A Busy Few Weeks

During the past few weeks, I have been spending a lot of time on the issue of Public Safety Broadband and the D Block reallocation. There are some very positive signs that the Executive Branch might now support this effort, and we are expecting to see the bills already introduced in Congress to be debated and perhaps acted upon after Congress returns on September 13, 2010.

Many of you are aware that I write for a number of publications, most of which are industry related, but you may not be aware that in recent months I have returned to Forbes as a contributor to its Intelligent Investor section at Forbes.com. This past week I wrote an article about Public Safety for Forbes and it was posted on the site a few days ago. This article, as with all Forbes articles, is slanted for the investment community. If you have not seen it, click on the highlighted link and you will see how I was able to work in a request for readers to show their support of the reallocation of the D Block to Public Safety by writing to their Representatives and Senators.

A week before, I received a copy of the most recent T-Mobile filing with the FCC in the form of a white paper that was supposed to refute comments about the FCC’s own white paper on capacity. I said “supposed to” because as I was writing my rebuttal (PDF below) and discussing the points in the T-Mobile paper with others, it became clear that this paper actually supports the reallocation of the D Block for Public Safety. How is that possible?

While they did set out to prove that 10 MHz of broadband spectrum is sufficient for Public Safety’s “immediate use,” they spent more time discussing how the PSBL 10 MHz of spectrum could be augmented with the already heavily used 4.9-GHz spectrum AND how the 700-MHz narrowband channels could be repurposed for broadband use, leaving only 40 narrowband channels for Public Safety “when out of the LTE footprint.”

In my cover letter to the FCC, I summed up my findings this way: “It is for these reasons and more I will demonstrate in the following response that the T-Mobile USA white paper actually supports the full allocation of the D Block to Public Safety. The bottom line is that the Public Safety community needs more contiguous spectrum, and the D Block is that spectrum”.

And in my conclusion section, I summarized my findings as follows:

Having reviewed and commented now on both the FCC’s own white paper on capacity requirements for Public Safety and this recent T-Mobile paper, I am more convinced than ever that those trying so hard to make what they believe and hope will be the right decisions are doing so without fully understanding the needs of the Public Safety community or realizing that for the past few years, criminals, as well as citizens and teenagers they protect and serve, have better communications capabilities than the first responder community.

In fact, this may be one of the key issues. Because everyone has the technology available, they take it for granted that Public Safety can use the same technology across the same networks. The reality is quite different. Public Safety communications must work when all else fails, it must be available in a split second, and it must be rock solid. There can be no dropped calls, no Blocked video connections, and no having to change location to be able to communicate. They need the capabilities now, regardless of where they are.

I am more convinced than ever that the way to provide Public Safety with the communications tools it needs is to reallocate the D Block and combine it with the PSBL spectrum. This would leave the 700-MHz narrowband voice channels in place and provide in a single portion of the spectrum what Public Safety has never had—interoperable voice and data communications across every city, town, and rural area in America, implemented in such a way that these interoperable communications channels are built to its standards and available for everyone who needs them from local through federal jurisdictions.

As an added benefit of reallocating the D Block to Public Safety and keeping the 700-MHz narrowband channels available, I strongly believe that in areas where Public Safety does not require the full, day-to-day usage of the entire 20 MHz of spectrum (rural America), that in conjunction with rural power companies, railroads, educational institutions, medical providers, and others, this network can serve not only Public Safety, but all of these organizations PLUS homes and businesses in rural America that have no access to broadband services today. And I believe this can be accomplished in a shorter period of time and with fewer federal dollars than any other solution being investigated by the federal government today.

Congress and the FCC have an opportunity to get this right. If they do not take full advantage now, the opportunity will be gone forever and during the next bridge collapse, Katrina, earthquake, or whatever we have to face, Public Safety will still not have the tools to communicate effectively between agencies and departments using both voice and data services. They also need these same tools on a day-to-day basis—a lost bag in Times Square could be just that, or it could be a dirty bomb. Those responsible for protecting us are entitled to the highest level of communications available. Reallocating the D Block and leaving the 700-MHz narrowband channels in place will provide Public Safety with the communications links it needs and deserves.”

Meanwhile, the Public Safety Spectrum Trust, Public Safety Alliance, APCO, and others have been working tirelessly for this cause. There have been some recent meetings with the Executive Branch in DC this past month and another will be held later this month. The feedback I am receiving is that these meetings have been fruitful and have enabled those involved directly with Public Safety to provide input to those in the Executive Branch as well as to the commercial operators.

September is an important month for the D Block reallocation. If all goes well, this matter could be resolved this month in favor of Public Safety. If not, it at least appears that Congress will make it clear to the FCC that it should not consider putting the D Block up for auction in 2011 until those in Congress who are looking into how the D Block should be allocated come to their conclusions.

If you have not yet reached out to your Representatives and Senators, this is the time to do so, and if you have, a second letter or email is in order. The more they hear from all of us who know that reallocating the D Block to Public Safety is the right thing to do, the better the chances of success.

One other point to keep in mind is that broadband in Rural America is a hot topic in Congress right now and with the D Block reallocation to Public Safety, there is a way to help rural America become wirelessly connected to the Internet with high-speed data capabilities. I will have more to say on this point, but when writing to your Representatives and Senators, it would be helpful to include a statement about the D Block reallocation also helping to solve rural broadband coverage issues faster and at less cost than anything proposed to date. Stand by for more on this subject.

Help make September a great month for Public Safety—Make your voice heard!

Andrew M. Seybold

T-Mobile White Paper Response 09-10-10


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