Chair – Tom McDonald, cfm vice Chair – Garrett Skinner, cfm sectretary
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Georgia Association of Floodplain Management 7 Martin Luther King, Jr. Drive, Room 440, Atlanta, GA 30334 Chair – Tom McDonald, CFM Vice Chair – Garrett Skinner, CFM Sectretary – Verna Yin, CFM Treasurer – Chris Budd, CFM June 28, 2010 Marlene H. Dortch Office of the Secretary Federal Communications Commission 4545 12th Street, SW Washington, D.C. 20554 RE: ET Docket No. 10-123 Dear Ms. Dortch: On behalf of the 250+ member Georgia Association of Floodplain Management (GAFM), I am writing to express GAFM’s opposition to reallocation of the 1675 to 1710 MHz frequencies, which are utilized by the NOAA Geostationary Operational Environmental Satellites Data Collection System (GOES DCS). The GOES DCS serves as the primary conduit for meteorological, hydrological, and seismic data collected by the federal government and others. Of extreme importance is the USGS real-time streamgage data. The USGS receives environmental data (streamflow, river stage, water quality, groundwater and weather data such as precipitation) from over 11,400 stations nationwide through the GOES DCS. This downlink carries critical environmental data used for the protection of life and property across not only the United States, but much of the Western Hemisphere. Many Federal, State, and local organizations, as well as the general public, use this real-time data for analysis, research, predictions, flood and storm advisories and warnings, and even outdoor recreation. The National Weather Service uses USGS streamgage information to make flood forecasts, advisories, and flood warnings for the Nation. The US Army Corp of Engineers and the Bureau of Reclamation use the information to manage water releases during rainfall events and for hydropower generation. State and local agencies use these data for the regulation, permitting, and allocation of water resources across the Nation. GAFM is concerned that sharing of this bandwidth (one of the two alternatives proposed) could slow down or disrupt transmission of critically important stream flow information. The Internet and other ground-based distribution services are subject to disruption during floods and thus cannot be considered “functionally equivalent substitutes” for the use of these frequencies. Let’s not forget that during Hurricane Katrina internet service was lost for an extended period of time over most of the gulf coast states. During a time when emergency responders, water managers, and forecasters most needed USGS data, it would not have been available if the proposed system of sharing the frequency band was in place. USGS stream gauges have repeatedly been threatened with discontinuation due to insufficient funding and I, on behalf of GAFM, have previously sent letters to both the House and Senate in December of 2009 on this issue. Moving the USGS off of this spectrum band (the second of the two alternatives proposed) could lead to additional costs in having to rely on a private vendor (and/or the internet) for critical data and possible costs to replace or modify individual stations to receive USGS data from a private vendor (and/or the internet). The cost to USGS and its streamgage funding partners is estimated at greater than 60 million dollars in new transmitters (all 11,400 data collections platforms (DCP’s) radios would have to be replaced and reprogrammed) to include salaries for technicians to replace, reprogram and adjust the station equipment. This would divert unnecessary resources away from an already cash-strapped system operations program and would potentially result in a reduction in the availability of real-time stream flow information. Additionally some form of new back-up system, more than likely created and provided by a private vendor, would have to be implemented, since the existing back-up system for GOES DCS data at EROS Data Center in Sioux Falls, SD would be rendered useless. I highly doubt that the cost of developing a new back-up system, estimated to cost several million dollars, will be borne by the private market. That additional cost will be passed along to the users – specifically, the users of the GOES DCS data. The GOES DCS is also used by the National Weather Service to distribute warnings and other information. Any loss or degradation to this system would thus impact local emergency management and public warning systems during hazard events, when timely information is most needed and, therefore, will be potentially compromising public health and welfare and overall life safety. The proposed reallocation of the GOES DCS frequency would result in increased vulnerability and/or increased cost for the transmission of data that are critically important for flood forecasting and hazard warning. This is information that is not only useful, it is information that people need, real-time, during critical times in their lives! Any reduction in this vital information has the potential to cost lives and result in increased flood damages. We respectfully request that the 1675-1710 MHz frequencies remain in the public domain and be preserved for the transmission of critical environmental data. Sincerely, Terri L Turner, AICP, CFM GAFM Immediate Past Chair for
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