PROPOSED FEDERAL TELECOMMUNICATIONS STANDARDS 1023, 1024 & 1044

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP90M01364R000700140063-7
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 10
• Document Creation Date: December 23, 2016
• Document Release Date: September 12, 2013
• Sequence Number: 63
• Publication Date: August 5, 1988
• Content Type: LETTER

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UTING AND TRANSMITTAL SLIP
Date
10 October 1988
TO: (Name, office symbol, room number,
T bonding, Agency/Post)
11. DIRECTOR OF COMMUNICATIONS
Initials
Date
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,
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File
Note and Return
Apcircival-.?
For Clearance
Per Conversation
As Requetted
For Correction
Prepare Reply
Circulate : ,
For Your Information .
See Me
Comment
Investigate
Signature
Coordination
Justify
REMARKS
FYI
? DO NOT use this form as a RECORD of approvals, concurrences, disposals,_
clearances, and similar actions
Room No.?Bldg.
Phone No.
5041-102 ?OPTIONAL FORM 41 (Rev. 7-76)
tab U.S. Government Printing ?Mem .1987-181-246/60000 Prescribed by GSA
FPMR (41 CFR) 1 01-11.206
TO:
? EXECUTIVE SECRETARIAT
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Date
STAT
STAT
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IExecutive Registry
88-3119X...
August 5, 1988
Jame:-; Al. Ifikson
Managet !Wuxi Sales
Cumaal flocnn: Company
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804 !;28-74!)0. 8'50 74'0
TO: Key Federal Government Executive and Manager
RE: PROPOSED FEDERAL TELECOMMUNICATIONS
STANDARDS 1023, 1024 & 1044
Dear Federal Executive and/or Manager:
IGE Mobile
Communications
General Electric Mobile Communications (GEMC) began encouraging the
establishment of a standard for voice encryption and trunking in mid 1986
and has since attempted to keep key government executives and military
managers informed as to its on-going developmental status as well as our
position on this subject.
GEMC's major concern has always been that the standard should reflect and
promote state-of-the-art technology, cost effectiveness and provide a well
planned and useful standard for the end user as well as the land mobile
industry for the next ten to fifteen years. Unfortunately, these concerns
have not been fully focused .upon and it appears that the existing,
embedded-outmoded technology base alone may be the driving force for this
proposed standard.
As an. example, in the area of trunking, to date, no manufacturer appears
to be planning to upgrade its customers' nontrunked radios. Consequently
as government agencies move to trunking (installations are now taking
place in some cases), the embedded technology base is threatened with
incompatibility and premature obsolescence.
Although the dominant manufacturer in this area has implied upgradeability
(in other than trunking) it has yet to quote publicly any pricing for
this. Historically the cost of upgra.deability will most likely exceed the
cost that a prudent manager would want to expend on older radios versus
the purchase of newer ones.
GEMC has consistently maintained that a single standard with steps in it
is the best approach and that this single standard should address voice
encryption (classified/sensitive) as well as trunking since all of DOD and
a good portion of non-DOD Federal customers who buy trunking require voice
encryption. However most, do not require classified (Type I) encryption.
Thus, the approach of publishing FS1023 then FS1024 and ultimately FS1044
(for trunking) as proposed by the LMR Subcommittee while trunking systems
are currently being installed by the government seems illogical and
ill-advised. The interoperability problem of DES FS1027 will only be
repeated. Couple this with some end-user requirements for simulcast
(simulcast under FS1023 would be a much more expensive way to go) one must
ask: why is the government pushing for a standard that will not serve its
needs and as Tom Jones' report (enclosed) states, will create an
unregulated monopoly by one manufacturer, as well.
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Federal Executive and/or Manager
August 5, 1988
Page 2
GEMC looks forward to working with you or any members of your staff to
help resolve these issues so that a true industry-wide standard is
established. In our continued efforts and belief that informed policy and
decision makers such as yourselves will protect and insure that a standard
is developed that is beneficial to the government, we are providing you
with the following information:
? A white paper which specifically addresses comments made by the
study entitled "Impact Assessment of Proposed Federal Standard
1023? by Lloyd Thomas Jones of the Institute for
Telecommunications Sciences (ITS) of NTIA.
? A copy of the above referenced study, should you not have
received same.
? A synopsis of FCC rules change report & order 87-112. Shows
where the FCC is planning to examine the technical aspects of
compatibility for the public safety spectrum under the "National
Public Safety Plan".
? ? A copy of a Freedom of Information Act Request to John Fernandez,
Chief Councils Office, NTIA/ITS requesting information to explain
inconsistences and lack of backup data in the above mentioned
study.
GEMC is willing in order to shorten the time to develop a standard for
voice encryption (FS-1023) and to create a level playing field for all
qualified manufacturers, GEMC was and continues to be willing to license
to the Federal Government use of its proprietary protocols at no cost.
This offer was formally made on November 11, 1986 in a letter to the NSA
from Mr. E. Hood, Vice Chairman of General Electric. The objective was to
allow the government to provide these protocols to any or all
manufacturers who supply radios under a Federal government procurement,
resulting in interoperational radios and systems.
GEMC has continued development of digitized voice since that time and has
achieved an improved level of voice quality using a technique defined as
Residual Excited Linear Predictive Coding (RELP). This method was
demonstrated to NSA on 6/17/88. The offer made in 1986 is now expanded to
include the proprietary RELP coding method, utilizing the most current
technology available.
Trunked radio systems available today are also proprietary and raise the
interoperability question again. GEMC is willing to release its
proforietary protocols to the Federal Government, contingent upon it being
accepted as a standard. The Federal government may then provide these
protocols to any or all manufacturers who supply radios to Federal, State
and Local government users under normal procurement policies.
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Federal Executive and/or Manager
August 5, 1988
Page 3
Please contact the undersigned or Kathryn Nicosia if we can provide you
with any additional information, meet with members of your staff to
discuss these issues, provide an executive briefing or a detailed
technical briefing for you or your staff.
GE MC looks forward to a state-of-the-art and economically sound standard
for voice encryption and trunking that will benefit all, manufacturers,
end-users and tax payers.
Sincerely,
James M. Erikson
JME/dd
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STAT
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GENERAL
ELECTRIC
GENERAL ELECTRIC MOBILE COMMUNICATIONS
COMMENTS ON
"IMPACT ASSESSMENT OF PROPOSED FEDERAL STANDARD 1023"
A STUDY BY LLOYD THOMAS JONES
OF THE
INSTITUTE FOR TELECOMMUNICATION SCIENCES
NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION
FOR THE
NATIONAL COMMUNICATIONS SYSTEM
GEMC
AUG. 5, 1988
804-528-7450
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GEMC Overall Assessment of Report
The preface of the report states that it is the aim of the report to assess,
. . the economic and technological ramifications associated with the
adoption of proposed Federal Standard 1023 entitled Telecommunications:
Interoperability Requirements for Encrypted, Digitized Voice Utilized with 25
Khz Channel FM Radios Operating Above 30 MHz".
GEMC must conclude after reading this report that the report is insufficient,
inconclusive and devoid of economic or technological data to support a
hypothesis that ". . .the proposed standard provides an acceptable means of
satisfying established Government requirements". Likewise the reference in
the report's introduction of R. F. Carroll Jr.'s Assistant Commissioner of
GSA letter of July 5, 1978 which highlights that, "it is essential that
Federal telecommunications standards be promulgated with due consideration of
product availability and economic and technological impact" has only been
alluded to with words such as "probably", "overwhelmingly", "thinking",
"possible", "merely", "satisfactory", "interest", "seriously consider",
"believe", "perceived", "minimal", and "reasonable".
These are not the words of a scientific report, let alone a report addressing
the disciplined study of economics and/or technology. Unlike the studies
which the ITS and NTIA are known for, this report contains vaguenesses and
unsubstantiated statements with basically no backup. It is for this reason,
GEMC must ask the following specific questions: (Note 1)
? What were the questions asked of company representatives referenced
as A,B,C,D and E under Section 4 p.6, Results of Verbal Survey.
? What are the dates, names, addresses and telephone numbers of each
point of contact from Company A, B, C, D and E.
? What were the written materials sent or notes taken during these
above mentioned conversations.
? What is the information concerning the use/modification of radios by
the Bureau of Alcohol Tobacco and Firearms (ATF) to include
individuals contacted telephone numbers and how the modification was
done.
? What type of analysis was used in addressing the economic
ramifications of FS1023.
? What else did Mr. R. F. Carroll, Jr.'s 5 July 1978 letter say.
? What are the other detailed cross-referenced material concerning the
companies spoken to that are referenced in this report.
? How was it determined that the "proposed Federal Standard 1023
contains the necessary detailed information to insure
interoperability between digitally encrypted radio (operating with
the same key) regardless of the manufacturer."
1) FOIA request dated 5 August to John Fernandez Chief Councils Office/ITS
has asked some similar questions (see attachment).
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? What are the facts that back up the statement that VOCODER
technology as well as advances in transceiver and 'modulation
technology ". . .developments are not far enough along to support
standardization at this point in time."
? What suppliers have expressed interest in providing FS1023 radios
and which individual made the statement.
? Which manufacturers, ? per the report, will provide the needed
encryption modules today.
? How did the report conclude and who are the: "sources that
perceive the economic impact of the draft standard to be minimal
and positive".
? What analysis identifies ". . .the 80 - 90% or more of the
Federal market for encrypted digital voice radios" that are at 12
Kbs CVSD and explanation of how this existing base of radios
should affect the impact of the standard.
? What evidence is there that the total base is economically
upgradeable to FS1023 type radios.
? What specific price quotes were obtained to prove the economic
upgradeability of the above mentioned existing base of radios.
? What was the rationale used by the Department of Coramerce/NTIA or
ITS that the granting of a monopoly to one manufacturer was OK,
or that it would only be a short term monopoly.
? What is the justification rationale to disregard the Competition
and Contracting Act by granting a short term monopoly.
? Why was there no supervisory review or staffing of this study by
ITS management and/or NTIA/Department of Commerce management
prior to publication of this study.
GEMC had hoped that the report would have used adequate scientific
analysis to answer the foregoing questions. However, as stated, GE has
provided NCS material including studies conducted by the Federal
Government (NTIA) and data on testing done by Dynastat, Inc. a well known
independent lab for GEMC. This information and data was obviously ignored
in the preparation of this report. In addition, the report minimizes the
over 200 plus comments made by the following class of individuals:
? LMR Manufacturers
? IEEE Land Mobile Radio Engineers
? Other interested parties who represent some of the leading
communications companies and corporations in America, ie, AT&T,
GTE, Hughes/General Motors, United Telecom, McCaw, Harris, Sony,
E Systems, COMSAT and Pactel to name just a few.
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?
GEMC spent time at the NCS reviewing all Of the comments that were
submitted prior to April 25. GEMC then reviewed additional comments that
the NCS allowed to be submitted after the closing date for comments.
Again, these comments were 95% or better in favor of the position which
GEMC has taken.
In ignoring these comments, the report on p. 5 paragraph 3.4 Survey Forms,
quotes ". . .but most merely submitted the checklist. . ." and states GEMC
led the respondants.
To say that leading LMR Communications Engineers, Senior Management of LMR
telecommunications companies, leading Technical Directors of various state
or local entities could be lead by GEMC or in fact in many cases, could be
lead by a competitor is ,beyond the scope of imagination. The people who
commented are all professionally knowledgable and responsible
representatives of their industry with titles such as; President, Vice
President, Senior Vice President, Chief Scientist, Chief Bureau of
Communications Engineers, Vice President of Development, Vice President of
Engineering, Division Vice President of Development, Vice President of
Engineering, Division Vice President-General Manager to name just a few.
Many of the checklists submitted to NCS had written notes in addition to
statements checked and in some cases not -every response was checked as
being in agreement with GEMC's position. Likewise, there were a number of
letters which were in fact unsolicited by GEMC which were also favorable
to our position. There was no letter, that totally supported the standard
as written, in fact, even Motorola's letter stated that clarifications
were needed. The reports' ignoring of this data is unscientific.
As stated in our cover letter and past communication, GEMC has remained
consistent in all official communications that "a single standard with
steps in it is the best approach and that this single standard should
address voice encryption (classified/sensitive) as well as trunking since
all of DOD and a good portion of non-DOD Federal customers who buy
trunking require voice encryption, however most do not require classified
(Type 1) encryption. The report references companies A thru E, however
GEMC could not find its official position within any of the above
mentioned companies that were cited.
GEMC's official position still is that there is a desperate need for a
standard for voice encryption and trunking and that once a Government
standard is in effect GEMC will at that time make a business determination
as to what action it will take.
To do otherwise would not be in any business' best interest. Thus, GEMC
must still wonder which other companies can be so committed to making
products for the FS1023 standard when only two manufacturers (GEMC being
one of them) entered the market to produce DES products.
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The author states "the standard contains no technical reciuirements that
will give one manufacturer an unfair competitive advantage over another".
Yet the author goes on to say "the standard would lead to a short term
monopoly by one manufacturer for Land Mobile radios employing Type 1
encryption". GEMC must again ask what is the author's definition of short
term and how the report can use DES purchases which caused. .
."effectively a monopoly to that user" as justification for setting up
another monopoly only this time using a Federal Standard to do it.
This is the reason for a standard and should not be the justification for
another monopoly. The past short term monopoly cost the government
millions of dollars as brought out by the GAO Report (to: The Chairman,
Subcommittee on Civil and Constitutional Rights, Committee on the
Judiciary, House of Representatives) on the cost of the FBI's Radio
System. The governmen.t and the LMR industry truly need an open standard
that all manufacturers can build to.
Additional technical points to consider:
? A Telecommunications standard at 9.6 Kb/s brings both price and
performance advantages in systems design.
? Simulcast at 12 Kb/s is more complex than 9.6 Kb/s thus 25%
degradation in site dispersal capability,compared to 9.6 Kb/s.
(This is a law of Physics.)
? The practical effect of this is' with 9.6 Kb/s rate, simulcast
sites could be spaced up to 25% further apart than with 12 Kb/s
baud rate. This is a greater dollar savings for the end user who
needs simulcast.
? Motorola, GE and others have worked jointly with the National
Public Safety Planning Advisory Committee (NPSPAC) to present to
the FCC the possibility of using 25 KHz bandwidth channels to get
nearly the same level of efficiency as 12.5 KHz channels. The
FCC has concurred with this approach and has issued report
(#87-112) to implement (see attached synopsis). This same
approach would be impossible if the FS1023 12 Kb/s standard is
instituted.
In closing, this report, we find, has little economic analysis or
scientific technical facts to conclude that Draft Standard FS1023 is in
the interest of the government, all manufacturers, end users and
taxpayers.
To create another barrier of entry for other manufacturers by issuing a
standard that no business manager could justify would result in a true
monopoly -- this is not the way to go.
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