Public Safety Advocate: FCC’s New Approach, FirstNet’s Future

This week’s Advocate opens with a discussion of a recent article in Urgent Communications based on statements made by the Public Safety and Homeland Security Bureau. “FCC officials are taking a new approach to public-safety spectrum policy, abandoning exclusive-use airwaves in favor of multi-purpose broadband frequencies that can be leveraged to support wireless communications for both first responders and the general public, according to an FCC official.” 

Next we will look toward the future of public-safety communications as I believe they will evolve from today to where it might be later in the 25-year FirstNet contract for network build-out and management services, which, as you know, was awarded to AT&T for what is now FirstNet (Built with AT&T). As we approach the initial five-year build-out deadline, we see the direction The FirstNet Authority is heading with its infusion of additional funds, which leads to thoughts about what the future holds for FirstNet.

The FCC’s Transformation

The Urgent Communications article quoted the FCC Public Safety and Homeland Security Bureau presentation given during the online Mission Critical Partner’s Conference, “Advancing Public Safety.” According to the Deputy Chief, the “FCC historically allocated spectrum for public safety’s exclusive use when he joined the agency in the early 1990s. Those exclusive allocations are still there, they’re very important, and I think they will continue to be very important for certainly the indefinite future, because that’s where a lot of the mission-critical communications that public safety relies on take place.” 

This is the good news for public safety. It is not clear to me whether the rest of his statements were an idea being floated during a conference to see how well it would be received, or if it is truly a precursor of what the FCC thinks is best for public safety. In either event, it is worth a discussion and, in my case, some pushback. 

Later in the article, the following quotes caught my attention: 

“FCC officials are taking a new approach to public-safety spectrum policy, abandoning exclusive-use airwaves in favor of multi-purpose broadband frequencies that can be leveraged to support wireless communications for both first responders and the general public,” according to an FCC official.

David Furth, Deputy Chief of the FCC’s Public Safety and Homeland Security Bureau, described the philosophical change as a “transformation,” noting that the FCC historically allocated spectrum for public safety’s exclusive use when he joined the agency in the early 1990s.

“But what we’re also seeing is that that kind of historically siloed approach to public-safety spectrum is not the model that we are likely to be using going forward, and there are a whole host of reasons for that.”

According to Furth, advances in technology—specifically, “the explosion of broadband”—in terms of both functionality and reliability are key factors that have driven the FCC’s new direction in public-safety spectrum policy.

“These broadband networks, which are multi-use, they can support public safety as much as a siloed network, and they can do so much more cost effectively than standalone networks,” Furth said. “As broadband technology gets better—as networks get better, as we move from 3G to 4G to 5G—what we’re seeing is that those multi-purpose networks can serve commercial needs—they can serve the public—but they can also provide public safety with the reliable and the secure—indeed, mission-critical—types of communications that public safety requires.”

“I remember when there was a debate going on within the commission and in the public-safety community about whether commercial networks would meet public safety’s requirements. I think we are now well past that debate. Now, it is going to be about how they do it, how they compete to do it, and I think public safety benefits from that.”

The above appears to indicate that today’s model of Land Mobile Radio (LMR) spectrum assignments overlaid with a single public-safety broadband network (FirstNet) is in jeopardy. Many of us have spoken up against using multiple broadband networks for public safety and the perils of doing so. Perhaps it is time to ask the FCC’s Public Safety and Homeland Security Bureau the following questions:

  1. Will you require every broadband network to upgrade to the latest versions of LTE and 5G standards as they are released?
  2. Will you require every broadband network to use the same pieces and parts of each revision so the networks are 100-percent-compatible?
  3. How will you handle off-network communications? ProSe as it has been developed is not an off-network solution.
  4. When a network experiences a failure, who will be responsible for ensuring the public-safety community remains connected?
  5. Will the FirstNet Authority, a federal government entity, have the capability of overseeing all public safety users on all networks?
  6. What is the required response time for network failures?
  7. How do you propose to handle deployables, and which network is responsible for deploying them in what areas of the United States?
  8. Who will be responsible for approving devices for use by the public-safety community?
  9. Who will be responsible for approving and hosting the applications library and vetting the applications across all broadband networks?

The comment by the Deputy Chief about FirstNet is next: 

“There’s a lot of broadband technology on a variety of bands that can be used by public safety. A prime example of that is FirstNet, but it’s not the only example,” he said. “What we’re seeing, for the first time, is commercial providers that are actually in multiple bands, and they’re competing with one another to serve public safety. That is not something that was going on when I first came to the commission.”

The issue here, and the Deputy Chief knows this, is that there was an open and fair bidding process for a SINGLE nationwide public-safety broadband network. Congress approved a single network; the public-safety community approved a single Nationwide Public-Safety Broadband Network (NPSBN), and AT&T saw fit to submit a bid for a single network when none of the other commercial broadband networks did. Now that FirstNet is a success and has shown it can offer public-safety users what they want and need, the other network operators have decided to horn in on the one network built for public safety with public-safety input. The FirstNet Authority is responsible for FirstNet (Built with AT&T) and it is an entity of the federal government but not a part of the FCC. Rather, it reports to the National Telecommunications and Information Association (NTIA) and the Department of Commerce (DOC). Does what the Deputy Chief is saying in this article and its presentation at the conference mean a portion of every broadband network will be under the auspices of The FirstNet Authority? I think not. A CEO for one network that did not submit a bid told me, “I like having federal and public-safety users on my network; however, I don’t want to have a partnership with the federal government.” 

My final comments on this article and presentation are if today’s FCC really is heading in this direction, who will make AT&T whole for the $Billions it has already spent building out the FirstNet network to meet the requirements of the FirstNet Authority? Who will ensure that other broadband network operators spend the money to upgrade their networks to public-safety grade? Who does a fire chief or police chief call when their portion of the network is down? Who will oversee fixing the problem and putting it back in service instead of pointing fingers?

The FirstNet Future

On March 30, 2017, The FirstNet Authority awarded a 25-year contract to AT&T to build out the FirstNet network. This means the initial five-year build-out is to be completed by spring of 2022. So far, AT&T is ahead of schedule and it is quite possible FirstNet (Built with AT&T) will have met 100-percent of the five-year build requirements before then. Meanwhile, as discussions in a previous Advocate and in multiple news outlets continue, The FirstNet Authority has voted to reinvest its first $218 Million back into the network as required by the law. 

Some of this money will go toward upgrading the LTE FirstNet core (network brains) to work with 5G as well as LTE. The balance of the funds will go toward procuring more deployables for times of major incidents or when large crowds gather. Meanwhile, AT&T has already announced that the public-safety community (FirstNet customers) will have access to the AT&T 5G network as it is deployed. The stage is set, and as I have said before, no broadband network I know of has ever been declared complete. Newer releases of the 3GPP standard are always forthcoming and they need to be evaluated and then integrated into the network, 5G is being built out and will become available to FirstNet, and at the end of the five-year build period there will still be twenty years remaining on the contract.

Assuming the FCC’s new approach is not implemented and FirstNet remains as it is today and needs to remain, what can we expect? First, as FirstNet (Built with AT&T) has stated, for the time being, the public-safety spectrum known as Band 14 will remain the primary spectrum used by FirstNet customers. Obviously, as 5G is rolled out and new revisions become available, it would seem inevitable that at some point Band 14 will be converted to 5G technology. However, I don’t expect that to happen for a number of years. Like 1G, 2G, and 3G before it, 4G (LTE) will be replaced with 5G. Today’s FCC seems to think this needs to happen right now, today, and has allocated $billions for 5G deployment in rural America. My take is that 5G will be deployed in three separate portions of the spectrum and it will provide vastly different amounts of capacity and data rates depending on how it is deployed over time.

5G will or is finding its way into 600 MHz, 700 MHz, and 800 MHz and over time it will replace LTE that is now called 5G low band. We are told data rates will be better than LTE but we are still waiting to see some commercial network results. Next is high band or as some prefer, mid-band, which is the spectrum from 3.4 GHz to 3.8 GHz (but approved up to 4.2 GHz). Again, expected capacity and speeds are not known for this spectrum but there is a lot of activity in this area. Finally, we will have Millimeter Wave spectrum in the 20-plus Gigahertz bands. These spectrum allocations are for relatively huge amounts of spectrum and speeds of 1 Gigabit or more. The downside of this very fast version of 5G is that each small-cell coverage area is measured in yards not miles.

Over the next ten years or perhaps sooner, 5G will replace 4G on all allocated broadband spectrum. I believe FirstNet’s move to 5G as its prime broadband service will be gradual as the 5G network is built on all three spectrum segments. 5G devices are already available but to my knowledge there is no single LTE/5G device that covers both the LTE bands and 5G bands. Vendors will be able to determine what LTE/5G capabilities to include in their devices once it is known who will own what 5G-capable spectrum. Another factor will be whether network operators will accept network slicing, or carving out portions of small-cell spectrum licensed to one network for use by other broadband networks.

While all this is happening, I hope Congress will finally fund Next-Generation 9-1-1 (NG911) and that it will be fully integrated into the public-safety broadband services system. If the FCC leaves the public-safety LMR spectrum in place, which I assume it will since it is not ideal for broadband, I think most LMR systems will be upgraded to digital technology (perhaps P25) and become IP back-end based. This will provide public safety with incoming voice, text, video, pictures, and data and enable those in the field to access both broadband and LMR services. What I see coming will be:

  1. Separate LTE/5G and LMR devices
  2. Separate but wireless integrated LTE/5G and LMR devices 
  3. Combined LTE/5G and LMR devices (single-band and multiband LMR)

I think sometime in the future we will end up with a single device that will monitor all incoming broadband and narrowband spectrum options for an area and funnel the communications to a speaker and a screen (see mission-critical article). Beyond that, my crystal ball is very cloudy. I know 6G is already on the horizon but at this point it is designed for spectrum above 100 Gigahertz and it will be extremely local, but anything is possible. Today’s communications devices are using spectrum that only a decade or so ago was not believed to have any value.

I have not addressed Artificial Intelligence (AI), speech-to-text, integrated sensors embedded in devices and on people, the Internet of Things (IoT), Unmanned Aerial Vehicles (UAVs or drones), and other devices to assist public safety. We might even see Little Low Earth Orbiting satellites (LEOs) providing 5G to parts of the United States that cannot be covered by terrestrial communications systems today. I am skeptical about Little LEOs and their ability to truly provide broadband communications at low latency, and I don’t think there is a real economic model to sustain them. 

None of us know exactly what will transpire in the way of communications over the next twenty years and none of us know how public-safety services will change. Many of us won’t be around to see how all this turns out, but we are leaving a viable set of communications platforms to be enhanced and upgraded as new technologies come online and we are providing a solid, grounded set of guidelines for future technologists and public-safety professionals.

Winding Down

I am hopeful that regardless of how the November election turns out, at least one if not two current FCC commissioners will move on to bigger and better things and they will be replaced with two new commissioners who really care about preserving our spectrum and will parcel it out wisely. Moreover, I am hopeful that under new management, we will see the FCC return to times past when FCC engineering staff studied proposed changes in spectrum allocations, ran tests to make sure they would not cause interference, worked with the industry,  actually listened to technologists in its employ, and did not plow ahead simply because they felt the change would be beneficial for the vendor community.

In October, 2016, I was invited to talk with students studying to become radio engineers at Auburn University’s Samuel Ginn College of Engineering. I was asked to speak about radio spectrum and its management, and titled my speech, “The New Stewards of Radio Spectrum.” After a general discussion of the radio spectrum with an emphasis on it being a finite resource, I displayed the following slide:

I outlined how spectrum is regulated starting at the International Telecommunications Union (ITU) with the United States being in ITU Region 2. The two bodies that control spectrum in the United States are the NTIA for spectrum assigned to federal users, and the FCC for spectrum assigned to all non-federal users. 

Later in the presentation, I discussed the current use of spectrum and its shortcomings, and looked at what is coming including 5G, which was only beginning to be talked about. Then I introduced Shannon’s Law, which is a statement in information theory that expresses maximum possible data speed that can be obtained in a data channel. Shannon’s Law says the highest obtainable error-free data speed, expressed in bits per second (bps), is a function of  bandwidth and  signal-to-noise ratio. This was followed by a statement and a question: “No wireless systems in existence today operate even close to this theoretical speed,” and “How close will your generation take us to this upper limit?” 

After explaining the RF noise floor and how increases cause receivers not to hear as well as they did, and providing examples of what is driving the RF noise floor higher, I challenged these students to always be aware of the RF noise floor and what they can do to keep it from increasing any further. After reading the Deputy Chief of the FCC’s Public Safety and Homeland Security Bureau’s statements, one particular slide came to mind. “Today’s Spectrum Disconnect” argues that driving all radio users toward broadband is not the most sensible plan for RF spectrum in the future. 

I closed with a challenge to be true stewards of our spectrum and warned that “Regardless of how efficiently spectrum is employed, it is doubtful there will ever be enough for all who want and need access.” (Realizing this presentation is now four years old, if you would like a PDF copy, I will be happy to send one to you.)

Many of these students have graduated by now and I hope if they remember only one thing it is my advice about being a steward of our spectrum—especially since some within today’s FCC don’t seem to be aware of that responsibility. 

Until next week…

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


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