Dear friends of Wireless Messaging,

Be sure to read the announcement from WiPath Communications. It was supposed to be in last week's newsletter but I let it slip.

WiPath Communications is pleased to announce that a ReFLEX version of its PDR2000 paging data receiver has just been released.

Details follow below.

We have four more comments this week about the use of ReFLEX technology by Public Safety agencies. I think they are well written and present some important points on this topic that we may not have considered previously. Good arguments are being made for both sides of the issue—private vs. public ReFLEX systems.

I invite you to send in additional comments for next week's newsletter.

Don't miss the AAPC comments on the Implementation of a Grant Program for Remote Community Alert Systems by the AAPC Task Force on Emergency Communications reproduced below.

Now on to more news and views.

Wireless Messaging Newsletter
VoIP Wi-Fi Paging Wi-MAX Telemetry Location Services Wireless Messaging	WIRELESS MESSAGING

This newsletter is brought to you by the generous support of our advertisers and the courtesy of iland Internet Solutions Corporation. For more information about the web-hosting services available from iland Internet Solutions Corporation, please click on their logo to the left.

There is no charge for subscription and there are no membership restrictions. Readers are a very select group of wireless industry professionals, and include the senior managers of many of the world's major Paging and Wireless Data companies. There is an even mix of operations managers, marketing people, and engineers—so I try to include items of interest to all three groups. It's all about staying up-to-date with business trends and technology. I regularly get reader's comments, so this newsletter has become a community forum for the Paging, and Wireless Data communities. You are welcome to contribute your ideas and opinions. Unless otherwise requested, all correspondence addressed to me is subject to publication in the newsletter and on my web site. I am very careful to protect the anonymity of those who request it.

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Comments on The Public Safety Applications Debate

2/19/07

I found the information Ron Mercer and Vincent Kelly provided very valuable to the industry if people are listening. After 24 years in the industry with carrier and manufacturing experience, I believe both arguments have merit. However I am going to come at this debate from a different perspective. Working for a manufacturer of telemetry devices that serves the emergency management sector, I get to talk to many customers from a neutral point of view. A lot of our customers perceive paging in general as dinosaur technology on the verge of extinction much less have any understanding of ReFLEX. The ReFLEX carriers and device/infrastructure manufacturers in this industry have done a poor job at marketing ReFLEX. Consequently, the technology is often not even on the radar screen when procurement officers for public/private entities go to market for M2M, telemetry, & emergency management solutions. Potential customers who are aware of ReFLEX, for the most part, view it as a text messaging product. They have no understanding of the overall technology or the network capabilities to securely integrate (WCTP) to back office platforms such as CRM (SAP), email (MS Exchange), or help desk (Remedy) applications. The above perceptions can be changed with strong marketing.

Those of us in the industry that launched ReFLEX technology back in the 90’s were sending text messages through e-mail mediums and peer to peer wireless devices before the American lexicon became familiar with terms like “Text Messaging” or “Texting.” Now text messaging is a billion dollar industry and the new term to brand “Text Messaging” is “Blackberry.” Rightfully, ReFLEX should have been the industry standard for e-mail/text messaging integration to platforms such as MS Exchange/Lotus Notes rather than Blackberry. Why did Blackberry take off at a time when ReFLEX providers had a huge advantage (coverage/existing customers)? Marketing & Branding. It was not price considering most Blackberry users pay an ARPU of about $75 to $100+ per month after paying hundreds of dollars for their devices. Does anyone remember “V-Client” or “AWES”? Like text messaging, we have a similar opportunity to be industry leaders in the M2M, telemetry, and emergency management market sectors. These are multi-million/billion dollar market sectors. As an industry we should work closely on coop marketing opportunities to penetrate these market sectors effectively.

M2M, telemetry, & emergency management applications are opportunities that are high density in terms of devices and low capacity in terms of data which are ideal requirements for ReFLEX & paging. Cost, ease of use, and existing wide area commercial carrier/private networks are other factors that make ReFLEX & paging very appealing to customers in these market sectors. These factors will fade fast to emerging technologies if ReFLEX/paging carriers, manufacturers, and integrators do not capitalize on these market sectors today. The paging industry can only cut its way to profitability through consolidation and network rationalization so long before churn eats away to the point that it becomes terminal to invest into new opportunities/markets. The next AAPC meeting in Myrtle Beach, SC is an excellent forum for industry leaders from manufactures & carriers to strategize on how we as an industry can become leaders in these new exciting multi-million/billion dollar market sectors.

Thanks Brad for continuing to fight the good fight,

Rex M. Lee
rlee@nighthawksystems.com
Nighthawk Systems, Inc.

From: "Jay Moskowitz" <jay@skymsg.com>
Date: February 16, 2007 3:26:16 PM CST
To: "'Brad Dye'" <brad@braddye.com>
Cc: "'Ron Mercer'" <ronofglobal@yahoo.com>
Subject: Vince Kelly and Ron Mercer Public/Private Paging

Brad,

Vince Kelly makes several very good points regarding the expanse and reliability of the public paging networks and the full time support and maintenance of these networks. It would make no sense to go through the considerable expenditures to create a competitive network and maintain it. A small fraction of that money is better spent in the creation of associated systems that connect to the public network, upgrading the coverage and support of the public network in areas which the government finds inadequately coverage or support (which simultaneously benefits the general public also), and to spend money to have the carriers upgrade their public systems to support the needs of homeland security. This becomes a variant of the original Motorola Oasis concept as Ron points out.

The biggest problem that I see in a shared public system is the overloading problem that made cellular network useless in the case of emergencies. If public systems will be used in lieu of government private systems but be supported with government money to expand upon their technology, we could insure that the existing infrastructure would adequately support a multi-priority scheme that would insure the emergency traffic over public traffic. This might mean giving special Internet input channels from specific government input systems priority over general public Internet traffic received. Telephony inputs would need to be prioritized to insure emergency calls through special sets of numbers always get through at the expense of public input that might ring a few extra times before being answered. And internal traffic priority would insure the delivery of emergency traffic before public traffic or introduce an algorithm that provides an intelligent mixture of such traffic. I don’t believe that all the necessary software is in place today to insure government traffic would be serviced before public traffic, but this is solvable.

A fraction of the money the government would spend on creating a nationwide emergency REFLEX system would be better spent on insuring the peaceful coexistence of public and emergency traffic on the existing carrier’s networks. And the government could always bring in independent consultants like Ron Mercer to audit the public systems to insure that they have been properly upgrade to sustain the excessive traffic mix of public and emergency traffic when necessary.

Jay Moskowitz
Wireless Marvels Inc.
Chief Wizard
12189 Landrum Way
Boynton Beach, FL 33437
(516) 249-6900 (office)
(516) 249-6001 (fax)
(516) 445-8724 (mobile)
Web site: www.wirelessmarvels.com
E-mail address: jay@wirelessmarvels.com
Personal e-mail: jay@skymsg.com
Instant Messenger (AOL/Yahoo/MSN): jayatrts

	Critical Response Systems, Inc. 1670 Oakbrook Drive, Suite 370 Norcross, GA 30093-1849 Tel: 770-441-9559 www.criticalresponse.com

Brad Dye
P.O. Box 13283
Springfield, IL 62791

February 22, 2007

Hi Brad.

I’ve been reading your contributions discussing the use of campus versus carrier ReFLEX networks for public safety. At my company, we’ve also been following the larger public/private spectrum policy argument within public safety and the FCC for the last few years, as guidance in our own product development and marketing. This is a very old and broad series of arguments centered on efficiency versus availability, mostly concerning the use of land mobile radio versus cell phones. There are many stakeholders and tens of billions of dollars at this table. Our debate here, private versus carrier paging, is a very small side discussion. While it essentially follows the same logic as the broader debate, there is an important difference. In its most potent form, Campus ReFLEX is both a carrier solution and a private system—an independent local ReFLEX system connected to a national carrier. This is a very unique concept, and an important point.

Public safety uses both carrier and private systems, depending on local circumstance and objectives. These decisions are made by communications professionals with experience in the relevant technologies and knowledge of their local requirements. They consider operational and funding standards from APCO, NFPA, ISO, SAFECOM, DHS, and others. They consider budgets, local agency command structures, local geography and topology, and many other factors. Generally speaking, public safety communications officials are experts in both public policy and communications technologies, and they work daily with some of the most advanced communications systems and challenging problems on the planet.

And, as our customers, they hold the answer to this debate. They know what they need, and they will spend money accordingly. But, let’s be honest. What the customer needs is not the main point of our discussion here now. Our real question, which we have studiously avoided so far, is this:

In the largest possible context, does “Campus ReFLEX” represent an opportunity for paging carriers, or an adversary to paging carriers?

I’ve been around long enough to know the various opinions. But after spending a great deal of time with public safety, I have gradually come to realize that, as an industry, we know less about our own technology than some of our customers. And herein lies the disconnect: we do not understand our technology, so we do not fully understand our business case. In reality, carriers should not only encourage proliferation of campus systems, but they should make Campus ReFLEX part of their product portfolio. Using any reasonable business criteria, in context of today’s competitive landscape, a carrier should see Campus ReFLEX as extremely positive in the short and long term. Consider these points, from my own first-hand experience over the past few years:

1. Campus ReFLEX is a natural upgrade path for 1-way users.
Insofar as alerting, there has never been a reasonable carrier upgrade path from 1-way paging to 2-way paging. Carrier ReFLEX has 20-second message latency, which is great as a nationwide business tool, but too slow for primary alerting. In comparison, Campus ReFLEX systems deliver messages within 5 seconds and allow users to reply directly to both personal and group messages. To play a role in public safety alerting and mobilization, it is far more efficient and cost effective for a carrier to deploy a local solution than to change the data pipeline architecture of their national system.

2. Campus ReFLEX is not a threat to carrier ReFLEX.
Over the years, as interest in this concept has waxed and waned, I have heard a continual murmur from carriers concerning the potential of self-competitiveness with Campus ReFLEX. Believe me, it’s just not there. The typical carrier customer has no interest whatsoever in Campus ReFLEX. They would run (not walk) away from the prospect of operating their own network. Likewise, good Campus ReFLEX prospects (e.g., volunteer fire agencies), are probably not currently using ReFLEX at all. Campus ReFLEX brings new users into the category; it does not move current users to a different tier.

3. Campus ReFLEX is a good way to recapture private users.
Over the last decade, carriers have lost many 1-way users to private systems operated by hospitals, public safety, and similar sectors. As an upgrade to private 1-way systems, Campus ReFLEX is a carrier/private partnership with obvious and compelling benefits. Campus ReFLEX can bring these users back onto carrier rosters.

4. Campus ReFLEX systems suffer negligible churn.
This was discovered years ago with the first Blackberry™ Server, and it holds true now with Campus ReFLEX. Historically, infrastructure partners are in it for the long term, and are far more loyal to their carriers than single unit customers.

5. Campus ReFLEX is synergistic to existing public safety radio systems.
Campus ReFLEX provides a strong alerting complement to existing P/S voice and data systems. ReFLEX can be easily added to a P/S radio system, using existing sites and spare interconnect bandwidth. Using this deployment model, an entire county-wide ReFLEX system, including design, redundant infrastructure, installation, integration, pagers, and a few years of maintenance, costs much less than a single trunked P25 base site. And while they are by no means trivial, ReFLEX systems are comparatively simple and cost-effective to maintain and operate. The low cost and efficiency of Campus ReFLEX makes it a great value, benefiting the customer and provider.

6. Campus ReFLEX meets key public safety objectives.
Public safety is primarily concerned with 2 characteristics of communications systems: availability and interoperability. Campus ReFLEX makes the grade with both measurements. Concerning availability, Campus ReFLEX is a case study in and of itself. Not only are campus systems built with overlapping base site coverage, but they use redundant control paths and geographically redundant control points. Moreover, in a properly constructed carrier/campus partnership, destruction of an entire RF system (carrier or campus) will simply cause pagers to fail over to the other RF system. Concerning interoperability, AAPC maintains a truly open standard for this, the ReFLEX Exchange Protocol (RXP). RXP 2.1 allows campus systems to interoperate with one another and with carrier networks, seamlessly and automatically, with no licensing burden to manufacturers, and with minimal administrative coordination between systems. In this context, it is not difficult to sell the obvious merits of Campus ReFLEX.

7. Campus ReFLEX keeps the technology up-to-date.
Campus systems give the end user access to both sides of the equation, network and subscriber devices. This encourages market-driven innovation. Most of the changes to ReFLEX 2.7.2, and almost all of the changes to 2.7.3, 2.7.4, and the upcoming 2.7.5, come from the public safety community. As a result, ReFLEX 2.7.5 is the best alerting and mobilization technology currently available, considering all solutions from WiMAX G, to APCO P25, to 3G cellular, to everything else. Instead of abandoning us for other technologies, our customers have given us valuable feedback we need to remain competitive. Over the last 2 years, I’ve seen far more energy and enthusiasm coming from public safety than I have from our own industry. We desperately need this energy.

8. Campus ReFLEX offers new vertical positions to carriers.
A Campus ReFLEX system is not necessarily a simple equipment sale. Campus customers range from completely self-maintained organizations that do everything internally, to organizations who simply want to lease complete solutions, including spectrum, fulfillment, support, and value added services. We have sold “campus systems” to organizations who operate much like local carriers, leasing service to end-user agencies. The paging industry has all of the skills and business processes needed to support the whole gamut of campus users, correctly, efficiently, and profitably. From this vantage point, such participation by carriers themselves will allow them to help customers find the best overall value position for their situation.

Carrier ReFLEX networks are marvelous systems. They have operated reliably for the past decade and have proven to be some of the most survivable carrier systems in existence. I am not arguing that Campus ReFLEX is somehow “better” than nationwide service. The two are completely different, serving different purposes for very different types of customer. My point here is that a largely untapped user base is asking for local control, local RF, and the most current protocol features. By and large, in the current model, these users will probably never become carrier ReFLEX customers.

We exist only at the pleasure of our current and future customers. We will provide what they need, or we will silently fade away. Campus ReFLEX is an extremely competitive way to meet many of these needs. It is not a threat to carriers; it is a unique opportunity for growth and an enhancement to carrier ReFLEX networks.

Sincerely,

James Dabbs
jdabbs@criticalresponse.com
Critical Response Systems, Inc.

22 FEB 07

Brad,

I felt it is time I got off the sideline and shared my thoughts with you and your readership regarding the recent private vs. public paging debate. I applaud both you and Mr. Mercer for bringing this issue to the front. I am a public safety communications professional, with many years of experience.

Public Safety has owned and operated private one-way paging systems for decades. I’m not sure why this all of a sudden has become an issue with ReFLEX. I see this as a natural progression to a newer full-featured technology providing options not available with one-way systems. Spectrum availability has limited choices for the Public Safety community in the past, however there appears to be significant spectrum not being utilized in CFR 47 Part 24. If private industry is not going to invest in network build-outs to benefit users, then I see no reason why Public Safety should not effectively utilize that scarce, finite resource.

The paging industry has obviously experienced a decline in subscribers over the past few years. The erosion of the subscriber base can clearly be attributed to improving cellular technology, not competing paging providers. A modern cellular telephone is a powerful communications device with paging type capabilities – SMS and e-mail. Years ago, it was easy to justify the need for a pager due to the superior coverage when compared to cellular. However, that paging coverage advantage no longer holds true in most service areas. Cellular providers have and continue to expand their networks into areas once dominated by the paging industry, even as paging networks consolidate their networks for supposed greater operating efficiencies. Even in-building coverage is being aggressively enhanced for cellular providers with the increase in microcell and in-building system installations.

As the paging industry continues to cope with the decline in subscriber numbers, manufacturers and carriers should attempt to innovate and cooperate with each other. The manufacturers and carriers should demonstrate leadership within the wireless industry through creativity and pioneering solutions, and not just continue to market the same dated products and services from 10 years ago. The current industry product offerings unfortunately resemble what was considered “leading edge” during the mid 1990s. Trying to control technology or spectrum, instead of expanding offerings and solutions, will inevitably result in the demise of the paging industry. No industry can survive and thrive without continually reinventing itself with innovative solutions, pioneering leadership, and products designed to meet current market needs.

The notion of a private ReFLEX paging network owned and operated by a Public Safety licensee is an area of innovation that should be embraced by the stagnant and weakening paging industry. The Public Safety community operates extensive radio networks for Police, Fire, EMS, and other government departments and officials. These wireless networks typically provide wide-area coverage with multiple levels of redundancy to maximize system availability in the event of network and site failures.

For a Public Safety entity to deploy a paging system not only makes sense in terms of local control and network integrity, but a Public Safety ReFLEX network also makes fiscal sense because the sites and associated telecommunications facilities are already in place (thereby reducing the oft-prohibitive site acquisition and development expenses which are usually the most time-consuming and expensive portion of any wireless network build-out). It is true that Public Safety does not normally utilize satellite technology for network connectivity. However Public Safety does typically utilize both microwave and private fiber networks, often paired together for path diversity. This microwave/fiber transport design paradigm approach is extremely reliable and certainly can support a carrier-grade ReFLEX network. Also, the Public Safety personnel overseeing and managing these mission-critical systems bring a level of expertise and professionalism that few industries can match. Such Public Safety personnel are very equipped and qualified to operate and manage a carrier-grade paging network.

Public Safety and related industries have the potential for significant growth as paging customers, but it will take innovation from manufacturers and carriers. The new ReFLEX campus solutions have enormous potential. Nationwide carriers should work with, not against, entities deploying these systems. The ability for a Public Safety licensee to control its own paging system design and functionality locally but have nationwide paging coverage on a commercial carriers network is one of the most unique and powerfully interoperable solutions conceived to date in the paging industry. As this design philosophy continues to develop and gain traction, Public Safety ReFLEX paging networks will undoubtedly create more paging subscriber interest, solidify and add value to the ReFLEX paging technology, instigate the funding of new private networks, and lead to paging equipment sales and services which should be considered a boon for all of the companies currently operating nationwide commercial paging systems.

Commercial ReFLEX carriers owe their shareholders a thorough analysis of this private Public Safety network ownership concept and all of its possible positive paging industry ramifications before these ideas are routinely dismissed. Nothing in the paging industry currently rivals the innovation rooted in the private Public Safety network ownership paradigm. AAPC should also embrace Public Safety officials seeking their involvement in the organization. Because AAPC members sell to Public Safety does not necessarily mean these same members should speak for the Public Safety community nor claim to even understand all of the current Public Safety system needs and requirements. With proper paging industry cooperation, Public Safety, and the paging industry can collectively revitalize a decaying market with a united approach toward innovation and pioneering system solutions.

Anonymous Public Safety Official

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SATELLITE FAILURES

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Postal Address:	WiPath Communications LLC 4467 Terracemeadow Ct. Moorpark, CA 93021
Street Address:	4467 Terracemeadow Ct. Moorpark, CA 93021
Web site:	www.wipath.com CLICK
E-mail:	info@wipath.com CLICK
Phone:	+1-805-532-9964
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Charles H. Beard
CSSI  KYQX  KMQX  KEQX  KSQX  KQXS  KCQX  KQXE
chb890@swbell.net home
chb890@aol.com home
Office: 877-341-2337 ext 400 or 133
Fax: 817-613-0230
Home: 817-596-8567 / 800-588-7716
Cellular: 817-613-7072 / 800-994-3013
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Email to pager: 8175961000@xpage.net

Press Release

WiPath Adds ReFLEX to its Paging Data Solutions Lineup

February 12, 2007

WiPath Communications is pleased to announce that a ReFLEX version of its PDR2000 paging data receiver has just been released. The new unit, designated the PRR2000 provides the ability to monitor ReFLEX capcodes and implements all of the standard functions of the PDR2000 including printer output, 2 serial data outputs with multiple programmable data capabilities, and remote relay switching.

The PRR2000 is able to receive messages sent on a ReFLEX network and print these messages to a serial or parallel printer. It can also output the messages to another serial device or to a PC where they can be logged using WiPath’s LogPage software. Multiple relays can be controlled using the capcodes or the messages as triggers and it is also capable of translating ReFLEX messages into POCSAG for retransmission.

The PRR2000 extends the line up of intelligent paging terminal devices manufactured by WiPath which includes the unique PDT2000 paging data terminal, a desktop or vehicle mounted paging receiver with very large display and multiple control capabilities and the PDR2000 which is billed as the worlds most intelligent paging data receiver.

Craig Meldrum, President of WiPath said today that this announcement is just the “ …first of what will be several new product announcements in the first quarter of 2007 as the company rapidly expands its product lineup and its presence in the North American market.”

About WiPath

WiPath is a leader in the provision of intelligent solutions in both paging and mobile data with a wide range of innovative solutions including local and wide area paging solutions, mobile data terminals, dispatch and field service solutions, vehicle tracking and management. WiPath specializes in providing both off-the-shelf and customized solutions to the paging and mobile communications industries. Website: www.wipath.com

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Vice President Marketing North America

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The Paging Industry expects quality, reliable, and high performance paging products.

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Contact Information   Kirk Alland   Unication USA   1901 E. Lamar Blvd.   Arlington, TX 76006   (817) 926-6771   kirk@unication.com

Wireless Communication Solutions

ISI-LX Internet Serial Interface with Protocol Conversion Converts Serial TAP message to SNPP, SMTP, or WCTP Pass through Serial Data to TCP/IP and TCP/IP back to Serial Supports Ethernet or PPP Connection to Internet w/Dial Backup Includes 4 Serial Ports for Multiplexing Traffic

IPG Internet Paging Gateway No Moving Parts Such as Hard Drives or Fans to Fail Supports 10Base-T Network Connection to Internet Accepts HTTP, SMTP, SNPP, and WCTP from Internet Sends TAP or TNPP to Your Paging Terminal

PageTrack Inexpensive method of automating your paging monitoring Uses standard paging receiver Available in 152-158 POCSAG or 929 FLEX (call for others)

Omega Unified Messaging Server Full Featured Internet Messaging Gateway TAP Concentrator and TNPP Routing Functions w/TNPP over Internet Serial Protocols Supported: GCP, SMDI, SMS, TAP, TNPP Internet Protocols Supported: AIM, HTTP, SMPP (out only), SMTP, SNPP, and WCTP Full Featured, Easy-to-use Voice/Fax/Numeric Mail Interface One Number For All Your Messaging Optional Hot-swap Hard Drives and Power Supplies Available

Please see our web site for even more products designed specifically for Personal Messaging carriers. For example, the Omega Messaging Gateway and Email Throttling Gateway (anti-spam).

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Hark Technologies

BloostonLaw Telecom Update
Vol. 10, No. 8
February 21, 2007

FCC Seeks Comments On Missoula Plan’s Amended Proposal For A “Federal Benchmark Mechanism”

The FCC seeks comments on amendments to the Missoula Plan that incorporate a proposal addressing issues faced by “early adopter” states, i.e. states that have already taken steps to substantially reduce intrastate access rates. The proposed amendments, referred to as the Federal Benchmark Mechanism (FBM), were described in an ex parte letter filed January 30, 2007, and corrected by another filing on February 5, 2007. The signatories to this ex parte letter assert that the proposed amendments to the Missoula Plan are a significant step in the direction of a more fair and balanced approach to addressing a critical problem the original Missoula Plan filing failed to address.

The Missoula Plan is an intercarrier compensation reform plan submitted by the National Association of Regulatory Utility Commissioners (NARUC) Task Force last July 24 (BloostonLaw Telecom Update, July 26, 2006). Supporters of the Missoula plan include AT&T, BellSouth Corp., Cingular Wireless, Global Crossing, Level 3 Communications, Embarq, Windstream, and 336 members of the Rural Alliance, among others. The current ex parte letter regarding the FBM was filed by the Chairman of the Wyoming Public Service Commission, staff members from four other state commissions (Indiana, Maine, Nebraska, and Vermont), and the Missoula Plan Supporters.

According to the letter, the Federal Benchmark Mechanism will create four methods of addressing various issues that “early adopter states” (those that have substantially lowered intrastate access rates) would otherwise face under the Missoula Plan.

First, the FBM addresses states with very high end-user rates that are at or above a High Benchmark Target rate. Such states presumably have allowed carriers to raise end-user rates to recover costs that previously were recovered through intrastate access charges. In these states, carriers would be permitted to raise the interstate residential subscriber line charges (SLCs) under the plan only to the extent that doing so would not cause residential per line revenues to exceed a defined level referred to as the High Benchmark Target. The FBM creates Category A Funding, which would replace some or all of the SLC increase that would otherwise be permitted under the Missoula Plan.

Second, the FBM creates Category B Funding, targeted at those states with the very highest rates. In these states, the residential per line revenues are already higher than the High Benchmark Target, before any SLC cap increase under the plan. States with such high rates will be eligible to recover from the FBM 75% of the difference between residential per line revenue (before any plan SLC increase) and the Benchmark. This funding must be used by the states first to reduce consumer contributions to any existing universal service fund, with any remaining amounts being used to reduce the interstate residential SLCs.

Third, the FBM endorses Category C Funding. This funding is designed to target FBM support to early adopter states that may not have raised local rates, but instead have adopted explicit universal service support as a means of reducing access charges. The funding is thus limited to states with eligible explicit universal service funds. The total amount of support a state receives between Category B and Category C Funding is limited to the lesser of $10 million or the size of the state’s universal service support funding, and Category C Funding must be used to reduce contributions to that state fund.

Fourth, the FBM includes a “Low Rate Adjustment,” which is intended to reduce the burden on the Restructure Mechanism by reducing reliance on that funding in states that have not had significant “early adopter” activity, and where residential per line revenue is thus below a “Low Benchmark Target.” Without the Low Rate Adjustment, these states would likely qualify for substantial Restructure Mechanism dollars under the Missoula Plan because of their higher access rates. The Low Rate Adjustment would replace some of those Restructure Mechanism dollars with an increased SLC cap.

The working group estimates that approximately $806 million will be needed to incorporate the FBM proposal into the Missoula Plan. This represents $579 million for Category A Funding; $141 million for Category B Funding; and $111 million for Category C Funding, less a $25 million reduction to the Restructure Mechanism attributable to the Low Rate Adjustment. The FBM provides net positive support for 39 states.

Comments in this CC Docket No. 01-92 proceeding are due March 19, and replies are due April 3.

BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, DC 20554

REPLY COMMENTS OF AAPC

THE AMERICAN ASSOCIATION OF PAGING CARRIERS (AAPC), by its Task Force on Emergency Communications, respectfully submits its reply to the comments filed in the captioned proceeding on February 6, 2007 by AT&T, Inc. (AT&T) and Maritime Communications/ Land Mobile, LLC (MC/LM), in response to the Public Notice, FCC 07-4, released January 23, 2007.¹ As its reply comments, AAPC respectfully states:

Background

In this proceeding the Commission has requested comments on the appropriate interpretation of the terms “Remote Communities,” “Commercial Mobile Service” and “Effectively Unserved,” as used in Section 605(a) of the WARN Act.² The WARN Act establishes a grant program for the installation of technologies in remote communities to enable residents of those communities to receive emergency alerts.

In relevant part, Section 605(a) directs the Under Secretary of Commerce for Oceans and Atmosphere to “establish a program under which grants may be made to provide for outdoor alerting technologies in remote communities effectively unserved by commercial mobile service . . . for the purpose of enabling residents of those communities to receive emergency alerts.” (Emphasis added). The Commission inquires whether its definition of “rural area” in other proceedings also would be appropriate to use for “remote communities” under the WARN Act, and whether the definition would be equally beneficial for purposes of administering the grant program envisioned by Section 605(a). The Commission also inquires whether “commercial mobile service” should be interpreted to have the same meaning as the term “commercial mobile radio service” in Section 332(d)(1) of the Communications Act³ and Section 20.3 of the Commission’s rules.⁴ Finally, the Commission poses several questions about how the term “effectively unserved” should be interpreted and applied.

AAPC is the national trade association representing the interests of paging carriers throughout the United States. Paging carriers are classified as Commercial Mobile Radio Service providers pursuant to Section 20.9 of the Commission’s rules.⁵ AAPC’s members include all of the nationwide paging operators licensed under Parts 22, 24 and 90 of the Commission’s rules, as well as the overwhelming majority of units served by regional and local paging systems licensed under Parts 22 and 90 of the rules; and they encompass in excess of 90 percent of the units served by the paging carrier industry. A representative of AAPC also serves on the Commercial Mobile Service Alert Advisory Committee established pursuant to Section 603(d)(3) of the WARN Act.

Comments in response to the Public Notice were filed by AT&T, Inc. on behalf of its affiliate AT&T Mobility LLC (f/k/a Cingular Wireless LLC) and by MC/LM. While AAPC largely agrees with the positions taken by both parties in their comments, AAPC does differ in certain respects, as discussed below.

Reply Comments

Commercial Mobile Service. AT&T supports using the same definition as for “Commercial Mobile Radio Service” in Section 20.9 of the Commission’s rules, but states that service by mobile satellite carriers should not be considered when determining whether or not a community is “effectively unserved”. MC/LM objects that the definition in the regulations is broader than Section 332(d)(1) of the Communications Act itself, but does not explain what licensee category set forth in Section 20.9 should be excluded for purposes of the WARN Act, or why it should be excluded.

AAPC agrees that the definition of “Commercial Mobile Radio Service” in Section 20.9 of the rules should be the starting point of the interpretation of “commercial mobile service” for purposes of the WARN Act, and AAPC also agrees with AT&T that mobile satellite carriers should be excluded from the definition. As AT&T correctly notes, considering mobile satellite carriers as commercial mobile service for purposes of the WARN Act would effectively mean that there are no “effectively unserved” communities at all, a result that hardly seems congruous with the Congressional intent in establishing the grant program.

Regardless of the reason for MC/LM’s objection, AAPC also agrees that other classes besides mobile satellite carriers likewise should be excluded from the definition. For example, it is not immediately evident that the Air-Ground Radiotelephone Service (Subpart G of Part 22) is relevant to this process, or that the Offshore Radiotelephone Service (Subpart I of Part 22) is relevant either. Accordingly, AAPC agrees with AT&T that mobile satellite carriers should be categorically excluded from the definition of commercial mobile service for purposes of the WARN Act. However, AAPC further suggests that carriers licensed under Subparts G and I of Part 22 perhaps also should be excluded as well.

Remote Communities. Both AT&T and MC/LM support the Commission’s proposed use of its definition of “rural area” in other proceedings (i.e., counties with a population density of 100 persons per square mile or less) as the definition of “remote communities” for purposes of the WARN Act. While AAPC also believes that the definition of “rural area” is the proper starting point, AAPC does not believe it adequately addresses the WARN Act provisions.

The purpose of Section 605(a) is to establish a grant program for community alerting systems. While it may be that the counties themselves will be applicants for these grants in some circumstances, AAPC believes it is more likely that the actual applicants will be the political subdivisions of the counties, such as incorporated villages, towns or cities, or perhaps townships. Accordingly, AAPC suggests that the definition of “remote communities” for purposes of the WARN Act should not be the “rural area” itself, but rather should be the political subdivisions of “rural areas” such as incorporated villages, towns or cities, or townships or their equivalent. Doing so at the subdivision level, rather than at the county level, also would facilitate application of the term “effectively unserved” as discussed in the next section.

Effectively Unserved. AT&T proposes that the coverage maps on the web sites of traditional terrestrial CMRS providers, including paging providers, be used to determine whether or not service is available to a particular remote community. MC/LM proposes that a remote community should be deemed to be unserved if (a) fewer than two competing CMCMRS providers offer service, or if (b) 100 subscriber units or less are actually receiving service.

AAPC agrees with AT&T that in implementing this provision, the Commission should be particularly sensitive to the potential burden that could be placed on the CMRS industries. For that reason, AAPC requests that the Commission reject MC/LM proposed standard as impractical and unduly burdensome. Instead, AAPC supports AT&T’s suggestion of using the web site information of traditional CMRS providers as prima facie evidence that a particular remote community is unserved for purposes of grant eligibility under Section 605(a). AAPC would add two provisos, however.

First, a CMRS provider should have the option, if it chooses to do so, of generating coverage maps that are not on a web site for purposes of this showing. While AAPC believes that most local and regional paging carriers do have their coverage maps posted on their web sites, as do the national carriers cited in AT&T’s comments, some of the smaller carriers may not. Therefore, a smaller carrier should have the option of demonstrating that it serves a particular remote community with traditional coverage maps in addition to web-based maps.

In this regard, for grant administration purposes, AAPC also requests that lists of communities seeking grants under Section 605(a) of the WARN Act should be posted in a timely and readily accessible fashion so that carriers in the area have notice of the application and the opportunity to show that they do in fact serve the community.

Additionally, the Commission should adopt the qualification that the remote community be served by a CMRS provider that does in fact distribute emergency alerts on its network. It is certainly conceivable, and entirely likely, that a remote community could be served only by a single CMRS provider that does not distribute emergency alerts,⁶ in which case it would be tantamount to not being served at all for purposes of Section 605(a) of the WARN Act. Under such circumstances, the purpose of the grant program obviously would be frustrated to not consider whether or not the CMRS provider actually distributes emergency alerts when determining whether a particular remote community should be eligible for a Section 605(a) grant.

February 22, 2007

¹ THE COMMISSION SEEKS COMMENTS ON IMPLEMENTATION OF A GRANT PROGRAM FOR REMOTE COMMUNITY ALERT SYSTEMS PURSUANT TO SECTION 605(A) OF THE WARNING, ALERT, AND RESPONSE NETWORK (WARN) ACT, FCC 07-4, PS Docket No. 07-8, released January 23, 2007.
² Warning, Alert, and Response Network (WARN) Act, Pub. L. No. 109-347, §§601-613, 120 Stat. 1936-1943(2006).
³ 47 U.S.C. §332(d)(1).
⁴ 47 C.F.R. §20.3.
⁵ See 47 C.F.R. §20.9(1), (6), (11).
⁶ While the issue has not yet been resolved, distribution of emergency alerts by CMRS providers at this point remains voluntary rather than mandatory.

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Nighthawk Systems Announces Doubling of Utility Product Revenues

From 2005 to 2006
—Trend Continues Into 2007—
—Recent Sale to Colorado Utility—

SAN ANTONIO, TX - 2/22/07 — Nighthawk Systems, Inc. (OTC BB: NIHK), a leading provider of intelligent wireless power management and emergency notification solutions, today announced that sales of its products to electric utilities more than doubled from 2005 to 2006. Anchored by sales of its CEO700 whole house disconnect units, revenues generated by sales of its utility division products rose approximately 120% from 2005 to 2006, and the sales trend has continued in early 2007.

Nighthawk also announced that it has received an initial order for its CEO700 whole house disconnect units from United Power of Brighton, Colorado. United Power is a rural cooperative providing electric service to over 60,000 meters representing more than 120,000 customers across Colorado’s northern front range. The CEO700 gives electric utilities the ability to wirelessly disconnect and reconnect power to residential electric meters from a centralized location, saving them significant time and money over the traditional manual disconnect method requiring multiple truck rolls and field personnel.

H. Douglas Saathoff, Nighthawk’s CEO, stated, “I’m extremely happy with the trends that I am seeing with our products in the electric utility industry. We continue to get initial orders from new customers like United Power and Cheyenne Light, Fuel and Power as announced earlier this week. These new customers recognize that they have an almost immediate opportunity to save time, effort and money, and then keep coming back with additional orders when they realize how easy it is to do so. New customers typically lead to revenues in both the near term and in the long run.”

Individuals interested in Nighthawk Systems can sign up to receive email alerts by visiting the Company’s website at www.nighthawksystems.com.

About Nighthawk Systems, Inc.
Nighthawk is a leading provider of intelligent wireless power control products that enable simultaneous activation or de-activation of multiple assets or systems on demand. Nighthawk's installed customer base includes major electric utilities, internet service providers and fire departments in 40 states. Nighthawk's products also enable custom message display, making them ideal for use in traffic control and emergency notification situations.

Forward-looking statements
Statements contained in this release, which are not historical facts, including statements about plans and expectations regarding business areas and opportunities, acceptance of new or existing businesses, capital resources and future business or financial results are "forward-looking" statements. You should not place undue reliance on these forward-looking statements. Such forward-looking statements are subject to risks and uncertainties, including, but not limited to, customer acceptance of our products, our ability to raise capital to fund our operations, our ability to develop and protect proprietary technology, government regulation, competition in our industry, general economic conditions and other risk factors which could cause actual results to differ materially from those projected or implied in the forward-looking statements. Although we believe the expectations reflected in the forward-looking statements are reasonable, they relate only to events as of the date on which the statements are made, and our future results, levels of activity, performance or achievements may not meet these expectations. We do not intend to update any of the forward-looking statements after the date of this press release to conform these statements to actual results or to changes in our expectations, except as required by law.

CONTACT:
Doug Saathoff
dsaathoff@nighthawksystems.com
(877) 7-NIGHTHAWK, Ext 701

EMERGENCY AUTOMATION & NOTIFICATION

• FIREHOUSES • SCHOOLS • PUBLIC FACILITIES • GOVERNMENT FACILITIES • EMERGENCY ROOMS •

WHAT DO FEDERAL AND STATE GOVERNMENT AGENCIES, FORTUNE 500 COMPANIES, WISPS, HAVE IN COMMON?

THEY ALL USE NIGHTHAWK.

Nighthawk Systems Inc. manufactures low cost and reliable remote control products for fire house alerting, volunteer alerting, activation of warning signs and sirens, and a number of applications for public safety.  The Company manufactures the EA1 and the FAS-8 which have been designed specifically for these applications.  Both products are paging based and will work with any public or private paging network.  They are available in all VHF, UHF, and 900 MHz paging frequencies.  The products can serve as the primary notification system or an excellent, low-cost backup to existing systems.

The EA1 is the solution for remotely activating public warning signage.  Examples include tornado sirens, flash flood warnings, fire danger, Amber Alert, icy roads, etc.  The EA1 can also send text messages to scrolling signs.  This can occur in conjunction with the activation of audible alarms and visual strobes.  This is ideal for public notification in buildings, schools, hotels, factories, etc. The group call feature allows for any number of signs or flashing lights to be activated at the same time over a wide geographic area.  In addition, the EA1 Emergency Alert is the perfect solution for low cost yet highly effective alerting of volunteer fire fighters in their home.  When activated the EA1 will emit an audible alarm and activate the power outlet on the units faceplate.  A common setup is to simply place the EA1 on a table and plug a lamp into the faceplate.  When paged from dispatch or any touch tone phone the EA1 will awaken the fire fighter to a lit room.  As an option the EA1 can be ordered with a serial cable, allowing for attachment of a serial printer.  When paged the alphanumeric message will be printed out at the same time the alarm sounds and the outlet is activated.  The EA1 is an ideal complement to alphanumeric belt pagers common to volunteers.

The FAS-8 is designed for activating one or more relays in a firehouse and if desired, printing the alphanumeric message to a serial printer.  For this application the FAS-8 is set to activate upon receiving the proper paging cap code sent from 911 dispatch.  Up to eight different devices can be activated all with individual time functions.  The most common devices to turn on include the PA amplifier, audible wake up alarm, and house lights.  The most common device turned off is the stove.  The FAS-8 can accept up to 8 different cap codes and have separate relay and time functions per cap code.  This allows for different alerting to be accomplished at the same physical location depending upon which cap code is sent.  This can be very helpful when fire crews and medical crews are housed in the same building.

FAS8

Put the innovative technology of Nighthawk to work for you. For more information on any of our products or services, please contact us.

Nighthawk Systems, Inc.
10715 Gulfdale, Suite 200
San Antonio, TX 78216

Phone: 877-764-4484
Fax: 210-341-2011
E-mail: sales@nighthawksystems.com
Web: www.nighthawksystems.com

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SATELLITE CONTROL FOR PAGING SYSTEMS

$500.00 FLAT RATE

TAPS—Texas Association of Paging Services is looking for partners on 152.480 MHz. Our association currently uses Echostar, formerly Spacecom, for distribution of our data and a large percentage of our members use the satellite to key their TXs. We have a CommOneSystems Gateway at the uplink in Chicago with a back-up running 24/7. Our paging coverage area on 152.480 MHz currently encompasses Texas, Oklahoma, New Mexico, Louisiana, and Kansas. The TAPS paging coverage is available to members of our Network on 152.480 MHz for $.005 a transmitter (per capcode per month), broken down by state or regions of states and members receive a credit towards their bill for each transmitter which they provide to our coverage. Members are able to use the satellite for their own use If you are on 152.480 MHz or just need a satellite for keying your own TXs on your frequency we have the solution for you.

TAPS will provide the gateways in Chicago, with Internet backbone and bandwidth on our satellite channel for $ 500.00 (for your system) a month.

Contact Ted Gaetjen @ 1-800-460-7243 or tedasap@asapchoice.com CLICK TO E-MAIL

With best regards,

73 DE K9IQY

Brad Dye
Wireless Messaging Consultant

P.O. Box 13283
Springfield, IL 62791 USA

“The reality of the other person is not in what he reveals to you, but in what he cannot reveal to you. Therefore, if you would understand him, listen not to what he says but rather what he does not say.”
—Kahlil Gibran