Alachua County SKYWARN
8401 NW 13th Street, # 114, Gainesville, Alachua County, FL 32653
Marlene H. Dortch
Office of the Secreatary
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554
Date: June 7, 2010
Re: Response Comment to FCC Docket ET-10-123
Dear Madame Secretary:
I am writing on behalf of Alachua County SKYWARN as it's Founder and
Coordinator, to comment on the proposed reallocation of the 1675-1710 MHz
frequency band now being used for meteorological services over to broadband
We strongly disagree with this idea and would encourage seeking broadband
Alachua County SKYWARN makes use of the proposed band for the reception of
down-linked EMWIN signals, which data is used to advise the local area populace
of weather- and other-related emergencies.
We shall attempt to answer all of the FCC's questions in the order as
presented within the FCC Notice.
Alachua County SKYWARN Response to ET Docket No. 10-123
Federal Communications Commission
Washington, D.C. 20554
In the Matter of ))
Request for information on use of ) ET Docket No. 10-123
1675 – 1710 MHz band ))
COMMENTS OF ALACHUA COUNTY SKYWARN
1. A description of the utility of the 1675-1710 MHz band for wireless
broadband services, including any pairing, band plan, or other licensing
approaches that would maximize this utility;
Alachua County SKYWARN sees no use for mobile broadband services in this
We believe that there are far more unlicensed users in this frequency
spread than can adequately be notified to repsond inside the unbelievably and
inexplicably short three week time period allotted by the FCC.
For this reason Alachua County SKYWARN humbly suggests a reasonable
extention of the response period to allow for word to get to these users and
to allow them more reasonably fair time to respond.
2. Identity of the non-federal entities accessing the services operating in the
1675-1710 MHz band;
We're not sure if it was intended that we answer in the local situation, or
the national, so we shall do both, here.
Non-federal entities which make use of the 1675-1710 MHz band include, but
are not limited to:
Emergency Management and Civil Defense agencies, including at the County
and University level;
University meteorological-related departments and institutions, students
SKYWARN-related storm spotting groups and organizations;
Amateur radio civil emergency-related groups and organizations such as
ARES and RACES;
Employees of the Press (newspaper and television, including TV mets);
Not sure if the military is "federal" or of it's own separate category so
we shall include various military agencies - such as Mayport NAS, which for a
time subscribed directly to us and used the data for disaster-related notice
General public (including civilians, pilots, owners of banks, restaurants,
and other businesses);
A list of even more users around the country - but by no means a
complete list - can be had from the web site of Zephyrus Electronics, Inc.,
That particular list shows now only downlink users but stations which also
retransmit the data locally as an additional means for the public to receive
the information should there be a power outage or the main lines of
communication go down...but ONLY those which include rebroadcasting
capability. Again, it is not a list of ALL of the EMWIN users across the
country, and should not be considered so.
3. A description of the purpose of such use (i.e., the equipment is used to
support TV weather forecasting or for conducting university research);
We know that local Emergency Management uses the data to obtain heads-up
notice at the same time as its NWS counterparts. It uses the data in-house to
alert its employees, fire/rescue employees, CERT and other disaster-response
group members, and also disseminates some information to in-house list
groups and even to Facebook.
Alachua County SKYWARN uses the data to disseminate weather-, disaster-,
civil-, and national-emergency information to the local general public
(including to surrounding counties, not just within Alachua County) for free as
a public service - especially for those who could not afford commercial
services, which were usually slower anyway. These include storm watches,
warnings, statements, and advisories; civil emergency-related bulletins; and
national emergency-related bulletins.
We distribute the data using various means - to E-mail, FAX, pager,
cellphone, PDA, list groups, and even to web pages, Twitter, and Facebook.
4. Which portions of the 1675-1710 MHz band are used;
Alachua County Office of Emergency Management, the University of Florida
Office of Emergency Management, and Alachua County SKYWARN all used the GOES
EMWIN downlink frequency of 1690.725 MHz.
5. How often the service is used (e.g., every day, scheduled times of day,
All local agencies make constant use of the EMWIN data on a
twenty-four-hour-a-day, seven-day-a-week period.
6. An estimate of the current investment in wireless equipment, including when
it was obtained and put into use;
We cannot speak for the Alachua County Office of Emergency Management, or
the University of Florida's EMA (both of which we encourage to respond on their
own), but the value of the Alachua County SKYWARN's equipment - obtained in
early 2003 - was around six thousand dollars ($6000).
1 computer tower
1 replacement computer tower
2 replacement monitors
1 speakers and power supply
1 replacement keyboard
1 replacement mouse
1 9-pin serial cable
1 RJ-11 cable
1 RJ-45 cable
1 CyberPower 500SL 275W UPS
2 replacement APC UPSs
1 Icom IC-F320S VHF transceiver (for local EMWIN rebroadcasting on
1 Astron SS-12 IC power supply
1 small desktop fan (to cool power supply and extend its life)
1 SAMI UPS6 6-foot (1.8M) mesh dish (package deal - includes Zephyrus
WX-13M GOES receiver and power supply, Zephyrus LNA, SAMI LNA cover, SAMI
quad pole assembly, non-penetrating roof mount)
1 wall-mount for specialized mounting (used later)
2 1/2 x 6' all-threaded (H.D. galvanized)
4 5" x 12" x 3/16" wall plates
Powder coating - 2 wall plates (above)
Various nuts and washers
1 Tigertronics NWT-12 modulator
1 Cushcraft PF-167 antenna (for local EMWIN rebroadcasting on 163.325
1 40' pushup mast for Cushcraft antenna
1 200' length of 9913 coax cable (assuming $1.33/ft)
1 200' length of RG-8 coax cable (assuming $1.20/ft)
4 PL-259 connectors and coax seal (assuming $2 ea.)
1 Polyphasor lightning protector
2 Decibel products clamps for antenna mast
2 Zephyrus WX-41 demodulators (2 x $149)
1 500MB memory upgrade
1 Windows 98 OS
1 Windows XP OS upgrade
1 WxMesg software (by Danny Lloyd) to handle downlink and bulletin
This is still much cheaper than other means of bulletin reception and
Other methods would be too expensive for our budget such as NOAAport,
which is just too unwieldy for the available real estate (eleven feet is
getting into the "monstrous" range), or too unreliable to utilize for serious
warning notification (such as Internet-based reception, with all of the
7. A description of whether and how the information and services currently
accessed can be obtained from other means; and if so, the anticipated costs and
timeframes for implementing any alternatives;
Alternative means of reception (should the 1675-1710 MHz downlink band be
removed from our use) would require purchase of completely different equipment
for NOAAport - which would require obtaining a an ELEVEN-FOOT dish, new
equipment and software capable of operating Linux or similar software required
to operate the NBSP software used with NOAAport, all of which would cost tens
of thousands, which is currently beyond our budget - and beyond the budget of
many similar organizations which now makes use of EMWIN downlink across the US.
8. Confirmation that, if the information currently available from the
meteorological satellite service were received at only a few receive sites and
distributed via terrestrial services, this would be a functionally equivalent
substitute for the direct reception of the satellite and radiosonde services;
Alachua County SKYWARN challenges the wording of this particular comment as
presumptive and unrealistic.
Downlink is not at all received at just a few sites around the world, but
from thousands of ground stations across the United States and around the
world - especially Emergency Management agencies, SIMULTANEOUSLY; and it is
this very fact which aids EMAs especially in being ABLE to respond so quickly
to disaster-related emergencies. To remove EMAs, while considered "federal"
and thus not allowed to respond herein, are still there nonetheless, still
counted as "unlicensed users" nonetheless, and are still using EMWIN to make
emergency-related, life-saving decisions, and they do not go away just because
broadband interests wish to quiet them.
To remove all of these ground stations and try to place all of the data
notification into the hands of Internet distribution, or a singular method of
distribution would, in our opinion, cause unacceptable potential for the loss
ACS does not see this methodology of thinking as anything logical or
reasonable in any way.
As well, again, we see no reliable means of distribution via terrestrial-based
services (such as Internet) due to the fact that this introduces too many
computers and servers between the point of initial downlink and the point of
end-user reception - caused by system crashes and downtimes, hacker/DOS or
similar attacks, simple Internet overload, or other system delays. If made
terrestrial-based, then unfortunately there will be a loss of the 2-plus-minute
lead time now enjoyed by thousands of EMAs, Civil Defense, and other agencies
and users worldwide. Broadband interests may think that this would be an
acceptable alternative; but unfortunately, the idea lacks real-world thinking
and experience. Internet-based, we have seen bulletins end up delayed on the
order of from hours to DAYS. This is not a reliable means for use in emergency
services or ANY kind of work, and the notifications dumb down to nothing more
than "convenience"-level and "curiosity"-level notices.
9. Any other information interested parties would like to identify regarding
use of the meteorological satellite and radiosonde services.
1) EMWIN is designed to bring speedy bulletins to Emergency Managers to aid
them in making quick decisions during times of severe weather, natural
disasters, or civil or national emergencies.
2) EMWIN provides users with up to 2-plus minutes of very important lead time
- even over the NOAA NWR (NOAA Weather Radio) system, allowing emergency
managers that much more time to prepare and make important tactical decisions
in the face of approaching emergencies.
3) It is extremely portable and quickly set up when needed, and can be set up
with very little time or notice.
4) It is relatively easily affordable to set up and maintain.
5) The EMWIN system is now currently being USED by thousands of EMAs and
Civil Defense agencies across the United States and in other countries. In
places like the Pacific islands, EMWIN is the only source of heads-up to
hurricanes and other emergencies. In fact, our government recently GIFTED an
EMWIN system to earthquake ravaged Haiti to help them in their time of need.
6) Bulletins provided by EMWIN include not just weather bulletins, but
bulletins regarding civil emergencies (Amber Alerts, 911 telephone outages, law
enforcement emergencies, hazmat emergencies, etc.), civil defense emergencies
(national attack warnings, fallout predictions, etc.), geological hazards
(earthquakes, tsunamis), and even space weather (solar flares, geomagnetic
storm warnings, etc.).
How It Is Used Locally
EMWIN is used locally by Alachua County SKYWARN to bring emergency
information to the local public. We know that it is also used here by the
Alachua County Office of Emergency Management, but we don't wish to step on
ACOEM and we would encourage them to file their own response detailing how
their system is used. We do know that while ACOEM uses it's system mostly for
in-house notifications, Alachua County SKYWARN's EMWIN system, gifted to us by
the Florida Division of Emergency Management in 2003, was intended for and has
for seven years faithfully served a much wider public audience, and even gone
far beyond what the duty actually called for and that was initially required in
it's service to the public, in fact.
Alachua County SKYWARN uses their system to notify anyone in the general
public for free as a public service - not just in Alachua County, but even
taking on nearby *surrounding* counties, too.
ACS notifies the public using email, FAX, pager, cellphone, listgroups,
and even makes their information available on the Internet through web pages,
Twitter, and Facebook.
While we mostly serve users in the general public, we've also served users in
the United States Navy, local city and county police and fire/rescue employees,
the Keystone Heights Fire Department, employees in local hospitals, as well as
employees in local TV and newspaper agencies, for some examples.
When down-linked from the GOES satellite, the bulletins are received at the
same time as our NWS counterparts, and are often redistributed on the order of
two or more minutes faster than the NWR, cutting down on thinking and
preparedness time. It allows emergency managers to think and make response
decisions that much faster. It allows spotter groups to get the callup out that
much faster. It allows amateur radio ARES/RACES groups that much more time to
prepare and respond. It gives the general public that much more time to
Problems With The Broadband Idea
Broadband is known to be a notoriously sloppy form of communication, which
can potentially cause a lot of interference with other systems and users.
Interference causing outages in the EMWIN system is not acceptable. The
information put out by EMWIN is depended on for heads-up information and
Distribution by other internet methods is also not acceptable since
internet systems introduce more equipment between the initial source and the
end user, allowing for crashes, downtimes, and delays due to system over usage,
or hacking or DOS attacks. This could delay bulletin dissemination on the order
of from hours to DAYS. We know that this affect cannot POSSIBLY allow EMWIN to
continue to be acceptable for Emergency Management or Civil Defense use, then.
We just cannot fathom anyone wishing to come along and second guess the
need for or the usefulness of the EMWIN downlink frequencies for such a prudent
and intelligent use. The government actually needs MORE systems such as this
which can be utilized during times of emergency as a quick means of getting
needed information to the public without delay. Taking these frequencies or even
sharing them with the broadband service - a service known to be so sloppily
controlled, operated, and maintained, causing severe interference to other
nearby co-users - would be a dreadful mistake in the EMWIN downlink band, and
take away or severely interfere with much-needed lead time not consistently or
dependably available using other internet-based distribution systems.
The 1675-1710 MHz band is so relatively small and certainly the broadband
interests can find another band less important to emergency/civil communications
than the EMWIN downlink band.
REQUEST FOR TIME PERIOD EXTENTION
Finally, and again, Alachua County SKYWARN would
like to offer that the time period currently allowed for people to make
comments was unfairly too short. From the 4th to the 28th was only 24 days -
three weeks. We didn't even get a whole month. This was not enough time
to properly and fairly notify all interested parties to the
situation, and at the time of the creation of THIS comment (6/21/2010) -
especially considering the LACK of comments so far seen online from many
Emergency Management Agencies at all concerning this - we can only conclude
that this is true. and we don't at this time think that very many Emergency
Management Agencies are even AWARE that this is going on or that they're even
supposed to respond. We kindly offer the suggestion that the FCC extend
the deadline for comments to a more reasonable and fair amount of time to
allow as many interested parties as possible time to voice their own
We thank you very much for your time and consideration.
Todd L. Sherman / KB4MHH
Alachua County SKYWARN
8401 NW 13th ST, # 114
Gainesville, FL 32653
Founder/Coordinator, Alachua County SKYWARN
Founder/Project Mgr., Alachua County EMWIN Project.