Our new President and Vice-President will be sworn in on January 20, hopefully without incident. Then the real work will begin as the public-safety community looks forward to a Federal Communications Commission (FCC) under new management which, we hope, will be more inclined to consider everyone who wants and needs access to wireless spectrum including critical-communications users and rural and economically-challenged people who do not have access to broadband services. Again, my hope is that the FCC will add public-safety communications experts to the Public Safety and Homeland Security Bureau (PSHSB) and establish a critical-communications advisory committee for guidance.
This week’s topics include the belief by many that broadband systems are the only route to future communications. If this is true, why did the last FCC take away 71-percent of the broadband spectrum licensed to the public-safety community? Then there is the issue of the riots in DC earlier this month and many participating in these illegal activities using broadband voice-messaging systems to coordinate their activities.
Apple’s iPhone, introduced on the AT&T network June 29, 2007, was the first product to take full advantage of broadband wireless spectrum. Three million units were sold by the end of 2007 and by the end of 2009, the AT&T network became overloaded in major cities such as New York and San Francisco, resulting in slow data rates on the network. It took much too long to download content and high user demand for data services jammed the networks. AT&T beefed up its network and the FCC responded by auctioning new spectrum for future broadband expansion.
Between 1994 and 2019, the FCC held spectrum auctions for a variety of different types of wireless communications systems to provide additional broadband spectrum for commercial broadband operators. Today, commercial networks have amassed a large amount of spectrum and are seeking more for their 5G roll-outs.
Meanwhile, in 2002, the FCC added 50 MHz of what was then very limited, low-range broadband spectrum known as 4.9-GHz spectrum for the public-safety community. For several reasons, 4.9 GHz was slow to be developed. First, vendors did not build WiFi-type radios for this band until a full year after it was allocated to public safety. Next, the FCC originally required public-safety licensees to apply for licenses not based on the number and location of radios, which is the norm for public-safety systems, but rather for geographic areas. Later, the FCC declared that if this spectrum was to be used for point-to-point wireless links, requests for licenses must be for specific locations indicating typical longitude, latitude, and elevation, which has been required for all public-safety systems for many years. Many within the public- safety community missed this change in licensing requirements so the total number of true end-points is unknown.
The next broadband spectrum allocation, 20 MHz of 700-MHz spectrum, was awarded to FirstNet on behalf of the public-safety community. However, this entire allocation was not forthcoming directly from the FCC. The FCC licensed 10 MHz of the spectrum to the Public Safety Spectrum Trust (PSST), but the second 10-MHz allocation had to go through Congress and be passed into law (the FCC did not believe this additional spectrum was warranted). FirstNet was created in February of 2012, ten years after the first broadband spectrum allocation to public safety.
Since the 4.9-GHz spectrum and 20 MHz of 700-MHz spectrum was allocated to FirstNet, the public-safety community has had only two dedicated broadband spectrum segments available to it on an exclusive basis. As of early 2020, the total exclusive-use broadband spectrum amounted to 70 MHz: 20 MHz in the 700-MHz band usable as longer-range broadband spectrum and 50 MHz of WiFi-type spectrum usable for short-range communications. Then in 2020, the FCC swooped in and decided the public-safety community no longer needed the 50 MHz of spectrum in the 4.9-GHz band and started the process to re-allocate this spectrum to each state. This ruling permits each state to issue a master lease for the spectrum and collect revenue from the lease. The leaseholder will be able to use the spectrum any way it decides will provide the best return on investment.
In this move, the FCC took back 71-percent of the broadband spectrum that had been allocated for public safety leaving it with excusive use of only 29-percent of the spectrum it held as of January 1, 2020. The FCC’s decision to take back this much spectrum is, at best, short-sighted considering the FCC itself states the future of spectrum use will be for broadband systems.
Public Safety Needs this Broadband Spectrum
In September of 2011 while the public-safety community was working to convince the U.S. Congress, the FCC, and the Executive Branch of the U.S. Government that it needed 20 MHz of 700-MHz spectrum for its fully-interoperable nationwide broadband network, a report known as the “Cornerstone LTE Network Testing Report” was filed with the FCC. This report was based on real-world capacity testing of video and data services using 10 MHz of spectrum in the 700-MHz band. These tests demonstrated that the way commercial broadband network capacity is tested and how public-safety networks should be tested is vastly different.
In an effort to prove public safety did not need the full 20 MHz of 700-MHz spectrum it was asking for, the FCC used a model taken from the 3GPP standards committee for calculating network capacity that called for a total of 19 cells sites, each with 3 sectors, for a total of 51 cell sectors. A standard interference number was used across the 51 cell sectors and then this model was used to predict network capacity. The results indicated public safety had more than enough spectrum with the 10 MHz already allocated to it.
The Cornerstone report told a different story. The difference between wide-area commercial cellular broadband usage and public-safety usage has to do with more than 70-percent of all public-safety incidents being confined to small geographic areas and, in many cases, public-safety usage is confined to a single cell sector. Therefore, the only way to calculate capacity for a dedicated public-safety network is to base tests on a single site/single sector basis. This methodology was employed in the live testing for the Cornerstone report and it proved that a minimum of 20 MHz of dedicated spectrum would be required for public safety. The FirstNet spectrum allocated by Congress is now set at 20 MHz.
These tests were completed in 2011 and FirstNet went live in 2017 not only with the 20 MHz of public-safety Band 14 spectrum, but with access to all of AT&T’s broadband spectrum as well. While not required in the FirstNet RFP, access to AT&T spectrum means public safety has access to more than the 20 MHz allocated. As a result, network congestion has been minimized even when many public-safety users are within a single cell sector.
Increasing Demand for Broadband
When the 4.9-GHz band was allocated to the public-safety community in 2002, it was envisioned as a close-in, short-range communications band. Over the years, it has also provided point-to-point links for all types of public-safety systems including backhaul for Land Mobile Radio (LMR) systems and point-to-point links for video and other high data-rate broadband uses. However, the need for broadband services is increasing dramatically with 5G being rolled out and broadband services becoming more and more important. Broadband capacity is being stretched by, for example, medical ultrasound for EMS personnel to quickly determine if a patient is bleeding internally, public safety’s increasing use of artificial intelligence for operational needs and training, and more, different types of alarms and sensors worn on first-responders’ uniforms.
At this time of increasing need for more bandwidth and capacity, the current FCC has chosen to take away 71-percent of the existing allocation for public-safety broadband services. Meanwhile, more spectrum is being made available to commercial broadband providers and even unlicensed broadband providers for their use and to increase their profits. The current FCC has all but ignored the public-safety community because it is not able to monetize its spectrum. Public safety’s needs for broadband services should be considered critical and should be given priority.
We are only on the cusp of discovering how broadband services will assist public safety in protecting the general public and keeping its personnel safe. Next-Generation 9-1-1 (NG911) is a new broadband pipe that will feed FirstNet’s broadband network and more broadband spectrum will be needed. While commercial and unlicensed operators are being given priority for new spectrum assets, the FCC has decided to cripple the future of public-safety broadband by taking away 71-percent (50 MHz) of its broadband spectrum assets.
If left in the hands of the public-safety community, 4.9-GHz spectrum would provide additional broadband capabilities on several fronts. It could be used outdoors for 5G deployment of broadband services including Unmanned Aerial Vehicles (UAVs, drones) and other devices while being used for inbuilding coverage with perhaps WiFi or even WiFi 6. The vendor community is already contemplating blending 5G and WiFi 6 into new broadband systems with greater capacity, better data speeds, and lower latency.
Why should the public-safety community be left out of this blending of technologies? Why should states that previously failed to take advantage of spectrum allocations set aside for them end up with spectrum that is not coordinated between states, is perhaps used differently in multiple states, and that will most likely result in interference at state borders? It would serve the United States public better to step back from the current FCC’s stance and take a new, harder look at this spectrum and how it should be used for the future of our public-safety and critical-communications users.
Broadband Voice Messaging and Protests/Riots
You might remember when Houston, Texas, was hit with severe flooding a few years back and a group of volunteers that became known as the Cajun Navy brought their boats into the area and helped rescue people stranded by the flooding. These folks made a huge difference in moving people out of harm’s way and they used a cellular voice messaging application to coordinate their efforts. While this worked well, it also provided information to those who wanted to commit burglaries. By listening in on the voice messaging system, they were able to know which houses were empty and ripe for plundering.
After-action reports cited the benefits of users on different cellular networks being able to set up communications to coordinate their rescue efforts. They also pointed out the downside to free and open use of non-encrypted voice communications. I bring this up because the same application was used by some of the protesters-turned-rioters to coordinate their activities.
Zello, the vendor of this application, which it prefers to call “voice messaging” and not “Push-To-Talk” (PTT), issued a press release after the events of January 6, 2021. The headline read, “Zello Takes Action Against Militias.” The opening paragraphs are as follows:
“First and foremost, let us be very clear about our stance on violence on our platform: we condemn the use of violence in the strongest possible terms and want our platform to be used for positive, constructive purposes and never for violence.
It is with deep sadness and anger that we have discovered evidence of Zello being misused by some individuals while storming the United States Capitol building last week. At this point though, we do not have any evidence of how Zello was effectively used beyond anecdotal reports of typical social media vanity messaging. Looking ahead, we are concerned that Zello could be misused by groups who have threatened to organize additional potentially violent protests and disrupt the U.S. Presidential Inauguration Festivities on January 20th.
In response we are taking immediate action to ban all militia-related channels, while clarifying a few important points relative to how Zello is used and explaining how you can help.”
The main issue appears to be the same issue that has created problems for social-media services such as Twitter, Parlor, Facebook, and even YouTube. Those in charge of the services have been slow to recognize they are not only being used for their intended purposes; they are being used for nefarious purposes as well. Zello has acknowledged its shortcomings as have most other social-media platforms. Now we will see how well they follow up on their promises for improvement.
Even though access to PTT services used on FirstNet and other networks is carefully regulated and are encrypted so traffic cannot be intercepted and used by others, some public-safety agencies appear to be using Zello voice messaging instead of better-regulated and encrypted choices. Perhaps it is time for public-safety and business services using non-encrypted and non-standard voice messaging or push-to-talk services to re-evaluate their use and look for a public-safety-approved PTT product and service.
Other Methods of Radio Communications
After January 6, 2021, the FCC issued a notice regarding the use of radio spectrum to commit or facilitate criminal acts. Its warning below calls out Amateur Radio and Personal Radio Services (Family Radio handhelds and GMRS radios) but the warning also applies to all forms of radio communications including Citizens Band radios.
The bottom line is that using any form of radio communications for illegal activities is a violation of FCC rules and regulations and fines and jail sentences await those who use radio devices for these purposes. I would not be surprised if this FCC statement also includes voice-messaging services used on January 6, 2021.
For many years it has been common knowledge that many organized groups have used radio communications for nefarious purposes. There is a saying in the industry that the bad guys sometimes have better communications than law enforcement. I think new systems such as FirstNet have somewhat evened the battle, but it would be great to see some who use radio communications for illegal purposes charged, fined, and perhaps jailed.
Hopefully, the worst of 2020 is behind us and the blip that occurred on January 6, 2021, will never be repeated.
Until next week…
Andrew M. Seybold
©2021, Andrew Seybold, Inc.