Subject: [NEXTEL-1] APCO Comments On Amendment of Parts 2, 73, 74 and 90 of the

From: [email-masked]
Date: Tue, 23 Sep 2003 11:46:21 -0400

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the matter of

Commission.s Rules to Permit   ET Docket No. 03-158 New York Metropolitan Area
MB Docket No. 03-159 Public Safety Agencies to Use
Frequencies at 482-488 MHz

To: The Commission

COMMENTS OF APCO
The Association of Public-Safety Communications Officials-International, Inc.
(.APCO.) hereby submits the following brief comments in response to the
Commission.s
Notice of Proposed Rulemaking (.NPRM.) in the above-captioned proceedings, FCC 03-

165, released July 10, 2003.

APCO, founded in 1935, is the nation.s oldest and largest public safety
communications organization.  Most of APCO.s over 16,000 members are state or
local
government employees directly involved in the management and operation of
communications systems for our nation.s police, fire, emergency medical, highway
maintenance, forestry conversation, and other public safety agencies.  APCO has
long
served as a certified frequency coordinator for Public Safety Pool channels, and
often
appears before the Commission on matters related to public safety communications.

The Commission has proposed a permanent reallocation of 482-488 MHz (TV Channel
16) for public safety communications in the New York metropolitan area.

Since 1995, New York area public safety agencies have used this spectrum pursuant
to a
temporary waiver granted by the Commission.   For the reasons set forth in the
NPRM,
the Commission should now make this spectrum available for public safety on a
permanent
basis through a change in its allocation rules.  In the alternative, the
Commission should
grant a permanent waiver pursuant to Section 337(c) of the Communications Act.

Metropolitan areas throughout the nation face severe shortages of radio spectrum
for public safety communications.  That results in overcrowded and interference
prone
public safety radio channels, the inability to implement state-of-the-art
communications
tools, and, in many cases, a lack of interoperability between public safety
agencies
responding to the same emergency.  The channel 16 frequencies at issue here have
been,
and should continue to be, an important vehicle for New York area public safety
agencies
to alleviate some of that spectrum congestion.

The New York area agencies have invested substantially in radio systems using
these frequencies, which have proven invaluable in their day-to-day public safety
operations, and in responding to major emergencies, including September 11, 2001.
As
further discussed in the NPRM, New York area public safety agencies have no place
else
to go, as all other radio frequency bands are already overcrowded, or (in the case
of the
700 MHz band) blocked by television broadcast stations until some uncertain future
date.

Therefore, APCO strongly supports spectrum reallocation or rule waivers to allow
permanent public safety use of 482-488 MHz (TV Channel 16) in the New York
metropolitan area.
Respectfully submitted,

ASSOCIATION OF PUBLIC-SAFETY
COMMUNICATIONS OFFICIALS-
INTERNATIONAL, INC.

By:

Robert M. Gurss
Director, Legal & Government Affairs
APCO International
1725 DeSales Street, NW
Suite 808
Washington, DC 20036
(202) 833-3800
September 22, 2003

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515083230

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