Connect Public Safety Now Is NOT Your Friend

Recently, the Coalition for 4G, made up of T-Mobile, Sprint-Nextel, The Rural Cellular Association, and other companies opposed to the reallocation of the 700-MHz D Block to Public Safety renamed itself. It is now known as “Connect Public Safety Now” (CPSN). In spite of the name change, this organization remains opposed to reallocating the D Block to Public Safety. Since Connect Public Safety Now believes that commercial broadband is more important than a Public Safety nationwide broadband network, I have taken to calling it “Connect Public Safety—NOT!”

Many members of this renamed organization are late to the party and are trying to catch up. They either did not show up during the original 700-MHz auctions or did not bid enough to win any 700-MHz spectrum. Now they have decided that it is in the best interests of the nation to withhold spectrum for Public Safety in favor of building a nationwide broadband network to compete with AT&T, Verizon, and other commercial network operators who understood the value of the 700-MHz spectrum and won spectrum during the auction.

I believe the Coalition for 4G renamed itself because it is losing its battle in Congress and the Executive Branch for another D Block auction and decided to “pretend” it has Public Safety’s best interests at heart. In reality, they have only their own perceived interests in mind. I think those who understand that not having enough spectrum available for Public Safety will impact their own safety should boycott these companies, but no one has that much influence. Instead, I might suggest to all Public Safety and governmental agencies that have contracts with these network operators consider cancelling them and making sure sales people for these companies understand why the contracts are being cancelled. When you hurt the sales people on the street, it doesn’t take long for word to reach the brass.

Then there was the embarrassing press conference held by CPSN on December 13 at the Press Club in Washington, DC. Credentialed hired guns stood up and made bold statements about CPSN having the best interests of Public Safety at heart. They all seem to have a history of working with Public Safety but they are now more interested in their own paychecks. Joe Hanna, a past president of APCO, went to work as a consultant for T-Mobile some time ago. He did not make an appearance at the event but he was still quoted in a few of the press releases. Mr. Witt of Witt Associates is one of CPSN’s hired guns, as is Dennis Roberson, who has been employed by T-Mobile for some time now. Roberson has an impressive resume and was CTO of Motorola, but in the chip division, long before broadband was even a blip on the horizon. Steve Berry, President and CEO of the Rural Communications Association, is actually doing his organization a disservice by being involved with CPSN. Should the D Block be reallocated to Public Safety (to the dismay of the CPSN), the RCA could work with Public Safety to build out rural America for both public and private broadband. John Kneuer, former head of the NTIA, is also a consultant for T-Mobile.  All of these people with their wonderful pedigrees are being paid by companies and organizations that missed their first shot at this spectrum and want another shot at it, Public Safety be damned!

None of these consultants and experts know as much about broadband and LTE as those who have been actively working with the Public Safety community for the past two years. They do not understand Public Safety’s broadband requirements, and as far as I can tell, none of them understand that priority access on commercial networks is only viable when a unit requesting priority can actually register on the network. If it can’t register on the network, for whatever reason, it can’t request priority access on the network.

Instead, these people readily accepted the information CPSN and T-Mobile provided: Priority access will provide access to commercial networks during times of Public Safety’s need for more spectrum. Other network operators that have pledged to work with Public Safety building private/public partnerships have stated publically that it is not in the best interest of their customers or stockholders to support Public Safety priority access on their networks. I don’t believe any of the experts investigated the number of incidents that occur multiple times per day that involve 50-150 Public Safety personnel in a confined area, all of whom need access to data including video, floor plans, mug shots, and other information. This access will not be possible unless the D Block is reallocated.

There have been many comments about doing the right thing for Public Safety (finally) and providing the spectrum it needs to function on a day-to-day basis and in major emergencies. Companies such as AT&T and Verizon support Public Safety’s efforts and are offering to enter into public/private partnerships in a variety of ways. However, CPSN wants the D Block for its own commercial use and says it will work with Public Safety, but that is not the same thing as entering into an agreement with the Public Safety community.

As outlined by the FCC in its National Broadband Report it presented to Congress in March of last year, the D Block auction would carry no such requirements for a public/private partnership and no requirement for priority access. Winners could gain access to the spectrum and then tell Public Safety that they won’t be offering priority access to them. Public Safety needs all 20 MHz of spectrum in the major metro areas on a daily basis. In other areas, it is the intention of the Public Safety community to work with partners to share the network when Public Safety demand is lower. HOWEVER, the primary difference in the two proposals is that with the D Block reallocated to Public Safety, Public Safety would control the network and the public partners would be the secondary users.

The major issue in this debate is that those from the CPSN side are not well versed in technology, or for that matter the limitations of LTE (every technology has limitations). They only know they want the spectrum and have seized on the idea of priority access without taking time to fully understand how it might work. (Priority access has not been implemented in any LTE network and is, at this point, only an element of the LTE specifications that might be implemented at some point.)

I have to wonder if CPSN or those it has won over in our government will accept any of the blame or responsibility when the Public Safety network is built within 10 MHz and it is proven once and for all that this is not sufficient bandwidth and capacity for day-to-day situations, let alone for major emergencies. I believe it is self-serving for CPSN to push auctioning the D Block, especially before the entities that have received waivers from the FCC to build out their systems have them in place. Only then will we have real-world numbers, and I am convinced that they will prove beyond a doubt that 10 MHz of spectrum is not sufficient for Public Safety.

This discovery will result in the FCC having to scramble to “find” more spectrum for Public Safety, and it will mean more years of the same problems we could have solved today. Once “new” spectrum has been identified and reallocated, a second broadband network will have to be built to meet Public Safety’s needs and all of the equipment in the field will have to be replaced with new equipment capable of operating on both bands. The result will not be higher data rates, but rather two separate networks that will increase capacity but not capabilities for the people in the field who are dedicated to saving lives and property. Perhaps as a condition of a D Block auction, winning bidders should be required to agree to fund a second Public Safety network when it is proven it is needed, and to replace all of the existing Public Safety devices.

So CPSN, if you are really on the side of Public Safety, why not enter into the following contract with the Public Safety community?

  • All D Block spectrum winners will provide complete and pre-emptive priority access to Public Safety whenever Public Safety requests it.
    • Need will be determined by Public Safety; not by the D Block winner
  • All D Block sites will be hardened to Public Safety standards
  • All D Block sites will have back-up electric service
  • When Public Safety roams on the D Block network, it will be charged the lowest rate for service that any of your customers pay (including large corporate customers)
  • You will provide emergency maintenance service to each and every one of your sites within a maximum of two hours after a problem is reported

I am sure CPSN will not agree to any of these conditions; it would not be in the best interests of its customers or their stockholders. But that is the level of assurance Public Safety needs to know it will have access when it is needed.

It all boils down to this: Will those within our government who have to decide about the D Block listen to a well oiled, well financed organization that wants the spectrum for its own commercial use, or will they listen to the Public Safety community that is unified in its effort to finally, after more than thirty years of begging and pleading, be given the spectrum resources it needs to solve interoperability issues that were evident during 9/11, Katrina, and other major emergencies, and on a day-to-day basis.

This is a one-time opportunity to get it right and I trust that those who hold the fate of the D Block in their hands will see through the rebranding of the “Coalition for 4G” to “Connect Public Safety Now” and be smart enough to know that CPSN really means CONNECT PUBLIC SAFETY—NOT!

Andrew M. Seybold

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