 19 radio services and had found differences in usage. In a study of its licensing database, the FCC found “very wide variations in usage, often exceeding factors of 10 for channels in the same frequency band designated for different radio services.”
Joint Comments in the refarming proceeding, filed by ITA, CICS and TELFAC, said, “Over time, the demand for frequencies in some services has diminished while the demand in other services has increased. The intensity of channel use today varies significantly among the services.”
A study of the 1993 FCC licensing database provided proof of these discrepancies that have evolved over the years. ITA looked at the total number of frequencies allocated to each service in the 30-50 MHz, 150-174 MHz and 450-470 MHz bands and compared it with the total number of stations operating in 1993. While these frequency-use numbers may be slightly inflated because of “over-licensing” on some private wireless systems, that phenomenon is universal and therefore does not materially affect the validity of this study.
The association divided the number of stations by the number of frequencies to find the number of stations per frequency.
The radio service with the most intensive use was business, with 376 total frequencies and more than 590,000 stations nationwide or 1,571 stations per frequency. Special industrial ranked second, with 135 total channels supporting nearly 108,000 stations or 799 stations per frequency.
The next three spots were public safety-related. Local government had 472 stations per frequency, fire had 365 stations per frequency, and special emergency/medical had 345 stations per frequency.
Several radio services had ratios of around 100 stations per frequency and below. Taxicab, which has 52 total frequencies, reported nearly 5,400 stations in 1993 or 103 stations per frequency. Forestry conservation reported 93 stations per frequency; motor carrier, 81 stations per frequency; forest products, 67 stations per frequency; and film and video, 33 stations per frequency.
The FCC has already consolidated some of the radio services, providing spectral efficiency. For example, film and video share six frequencies with special industrial and four frequencies with relay press.
A healthy side effect of radio service consolidation is competitive frequency coordination.
Historically, one of the chief complaints against the frequency advisory committees was that some of them have monopolies in their radio services. It would seem that applicants or their agents prefer choice. With the marketplace dictating performance from coordinators, the FCC will spend less time and money in its oversight role. In recent years, the commission has worked hard to encourage competition as a benefit to the consumer.
Another problem with having multiple radio services below 800 MHz is interservice sharing. When all of an area’s frequencies are assigned in one radio service, an applicant can access channels in another radio service. However, the applicant must pay the coordination fees of its primary coordinator and of the coordinator of the other radio service’s channels. There may be multiple coordinators for this spectrum, so coordination costs may run higher than necessary. Plus, the process is quite time-consuming. With a pool arrangement and competitive coordination, the inefficiencies of interservice sharing will be eliminated.
In the process of creating regulatory parity between enhanced SMRs and cellular carriers, the FCC is taking down regulatory barriers that don’t appear to make sense anymore. Many of the barriers between the 19 radio services are not relevant in today’s marketplace.
For example, a manufacturer cannot share frequencies between its plant and its warehouse, requiring it use the manufacturers radio service for operations in its main building and the business radio service for personnel on the dock. Frequencies used in the process of brewing beer cannot be used by a brewery to deliver it. The same brewer would have to use yet another radio service, the special industry radio service, to get frequencies to support its farming activity.
“Look, under the current rules, if you got three MAC trucks barreling down the highway side by side, depending on their shipment, they will probably each use a different radio service,” said Mark E. Crosby, ITA president. “The one with concrete is using the special industrial radio service . . . the one with the logs is using the forest products radio service*…*and the other hauling cargo is probably licensed in the motor carrier radio service. I don’t believe such regulations serve today’s requirements.”
Even if the frequencies were redistributed to revamp the present 19-service configuration, it would become obsolete again, as social priorities change and industries ebb and flow. The answer is to simplify.
As the FCC does its spring cleaning this year, it should take the mop to the old cob web of radio services. Four radio services-private industrial, specialized mobile radio, business/general category and public safety-offer flexibility, which is sorely needed to create an equitable private wireless spectrum allocation.
J. Sharpe Smith is manager of communications for the Industrial Telecommunications Association, based in Washington, D.C., a national advocate and service organization for more than 7,800 private land mobile radio licensees.