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The Public Safety and Homeland Security Bureau of the FCC is soliciting comments on a Petition for Rulemaking filed by the National Public Safety Telecommunications Council (NPSTC) which requests that the Commission allow narrowband analog operation on some 700 MHz channels. Current rules require that digital modulation be used. Digital modulation has proven to be problematic and some agencies are refusing to use very expensive new radio systems that have been purchased because of the issues.

This is significant because NPSTC and the FCC appear to be recognizing some of the problems with digital police and fire communications systems. The proposed changes to the FCC rule are limited in scope and provide for analog operation on only 12 simplex channels at power levels not exceed 20 watts ERP. Analog operation on base stations is not being considered at this time. The stated purpose is to facilitate on-scene incident response using mobile and portable radios only.

This action by NPSTC and the FCC affords an opportunity for the fire service and others to further request the use of analog modulation on channels designated for General Use in the 700 MHz band, expanding NPSTC’s original proposal.

My advice is to defer the conversion to digital radio technology for as long as possible, and for not less than one more generation of equipment. Today’s digital technology is immature, as are the FCC rules regarding its use. Narrowband analog technology works quite well and has superior performance in almost all scenarios.

Comments to the FCC are due by July 31, 2008.

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