paging information resource

Before the
Federal Communications Commission
Washington, DC  20554

In the Matter of )  
Recommendations of the Independent Panel ) EB Docket No. 06-119
Reviewing the Impact of Hurricane Katrina on )  
Communications Networks )  
To: The Commission, en banc    



Brad Dye and Ron Mercer are consultants with many years of experience with wireless communications technology who are currently active in the development of communications systems for Homeland Security and other applications. Based on this experience, Brad Dye and Ron Mercer respectfully submit their comments to the Federal Communications Commission in response to the Commission’s Notice of Proposed Rulemaking (NPRM).1


Hurricane Katrina struck the Gulf Coast in late August 2005 causing extraordinary damage to the communications facilities in the region. In January 2006 Chairman Martin established an Independent Panel (the “Katrina Panel”) to study the impact of the hurricane on all sectors of the telecommunications and media industries and to make recommendations concerning ways to improve disaster preparedness with particular emphasis on the communications facilities available to first responders such as police, fire fighters and emergency medical personnel.

The Katrina Panel issued its Report and Recommendations to the Commission (the “Report”) on June 12, 2006. In its report, the Panel found paging systems “more reliable” during the disaster than voice/cellular systems.2 In view of this finding, the Commission initiated this proceeding to address and implement the Panel’s recommendations and, to this end, the Commission has solicited public comments concerning what actions it can take to address the Katrina Panel’s recommendations and the following comments are in response to that solicitation.

In recent months, several paging industry experts have presented testimony documenting the performance of paging systems in disaster situations. In general, paging system performance, particularly the performance of two-way paging systems based on the ReFLEX protocol, have been found to be superior to that demonstrated by most other communications systems.3

In summary, the numerous explanations for this superior performance include:

  • Paging systems use of satellite rather than terrestrial networks for backbone distribution;
  • The use of multiple high power base station transmitters each with up to 3,500 watts Effective Radiated Power (ERP);
  • Antenna heights of 300 feet or more;
  • Simulcast network configurations;
  • The inherent redundancy of paging base station facilities;
  • The ability of paging radio signals to penetrate buildings;
  • The long battery life of paging receivers;
  • The ability of paging systems to simultaneously broadcast messages to thousands of users;
  • The ability of paging systems to remotely activate public warning devices such as signage over highways warning the public of road conditions, fires, Amber Alerts, and other similar emergencies;
  • The availability of two-way paging devices to send and receive text messages via the Internet rather than the terrestrial facilities used for voice telephone traffic;
  • The retention of critical information (such as address, the names of individuals etc.) until deleted by the user. Allows users to easily recheck details without the need to write them down as would be required with voice communications;
  • Narrow-Band PCS/ReFLEX paging technology provides radio coverage areas which are totally independent of system traffic (the wideband, spread-spectrum technology used by cellular systems exhibits cell size shrinkage as traffic volume increases);
  • The “store and forward/delivery-retry” mode used in ReFLEX paging assures that multiple attempts will automatically be made to deliver both outbound and inbound messages;
  • The store & forward operating mode also tends to smooth the service demand peaks that are common during emergencies;
  • The asymmetrical inbound/outbound transmission characteristic of two-way paging allows users to receive outbound messages even if they are temporarily unable to reply to the received messages or to originate inbound messages;
  • The ability for users to “roam” from private to public systems.

Comments on the Panel’s Recommendations

Pursuant to its review, the Panel recommended paging technology as an alternate communications channel for organizations to use in contacting their “key players” during emergencies and as an “effective back-up” solution for existing public safety communications systems. We commend the Panel for its diligent and thorough review of the impact of Hurricane Katrina, and we are in general agreement with its findings and recommendations.

We do, however, wish to offer several additional comments:

Public vs. Private System Considerations:

Many of the performance observations referred to above are based upon the experiences of subscribers to two-way paging systems that are operated by service providing organizations and marketed on a monthly subscription basis to the general public (Carrier Provided nPCS Public Systems). The technology used in these public systems is virtually identical to that which would be used in private systems and therefore most of the advantages listed above would accrue to either public or private implementations. Private systems, however, demonstrate several unique attributes including:

  • Intensified radio coverage with larger coverage areas, greater building penetration and fewer “dead spots”, (For example, a private one-way paging system currently being constructed in Erie County New York will include 25 base stations as contrasted with a public system in the same geographic area which uses 10 base stations.) Most public systems are designed to provide reliability figure {Grade Of Service or GOS} of “.90.” That is, reception should be possible in 90% of locations, 90% of the time. In sharp contrast, published specifications for first responder systems most often require general reliability of 99% and reliability in specific locations of 99.9%); [added later]
  • A limited number of users that assures manageable traffic loading in emergencies,
  • Consistent operational features, such as the alerting tone patterns assigned to emergency and non-emergency situations, used by all user devices in the system;
  • The ability for system administrators to control the use of the system during emergencies.

Accordingly, while subscription to carrier provided public services could, in certain cases, provide the two-way paging communications required by first responder organizations, there would be instances where a dedicated system operated by a public safety entity is absolutely required.

Summary and Recommendations

Two-way paging has demonstrated compelling benefits in terms of functionality, geographic coverage, in-building penetration, and the ability to support reliable delivery in difficult environments. It is positioned to be extremely helpful to emergency personnel for public safety and other homeland security applications through its wireless instant messaging, broadcast messaging, e-mail, and location-based capabilities. The inherent strengths of two-way paging features and functionality can provide an excellent means of communication as a primary or backup system for emergency personnel and homeland security.

Similarly, the beneficial characteristics of one-way paging technology would be advantageous in the Emergency Alerting System (EAS) that the Commission is currently reviewing.

It is our firm belief that Paging is the BEST technology to use when it is necessary to alert many people in a short time.

  • Because of "group call" a feature of paging that allows us to alert almost an unlimited number of people with one single radio transmission (to a common capcode). For example, with paging technology a message can be sent to over a million people in the time it takes to make two or three telephone calls.
  • Because of “simulcasting” a feature of Paging that allows the same radio message to be broadcast over multiple transmitters simultaneously — (simultaneous + broadcast = simulcast) meaning that a radio Paging signal generally has much better penetration into, under, and around buildings and is less likely to be blocked by obstructions since it will be coming to the Pager from several different directions at the same time.
  • Because of the fact that Paging systems cost a fraction of other technologies like cell phone systems.
  • Because most Paging transmitters are individually controlled over satellite links and they do not need a physical landline running back to the control point (like the fiber-optic networks used in cellular systems).
  • Because Paging is a mature technology. It has been refined and perfected over many years and it works very well. It is here today and available to be used RIGHT NOW!

We can use a proven technology that is already deployed coast-to-coast. One-way paging is by far the fastest, least costly, and most reliable way that we have to warn millions of people about impending danger. We know that no telephone—neither cellular nor wireline—will work when everyone tries to use them at the same time. We also know that one-way radio paging systems work very well when it is necessary to send a message to everyone on the system at the same time. Technically, we call it “group call to a common capcode.” It's easy for one-way paging. No other technology can do that. Traditional broadcast radio and television come the closest, but their ability to network and cover the whole country is limited, complex, and costly. Even “reverse-911” systems, that claim to be able to call out from a 911 call center to alert everyone in a given area using regular telephones, make no sense when it is necessary to notify over one million people in one minute. Paging can do it while other technologies are still thinking about it.

We also believe that:

  1. The Commission should permit private two-way paging systems to be licensed by public safety community in the 896-901/935-940 MHz band.
  2. The Commission should work with public safety community organizations to develop and implement practices for disaster preparedness and these practices should include paging.
  3. The Commission should incorporate paging technology into the EAS.

Brad Dye and Ron Mercer stand ready to assist the Commission in any way deemed necessary.

  Respectfully submitted,
New address:
P.O. Box 266
Fairfield, IL 62837 USA
Telephone: 618-599-7869
Brad Dye — K9IQY
Wireless Messaging Consultant
P.O. Box 266
Fairfield, IL 62837
Telephone: 618-842-3842

  Ron Mercer
Telecommunications Consultant
217 First Street
East Northport, NY 11731

Dated: August 7, 2006  

1 Notice of Proposed Rulemaking, EB Docket. No. 06-119, 71 Fed. Reg. 38564 (July 7, 2006) (Notice).
2 Page 10 of the “Report.”
3 Please refer to reference appendix


“Wireless Messaging for Homeland Security” Dr. Peter Kapsales, March 2004. (

“Message to the Wireless Messaging Newsletter” from Carter C. Blumeyer, Communication Specialist, FEMA Urban Search and Rescue, August 30, 2005 2:49:53 PM CDT.

“Fully Interoperable First Responder Alerting System Based on ReFLEX Two-Way Messaging Technology”
Barrett M. Kanne October 2004. (

“The ReFLEX™ Advantage In Homeland Security/First Responder Applications”
Ron Mercer Version 2.0—December 5, 2005. (

 “Mission Critical Paging and Messaging Capabilities,”
USA Mobility, Inc. September 21, 2005. (

Application of County of Monroe, New York to Operate a Public Safety Talkback Paging System on 900 MHz Frequencies in Rochester, New York, File No. 0001897038.

Waiver request filed by the City of Richmond, Virginia, which seeks to operate a regional public safety two-way paging system on 900 MHz band Narrowband PCS (NPCS) Channel 16 (frequencies 930.65 - 930.70 MHz and 901.8125 - 901.8250 MHz).

“Improvement of network reliability and public safety communications in times of crisis”
AAPC/USA Mobility, September 23, 2005.

ReFLEX is a registered trademark of Motorola, Inc.

Example of Home/Office/School
alerting device like the one being used in Israel
right arrow newsletter

Comments filed with the FCC on August 7, 2006

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