FCC 89-69
`FCC 89-69
`
`Federal Communications Commission Record
`FedeFal Communications Commission Recoi-d
`
`4 FCC Rcd No. 9
`4 FCC Red No. 9
`
`Before the
`Federal Communications Commission
`Washington, D.C. 20554
`
`GEN. Docket No. 88-441
`
`In the matter of
`
`Technical compatibility protocol
`standards for equipment operating
`in the 800 MHz public safety bands.
`
`MEMORANDUM OPINION AND ORDER
`
`Adopted: February 22, 1989;
`
`Released: May 1, 1989
`
`By the Commission: Commissioner Ouello concurring
`and issuing a statement. Commissioner Dennis issuing a
`separate statement at a later date.
`
`1. INTRODUCTION
`1. On September 7, 1988, we released a Notice of
`Inquiry to explore the advantages and disadvantages of
`adopting a uniform trunking standard for radio equip-
`ment manufactured
`for
`trunked operation
`in
`the
`821-824/866-869 MHz public safety spectrum.' In response
`to the Notice we received comments and reply comments
`from a variety of organizations and individuals represent-
`ing public safety communications equipment manufactur-
`ers, the public safety community, and other interested
`organizations.
`2. After careful consideration of the record developed
`herein, we have concluded that a Commission-mandated
`uniform trunking standard for analog communications is
`not necessary to achieve adequate interoperability among
`800 MHz public safety entities. Our decision is not in-
`tended to prevent the industry from pursuing enhanced
`interoperability capabilities, either through the regional
`planning process established in the Public Safety National
`Plan proceeding,z or through the development of com-
`patible trunked public safety communications systems. We
`conclude, however, that the steps we have taken to assure
`interoperability are adequate and that further federal in-
`tervention is not warranted at this time. We also conclude
`that the public interest will be served in this matter by
`the timely licensing of public safety communications sys-
`tems. There is an immediate need for essential public
`safety systems in some areas of the country and the com-
`ments emphasize the importance of licensing these ser-
`vices without delay.
`3. Our objective in this proceeding was to determine
`whether a trunked technology standard for analog com-
`munications 3 should be developed to achieve enhanced
`interoperability among various trunked public safety radio
`systems. We conclude that it would be inappropriate to
`consider imposing standards utilizing this existing technol-
`ogy at this time. Rather, we believe the public safety
`community's interest in interoperability and our overrid-
`ing objective of providing maximum spectrum efficiency
`will best be served by focusing on the development and
`
`use of future technologies, i.e., digital and other advanced
`communications technologies. Accordingly, we will ini-
`tiate a further inquiry in this docket to explore the ways
`in which future radio communication technologies can be
`used to meet the evolving operational and spectrum needs
`of the public safety community.
`
`I. BACKGROUND
`4. On December 18, 1987. we released a Report and
`Order adopting policies, service rules, and technical stan-
`dards to govern use of the 821-824/866-869 MHz public
`safety spectrum. Several petitions were filed asking re-
`consideration. On July 20, 1988, we adopted a Memoran-
`dum Opinion and Order on Reconsideration ' addressing
`four of these petitions, including one filed by General
`Electric Mobile Communications Business (General Elec-
`tric) seeking reconsideration of our decision in the Report
`and Order regarding trunking standards for equipment
`operating in the 800 MHz public safety spectrum. We
`that a further proceeding was necessary
`concluded
`to
`explore
`fully the question of trunking standards. We
`therefore released a Notice of Inquiry on September 7,
`1988, requesting public comment on issues relating
`to
`technical compatibility protocol standards' for 800 MHz
`public safety equipment.
`5. Although we received comments on General Elec-
`tric's petition for reconsideration, the record was insuffi-
`cient
`to support a conclusion
`regarding
`the trunking
`standards question. In particular, the comments did not
`fully discuss (I) the utility of standards or the time neces-
`sary to develop standards, (2) whether a trunking standard
`would result in interoperability, or (3) the effect trunking
`standards could have on the cost of radio equipment or
`on the evolution of trunking technology. 6 Accordingly,
`the Notice sought information on four issues central to
`the trunking question:
`
`1) the timeframe necessary to develop a standard
`and market equipment using the standard;
`*2) how the use of a common signalling standard
`could enable intercommunication among different
`trunking systems operating on different channels;
`3) the effect a common standard might have on the
`cost of equipment; and
`4) the possible effect a standard might have on the
`development of radio communication technologies.
`
`6. We received comments from a variety of organiza-
`tions and individuals representing the ejuipment industry
`and
`the public
`safety community. Most of
`the
`commenters addressed the primary concerns raised in the
`Notice, and a few offered various new suggestions and
`approaches to dealing with the trunking standards issue.
`There was, however, no consensus among the commenters
`i.e.,
`on
`any
`of
`the major
`issues
`listed
`above.
`interoperability, equipment cost, timing, and future tech-
`nologies. There was, however, almost unanimous agree-
`ment that regardless of what we decide on the subject of
`trunking standards, licensing on the new 800 MHz public
`safety spectrum should not be delayed. In reaching our
`decision on whether to adopt uniform trunking standards.
`we gave great weight to this clear desire of the public
`safety community.
`
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`Federal Communications Commission Record
`4 FCC Rcd No. 9
`Federal Communications Commission Record
`4 FCC Red No. 9
`10.
`II. SUMMARY OF COMMENTS
`In addition to
`the obvious disagreement among
`commenters concerning the
`technical and operational
`adequacy of the mutual aid network, there is also consid-
`erable disagreement over the more basic issue of whether
`the establishment of standard signalling protocols will, in
`fact, enable effective interoperability among trunked sys-
`tems operating on different system protocols. The first and
`most obvious requirement necessary to permit commu-
`nications between neighboring jurisdictions is that they be
`capable of operating on the same frequencies. Currently,
`frequency sharing arrangements exist among adjoining ju-
`risdictions around the country, and these enable inter-
`regional emergencies."4 The
`communication during
`advocates of trunking standards argue
`that. given this
`existing practice of intercommunication among agencies
`with similar trunked system protocols, the existence of a
`common signalling protocol standard would allow the
`same intercommunication among agencies operating with
`different system designs. North American Philips Cor-
`poration (Philips) further argues that such an approach
`that simply addresses the standardization of the RF pro-
`tocols that link mobile units and base stations would
`allow an equipment manufacturer to incorporate in the
`design of equipment the various features desired by its
`customers. Philips Comments at 5.
`11. The major source of controversy on the use of
`"frequency-sharing"
`to enable interoperation among in-
`compatible trunked systems is not whether it is techni-
`cally achievable, but whether it is operationally feasible or
`advisable
`to permit "roaming"
`to occur in emergency
`situations. The California Public-Safety Radio Association,
`Inc. (CPRA),
`in its comments, asserts that most law en-
`forcement agencies may not. want other users to enter into
`their systems during a disaster when queueing within a
`system is at a maximum.13 CPRA states that the overload
`that would occur on-a trunked system at this most critical
`time would be unacceptable. CPRA further points out
`that even if law enforcement agencies desired access by
`other selected users, the firmware and software changes in
`their control systems would be frequent and would re-
`quire constant updates
`to all participating agencies'
`databases as units are added and deleted from the various
`forces or, as the Region 40 Public Safety Communications
`Planning Committee
`indicates, trunked systems are re-
`grouped from time to time. Region 40 Comments at 1.
`While this would not be an
`insurmountable problem,
`CPRA expresses the concern that errors'in the databases
`could create situations where appropriate personnel
`would not be able to access systems during emergencies.
`CPRA Comments at 4.
`12. General Electric, in its reply comments, addresses
`the various operational concerns presented by roaming
`and points out that roamers today "can and do move
`from one adjacent trunked system to another manufac-
`tured by the same firm, [and that] existing trunked sys-
`tems already have the management tools to control those
`callers." General Electric Reply Comments at 20. It sug-
`gests that if roaming does not present any problems today,
`then
`it is extremely unlikely to do so
`in the future.
`General Electric Reply Comments at 22. Philips indicates
`further that in the United Kingdom and other countries,
`the necessary software protocols and hardware have been
`developed to allow roaming within and between systems
`and that similar results could be achieved in the United
`States. Philips Comments at 22.
`
`Interoperability
`for Public Safety 8
`7. In developing the National Plan
`one of our primary objectives was to provide a mecha-
`nism that would enable different public safety entities to
`communicate with one another in emergencies. We con-
`curred with the recommendation of the National Public
`(NPSPAC) 9
`Safety Planning Advisory Committee
`that
`interoperability should be achieved through the use of
`five
`"mutual
`aid"
`channels
`contained
`in
`the
`821-824/866-869 MHz bands. We agreed with its recom-
`mendations that the mutual aid channels operate in the
`conventional mode and that all mobiles and portable
`radios operating in the new bands be equipped to operate
`on all five channels. In our Report and Order, we directed
`the various regions to explain in their regional plans how
`the interoperability channels are to be managed.' 0 In the
`Report and Order, we also gave regions, in the develop-
`ment of their plans, the freedom to provide for as many
`additional mutual aid channels as they deem necessary to
`satisfy their intercommunication needs. This type of flexi-
`bility was the cornerstone of the National Plan for Public
`Safety. Thus, in establishing the National Plan, we pro-
`vided both the necessary spectrum as well as the various
`technical and operational rules to permit an organized
`and
`effective
`system
`for
`achieving
`regional
`interoperability.
`8. Despite this effort, certain commenters believe that
`the mutual aid channel concept is inadequate to meet the
`needs for intercommunication among neighboring juris-
`dictions. For example, MX-COM, Inc. in its comments,
`feels that the mutual aid channels will "sit idle most of
`the time - and are probably inadequate
`to the traffic
`demands of a major calamity." MX-COM, Inc. Comments
`at 9. On the other hand, Orange County. California be-
`that
`to attain
`interoperability with neighboring
`lieves
`agencies planning to implement 800 MHz trunked radio
`systems, the use of the conventional five mutual aid chan-
`nels, supplemented by the two statewide mutual aid chan-
`nels currently proposed
`in
`the Southern California
`Regional Plan, is more than adequate to meet the county's
`interoperability requirements. Orange County Comments
`at 4.
`9. Another concern raised by several commenters was
`that the conventional mutual aid network is operationally
`inferior to the more sophisticated trunked intercommuni-
`cation system during emergency situations. They point out
`that a computer-controlled trunked system
`is capable of
`dynamic regrouping of callers" . positive identification of
`callers,' 2 and other capabilities not available to the dis-
`patcher
`in a conventional
`system. Motorola.
`Inc.
`(Motorola) points out. however, that through the use of
`"gateways,"
`units of neighboring jurisdictions, whether
`transmitting on different bands or using different modes
`(trunked or conventional) of operation, can talk to each
`other efficiently. General Electric disputes the effective-
`ness of the gateway system, claiming that this procedure
`calls for units wanting to be patched through to another
`unit or group on a trunked system to "go
`through an
`elaborate process, which introduces delays and resulting
`inefficiencies that are virtually absent for calls that go
`from a caller directly into a trunked system." General
`Electric Reply Comments at 13.
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`Federal Communications Commission Record
`Federal Communications Commission Record
`tion that public safety systems are best served by suppliers
`13. In addition to the various methods and procedures
`who take total responsibility for a complete communica-
`for achieving interoperability discussed in the preceding
`to use of multi-mode
`tions system. Another drawback
`paragraphs, a new approach was offered and debated in
`radios, according to Motorola, is that with the likelihood
`the comments. This was the use of "multi-mode" radios.
`that manufacturers will enhance their systems periodically
`Mobile radios designed with multi-mode capability would
`to bring new features to their customers, users of multi-
`be able to operate with the signalling protocols of more
`mode radios will be required
`to upgrade their radios
`thus be able to
`than one trunking system and would
`repeatedly to conform with the current state-of-the-art.
`communicate with more than one manufacturer's system.
`Finally, Motorola agrees with Philips that multi-mode
`General Electric, a strong advocate of this approach, states
`radios will be more expensive than today's single mode
`that from an engineering standpoint, "all that is required
`units, but perhaps equally as important, asserts that multi-
`is for program memory capacity to be expanded to con-
`mode radios (which contain the designs of different man-
`tain the software that would enable radios to recognize
`ufacturers) could cause operational difficulties for users
`and emulate other protocols." General Electric Comments
`and dispatchers. Motorola Reply Comments at 25-27.
`at 7. One of the primary advantages offered by multi-
`mode radios, according to General Electric, is that "the
`acquisition of new systems could continue without risk of
`obsolescence of embedded trunking equipment," and that
`this would create "backward compatibility" that would
`eliminate adverse impact on existing systems. General
`Electric Comments at 8. General Electric suggests that all
`to begin development of multi-
`that would be required
`mode radios would be to overcome existing patent bar-
`the cross-licensing .of manufacturers'
`riers
`through
`protocols, and General Electric consequently urges the
`Commission to establish a "framework" for manufacturers
`producing equipment to APCO-16 standards to cross-li-
`cense their protocols. General Electric Reply Comments
`at 3.
`14. The Associated Public-Safety Communications Of-
`ficers, Inc. (APCO) offers support to the multi-mode ra-
`dio concept to the extent that multi-mode radios offer an
`"optional approach which will permit Public Safety agen-
`cies to procure radio equipment which would be inter-
`in a communication system from multiple
`changeable
`manufacturers." APCO Comments at 36. APCO, however.
`believes that the development of multi-mode radios is no
`different than development of any other type of equip-
`ment and thus sees no need for Commission involvement.
`APCO Comments at 36. While Philips agrees that a multi-
`mode radio has certain advantages, such as backward
`compatibility, it feels that this approach would require
`substantial development costs for manufacturers, could
`increase the probability of equipment failure, and could
`complicate equipment repair. Philips Reply Comments at
`34. According to Philips, however, the primary impedi-
`ment to multi-mode radios is that development will be
`impossible unless all manufacturers are willing to disclose
`their proprietary protocols, and Philips appears to be
`unsure as to whether all the major players would be
`willing to do so on a voluntary basis. Philips Reply Com-
`ments at 35.
`-15. Motorola, in its reply comments, expresses a num-
`ber of its concerns about the multi-mode radio concept.
`First, it raises the question of whether a multi-mode radio
`would be limited only to systems that meet APCO 16
`requirements. (Motorola indicates that only its system and
`General Electric's currently comply.) Motorola believes
`that there would have to be agreed upon minimum cri-
`teria that a system would have to meet to qualify, and the
`issue of which manufacturers' protocols should be in-
`cluded on radios and which should be excluded would be
`likely to be controversial and could have antitrust im-
`plications. Motorola Reply Comments at 9 and 15.
`Motorola further points out that the multi-mode radio
`the responsibility [for system failure]
`concept "spreads
`among multiple vendors," which is contrary to its posi-
`
`Timing
`16. In our Notice of Inquirv, we asked that commenters
`offer their estimates on how long it would take for the
`industry to develop a trunking standard and how long it
`would take before equipment built to that standard would
`be available on the market. There was no consensus
`this question.
`among the equipment manufacturers on
`There was general agreement, however, that if all or parts
`of existing standards were adopted, the process would
`than if a standard were
`proceed much more quickly
`developed from scratch. For example, Ericsson, Inc. be-
`lieves that if a current, publicly-availableii standard were
`to be chosen, a number of manufacturers could begin
`delivering equipment as soon as the standard were set.
`Ericsson Comments at 6. Philips agrees, stating that with
`regulatory leadership and industry cooperation, and using
`the British standard as a starting point, the process could
`be completed in a matter of months. Philips Comments at
`25. Regardless of which standard is adopted, King Radio
`Corporation believes that manufacturers should be able to
`respond very quickly because most of the developmental
`effort would be in software rather than circuit design.
`King Radio Comments at 6.
`17. Motorola states, based on the recent history of the
`standards process, that it will take 3 to 5 years for the
`industry to develop and agree upon a single trunking
`to achieve
`the length of time required
`standard. On
`equipment availability, Motorola makes no definite pre-
`diction, but points out that it took them four years after
`the APCO 16 recommendations were issued to market
`equipment that complied with those recommendations.
`Motorola Comments at 60-61. On the use of the existing
`MPT 1327 standard, Motorola has serious reservations as
`to its adequacy to meet the unique operational require-
`ments of public safety users.' 7 Thus, Motorola concludes
`that the suggested use of MPT 1327 as a starting point
`would provide little time advantage because the effort to
`adapt MPT 1327 for public safety use "would be akin to
`developing a brand new standard." Motorola Reply Com-
`ments at 30.
`18. Philips, in its reply comments, disputes Motorola's
`claims of the inadequacy of MPT 1327. It specifically
`addresses a number of the "faults" in MPT 1327 identified
`by Motorola'8 , and provides various technical explana-
`tions to refute Motorola's criticisms. Philips concludes
`that while MPT 1327 is not perfectly suited in all respects
`to public safety needs, it could easily be adapted to the
`U.S. public safety market. Philips Reply Comments at
`23-27.
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`23. It is argued by a number of commenters that be-
`19. Despite the obvious disagreement among industry
`commenters on the length of time it would take to adopt
`yond the lack of competition that can occur in the initial
`a trunking standard and market equipment, there was one
`purchase of equipment when purchasers go "sole-source"
`matter on which there was almost unanimous agreement.
`because of the absence of compatibility among different
`Nearly all commenters believed that regardless of the
`systems, there also exists a more serious lack of competi-
`reached by
`ultimate decision
`the Commission on the
`tion that can occur when users cannot choose from a
`trunking standards issue, there should be no impediment
`variety of vendors in the purchase of add-on and replace-
`to the licensing of the new 800 MHz public safety spec-
`ment equipment due to the incompatibility of different
`trum. See E.F. Johnson Comments at 7.
`manufacturers' systems. These commenters state that pub-
`lic safety agencies would like to have the flexibility
`to
`obtain add-on and replacement equipment from more
`than one source and not be "locked-in" to the manufac-
`turer that provided their basic system. They feel that if
`equipment can be acquired from a second source and
`there is competition from various manufacturers for the
`sale of this equipment, then the costs will be lower than if
`the buyer must, for system compatibility reasons, deal
`with the original vendor.
`24. These users believe that the adoption of a common
`trunking standard will permit competition to occur by
`enabling different manufacturers to produce compatible
`equipment. For example, CPRA states that the present
`requirement
`that an agency purchase additional equip-
`ment from the same vendor may present some cost dis-
`advantages. CPRA Comments at 2. Similarly,
`the Port
`Authority of New York and New Jersey points out that
`compatibility will enable
`the benefits of competition
`among manufacturers of public safety radio equipment to
`become available to public safety users and that the ad-
`vent of competitive bidding among vendors "can only
`result in
`lower costs for public safety agencies and a
`greater spur to improvements in equipment itself among
`manufacturers and vendors." Port Authority Comments at
`1 and 2. Spectrum Resources, Inc. (SRI) offers evidence
`in support of competition, stating that from its experience
`in assisting the purchase of equipment for governmental
`agencies, when a vendor is the sole source for equipment
`they have no reason to supply equipment at other than
`list price, while when these vendors are put in a competi-
`tive situation they almost always.take a different position
`on pricing. SRI further indicates that in such a competi-
`tive environment "it is not unusual to see discounts from
`list price in the twenty-five to fifty percent range." SRI
`Comments at 3.
`25. Other commenters suggest that there are better ways
`of approaching the "lock-in" problem than through fed-
`eral
`intervention
`in
`the form of trunking standards.
`APCO, for example, states that agencies could include in
`their initial solicitation and contracting documents provi-
`sions designed to accommodate future system expansion.
`APCO further believes that there is sufficient competition
`in the radio communications market to enable buyers to
`establish reasonable
`terms for the equipment
`they are
`purchasing. APCO Comments at 11. The State of Florida
`Division of Communications (Florida) presents a different
`side to this argument, disputing claims that users may
`avoid monopoly pricing difficulties by sufficiently clever
`procurement and long-term contractual strategies. They
`note that equipment models and features often change
`time, and that a change or discontinuance of a
`over
`particular model generally negates existing contract terms.
`This, according to Florida. voids previously agreed-upon
`prices, necessitates contract re-negotiation, and almost al-
`ways results in higher equipment costs to the purchaser.
`Florida Comments at 7. Philips, in
`its reply comment
`adds that merely knowing the price to be charged by an
`
`Equipment Cost
`20. Another key question raised in our Notice was the
`effect that the establishment of a trunking standard might
`have on the price and availability of equipment. We are
`concerned with both the effect on the initial cost of a
`system purchased by a public safety user and the cost of
`add-on or replacement equipment purchased by the user
`during the life of his system. Besides the discussion of the
`possible increased cost for multi-mode radio equipment
`(see pares. 13 and 14, supra) there was little reference in
`the comments to potential increases that might occur in
`the price of equipment if equipment were to be built to a
`common standard. Various commenters, however, alluded
`to the additional R&D work that would be needed to
`develop new circuit hardware and protocol software, and
`it is possible that the costs incurred by manufacturers in
`these efforts could be passed on to the purchasers. One
`commenter, DuPage Public Safety Communications
`(DuComm), also indicated the belief that if standards are
`adopted and are licensable, then the costs of the licensing
`fees could be passed on to the purchaser. Du-Comm
`Comments at 4.
`21. The discussion of possible reductions in equipment
`costs centered around two closely related issues: 1) the
`effect standards might have on the use of the "sole-
`source" approach by agencies in the initial purchase of
`their systems, and 2)
`the possible effect standards might
`have on the use of the "second-source" option when
`purchasing future, add-on or replacement equipment.
`22. Currently, some agencies choose
`the sole-source
`method when purchasing land mobile radio systems. In
`using this approach, they forego the possible cost advan-
`tages of competitive bidding for several possible reasons:
`1) in order to take advantage of the unique system fea-
`tures offered by a particular manufacturer, 2) to use a
`manufacturer that can provide a turn-key system (to avoid
`expending funds to conduct detailed analyses and write
`specifications for proposals from several bidding manufac-
`turers), or 3) the desire to have interoperability with a
`neighboring jurisdiction using a particular trunking sys-
`tem. The advent of a common trunking standard would
`probably not cause purchasers desiring the sole-source
`option for the first two reasons to change their decision to
`use this approach. Those who use sole-source to achieve
`interoperability, however, could prefer the multi-source
`option if that were to become available to them under a
`"trunking standards" environment. Electrocom, Inc. of-
`fered evidence of such a scenario in the State of Louisiana
`where
`the purchase of a particular manufacturer's
`trunked system by the State Police apparently forced a
`local jurisdiction within the state, desiring interoperability
`with the State Police network, to go "sole-source" and
`thus, in Electrocom's words "deny the public the benefits
`of competitive bidding." Electrocom Comments at 4.
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`original equipment supplier for future equipment add-ons
`and system enhancements is not the same as having the
`ability to choose from among multiple suppliers at the
`time the add-ons or enhancements are needed. Philips
`also points out that years after a system is installed, the
`manufacturer offering the best equipment at the best price
`"may
`be
`some
`relatively
`recent entrant
`into
`the
`marketplace, and the original system supplier may no
`longer be at all competitive in terms of quality or features
`or price." Philips Reply Comments at 20 and 21.
`26. Ted Vratny, representing Du-Comm. supports the
`APCO position and similarly believes that the concern of
`is a
`pricing for add-on and replacement equipment
`contractual and administrative problem that can be dealt
`with effectively without the need for technical standards.
`From his experience as director of a large intergovern-
`mental emergency communications agency, he has ob-
`served that it is more advantageous for an agency to make
`a careful initial decision that it can live with for several
`years. According to Vratny, this requires that administra-
`tors prepare adequate specifications and make every effort
`to implement long term solutions. In the final analysis, he
`points out, an agency does have the. choice not to pur-
`chase equipment or delay projects that are not cost effec-
`tive. Du-Comm Comments at 2-3.
`27. Another
`of
`issue
`the
`on
`consideration
`"second-sourcing", as discussed by several commenters, is
`that some agencies may prefer to use one particular man-
`ufacturer's equipment for operational and technical rea-
`indicated,
`the
`locations of
`sons. As Orange County
`controls and displays can vary from vendor to vendor on
`otherwise compatible equipment, and that a radio system
`containing equipment built by several different manufac-
`turers can create operational and training problems. Or-
`ange County Comments at 3. They further point out that
`for agencies that service their own equipment, having
`multiple equipment suppliers requires stocking of parts
`from different manufacturers and in some cases additional
`test equipment. Orange County also empha-
`specialized
`sizes that due to the nature of the competitive process a
`trunking. standard could force agencies to accept equip-
`ment from undesired vendors. Orange County Comments
`at 3. The Lenexa, Kansas Police Department makes the
`point that, at least from its perspective, it is desirable to
`have a single point of service contact for a complicated
`radio system, especially one involving trunking technol-
`ogy. They also indicate that, in a mixed "network" of
`equipment from several makers, a problem with any of
`the equipment could affect all users on the network.
`Lenexa Comments at 3. Ted Vratny (Du-Comm) concurs,
`with this position, stating that it is extremely costly to
`"play mix and match" with radios and fixed-end equip-
`ment. When this occurs, Vratny claims, service times and
`costs often increase because technicians must be trained to
`repair different types of equipment. Vratny indicates fur-
`that to accommodate different systems one must
`ther
`maintain a larger inventory of parts for different manufac-
`turer's equipment and that "this is taxpayer money sitting
`on the shelf." Du-Comm Comments at 3.
`
`Future Technologies
`28. An important consideration in analyzing the ar-
`guments for and against trunking standards is the concern
`that the adoption of a standard could retard or stifle
`future technological innovation in the field of trunking
`technology and in land mobile radio in general.
`
`3M
`
`29. On the first point,
`the County of Los Angeles
`fears
`that because
`Facilities Management Department
`long time to develop they would be
`standards take a
`difficult to modify rapidly as new technologies become
`available. It further believes that a standard trunking sys-
`tem could have a stifling effect on creativity "as new
`technical improvements [could not] be implemented with-
`out obtaining agreement to change the standard, therefore
`limiting solutions to communications problems." County
`of Los Angeles Comments at 4. Motorola expresses a
`related concern that a trunking standard developed by a
`number of manufacturers could represent a compromise,
`or "common denominator" standard that would not be
`equal to the level of the more advanced systems. Such a
`to
`scenario would be even more
`likely, according
`Motorola, if industry representatives were ordered by the
`FCC to mandate a standard "or else" and if the overriding
`priority became to complete the task as quickly as possi-
`ble. Motorola Comments at 18-19. Motorola states un-
`equivocally that a standard mandated by the Commission
`will retard technology because new public safety systems
`from both Motorola and its competitors "will dry up as
`soon as an FCC proceeding to launch a standard is ini-
`tiated." Motorola Reply Comments at 2. APCO agrees
`with this opinion, stating that if a standard were to be
`to
`adopted "manufacturers would have little incentive
`develop advanced products of any type, including digital,
`then become non-standard." APCO
`since
`they would
`Comments at 13. Philips does not share APCO's opinion
`that advanced technology would be retarded if a standard
`were to be adopted. They point to the current develop-
`ment underway to adopt a digital standard to supplement
`the current cellular analog standard, and indicate that
`adoption of a digital standard would not render analog
`radios obsolet