05/20/1975FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554
11 JUN 1975
IN REPLY REFER TO:
7820-12
Monroe County
Monroe County Courthouse
Key West, Florida 33040
Attention: Clerk, Board of Commissioners
Gentlemen:
On May 20, 1975, the Commission adopted a Memorandum Opinion and
Order concerning your waiver request for relief of multi -channel
equipment requirements in the Special Emergency Radio Service.
Enclosed is a copy of this order.
As a result of the action in the order, only a portion of the
waiver request was approved and the application you have submitted
is granted accordingly. If further information is needed, please
contact our Industrial and Public Safety Facilities Division, Room
5308, (202) 632-6475.
Sincerely yours,
har es Higginbotham
Chief, Safety and Special
Radio Services Bureau
Enclosures:
License(s)
Memorandum Opinion & Order
Before the S
FEDERAL COMMUNICATIONS COMMISSION FCC 75-583
Washington, D. C. 20554 35097
In the Matter of )
)
Waiver of Part 89 of the Commission's )
Rules relating to requirements for )
multi -channel equipment capability )
for operation of Medical Services )
Radio Systems. )
MEMORANDUM OPINION AND ORDER
Adopted: May 20, 1975
Released: May 28, 1975
By the Commission: Commissioners Quello and Washburn absent.
1. Requests have been received for waivers of Sections
89.525(f)(2)(ii) and (iii) of the Commission's Rules governing the
assignment of eight frequency pairs in the 463/468 MHz band for
Medical Services radio systems in the Special Emergency Radio Service.
These frequencies are assigned in a "block" for designated primary
and secondary medical radio uses. The rule sections involved in these
waiver requests provide that base and control station equipment for
use of these frequencies must be capable of transmit/receive on at
least three (four, when telemetry is utilized) of the frequency pairs;
and that mobile equipment for use of the frequencies must be capable
of transmit/receive on each of the eight frequency pairs.
2. The waivers being sought are requested in connection
with applications for licensing of medical services radio systems
submitted by the following parties: John D. Archbold Memorial Hospital,
Thomasville, Georgia; Jefferson County Ambulance Service, Monticello,
Florida; Doctor's Memorial Hospital, Perry Florida.; Holmes County
Hospital, Bonifay, Florida; Calhoun. General Hospital, Blountstown,
Florida; Wakulla Ambulance Service, Crawfordville, Florida; Madison
County Memorial Hospital, Madison Florida; Gadsden Memorial Hospital,
Quincy, Florida; Tallahassee Memorial Hospital, Tallahassee, Florida;
and Monroe County Fisherman's Hospital, Key West, Florida.
3. Each of these applicants, excepting Monroe County,
would operate as an emergency medical services (EMS) provider in the
"Tallahassee EMS Communications Major Catchment Area" under an area -
wide plan for that medical -care region in Northern Florida. The
Monroe County operation is based at Fisherman's Hospital in the city
of Marathon in the Middle Keys area of the Florida Keys.
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4. The base station operations of Tallahassee Memorial
Hospital,which is the regional medical center, would meet the multi-
channel rule requirements. All other applications for base station
facilities contemplate only two -channel capability, rather than the ,
three or four channels required by the rules. One of these two channels
is a "common calling" frequency for inter -system requirements. Effectively
therefore, each of these base stations has only one "working" channel
to handle all intea-system medical requirements. In the associated
mobile unit operations proposed in these applications, Tallahassee
Memorial Hospital plans only four -channel capability, and all other
applicants propose only three -channel capability rather than the
required full eight -channel capability. One of these mobile frequencies
is paired with the base station "common calling" channel. No mobile
units can access "working" channels for all base stations in the area -
wide system. As none of these systems totally complies with the
Commission's rules, they can not be licensed without waiver action.
5. Representations in support of the requested waivers show
that the proposed radio systems would operate in accordance with state-
wide plans for EMS communications as developed by the Department of
General Services of the State of Florida. It is argued that under
the State's programs, the additional base and mobile channel capability
as required by the Commission's Rules is not necessary and that "the
multi -channel equipment rule has the net effect of being a substitute
for the State and local planning of EMS communications systems." This,
it is contended, defeats the Commission's objective "for compatible
EMS systems," in that "there is no flexibility for creative systems,
implementation, cost effectiveness, or maximization of available resources. 1/
6. A more specific basis for waiver action was presented as
to the Monroe County application for the Fisherman's Hospital in Marathon,
Florida. Here, Marathon's relative isolation from other communities
(it is essentially an island community in the Gulf area linked to the
Florida mainland some 100 miles north by an intercoastal highway) is
depicted to illustrate its comparatively limited requirements for
intersystem medical communications.
l/ An argument had been originally presented that meeting the multi-
channel requirement was a cost problem. However, a detailed cost analysis
of bids developed under State procurement offers for equipment require-
ments indicated only a 4% to 7% price differental between equipment needed
for the proposed operations and equipment that would be required for
compliance with the Commission's rules. Further, a significant portion of
this differential appeared to relate to features of the system not required
by the Commission's rules, and to non -equipment services called for in the
Requests For Procurement. The State concluded, "We do not consider the
vendor's costs a significant problem... In any event the cost problem does
not affect the numbers of channels required."
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7. The basis and purpose of the multi -channel requirements
in UHF medical radio systems were discussed extensively in connection
1 with the rule making proceeding in Docket 19880. Rule changes adopted
in this Docket included allocation of frequencies in the 463/468 MHz
band exclusively for medical services operations with standards for
their assignment and use. (See the Report and Order in Docket 19880,
adopted July 2, 1974, 47 FCC 2nd 676.) In response to a request from
the State of Florida for reconsideration of the multi -channel require-
ment, the Commission addressed the issues noted by the State in a
Memorandum Opinion and Order adopted in Docket 19880 on October 22,
1974, (49 FCC 2nd 368.) The Commission found and stated, with respect
to mobile stations:
"...the necessity for flexibility in the potentially wide-
ranging emergency activities for most ambulances mandates
full eight -channel capability."
And, with respect to base and control stations:
"The more relevant needs for these stations are that systems
have the ability to handle separately the many different
medical communication requirements, and that there be sufficient
channels available to assure a 'clear channel' for emergencies.
For these purposes, we find that four channels, when bio-medical
telemetry is employed in the system, and three channels, when
telemetry is not used, are the minimum requisite number of channels
which should be available at base and control stations."
8. The arguments and factors presented to support these
requests for waivers of the multi -channel requirements have been
carefully examined. We have extensively studied and discussed with
State officials in Florida each of the systems involved, and the impact
of these requirements on State and local medical communications planning
efforts and operations. With respect to the systems in the Tallahassee
region, the Commission finds no valid basis for grant of any waiver
as to the equipment standards. The Tallahassee system is designed to
provide area -wide coordinated inter -system communications capability
for a number of communities in Northwest Florida. We recognize that
some of these communities are very small and operate few medical vehicles.
Nevertheless, the area and the systems are similar to those served by
many "common" systems that are being developed for medical services
throughout the country. Systems of this type are usually designed to
optimize the full potential of the block -assigned 463/468 MHz channels,
whereas, the Tallahassee area system would be a somewhat more limited
approach on the reduced number of channels we are requested to approve.
In any event, we are not aware of any unique factor or compelling exten-
uating situation in the Tallahassee system that would warrant in the
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public interest an exception to the multi -channel rule requirement.
Accordingly, the waiver requests for the applicants in the Tallahassee
area are denied.
9. We have reached a different conclusion with regard to
the request from Monroe County for the Fisherman's Hospital in Key
West. One of the primary purposes for the base and control station
multi -channel requirement is the need to accommodate intersystem
communications requirements when medical emergencies develop involving
itinerant medical units that normally operate on different channels.
It is recognized, however, that there may exist unusual situations
where a hospital is so remotely located and its operations are so
limited that there would be no reasonable likelihood of need to radio -
communicate with other licensed systems. Geographically and logistically,
the hospital base station operation at Marathon, Florida, appears to
fall within this category. Therefore, the Commission is granting the
request for waiver as to the Monroe County system. We are not including
the mobile units for the Monroe County system in this waiver approval.
These vehicles would well be expected to have need to travel to and
communicate with other hospitals or personnel in other communities
for medical emergencies, and this requires full -channel capability in
the mobile units.
10. It is noted that there are other base station operations
where it may be appropriate to favorably consider exception to the
multi -channel equipment requirements. One common example could apply
in the operation of such medically related activities as blood banks
or eye banks which are included in the eligibility category for medical
services. These functions are generally designed to serve particular
hospitals and there may be little or no need for system capability beyond
communication with the hospitals served. Requests of this nature can
be considered on a case by case basis.
11. Oral hearing before the Commission has been requested
by the Florida Department of General Services who, although not a party
applicant,seeks to present information concerning the waivers we have
considered herein. Even assuming that the State would be a proper
party for appearance in a hearing of this nature, the Commission believes
that it is fully cognizant of the issues involved as to these requests
and there are no facts in dispute. Consequently, we find that there is
no apparent purpose or public interest requirement to be served by an
oral hearing and this request is denied as to Florida or as to any of
the proper party applicants.
A
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12. In consideration of the foregoing, IT IS ORDERED
That, the application requests for waiver of Part 89 of the Commission's
Rules submitted by the parties listed in Paragraph 2 herein, relating
to requirements for multi -channel equipment capability for operation
of Medical Services radio systems, ARE DENIED, except that the request
for waiver as to multi -channel base station requirements for the Fish-
erman's Hospital in Monroe County, Florida, IS GRANTED.
FEDERAL COMMUNICATIONS COMMISSION
Vincent J. Mullins
Secretary
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