Thursday, February 24, 2011

Letter to Congressman Burman re: AB 607

The following is my letter to my congressman, Howard L. Berman regarding AB 607

February 24, 2011

The Honorable Howard L. Berman
United States House of Representatives
2221 Rayburn House Office Building
Washington, DC 20515

RE: HR 607

Dear Representative Berman:

I am a registered voter in your district, an Amateur Operator K6JGZ, and an active volunteer for the Los Angeles Fire Department Auxiliary Communications Service. The LAFD ACS provides emergency communications for the LAFD and the City of Los Angeles and your district and is administered by the LAFD. We use the 2 meter and 420 – 440 MHz spectrum to do so. H.R. 607 would take the 420-220 mHz frequencies away from us to be sold for commercial use.

H.R. 607 provides for the reallocation of other spectrum for auction to commercial users in order to offset the loss of revenue anticipated by the auction of the D-Block, including the 420-440 MHz spectrum (the UHF 70-cm band) as part of a frequency swap and auction. We’re already using this portion of the Amateur spectrum for emergency communications. We have our own money invested in emergency communications 420-440 MHz spectrum radios and even more invested in mountaintop repeater systems. Our emergency communication plans use these frequencies and we are trained and prepared to use them whenever necessary. We are already sharing parts of the 440 MHz band with the Federal government for critical defense purposes, including Pave Paws radars for detecting surface-launched missiles aimed at the United States, and for airborne radars used for drug interdiction. The Amateur Service carefully coordinates its uses of this band to insure compatibility. The two services have a very good record of sharing this spectrum successfully, putting it to good use for both military and civilian purposes in the national interest. There is no reason to take this band from us for commercial operators – they have plenty of spectrum, but of course they are lobbying heavily for more so they can charge us to use it.

As a voter in your district, an active emergency communications volunteer, and as one of the nearly 700,000 federally licensed Amateur Radio operators across the nation, I ask that you oppose H.R. 607, the "Broadband for First Responders Act of 2011" in its current form. H.R. 607 was introduced by Congressman Peter King (R-NY) and referred to the House Committee on Energy and Commerce.

H.R. 607 proposes to allocate the "D-Block" of frequencies (frequencies previously occupied by analog television) to be developed into an interoperable Public Safety wireless network. Earlier, it had been expected that the D-Block would be auctioned by the FCC for commercial use, but there is now substantial support for the allocation of the D-Block to Public Safety. H.R. 607 also provides for the reallocation of other spectrum for auction to commercial users, in order to offset the loss of revenue anticipated by the auction of the D-Block.

While I strongly support the work of the Public Safety officials who put their lives on the line for our safety, my opposition to the bill stems from the inclusion of the 420-440 MHz spectrum (the UHF 70-cm band) as part of a frequency swap and auction. Very little of this spectrum is allocated to Public Safety, and only in very limited areas. Rather, it is allocated to government radiolocation services on a primary basis, with Amateur Radio allocated on a secondary basis..

Amateur radio emergency communications rely heavily on our limited frequency allocations in the VHF and UHF radio bands. The loss of access to the 420-440 MHz spectrum would make it very difficult for us to maintain this capability and would mean we could no longer use numerous systems that have been constructed on our own time and at personal expense to provide this important communications support.

Amateur Radio operators across the country repeatedly demonstrate our commitment to public service and emergency communications. Through our work with FEMA and other Homeland Security activities, state and local Emergency Management offices, and numerous charitable relief agencies, volunteer Amateur Radio operators assist the first responders, doing so at no cost to the agencies we support. The role of the Amateur Radio Service as a partner to Public Safety in providing supporting public service and emergency communications necessitates our retention of full access to the entire 70-cm band.

We understand and support that Public Safety officials must have the spectrum they need to do their jobs. However, it is not necessary to do so in the ill-conceived manner proposed in this bill. Other pending legislation provides for this important goal to be realized without the proposed reallocation of non-Public Safety spectrum for commercial auction that is included in H.R. 607.

I’m sure you are already aware that the chances of the “Big One” or other natural or manmade disaster disrupting normal communications in the Los Angeles area is highly likely. We stand by ready to help, as we can, with our totally self sufficient battery operated emcomm equipment and we train continuously to provide the best service possible. I urge you to oppose H.R. 607 in its current form.

Thank you for your consideration.


Jonathan G. Zimmerman
K6JGZ / WQKX334
Los Angeles Fire Department Auxiliary Communications Service
LAFD Battalion 14 Communications Group Leader
LAFD ACS – CERT Liaison
Los Angeles Fire Department Community Emergency Response Team Member

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