Addressing Licensing Issues for Interoperability Channels

1. INTEROPERABILITY CHANNEL LICENSING ISSUE Presentation to CalSIEC 22 JUNE 2009

2. CLEMARS • Plan developed under OES, Law Enforcement Division • CLEMARS Executive Committee provides policy guidance • All licenses held by State • Technical restrictions • Antenna Height • Power output

3. CLEMARS FREQUENCIES • CLEMARS 1 154.920 MHz • CLEMARS 2 154.935 MHz • NALEMARS 155.475 MHz • CLEMARS 4/5 460/465.025 MHz • CLEMARS 6/7 39.46/45.86 MHz • CLEMARS 8/9 823/868.5125 MHz • CLEMARS 20/21* 821/866.2000 MHz • CLEMARS 22** 484.2375 MHz *Northern California Only ** Los Angeles Only

4. CLERS • Plan developed under OES • Intended as point-to-point network • Mountain-top repeaters licensed by State • Control stations licensed by individual agencies • 12 frequencies combinations in VHF and UHF bands

5. FIRE WHITE • Plan developed under OES, Fire and Rescue Branch • Licenses held by individual agencies • Technical restrictions • Power output • Primarily mobile operations

6. FIRE WHITE FREQUENCIES • White 1 154.280 MHz • White 2 154.265 MHz • White 3 154.295 MHz

7. CESRS/CALCORD • Plan developed by OES • Licenses held by State • Technical Restrictions • CALCORD is mobile only • Frequencies • CESRS 153.755/154.980 MHz • CALCORD 156.075 MHz

8. HEARS • Plan developed under Emergency Medical Services Authority • Licenses held by individual agency • Frequency • 155.340 MHz

9. NPSPAC MUTUAL AID • Plans developed by Region 5 (Southern California) and Region 6 (Northern California) Regional Planning Committees • Committee review/approve all applications • All licenses held by State • Technical Restrictions

10. NPSPAC FREQUENCIES • ICALL 821/866.0125 MHz • ITAC 1 821/866.5125 MHz • ITAC 2 822/867.0125 MHz • ITAC 3 822/867.5125 MHz • ITAC 4 823/868.0125 MHz

11. 700 MHz INTEROP CHANNELS • Plan to be developed by CalSIEC • Channel names defined • Not yet defined • Who will license stations • Technical limitations • Operational requirements

12. NEW CHANNELS • Unknown if any entity has “assumed” responsibility for these • Not yet defined • Who will license stations • Technical limitations • Operational requirements

13. “NEW” Frequencies • VCALL 155.7525 MHz • VTAC 1 151.1375 MHz • VTAC 2 154.4525 MHz • VTAC 3 158.7375 MHz • VTAC 4 159.4725 MHz • UCALL 453/458.2125 MHz • UTAC 1 453/458.4625 MHz • UTAC 2 453/458.7125 MHz • UTAC 3 453/458.8625 MHz

14. LICENSING PROBLEMS • Licenses intended to be held by differing entities • Some state-held/Some individual agency-held • Difficult to change due to “legacy” processes • “Plan” developed by different groups • OES (now Cal EMA) on older frequencies • 800 MHz Regional Planning Committees (2) • Cal SIEC • Recommend consolidation under Cal SIEC

15. LICENSING PROBLEMS • Existing plans need to be reviewed and updated • Recommend Cal SIEC establish a series of “working groups” to accomplish this task • Cal SIEC Executive should then review the individual “plans” for consistency

16. LICENSING PROBLEMS • Existing process for licenses held by State is not functioning properly • Current Process • “Requesting agency” prepares a state-generated form • Submits form together with fee to OES for review for compliance with plan • OES forwards form to DGS-TD for preparation of license application to FCC • License forwarded to “requesting agency”

17. RECOMMENDATION • Establish a working group to define a new process • Requests complying with defined criteria should be “fast-tracked” (i.e. staff are authorized to process) • Requests not complying with defined criteria should be diverted through an “Exception Process” that requires review/approval by one or more higher level policy committees • Requests that affect other users, all of whom are within a Regional Planning Area, might require review/approval by the Regional Planning Area Executive Committee • Requests having greater effect might require review/approval by the Cal SIEC Executive Committee • The new process must clearly define “who” is responsible for completing each step and forwarding to next stage

18. LICENSING PROBLEMS • State-generated form does not collect all of the required information • Recommend using FCC Form 600 as alternative • “Requesting agency” does not provide all of the required information • Recommend using FCC Form 600. If incomplete, return to “requesting agency” • Requests “disappear into Black Hole” • Provide feedback to “requesting agency” throughout process

19. DESIRED OUTCOMES • Decision • Is “responsibility” for all interop channels going to be consolidated within Cal SIEC or continue to be separated? • Creation of “working groups” to review and update (in some cases “create”) plans • Plan updates should define criteria for a “routine” application • Creation of a “working group” to update licensing process • Includes decision as to “who” will license each channel • Should include both a “routine” and an “exception” process • Clearly defines “who” performs each step

20. “LETTER LICENSES” • Agency “A” authorizes Agency “B” to operate under the license held by Agency “A” • Permitted under Section 90.421 of the FCC Rules • Agency “A” assumes responsibility for how Agency “B” operates • Applies to mobile stations only • Fixed stations must be properly licensed • Question---does Agency “A” license in its own name, or does it allow Agency “B” to obtain a license on the frequency

21. RECOMMENDATION • Standardize a process • Information needs to be exchanged • Frequencies authorized • Power and ERP permitted • CTCSS tones, system ID codes, etc. • Area of operation permitted • Callsign under which stations are to operate • Recommend periodic renewal