OHSAS 18001 standard, element 4.4.3.2, Participation and consultation, requires a company to establish, implement and maintain procedures for the participation of workers in the occupational health and safety (OH&S) program by their involvement in haza…

I am opposed to the privatization of the radio spectrum for I see, in the end, little distinction between the eventual birth of a private FCC (equivalent) and the current government run FCC. I prefer the government run FCC since, in theory, it is acting on behalf of the citizens of the United States. Also, I believe that the FCC may be getting excessively bad press and that positive aspects are conveniently overlooked. For example, the FCC, in terms of the Amateur Bands, has delegated band planning and band operating responsibilities to the users. Since the focus of my reply is meant for topic #2, I will cut this one short.

In terms of topic #2, the statement is made that the way “by which spectrum is doled out to, and used, by public safety agencies is broken.” I believe incorrectly mixes access to the radio spectrum with how agencies actually use the spectrum. The two concepts are separate. The claim is made that when public agencies build there own infrastructure that this is inefficient and that they fail to properly coordinate. Those are organizational issues that require that these agencies get their act together, it does not justify the expropriation of government owned spectrum for the benefit of a private entity. This is simply the reverse eminent domain (see Kelo v. City of New London, 125 S. Ct. 2655 (2005)).

The statement is made that “Nextel founder Morgan O’Brian’s new venture, Cyren Call, recently filed a petition with FCC that proposes creating a nationwide, completely interoperable wireless network that could be used by public safety users.” I agree, let him try and make him compete, in a free market, for his proposed service; but do not expropriate the existing public service bands. If his approach works, the public agencies will abandon the frequencies and the FCC can lease the abandoned frequencies to others.

The statement is made that “Agencies only pay an access fee and a monthly fee for each handset used — a lot like a cell phone.”. This could be a good thing or it could be a bad thing, depends on your perspective. Renting makes sense if you only intend to use a piece of property (radio equipment) for a limited period of time and your net outlay is less than the cost of that property. Owning makes sense if you intend to hold that piece or property for a long period of time. Owning may be the cheaper alternative for government agencies. Additionally, private companies seek to make a profit, which is an added expense to the taxpayer. If, Mr. O’Brien’s can truly offer a cheaper service let him compete, in the free market, to freely convince the public agencies to switch to his service.

Also I would like to add, that most radio equipment bought by government agencies is already purchased from private companies which helps the economy and where access to the spectrum is, as far as I know is free for public agencies. Now private industry not only seeks continued revenue from the sale of equipment but also from access to the spectrum. Sounds like a form to taxation. In conclusion, radio spectrum that belongs to the government agencies cannot be expropriated to “tax” them as a subsidy to benefit a private company.