700-MHz Narrowband/Broadband Sharing–My Comments

The FCC has asked for comments and listed a series of questions regarding the feasability of sharing the exisitng 700 MHz Narrowband Public Safety Spectrum by permitting some agencies to use some of the spectrum for boardband systems. I contend that this should not even be consdiered since it will great interference between the two servcies and prevent the 700 MHz narrowband spectrum from providing nationwide voice interoperability. Below is the letter I submitted to the FCC followed by the PDF file of the rest of the filing.

Andy Seybold

November 29, 2010


Electronic Filing

Ms. Marlene H. Dortch
Federal Communications Commission
445 12th Street, SW, Room TW-A325
Washington, D.C. 20554

Re: DA-10-1877A Filed under PS Docket No. 06-229

Dear Ms. Dortch:

Below please find my comments on DA 10-1877, Public Safety and Homeland Security Bureau Seeks Comment on the Technical and Operational Feasibility of enabling flexible use of the 700 MHz Public Safety Narrowband allocation and guard band for broadband services. These comments are to be filed under PS Docket No. 06-229.

The comments I have filed below will answer all 22 questions put forth by the PSHSB in this Public Notice. I have been directly and indirectly involved with public safety communications use, systems design, and implementations since the early 1970s, and have helped develop public safety systems on the East Coast, in the Mid-West, and on the West Coast. Since the 1980s, I have published numerous articles about the issue of public safety voice and data interoperability, and have been active for the past two years commenting on the PSHSB’s premise that the 10 MHz of spectrum already allocated to public safety for a nationwide fully interoperable broadband network provides public safety with enough spectrum to meet day-to-day needs and that during major emergencies public safety will be able to share broadband spectrum with the existing commercial broadband networks on a priority basis.

In many of my previous filings I have disputed this assumption by the PSHSB and proven conclusively that 10 MHz of broadband spectrum will not be sufficient to meet public safety’s requirements on a daily basis. Most recently, I commented on the release of the FCC white paper entitled Mobile Broadband: The benefits of Additional Spectrum, which pointed out the explosive growth of broadband service demand over the past two years and the predicted increasing demand for these services moving forward. This same type of demand for broadband services will also occur in the public safety sector, and as such, this paper reinforces my position that 10 MHz of broadband spectrum will not be sufficient for the public safety community to provide for day-to-day operational requirements.

T-Mobile, in its most recent filing, also confirmed this by concentrating on other portions of the spectrum over which public safety could use broadband services. One of these was the proposal for sharing the existing narrowband spectrum, permitting a mixture of both broadband and narrowband services.

Now the PSHSB has asked for comments on this type of broadband sharing, which suggests to me that the PSHSB does not, in fact, believe that the currently allocated 10 MHz of broadband spectrum is sufficient to meet the day-to-day requirements of local, county, state, and federal, first responders.

In general, my comments focus on the following facts:

1) Neither LTE nor any broadband technology is capable of providing all of the various types of voice services required by public safety.

2) The 3GPP standards body, which oversees the standards for LTE, does not have any agenda item for the next three releases of LTE that would provide the types of one-to-many voice and off-network voice communications that are of vital importance to public safety.

3) Mixing broadband and narrowband voice in the same portion of the spectrum detracts from interoperability for either broadband data or voice services.

4) Mixing the two vastly different types of technology on a shared basis in the narrowband spectrum will cause interference to both narrowband and broadband services where they overlap and will, in essence, be detrimental to both types of services.

5) The goal of the PSHSB should be to provide public safety with a roadmap for BOTH nationwide interoperable voice and data services. To that end, the narrowband spectrum must be reserved for narrowband voice services and the broadband portion of the public safety spectrum reserved for fully interoperable broadband services.

6) Mixing broadband and narrowband systems on the narrowband portion of the spectrum will set public safety interoperable communications back several decades instead of providing a clear migration path for both voice and data services.

7) Providing public safety with sufficient spectrum to enable the development of both a nationwide broadband network (which requires the full 20 MHz of spectrum) and with the ability to migrate voice systems to a common set of narrowband channels that include channels set aside for interoperability with all of the agencies that will be involved during major emergencies is the right approach to solving public safety interoperability issues and is the fiscally responsible thing to do.

Respectfully submitted,

Andrew M. Seybold
CEO and Principal Consultant

Jennifer Manna, Jennifer.manna@fcc.gov
David Furth, david.furth@fcc.gov



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