Dear Chairman Kennard:
I want to commend your recent statement urging that Congress provide incentives for broadcasters to meet the 2006 “deadline” for conversion to Digital Television (DTV). Any delay in that conversion will prevent police, fire, emergency medical, and other public-safety agencies from implementing new, interoperable radio communications systems in portions of the radio spectrum occupied by channels 60-69.
As you know, Congress mandated in 1997 that, as part of the DTV transition, 24 megahertz (the equivalent of four TV channels) from TV channels 60-69 be reallocated for public-safety radio communications, with the remaining channels to be reallocated for commercial services through auction. The FCC responded with an allocation of 769-776/794-806 MHz for public-safety services, which corresponds to TV channels 63, 64, 68, and 69. In many areas of the country, some or all of these channels are vacant, which will allow public-safety operations to proceed as soon as equipment becomes available (which cannot occur until the Commission resolves critical interoperability standards issues in Docket 96-86).
However, in many other parts of the country, some or all of the reallocated channels are occupied by analog (and in a few instances, digital) television stations. Thus, public-safety use of the spectrum is blocked in many instances until the end of the DTV transition.
Unfortunately, the DTV transition debate is often colored by the potential revenue from auction of reallocated spectrum. However, much more than dollars and cents are at issue. Congress, the FCC, and general public must recognize that the DTV transition will also impact the availability of radio spectrum for our nation’s public-safety personnel. There is currently a severe shortage of spectrum available for public-safety operations, which leads to dangerous congestion on existing radio channels, a lack of interoperability between public-safety personnel from different agencies responding to the same emergency, and the inability to implement new public-safety communications tools. While the reallocation of 24 megahertz from channels 60-69 is only the first step toward solving those problems, it will go a long way toward mitigating some of the most critical needs facing many public-safety agencies. That assumes, however, that all 24 megahertz is available across the nation, and not blocked by ongoing television broadcast operations.
Sincerely,
Lyle Gallagher
President
APCO
North Dakota State Radio Communications
