Comments: NIST Draft Report

Comments on the Draft Report and Recommendations of the Visiting Committee on Advanced Technology of the National Institute of Standards and Technology dated November 27, 2011

This draft report is being circulated and the entire report is below in PDF format. I have written the following document and submitted it to the committee for review.

Note: These comments are being made by Andrew M. Seybold as an individual and do not reflect the views of any Public Safety organization at this point in time.

General Comments

The vision of this report is certainly a vision that is shared by the public safety community: Having complete interoperability on a mission-critical basis nationwide. While this is a worthy goal and one that should be worked toward, this report needs to be viewed in light of a long-term vision and the road to that vision will mostly likely be measured in decades as opposed to years. There will have to be some major and fundamental changes concerning spectrum policy and allocations, there will need to be major advances in both cognitive and software-defined radios, and operational changes. It is not clear from this report that the authors truly understand the complexities of today’s public safety voice and low-speed data systems, nor the implications of adding a single slice of broadband-capable spectrum to these allocations.

Unlike the Internet where bandwidth can be added with routers and additional fiber assets when needed, the wireless spectrum is finite in nature and at present is totally occupied by many different types of communications services. Existing services that now require additional bandwidth cannot simply expand the amount of spectrum they utilize but must rely on other techniques to add capacity, such as adding sites spaced closer together. This is a time-consuming and expensive proposition. In some portions of the United States it can take as much as three years to add a single site because of zoning and permitting issues. The goals stated in this report, therefore, should be considered as goals worth working toward but on a long-term basis and decisions regarding operational considerations and network capacity should be taken completely within the context of wireless spectrum and the constraints placed on capacity growth, which are very different from those within the wired community.

This document is well intentioned but it appears as though the authors are trying to fit the intricacies’ of public safety voice, data, and video communications into a mold that was developed and is known as the Internet, which is based on the Internet Protocol (IP), rather than framing the values of an IP architecture within the constraints of the bandwidths associated with the current spectrum holdings of the public safety community. These spectrum holdings are spread out in multiple small segments of the spectrum from 30 MHz up to 800 MHz, and on narrow voice channels that are often intermingled with other narrowband voice channels for business and industrial radio services. Further, the 700-MHz broadband allocation for public safety at this point in time is only 10 MHz (5X5 MHz). Even when Congress reallocates the D Block to public safety, the new public safety broadband spectrum will only be 20 MHz (10X10 MHz). As noted in the report,[1] during incidents in confined areas this is not enough spectrum in which, today, to operate voice, video, and data.

This report recommends a number of items that are important and some things that are not practical to accomplish during routine but sizeable incidents that occur on a daily basis. For example, the use of deployables, mesh technologies, and replaceable network segments will, indeed, be valuable for incidents such as earthquakes, wild land fires, tornadoes, hurricanes, and other disasters that occur over wide areas and where emergency communications are needed for days, if not weeks. However, none of these capacity increasing capabilities are possible for most local incidents that occur on a daily basis and are of short but intense duration.

Further, unlike the wired Internet, the broadband spectrum currently assigned to public safety using the LTE technology has a spectrum re-use pattern of one-to-one, that is, each site uses all of the broadband spectrum, thus sites can and do cause interference to each other unless they are properly engineered. Even then, adding new sites requires extensive planning in order to minimize this interference and this type of network does not lend itself to ad hoc or mesh typologies that are put up and taken down. Mesh may in fact play an important role in public safety communications over time but must be viewed in the context of the interference it could generate. Using LTE, it is possible to deploy additional devices or nodes and have these nodes cause interference to the existing infrastructure, thereby actually degrading network performance.

The authors refer to the first hour of an incident as the “Golden Hour.” During this time those involved in the incident are busy managing the incident and taking action to prevent it from escalating beyond its current level. They have no interest, time, or ability to manage communications links as part of their tasks. To reiterate a statement made above, the first responders are USERS of communications technologies and do not have the time or the training to make changes to the infrastructure during incidents. The job of those involved with planning, building, and operating these networks is to make sure our first responders have all of the communications capabilities they need, when and where they need them.

The premise that is most important for first responders is that their communications links are invisible to them, they are mission-critical, taken for granted, and designed and implemented by others on their behalf and these links are expected to work wherever the incident is regardless of how many people are on the scene of the incident. Unlike the Internet, which is neither a mission-critical network nor a managed network, these wireless communications networks must be both mission-critical and managed. Management in the case of first responder communications does not mean managing the communications links but rather the traffic across those links. This is normally the purview of the dispatch center but it can also shift to the incident commander or communications emergency van at the scene. It is the job of those who manage the traffic to assign channels of operation that enable each sub-group involved in the response to be able to communicate among themselves and for the system traffic manager to be able to monitor and interact with all of this traffic be it voice, data, or video.

This report seems to expect the first responder community to become conversant in the various forms of communications needed and to be able to ask for what they need when they need it. In the Internet world that this report is based on and that is used as a comparison of the state of public safety communications, those who use the Internet have no involvement with its development or its deployment and do not have the ability to ask for and receive more bandwidth on demand. They are USERS who make use of the Internet to communicate. We must keep in mind that first responders are USERS of the voice and data networks they need and they are not trained communications engineers nor are they communicators. They are users of an infrastructure that has been designed and built to mission-critical standards for them by others who work with the first responder community every day and who are well versed in the needs of this community. Further, when this infrastructure is not available, all of the field devices are capable of one-to-one and one-to-many communications over fairly long distances and deep into buildings. This is not an attribute of either the Internet or commercial broadband networks where connectivity between devices must be managed by the network.

Further, the idea presented in this report that there should be a central “single entity in charge across the entire public safety enterprise” does not exhibit an understanding, as stated elsewhere in the report, that most incidents are local in nature or start as local in nature. Further, this statement does not take into account the fact that those who provide public safety services within a given service area have an understanding and a knowledge of their requirements, which in many cases are unique to their own environs and cannot possibly be transferred to a single entity. Having a nationwide organization to govern the overall network architecture is important going forward, but retaining local control over the day-to-day operations of the public safety community is of paramount importance.

Specific Comments

Observations and Context

1.1  Scope of Public Safety Community

This section states: “At least one commentator observed that achieving public safety is hard because the effort is fragmented across the country. No single entity is in charge across the entire public safety enterprise, and solutions are expensive. Leadership is needed and costs need to be reduced. The classic “name a Czar” solution is not likely to work, either. Frameworks for cooperation that can build on common planning, standards, technology, budgeting and practices seem to be the most productive avenues for progress.”

Are the authors calling for a nationwide public safety force or are they calling for a nationwide body to govern the use of public safety spectrum? It is difficult to tell from this paragraph. If it is the latter they should also be aware that it is the goal of the public safety community to have a nationwide broadband network that is a single license holder, and governance for the nationwide aspects of the network’s deployment and operation. Beyond that the local jurisdictions must have the ability to manage their own portion of the network. A nationwide governance organization cannot know what the local requirements are, what the local coverage requirements are, and how the local jurisdictions are managed.

My view is that it would be almost impossible to place the control and operation of the existing narrowband channels under such an organization. The local, regional, and state public safety agencies have been working diligently to make their voice systems more interoperable and many local jurisdictions are now served by regional and even statewide networks or overlay networks to provide for interoperability. Yet in each case the autonomy of the local jurisdictions remains in place, as it must, now and into the future.

Savings for all can certainly be enjoyed by combining networks and consolidating 911 and dispatch functions, but at the end of the day it is the chief of each service in any given area who is responsible for the actions and day-to-day activities of those who serve beneath him or her. It is the local feet-on-the-street first responders who understand their needs, their terrain, their population, and their problems. Trying to manage them and consolidate them into larger and less autonomous groups is not an option now or in the future. As important as technology is to these departments, local control of their resources is more important. The issues of technology advancements need to take into consideration the politics involved in the public safety community as in every other community. It is necessary to balance technology and achieve cost savings by aggregation of resources with the very real world of resource management and this must be accomplished from the ground up as opposed from the top down if it is to succeed.

1.2  Modern Communications

This section discusses the fact that voice communications is not enough in this day and age and that voice, data, and video are needed. Then it goes on to declare that the world of packet does not care what is being carried inside a packet—in other words, bits are bits. The statement goes on to say that first responders need access to the world-wide-web, which is a true statement. However, the authors do not address the fact that the world-wide-web, which is accessible only via the Internet, relies on a wired network that is neither mission-critical in design nor a managed network. It is a first come, first served network that is subject to not only local but international congestion, and today the Internet is the vehicle being used by hackers and purveyors of malware intended to cripple sites, invade even the most secure of sites, and otherwise wreak havoc with communications. Nor does this statement address the fact that within public safety voice must always have absolute priority during incidents. Data and video are great new enhancements that will assist the public safety community and provide better service for the general public but the first and last line of defense is and most likely will continue to be voice communications.

Even fighter pilots with millions of dollars worth of sophisticated data communications gear, heads-up controls, radar, and other modern day electronics ignore all of this technology when two or more of them are involved in a dog fight. Instead, voice between the pilots is how they communicate, coordinate, and survive a battle. Voice must have absolute priority over all other forms of communications, not only on-network voice but off-network as well. Perhaps in the future IP-based systems will be able to handle all of the requirements of public safety mission-critical voice but the road to the ideal will include a number of smaller steps along the way. It is ambitious and commendable to have an end goal, but voice over broadband for public safety will come in much smaller steps. It will start with non-mission-critical telephone voice and push-to-talk services. It will evolve to include IP bridges between voice over IP and existing P25 and analog networks, and it will continue to evolve over time. The ultimate goal is still in the distant future, not on the horizon.

The following is the last paragraph of this section: “Implicit in these observations is the apparent need for standards that will permit interoperation of communication devices and systems across a broad swath of actors in the public safety landscape. That these standards would benefit from international scope should be apparent, in the interest of facilitating responses to nondomestic emergencies, and taking advantage of larger markets to drive costs down through economies of scale.”

Public safety’s choice of LTE and its FCC-mandated use on the public safety broadband network were made because LTE is based on standards of an international scope. In the realm of existing narrowband voice technologies there are no international standards. Some of the world makes use of a voice technology known as Tetra while in the United States there is a standard for digital voice known as P25, a term used by the authors in other parts of this paper.

It should be noted that LTE as a standard is worldwide and many public safety agencies around the world are seeking spectrum over which to deploy the LTE standard for public safety broadband. It should also be pointed out here that even within the world of commercial LTE deployments, this technology, so far, will be used on more than 41 different portions of the spectrum in both the more common Frequency Division Duplex (FDD) version and the newer Time Division Duplex (TDD) version. Therefore it is doubtful that there will be any LTE devices capable of commercial use on a global basis, let alone within the public safety community. However, several countries including Canada are following the lead of the United States and asking for spectrum within the same band as that which will be used within the United States.

1.3  Resilience, Robustness and Recovery

This section deals primarily with the issues related to major network failures due to such things as loss of power, loss of infrastructure, and lack of operating personnel and recommends the caching of such equipment that is based, again, on standards. The authors are perhaps not aware that today there are already caches of voice-capable radios for the various services across the United States and that they can and are deployed on an as-needed basis, as was mentioned above. However, it takes time to move these caches into position and deploy them. Time is not available for short-duration incidents but these caches are certainly a valuable resource during longer-term incidents due to natural or man-made disasters. Deploying temporary broadband infrastructure when required depends upon many variables, some of which are time consuming. First is the issue of network-inflicted interference if the new infrastructure is not deployed properly and second, there is the issue of the backhaul from the temporary sites. Backhaul for broadband will require between 30 and 50 MHz of capacity from each cell site back to the network core, and this backhaul will need to be low latency connections that, in many cases, rule out the use of satellite services.

Unlike standalone voice communications equipment, the broadband network must be deployed as a network complete with several working databases and other back-end infrastructure. If a new network or network core is deployed to replace one that is out of service, it must either be connected to the nationwide network in order to be populated with the list of approved and authorized devices or such a database must be built in the field at the scene of the incident. This is a long and involved process, yet until it is completed the broadband network is totally unusable in the field. If the Internet were to lose all of its name servers, users would not be able to traverse the Internet without knowing the specific IP address of the device they want to communicate with, and this is also true within an LTE broadband network.

Authors note: During Katrina both the commercial and public safety equipment and service providers quickly shipped equipment and personnel to New Orleans. Within 48 hours of the hurricane most of the wireless communications infrastructure could have been rebuilt, portable radio batteries recharged, and some of the commercial networks placed back into service. However, those in charge of the incident would not permit the equipment or the personnel in attendance to install it into the city because they were not deemed “first responders” and therefore were excluded from the area.[2]

Having deployable caches of equipment is a critical part of public safety communications as long as there is a realization that this equipment will take time to transport and set up. If those trained in its deployment are excluded from the incident it will be of little use to those who need it when they need it.

The last paragraph in this section states: “At least one participant in the public meetings suggested the creation of self-supporting “Regional Resilience Networks” acting as emergency communications utility companies that could be interconnected, possibly through commercial backbones. Such systems in the 25 largest coastal metropolitan areas would cover approximately 100 million of the 330 million U.S. populations. In a related observation, the incorporation of private sector facilities, organizations and resources into national scale planning for public safety could lead to cost sharing and increased coherence.”

It should be noted that this idea was brought forth by “at least one participant in the public meetings” and was not consensus-driven. Using commercial backbones during an emergency has proven time and time again to be an unworkable solution for emergency communications. The public networks and their backbones become overloaded during emergencies, which is one of the reasons cited by public safety as to why it cannot successfully make use of bandwidth on commercial networks. Further, if the Internet is the method of connection, it should be pointed out again that it is not a secure network, it is not a mission-critical network, it is not a managed network, and it has no priority capabilities built into it.

1.4  Security, Authentication and Access Control

I have few comments regarding this section but the authors have previously argued for a nationwide system and here they are saying that, “Again, the need for broadly applicable standards is clear, as are distributed methods for authentication to avoid the potential clumsiness and latency of overly centralized management.” [Emphasis added]

1.5  Cost

This section deals with the costs of equipment for public safety systems. One of the reasons public safety chose to make use of the standard LTE technology was to take advantage of the cost savings because of the volumes of devices that will be built for LTE over the course of the technology’s life. However, it should be noted that the public safety allocation is in the portion of the 700-MHz spectrum known as Band 14, which is not the same as the Verizon allocation (Band 13) or the AT&T allocation (Band 17). The result is that while the basic chipsets are designed to operate across the entire 700-MHz band of spectrum, software, filters, duplexers, and other components are specific to one or two of the bands but not all three.

The ultimate goal of the public safety community is to evolve the LTE broadband network in such a way that it meets most of the goals of the report, but again the operative word here is “evolve.” The first LTE broadband devices are being designed as data modems. Some will support one or two of the commercial portions of the 700-MHz spectrum and some will also include support for both the 1900 MHz and 850-MHz commercial bands for roaming on existing 3G broadband networks. Over time, handheld devices will become available and it is hoped that these will evolve into combination LTE and P25 or narrowband voice units with dual functionality, and perhaps in the future evolve further into devices that will provide both data and voice services over the public safety LTE spectrum. It is certainly the goal of the public safety community to encourage vendors to develop products that move along this evolutionary path.

The comments in this section regarding the adapted and augmented use of commercial off-the-shelf equipment will be address in section 1.6 below.

1.6  Interoperation with Commercially Deployed Systems

Paragraph one of this section discusses the needs for the public safety network to extend beyond the capabilities of the commercial networks and the commercial evolution of LTE. One of these attributes that goes beyond the commercial standards deployed to date has to do with peer-to-peer or off-network (called simplex or tactical communications within the public safety community). If LTE is truly to become the voice, data, and video network of choice for public safety this is one of the critical needs that will have to be solved. Off-network, even when network coverage is available, is one of the most important forms of voice communications used by the public safety community.

There are a number of technical issues that must be overcome before LTE devices can provide this type of communications. Without going into the details, one of the issues concerns the very different transmit power levels between existing narrowband voice systems (5 watts to 100 watts) and LTE devices (typically ¼ of a watt). This difference in transmit power will make it extremely difficult to use LTE devices to provide one-to-one and one-to-many communications over the distances required and within the confines of buildings. In addition, today’s LTE devices are 100% dependent upon the intelligence built into the network with regard to their channel assignment. Finally, there is the issue of how many separate and distinct talk paths are needed during a given incident. Some may require only a handful of separate voice paths and some such as wild land fires may require eighty or more individual talk paths.

The last point made in this section deals with the adaptation of commercial equipment to serve emergency needs for the cost savings if nothing else. This is a good thing to aspire to but consideration has to be given to making the public safety spectrum available on commercial devices. If there are commercial devices in existence that have the capability to make use of the public safety dedicated spectrum, even if that portion of the spectrum is “locked out,” this could give rise to hackers who can and will find a way to unlock the spectrum, access it and, for fun or for malicious purposes, perhaps hack into the public safety network.

1.7  Role of 911 and Other Online Public Safety Systems

This section discusses today’s 911 system and its upgrade to Next Generation 911. There will be synergy between the use of public safety broadband services and NG-911, and the conclusions drawn in this section are worthy of inclusion in the future planning of the entire public safety ecosystem.

1.8  Frequency Allocations

The first paragraph of this section comments on the existing 700-MHz allocations for both broadband and narrowband public safety services. However, the last sentence in paragraph one states, “The use of 700 MHz spectrum for public safety applications is attractive because of its propagation and penetration characteristics.” This is accurate when weighed against the commercial use of 850, 1700, 1900, and 2100-MHz spectrum but is not a true statement when weighed against existing public safety spectrum in the 30, 150, and 450-MHz bands. Replacing existing narrowband voice systems in these three bands will require two to three times the number of radios sites and infrastructure in use today to provide for the same propagation. In reality, the 150-MHz band has become the gold standard for fire communications because of its propagation characteristics.

The balance of this section discusses the use of the public safety licensed 4.9-GHz spectrum as well as the use of the unlicensed 2.4 and 5 GHz or Wi-Fi spectrum. While there is some merit in using the licensed 4.9-GHz spectrum for public safety mission-critical applications, even though it is being used today for point-to-point camera and data services, it would be foolhardy for the public safety community to consider the use of the unlicensed and public 2.4 and 5-GHz Wi-Fi spectrum. This spectrum is already heavily used by many organizations and relying on its availability, especially within commercial buildings or even homes, would have the same result as trying to rely on commercial wide-area networks. Neither band offers any form of priority and the 2.4-GHz band is so heavily used, especially in metropolitan areas, that the range of existing commercial devices has deteriorated over the course of the past few years and indications are that this deterioration will continue.

Television white space, the latest type of unlicensed spectrum to be released for public use, is also discussed in this section. It too should not be considered as an option for any form of public safety mission-critical communications. The portion of the spectrum available for white space use varies from metro area to metro area and therefore defeats the goal of nationwide interoperability. If in order to reclaim additional spectrum in the future the FCC requires TV broadcasters to vacate additional spectrum in the 500 and 600-MHz bands, then availability of TV white space for use by anyone is in doubt. Therefore TV white space should not be considered as a long-term solution for public safety, or the public for that matter.

1.9  The Role of Wired Communication

I agree with this section’s premise that public safety may not have to build out all of the required backhaul but might be able to rely on others for some of it. This is a good concept and one that public safety has embraced. Companies such as AT&T, Verizon, Sprint, Harris, Motorola, and others have existing private broadband networks in place that if previsioned properly could in fact become part of the nationwide public safety broadband network. However, the use of the public Internet by the public safety network for any part of its backhaul requirements should be strictly forbidden.

2.0 Desirable Features of a Public Safety Network Design and System

2.1 Flexible System Architecture

The premise of this section is correct, but I take exception to the authors’ belief that, “One can also imagine the use of packet encapsulation and encryption methods to extend the reach of a secured public safety network across commercial backbones to increase the scope and resilience of the system.” Public safety simply cannot afford to trust the Internet even with the use of packet encapsulation and encryption. The Internet is not a secure network, it is not a managed network, and it has no provisions for priority access or priority traffic routing. Further, it is a worldwide network and millions of users have access to it including those who would bring harm to the United States.

2.1.1 Use of Internet Protocols

This section deals with the Internet and IP and suggests that IP is the solution to all communications issues, thus all public safety traffic should become IP-based so it can be transported in more ways in a more efficient manner.

These statements are all true and correct, but unmentioned is that packets rely on broadband capacity, especially when the packets are carrying video traffic, and that mission-critical voice requires absolute priority all of the time. The vast majority of the public safety narrowband spectrum is in eight different portions of the spectrum. In the spectrum below 512 MHz (for public safety that includes 150, 220, 450, and 470-512 MHz) each voice channel must be converted from a 25-KHz channel to two 12.5-KHz channels by January 1, 2013, and sometime in the future to 6.25-KHz channels. In a world that is enamored with broadband, public safety and other Land Mobile Radio (LMR) customers are being required to reduce the bandwidth of their voice channels. Add to this the fact that these channels are intermingled with channels used by business and industrial LMR systems and you can see that it is not practical, today, to replace these systems with broadband systems. There simply is not enough available spectrum for the public safety community.

The authors clearly show their bias for the Internet and the IP protocol in this section. While it is agreed that IP is the future of communications, there are a number of issues that need to be resolved before public safety can reliably and economically convert its existing narrowband voice systems to IP-based, packet-only systems. As an ultimate goal this is on target, but this paper does not address how a transition from today’s technology to an all-IP system could be accomplished, what the cost of doing so would be, or how the transition could be made in an orderly fashion.

2.1.2 Backward Compatibility

It is unclear exactly what the authors’ point is in this section except to discuss the use of multiple radios within a single device. This type of development is already underway and voice products are available.  Multiple radios in commercial devices are commonplace today. The issue not discussed is how to transition from today’s multi-band environment to an all-IP future vision.

2.1.3 Mesh or Mobile Ad Hoc Networking

This section discusses the use of mesh networks. There is value in making use of mesh networks as extensions of other networks or as standalone networks. Mesh technologies, balanced with the potential of interference, should certainly be part of the long-term vision of the public safety broadband network.

2.1.4 Robustness and Recovery

This section is basically a restatement of section 1.3 and the same comments for that section apply to this one.

2.2 Security and Authentication (entire Section)

A restatement of the issues raised in section 1.4, again the same comments apply to this section.

2.3 Standards Applications and/or Development

I agree with the statements in this section and various organizations within the public safety community have recognized the need for the use of common APIs and the vetting of applications from the development community, both within and outside of the public safety community. However, there is the question of the type of back-end infrastructure that will be employed within the public safety broadband network. If the entire system is based on an IMS core technology then SIP-based applications, including push-to-talk, will be viable on a fully interoperable basis. However, if some of the local or regional networks are deployed without IMS in the core, in order to save money, there will be compatibility issues across the network. SIP-based applications require IMS in the core to function properly.

2.4 Ruggedization

I concur with the comments in this section.

2.5 Sensor and Location Systems

For the most part I concur with this section. However, I question the use of commercial Wi-Fi as a method of in-building location. There is research underway today that could provide a more robust solution than relying on unlicensed spectrum devices for in-building location.

Further, while the use of sensors will be very helpful within the public safety community, care needs to be taken and if these sensors need to “talk to” the network then perhaps an aggregation of sensors within a location with a common connection to the network should be explored.

2.6 High Density Radio Operation

It is well known within the public safety community that incidents usually occur within confined areas and that the number of first responders can place a capacity burden on any communications network in use within this confined area. This is one reason off-network voice communications is so important in public safety. Moving off the network, even when within the range of the network, provides relief for the main network while permitting those on the scene to communicate as needed. In this case, multiple voice paths and/or data paths for peer-to-peer communications will be necessary.

No matter how robust networks are or how much spectrum is available to them, there will remain a need for off-network communications for precisely that reason. As the incident grows in size, the need for additional off-network channels for voice will also grow. Data services should also be able to operate off-network in the same manner. However, congestion must be managed. Congestion on a voice network is managed by the person assigned to the incident as the incident commander; in the case of off-network communications it is handled by the head of the group on that channel. It is unclear how off-network data capacity issues will be handled in the future and they should be taken into consideration during the long-term planning stages.

2.7 Next Generation 911 Emergency Services IP Networks

This section states the fact that both NG-911 and the public safety broadband network are based on broadband technologies and that there are probably some (or many) synergies developing between these two. I agree with these statements.

3.0 Prototyping, Collaboration and Testing

It is the view of the authors in this section that test beds must be employed in order to prove concepts and operational requirements and that the public safety community must be privy to these test beds and be able to provide their input. I concur, though some of the examples cited are from the military, which so far has been unwilling to share its findings and its research with members of the public safety community. I would assert that much of the work done for the benefit of the military has a direct correlation to public safety and that closer cooperation between the two groups would prove to be of great value.

4.0 Multiple Stakeholders

This section of the report acknowledges that there are many different public safety-related stakeholders and this is a correct statement. It goes further to point out that funding cycles are different and that many of the decisions made regarding communications do not take into account the need for interoperability. I would contend that now, more than ever, interoperability provisions are being included in system designs around the nation. Even so, more needs to be done. The key issue here is funding and its availability to provide the basis for more interoperable systems.

5.0 Programmatic Considerations

5.1 Public Safety Network Interoperability Panel (PSIP)

This section recommends that a PSIP be established to promote better public safety interoperability. It does not address the issue that interoperability is made more difficult because existing voice systems are spread out over eight different portions of the spectrum. For example, typically, in California the highway patrol operates in the 30-MHz portion of the spectrum while most fire agencies operate in the 150-MHz spectrum. Fire, police, and EMS are also assigned spectrum in the 450-MHz band, 700-MHz narrowband, and 800-MHz narrowband spectrum.

While a PSIP could probably help solve some of the interoperability issues, public safety has taken its own steps to rectify the situation. The use of 700-MHz narrowband networks as overlays for use by all agencies has been successful where they have been deployed, but again, funding these networks is a major issue. The idea that a panel of experts can solve problems created over thirty years of diverse frequency assignments is not a practical solution to the problem. There are others that are more viable, including additional funding for 700-MHz overlay systems. While these systems are not ideal, they are better than what is in place today.

5.2 Coordinated Research, Development and Testing

I agree that coordinated research and development and testing are required as we move forward. However, not one of the agencies mentioned in this section is qualified or has the knowledge of what the public safety community really needs to be able to perform its tasks. So far these test beds have been long on spending funds and short on accepting input from those who will benefit from the technologies.

In addition, between and among the agencies mentioned there are ongoing turf wars that impede progress and the desire to understand the requirements of the public safety community. One lesson that should have been learned by the Federal Government is that there needs to be input from those being served by these agencies. Instead they seem to be intent on building their own empires and moving forward to obtain funding which, frankly, could be better used by the public safety community.

Further, some of the tasks identified in the report should be the purview of the public safety community and NOT various organizations within the Federal Government. I would like to ask how many of those involved in this research have ridden along with police and fire units on a Friday or Saturday night. Perhaps I should also ask that of the authors of this report. Until those involved have a real understanding of the day-to-day issues that need to be resolved, they cannot, even with all of the testing in the world or all of the money in the world, be successful in developing standards that will provide the type of communications services needed by the public safety community.

The public safety community goes in harm’s way every day. The most dreaded call that can be given to a police officer working a beat is a domestic violence call. Why? If you have never been in the field or talked to those in the trenches you won’t understand why that is the case but it is true. Public safety communications is not about the nation. Yes, we need to be able to move people and equipment anywhere in this nation at a moment’s notice and have the communications systems work. On a daily basis it is about the cop, the firefighter, or the EMS paramedic who needs help and needs it right away. That is who we should be addressing in our plans for this next generation of networks, not a group of theorists who suddenly embrace IP and the wonders of the Internet.

5.3 National Incident Management System (NIMS)

I am in full agreement with the statements made by the authors in this section.

5.4 Training and Evaluation Program

Training must happen on a local level. Yes, there should be input from the nationwide network organization but different levels of training are needed in different areas. One size fits all training will not be sufficient in this case.

Repeating my comment regarding the network and public safety communications in general, the USERS of these communications networks are public safety professionals. Communications is one tool they have at their disposal. They do not need to be, and should not be required to be, experts in communications technology. The most important thing to remember is that the MOST IMPORTANT type of communications begins with the emergency button on the radio. If that button is pushed, the request for help MUST be heard and must be acted upon.

6.0 Conclusions and Recommendations

For this final section of the report my comments are below each of the recommendations.

1. A Public Safety Capability organization should be selected or created to orchestrate the detailed design, development and coordinated operation of a new, national public safety communication system. It should include a Public Safety Interoperability Panel and resource management capability.

A “new” network? Public safety has legacy voice systems that will be in operation for many years. 10 MHz or even 20 MHz of LTE spectrum is not sufficient to provide all of the voice, data, and video services required by public safety.

It would be better to involve the public safety community in the EVOLUTION of its existing systems into the future than to try to design a “new” communications system. It is not possible to build such a network and simply declare that on a certain date everyone will suddenly move over to the new network. Even the Internet evolved over many years into its present form and it is still evolving.

2. The architecture of the new public safety network should:

a. Incorporate commercial technology where appropriate.

Agree at least for the broadband portion of the network.

b. Extend commercial technology to achieve robustness.

Agreed except that traffic on the commercial networks should be relegated to non-mission-critical traffic along the lines of administrative or logistical support of an incident. Mission-critical traffic should never be routed over a commercial network.

c. Provide for backward compatibility or interoperability through standards adoption and/or development where feasible. Including interoperation with existing and new 911 systems.

Within reason, broadband and the Internet and IP is not always the best technology available for voice traffic, at least in the near future. Technologies can be intermingled to provide the best of all worlds for the first responder community, but the most important criteria is that it works every time regardless of where they are.

d. Give high priority to cost-effectiveness and affordability.

Agreed but NOT to the point of short-changing the requirements of the public safety community.

e. Take advantage of Internet and other packet-based technologies to support multi-media communication and mobile ad hoc network formation.

Agreed that IP is the future of SOME communications systems but not all, and with the caveat that NO public safety mission-critical communications ever use the public Internet for transport.

f. Incorporate assigned public safety spectrum and other data communication spectrum assignments and include opportunity for sharing where feasible.

Because the spectrum below 512 MHz assigned to public safety is intermingled with other Land Mobile Radio users this is neither always practical nor achievable. Sharing of public safety spectrum with others is not a good idea. Would the Secret Service be willing or should they share the spectrum they use to coordinate the protection of the President and other Government officials? Public safety needs dedicated spectrum; they never know when the next incident will occur or the magnitude of the incident. Perhaps they should be able to share spectrum in use by others on a non-mission critical basis but they should NEVER be required to share their spectrum even when not in use with others unless public safety has full pre-emptive authority to override non-public safety users.

g. Incorporate strong, federated authentication and other security technology to positively identify and authorize personnel and equipment permitted in the system.

Agreed, this is important for the public safety community.

h. Incorporate advanced position location capabilities, including indoor and underground location.

Agreed but NOT by making use of unlicensed consumer-grade Wi-Fi or other types of networks.


I attended and participated in the session conducted by the authors of this report in Philadelphia in August of 2011. It was obvious to me and others who attended that those leading the session were Internet and IP-centric and were not conversant in the intricacies of public safety communications. During this session we tried to convey the points that there are differences in spectrum assignments, that mission-critical voice is a necessity, and that off-network or peer-to-peer and peer-to-many peer communications is vital within the public safety community.

This report is a reflection that we failed to convince the authors that:

  1. Public safety had already embraced a commercial technology in the form of LTE.
  2. That network capacity is and will remain an issue.
  3. That mission-critical communications requires a different set of criteria than the Internet, which is not a mission-critical network.
  4. That IP is the future for all broadband communications, but narrowband communications is and will remain needed for a long time.
  5. That the public safety community is willing to adopt new technologies and move into the 22nd century but cannot sacrifice the attributes that are critical to its success and safety.
  6. That a grounded understanding of the requirements of public safety is vital to the success of any new technology deployment.

It is difficult for those who created the Internet and grew up with its influence to understand that there are several types of communications with needs that cannot be met simply by embracing the premise that the Internet and IP-based packet systems can solve everyone’s needs all of the time.

I would like to recommend to the authors of this report that if they are to change the way public safety communications are implemented today for the better, that they immerse themselves in the day-to-day operations of the first responder community. They should ride along with a metro police agency on multiple Friday and Saturday nights. They should also ride along with a fire unit responding to countless EMS and fire calls, and with paramedics who are often rerouted from one incident to another deemed more life threatening.

It is not possible to understand the unique and complex nature of public safety communications in any other way. You cannot simply host a number of meetings nor can you simply listen to a few first responders. You have to live it in real time. You will come to understand that in many instances the radios first responders wear on their belts are their only lifeline to safety.

I have provided my comments and narratives in the hopes of assisting the authors in moving forward. Public safety communications is not about P25, it is not about IP or the Internet, and it is not about today versus tomorrow. It is about a lifeline between those who go in harm’s way every day and those who can ensure they remain safe and who support them in their efforts.

Andrew M. Seybold

Link to Draft Report and Recommendations of the Visiting Committee on Advanced Technology of the National Institute of Standards and Technology dated November 27, 2011

[1] Broadband congestion

[2] APCO Magazine Article by Andrew Seybold



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