If you are responsible for planning, implementing, and/or day-to-day operations for Public Safety networks, this is a busy time for you. Not only must you keep your eye on the day-to-day operation of your own networks, if you have systems that operate below 512 MHz, you have to be concerned about the looming January 2013 narrowband deadline. If you are planning to or are using 700-MHz narrowband channels for a network, you have to be concerned about the FCC possibly authorizing use of broadband services in that portion of the spectrum. You have to be aware that Next Generation 9-1-1 (NG9-1-1) will have multiple implications for you and your systems and, of course, you have one eye on the issue of 700-MHz broadband for Public Safety. On top of all this, your budgets are being cut and perhaps you have had to lay off personnel.
On the 700-MHz broadband front, Congress adjourned before taking any action on the D Block reallocation to Public Safety, the first round of Broadband Technology Opportunities Program (BTOP) grants have been awarded to some of the organizations that were granted waivers to build systems using the existing 10 MHz of Public Safety broadband spectrum, and the FCC is considering the next round of waivers. Meanwhile, several of the network operators that oppose reallocation of the D Block have been walking the halls of the FCC and Congress trying to derail the momentum that appears to be moving in favor of Public Safety thanks to the hard work of the Public Safety Spectrum Trust, the Public Safety Alliance, APCO, and others. It remains to be seen whether anything will happen in Congress during its lame duck session after the elections and perhaps into the next session of Congress, perhaps with a different party in charge of the House and possibly the Senate.
During these next few months, all of us involved with Public Safety need to keep active by reaching out to our members of Congress and if we have a new Representative or Senator after the election, we must make sure they understand our needs and why the D Block is so vitally important to Public Safety. We also need to continue to respond to the FCC’s requests for comments on the use of broadband in the 700-MHz narrowband spectrum and to filings that continue to be made by those who oppose this effort. I, for one, will be responding to all of these over the next few weeks and hope all of you will do the same.
Since the FCC has received no formal direction from Congress about the D Block, it is possible this matter will be put back on the Commissioner’s agenda for one of the upcoming meetings and work will begin on crafting rules for an auction of the D Block. If this happens, we have to be prepared to fight it in every way we can. Meanwhile, we have to be proactive to keep this issue in front of those who have already agreed to help us and to try to persuade those who have not yet agreed that reallocation is the right course of action.
When visiting with Senators’ and Representatives’ staffers over the past six months, the question of funding for the Public Safety broadband network has been raised over and over again, as well as the issue of public/private partnerships. The Rockefeller bill addresses the initial and long-term funding requirements and my answer to the pubic/private partnerships is that we need to know how much spectrum we will have before Public Safety can sit down with those who want to partner with us. If the D Block is auctioned, we will be limited in our ability to work with some of the potential partners, but if the D Block is reallocated, we will be able to work with more partners, and I believe we will also be able to ensure that Public Safety broadband networks are built out in a timely fashion to cover rural America AND to serve people in rural America today who do not have access to broadband services.
Narrowband 700-MHz Spectrum
When T-Mobile submitted its white paper on 700-MHz broadband capacity, it set out to make three points:
- The existing 10 MHz of Public Safety Spectrum is sufficient for Public Safety communications;
- This spectrum could be augmented by use of the 50 MHz of broadband spectrum allocated for Public Safety at 4.9 GHz; and
- That the 700-MHz narrowband spectrum could be repurposed for broadband leaving a few narrowband voice channels for simplex operation and coordination.
In my response I pointed out that if T-Mobile indeed thinks that 10 MHz of broadband spectrum is sufficient for Public Safety, why did it spend so much time in the white paper talking about using both the 4.9-GHz spectrum that is already heavily licensed and heavily used in many areas of the United States, and converting the 700-MHz narrowband spectrum to broadband, which is also already licensed for use in many parts of the United States with many more licenses in the coordination process. I also stated that converting the narrowband spectrum to broadband would set Public Safety voice communications back several decades.
The FCC has now issued public notice DA 10-1877 dated September 28, 2010, asking for comments on the Technical and Operational Feasibility of enabling flexible use of the 700-MHz Public Safety narrowband allocation and guard band for broadband services. Comments are due by December 3, 2010, and reply comments are due by January 7, 2011.
We must respond to this notice and let the FCC know that this is not a good idea for a number of reasons. First, it would mean that the opportunity to provide interoperable voice communications in the 700-MHz band would be lost in areas that chose to use broadband. Second, where narrowband and broadband systems touch each other, the interference to both services would mean that neither system would work. Next there is the issue of finding chipset and device vendors for broadband services in this portion of spectrum. Then, of course, is the fact that this spectrum would NOT provide for nationwide interoperability if some was used for narrowband channels and some for broadband services.
The current FCC seems to believe that broadband is all we need going forward and that it will provide for all of the voice services needed by Public Safety. This is simply not true. First of all, while LTE will provide for multi-casting (one-to-many) at some point, it will not provide enough multi-casting channels to meet the requirements of most major cities that have multiple division-wide and citywide communications channels. Most importantly, LTE will not provide for tactical, simplex, or talk-around capabilities. I will be filing my response to this latest document reiterating what I have said in several previous filings and I will provide additional information that will prove that broadband voice services cannot meet the requirements of the Public Safety community in the near term (5-10 years) and possibly not ever.
It is imperative that Public Safety respond to this Notice before the December 3 deadline because the implications for Public Safety are many. First, if the FCC truly believes this is a workable solution, this provides additional ammunition to auction the D Block. Most importantly, it would strip Public Safety of this first time ever opportunity for access to standard voice channels on a nationwide basis for interoperability on a federal, regional, statewide, and local basis.
I have to wonder who has convinced the FCC that broadband is the only future for the efficient use of spectrum, and how those within the FCC whose job it is to “collaborate with the Public Safety community, industry and other government entities to license, facilitate, restore and recover communications services used by the citizens of the United States, including first responders, before, during and after emergencies by disseminating critical information to the public and by implementing the Commission’s policy initiatives” (according to the FCC website). I guess I don’t understand why the Public Safety and Homeland Security Bureau appears to be siding with commercial interests in these matters instead of working with the Public Safety community to provide, for the first time, both a fully interoperable nationwide broadband system AND a fully interoperable nationwide voice communications network or series of networks. It seems to me that accomplishing this on behalf of Public Safety would be a legacy I would want to have after my time at the FCC ended.
The law of the land, as passed by the FCC, is that as of January 1, 2013, all Land Mobile Radio (LMR) systems operating below 512 MHz must convert from their existing 25-KHz channels to narrowband channels that will be 12.5 KHz, and perhaps later, another step that would reduce the channel bandwidth to 6.25 KHz. Public Safety has known about this requirement for a long time and many other departments have already purchased equipment capable of both wideband and narrowband operation. However, many departments large and small are still operating with equipment that is not capable of narrowband operation and in some cases many of these departments, especially the ones without their own communications professionals, are not even aware that this deadline exists.
Some departments believe that the FCC will extend the deadline but most people I have talked with believe the FCC has given the Land Mobile Radio industry plenty of time to prepare for this transition thus no extensions will be granted. Narrowband and wideband operation are not compatible and If extensions are granted, there will be interference between systems.
One issue that is being hotly contested is that when a system moves from wideband to narrowband, the range of that system is degraded; I have seen as much as a 30% loss in coverage. From my own experience with putting narrowband systems on the air, I can attest to the fact that there is, in fact, a loss in coverage area. We recently added channels to a countywide fire system that already had channels deployed in wideband mode and we used the same sites and same equipment for the new narrowband channels. The result is that we have to add at least two new sites to equal the coverage we had using wideband. I have heard many different explanations for this, both for and against the loss of coverage, but in this case we were able to see and measure the differences.
There are many resources on the Internet to learn more about narrowbanding. One of the best ways to find these resources is to sign onto the Quality Mobile Communications site and click on Narrowband Alerts. Nick Ruark, who owns Quality Mobile, has for many years supported Land Mobile Radio and Public Safety communications with several Yahoo groups, the most popular being the Private Wireless Forum.
National Emergency Number Association (NENA), APCO, and many others are working with the Feds on next-generation 9-1-1. From what I have learned, this is not simply about upgrading current 9-1-1 systems, it includes broadband capabilities, the addition of text and MMS messaging, and added capabilities for Public Safety Answering Points (PSAPs). There is a lot of work being done in this area, and from my perspective, NG9-1-1 and Public Safety broadband systems together will bring the Public Safety community into the 21st century and provide many of the capabilities that have been available to consumer and business mobility customers for a number of years. There are still unresolved issues including how to handle Voice over IP calls, how to make sure that a text message sent for help will actually be delivered and verified, and one of the most important issues, how to keep Internet traffic that will be carrying these new forms of calls for help isolated and away from the NG9-1-1 and broadband network back-ends.
This is a busy time for Public Safety communications. There is a lot of work to be done, but from where I sit, it really looks as though Public Safety, for the first time, can end up with the broadband and narrowband networks it needs on a nationwide and fully interoperable basis, upgraded and better 9-1-1 services, and the tools to not only respond to calls from the public more quickly, but to do so in ways that will be safer for those responding. Information at the scene and about the scene is critical to Public Safety, as is having access to crime-solving tools at a crime scene.
For the first time since I became involved with the Public Safety community in the late 1960s as both a first responder and with Public Safety communications, the Public Safety community has united to finally obtain the tools it needs. The Public Safety Alliance, APCO, NPSTC, IACP, IAFC, NSA, and others are working together on the issues surrounding wireless broadband and communications requirements for all of Public Safety. This has resulted in an awareness of Public Safety needs for many who hold the key to the future of Public Safety communications. There is a lot of hard work ahead in many of these areas, with a common goal to bring to Public Safety communications the same capabilities that are available to anyone with a smartphone. We cannot stop now. If anything, we need to redouble our efforts over the next year to make all of this a reality before we reach the tenth anniversary of 9/11.
Andrew M. Seybold