My Most Recent FCC Filing

Today I filed comments on the FCC’s Third Report and Order and Fourth Further Notice of Proposed Rulemaking (FNPRM) that was published on January 25, 2011, and on which public comments are due by April 11 and reply comments by May 10. The FCC’s document is based on its belief that strong rules (and lots of them) are needed to ensure that the Public Safety 700-MHz nationwide broadband network be built as a fully interoperable network everywhere.

However, it is my contention, and that of many others, that while the FCC does need to impose some rules that will help ensure nationwide interoperability, many of the items in the FNPRM should remain the purview of the various standards bodies that are working on the LTE and subsequent air-interface standards and that many other items should be determined by a Nationwide Network Governance Entity (NNGE). This body should be formed and funded, and include members of the Public Safety community, representatives of several federal governmental organizations, and perhaps some of the entities that have already received waivers to build out their own LTE networks on the now-licensed 10 MHz of broadband spectrum.

Further, this organization should be empowered to hire professionals in network system design, construction, and operation, individuals with a business and financial background, and perhaps sub-contractors that would be directed by the NNGE in the build-out and operation of the network. It should also be empowered to enter into agreements with commercial vendors as well as commercial network operators and others interested in forming public/private partnerships with the Public Safety community.

The other point I made in this filing is that until the issue of the reallocation of the D Block is finalized by Congress, some of the proposed rules (such as out-of-band emissions) should not be finalized. Once action has been taken by Congress, hopefully resulting in a bill being sent to the President for his signature, the FCC should not move forward with these specific rules.

The entire filing is fairly consistent with others I have seen and helped prepare over the past few weeks and it appears as though the Public Safety community, once again, is unified in the determination that the FCC is acting prematurely, and that many of the items listed in this FNPRM should be held until after both the formation of the NNGE and the outcome of the proposed D Block reallocation.

I then delved into exactly what the FCC should and should not incorporate into its rulemaking if it decides to move ahead with rulemaking, and I followed that up with a paragraph-by-paragraph listing of the FNPRM and my recommendations as which organization—FCC, NNGE, and/or standards bodies— should be responsible for each paragraph’s topic.

This entire filing is attached to this issue of the Public Safety Advocate and is available on the FCC’s website. I also expect to be filing reply comments, which are due by May 10, 2011—unless there is a government shutdown, in which case the deadline will be extended.

Andrew M. Seybold



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