Public Safety Advocate: Congressional and FCC Missteps Keep Future Uncertain

In last week’s Advocate, I said one good thing had resulted from the pandemic because changing circumstances influenced more public-safety agencies to join the FirstNet network. I was concerned about both wired and wireless networks encountering difficulties keeping up with the increased load of work-from-home and school-from-home programs that started in March. Since FirstNet (Built with AT&T) is the only network with dedicated spectrum for public-safety broadband, I concluded that FirstNet would have a decided advantage if there were network slowdowns or other disruptions on other networks.

A few days later, Ed Horowitz, Chairman of The FirstNet Authority, was quoted in several articles as saying he believed FirstNet (Built with AT&T) reached a “tipping” point last December when it reported more than a million FirstNet connections, more than one-hundred FirstNet-approved devices, and a robust App Catalog, and that it had completed more than 75-percent of the build-out requirements ahead of schedule. He then stated, “I’d say that the pandemic, with no question, has accelerated everything. Until then, FirstNet was essentially being reviewed—municipality by municipality, state by state—and there was … a deliberate process whereby FirstNet was being adopted … The pandemic just moved the curve at 30 degrees, instead of 10 degrees.” That followed on the heels of FirstNet announcing that as of last week it had more than 1.5-million connections from more than 13,000 agencies. Mr. Horowitz said he believed that “something on the order of 80% are primary,” which refers to the classification of users that are with full EMS, fire, and law-enforcement agencies. 

Toward the end of the interview, Derek Orr, Chief of the Public-Safety Communications Research (PSCR) Division of the National Institute of Standards and Technology (NIST) followed with, “It really is incredible to see what’s happened just in a matter of a couple of years, going from releasing an RFP to actually having 1.5 million-plus subscribers on the network. To put that in perspective, when FirstNet was starting to look, and we [PSCR] were helping with some of this, at what the potential … public-safety subscriber pool, there were estimates of maybe 2.5 [million] to 4 million—depending on how you count them— public-safety personnel in the United States.”

It is a tribute to the labors of The FirstNet Authority and FirstNet (Built with AT&T) that we have reached these milestones in such a short time. FirstNet became a reality when the law creating it was signed in February, 2012, development of the network began when the contract to build and operate the network was awarded in March, 2017, and all of the states and territories had opted into the system by the end of 2017. The true FirstNet (Built with A&T) start date should probably be January 1, 2018. 

The increasing number of public-safety agencies joining FirstNet is in spite of the fact that other network operators that chose not to bid on The FirstNet Authority’s RFP have decided they want to compete with FirstNet after seeing how fast the public-safety community is joining the network. Recently, one network operator even stated it would provide public safety with free 5G services but, it appears, these services would not include priority and pre-emption (which is a non-negotiable requirement) and without the dedicated public-safety-only spectrum available exclusively on the FirstNet network (Band 14).

During 2020, FirstNet has had a huge positive impact on public-safety’s ability to provide emergency communications across the entire nation. The power of FirstNet, augmented by localized Land Mobile Radio (LMR) systems, provides redundancy and the ability to communicate by voice on two separate networks. 

Spectrum Issues

Meanwhile, both Congress and the Federal Communications Commission (FCC) seem determined to ignore the needs of the critical-communications community. The most pressing issue at the moment for eleven of the largest metropolitan areas is that Congress has not acted to repeal the T-Band giveback. As a result, the FCC has had to move forward with plans to auction the T-Band 470–512-spectrum in 6-MHz blocks. For the most part, this spectrum is available in only a few of the eleven metro areas and certainly not nationwide. TV stations are located on both sides of this spectrum and even today, with this spectrum dedicated to public-safety LMR systems, public safety is dealing with many interference issues from both higher and lower TV stations. I, for one, believe the highest and best use of this spectrum is to leave it in the hands of the public-safety community. 

The National Public-Safety Telecommunications Council (NPSTC), all major public-safety organizations, the Government Accounting Office (GAO), and even the FCC chairman have indicated to Congress that the T-Band giveback MUST be repealed. However, Senate Members have not been able to come together to pass a simple, one-paragraph bill that would keep the T-Band for public safety. NPSTC’s two detailed and well-written reports conclude there is no satisfactory spectrum available to accept agencies that will have to relocate. Further, even if T-Band spectrum was cleared, auctioning it would not raise enough money to cover the cost of relocating the public-safety users, let alone provide a windfall to the U. S. Treasury. And then the two years public safety would have to vacate the spectrum does not begin to be enough time for public safety to find spectrum (not likely), license it, design replacements for existing T-Band systems, and build and permit them. During this time, T-Band and any new systems would have to operate simultaneously with existing systems until the new ones prove satisfactory. I hope the Senate wakes up soon. I am still hopeful that if the spectrum has to be to auctioned, some large corporation will buy it all and hand it back over the public-safety community. 

If the auctions fail as I believe they will, Congress will receive a wake-up call, the FCC will end up with a blackeye, and the public-safety community in the eleven metro areas will be in limbo until someone comes up with a solution. FirstNet could provide some relief to these agencies but FirstNet’s Push-To-Talk (PTT) capabilities do not provide for off-network communications that are vital to any public-safety system, and it is not clear if off-network PTT over broadband will ever be capable of providing the same coverage as LMR inside buildings or when out of network range, either on LTE or after moving to 5G. I repeat, I firmly believe the T-Band needs to remain in the hands of public-safety agencies now using it. 

6 GHz

The 6-GHz band is home to scores of point-to-point critical-communications microwave systems serving public safety, utilities, National Association of Broadcasters (NAB) users, and others. Broadcasters also use the 6-GHz band for remote uplinks and downlinks for news stories and events that occur anywhere and everywhere. Yet the FCC voted to add unlicensed WiFi 6 and “other unlicensed” uses to this mix. The FCC is confident that use of the automated frequency system that assigns “clear” spectrum in a given area will ensure there are no interference issues. However, past performance of TV white-space databases has not, so far, proven this approach to be bulletproof. 

Mixing licensed and unlicensed users on the same spectrum is a recipe for disaster, mostly because trying to track down an unlicensed radio that is interfering with a microwave transmission would be like looking for a needle in a haystack. Even so, companies including Verizon and Ericsson are attempting to have some 6-GHZ spectrum re-allocated for 5G services. Meanwhile, the NTIA’s microwave spectrum in the 7-GHz band remains off-limits to additional types of uses. After all, the 7-GHz federal spectrum runs point-to-point microwave systems for federal users who are more important than public safety or other critical-communications users in the 6-GHz band. 

Ligado

Ligado, formerly LightSquared, has returned to the FCC, this time seeking approval to build out a 5G Internet of Things (IoT) network in the 1–2-GHz L-Band spectrum it previously wanted to convert to satellite spectrum. Because it is adjacent to Global Positioning Service (GPS) spectrum, the U.S. Military and many other organizations believe interference could cripple the GPS system in some parts of the United States. Even though this is the same reason LightSquared’s request was denied, the FCC approved the Ligado 5G IoT network. In opposition, one Senator is holding up re-confirmation of Commissioner Michael O’Reilly until he agrees to vote to rescind FCC approval. (UPDATE-The President has just with Drawn Mr. O’Reilly from the confirmation process, but the reason is unclear.)

All this activity surrounding reallocation and approval of spectrum for uses that have the potential to cause interference is simply another indication that those at the FCC, or perhaps the three majority Commissioners, either do not fully understand critical-communications infrastructure or simply believe if it turns out that there is an issue they will have left office and headed for greener pastures (regardless of how the election turns out). Whichever party wins in November, I can only hope there will be new Commissioners who will take the time and trouble to understand how fundamentals including interference and rising noise-floor levels affect receive capabilities and they will err on the side of critical-communications systems. 

Once spectrum is carved up or shared, in use, and interference issues arise, it is almost impossible to find a cure for problems that have been created. Consider the Nextel experience. When Nextel won the right to convert LMR specialized mobile radio systems to a cellular architecture, there was a huge outcry from public-safety users on adjacent spectrum. Whenever public-safety users were in close proximity to a Nextel low-level cell site, interference to the public-safety radio meant the unit could not receive transmissions over the network. It took an extraordinary amount of money to fix the problem, first from Nextel and then from Sprint after it bought Nextel. The disruption to public-safety systems, which could have been avoided, was extensive and the necessary rebanding of radios was a major, expensive undertaking that was costly to everyone involved. 

Virtual Shows

Because of the pandemic, we are living in a time of virtual everything without in-person conferences or events. Even the Consumer Electronics Show (CES), the world’s largest annual conference and exhibition held in January in Las Vegas, will be virtual this year. APCO 2020, the International Wireless Communications Expo (IWCE), the International Association of Chiefs of Police (IACP) Conference 2020, and other public-safety shows will be online. The PSCR 2020 conference normally held in June in San Diego or another west-coast city was virtual this year and I believe it provided a model for virtual shows.

The PSCR 2020 virtual conference was held from July 27 through 31, and all indications are that it was well attended. PSCR Chief Derrick Orr led off the event and the keynote speech was delivered by Todd Early, Texas Department of Public Services and Chairman of the Public-Safety Advisory Committee (PSAC). The PSCR has been instrumental in working with the public-safety community even before the advent of FirstNet. I believe the first sessions I attended were held in 2010 and its regular yearly stakeholder conferences started in 2012. Most of the information and various components of PSCR 2020 will be posted online and can be replayed if you missed this event that featured on-demand sessions, live sessions, tech demos, and even a networking lounge. Congratulations to Derrick and the rest of the PSCR staff. They certainly proved that virtual can be a great way to learn.

Many of us would be in Orlando for the APCO 2020 conference that was cancelled, but APCO has instead set up sessions online under the banner, “APCO Virtual Classroom.” Many within the public-safety community attend the APCO conference to become certified or re-certified in aspects of public-safety communications. These virtual classroom sessions will replace the in-person classroom sessions this year and will count toward certification.

The annual IWCE conference and exhibition will be next and it will run Monday, August 24 to Thursday, August 27, 2020. While content has had to be condensed, this conference is still a must-attend for most of us and I will be leading two sessions during the three days. Events kick off Monday with some day-long sessions and several keynotes including one from Jeff Johnson, CEO of the Western Fire Chiefs Association. Chief Johnson was deeply involved in Public-Safety Alliance (PSA) efforts to move FirstNet through Congress and he was later elected to The FirstNet Authority board of directors, eventually ending his engagement as Vice-Chairman. His presentations are always worth listening to.

The Virtual Exhibit Hall will open at 1:00 p.m. every day, but on Thursday, the last day of the show, the exhibit floor will open at 10:00 a.m. and close early at 4:30 p.m. so we can all catch our virtual flights home.

Winding Down

As we move through the first week of August, we continue to see more incidents pushing our public-safety professionals to the brink. COVID-19 cases are still rising, Hurricane Hanna hit last week, and this week tropical storm/hurricane Isaias is hit Florida and is moving up the east coast. Meanwhile in California, as of Tuesday, August 4, 2020, the Apple fire has burned more than 26,000 acres and is 15-percent contained. Many evacuation orders have been issued and evacuation centers have been set up. If there are large numbers of evacuees in these centers and they cannot properly social distance, we could see a further increase in the number of COVID-19 cases. 

FirstNet is being kept busy with all this and more. Every week there are more press releases about new cell sites coming online for FirstNet users, and we are coming closer to the deadline for finishing tasks that must be completed within the first five-year build-out period. Happily, FirstNet (Built with AT&T) is about a year ahead of schedule. The completion of the final phase of this first part of the contract will not signal a stop of network build-out activity. As I have said many times, I have never seen a broadband network that is deemed to be 100-percent complete. And now FirstNet is preparing to add 5G capabilities to the FirstNet LTE network. There is a lot to do as The FirstNet Authority is reinvesting money back into the network, and AT&T is moving forward on many fronts. 

I hope our first responders can take a break at some point to catch up with their lives and spend time with their families. I do not know that I have ever seen such heavy demand for the services of our public-safety professionals than there is today. 

Until next week…

Andrew M. Seybold
©2020, Andrew Seybold, Inc.

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2 Comments on "Public Safety Advocate: Congressional and FCC Missteps Keep Future Uncertain"

  1. “FirstNet’s Push-To-Talk (PTT) capabilities do not provide for off-network communications that are vital to any public-safety system”

    Remember that there are other 3GPP concepts/functionalities to be used there, e.g. IOPS, Relay Nodes/IAB, and HPUE.

  2. Yes there are other 3GPP concepts/functionalities, but first of all I do not believe that having to make use of a relay is a suitable solution since there is no guarantee that whom ever or what ever is the relay will stay where is it needed and even when used the distance covered is not adequate. HPUE–it is going to take a lot of work before HPUE is capable of being used in a handheld because of the battery considerations. I am a purest, to me OFF-NET means one to one, one to many with NOTHING required between the two or multiple users and I don’t see any 3GPP solutions at this point in time which will meet what I believe are the off-network requirements for the public safety community. If LTE is used for public safety on a commercial network, even with priority and pre-emption as some countries are doing or planning on doing I don’t believe that HPUE is approved for these types of networks.

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