There is no choice:  4.9 GHz belongs to Public Safety

By Michael Barnbeck

“Who should control the 4.9 GHz public safety spectrum?”

The crux of the issue is whether this spectrum should be assigned to the FirstNet Authority, so all first responders have access to it or be controlled exclusively by local agencies along with shared access by Critical Infrastructure.  Currently, the Public Safety Spectrum Alliance (PSSA), a program within the Public Safety Broadband Technology Association (PSBTA) supports authorizing the FirstNet Authority to have a nationwide license.  The other side of this issue is represented by the Coalition for Emergency Response and Critical Infrastructure (CERCI) that is advocating that local agencies should be allowed to control and build their own networks along while allowing access to Critical Infrastructure (CI) companies.  Before delving into this topic, it should first be strongly stated, this spectrum has already been allocated to public safety for public safety use and the debate is about how to maximize the use for the greater good of all of public safety.  Both groups contend current incumbent users must be protected so they can continue to operate interference free.

Where this spectrum exists and how it should be deployed is pretty simple.  Maintaining this spectrum for all public safety is crucial to promote safety, as well as current and future continuity of operations.  The only logical answer and key to future success is a nationwide governance model.  This would provide widespread access to all of public safety, ensuring broad accessibility and utilization of the spectrum efficiently and effectively.  Additionally, this ensures local control and interoperability at the local, state, and nationwide levels.  Public safety already has an existing model to follow.  The Nationwide Public Safety Broadband Network (NPSBN), also known as FirstNet, has been built-out and used successfully for over 5 years.  This is a network owned by public safety and governed by the FirstNet Authority Board, a federal government entity within the Department of Commerce.  This network is robust; it contains within it built-in public-safety grade redundancies, stable funding for future growth (as we have just seen with the announcement by FirstNet of a new round of reinvestment totaling over $500 million), provides secondary access available to critical infrastructure entities, and has a nationwide emergency response operations model serving public safety 24/7.  This is where the 4.9 spectrum should reside and be managed.

Every jurisdiction will have different needs, uses, and applications regarding the 4.9 spectrum.  Having this spectrum managed within the FirstNet Authority Board absolutely does not take away public safety jurisdiction’s individual rights and applications, rather it enhances it.  While government overreach is sometimes a concern that many end users may share, the consistency and standardization of the FirstNet Authority Board model prevents this from becoming a problem.   The FirstNet Authority Board consists of first responders charged with a mission to protect public safety and its end users.  They understand what is at stake and the importance of representing our community to the best of their ability.  These leaders have a proven track record and are willing to stand up for our needs.  One must only look at the hundreds of applications that have been built to operate on the FirstNet Network, the expanded and enhanced coverage and the 5.5 million users who have migrated to FirstNet to realize the positive impact FirstNet has had on our world.

With the 4.9 spectrum, we do not want to go backward in time and again have disparate systems that are unable to work, communicate, and integrate with one another.  That is exactly what will happen if the CERCI proposal is adopted. The last 20 years have shown us that this model does not work.  Chief Ken Corey, who represents that group, fails to understand or acknowledge the fact that New York City tried to build their own network at a cost of $500 million with an annual operating cost of $38 million and after three years it failed. 

FirstNet, with an overall governance model for this spectrum gives us uniformity, reliability, financial support, and consistency.  Following this model gives us spectrum band management to deconflict interference and ensures public safety personnel all have access to 4.9 GHz through FirstNet, regardless of your geographic location.  Currently, the concern for this spectrum is that public safety has underutilized it.  Yes, this is true.  But there are several reasons why this has happened.  The first and most important reason is cost.  We all compete for budgetary dollars within our jurisdictions.  The cost of building out and maintaining another private network is difficult if not impossible, especially for cash-strapped jurisdictions.  As I noted above, even America’s wealthiest city could not make this model work.  This defines most jurisdictions in the United States in that there are those that have the money, which couldn’t make it sustainable, and most of public safety that doesn’t have the funding to build their own.  Next is technical support for build-out and maintenance.  Technical resources are limited, and technology is evolving rapidly in our society.  In most cases, the associated costs for design and implementation for most jurisdictions are unobtainable, let alone the long-term cost for maintenance and upgrades.  This is an excellent time to point out that this model CERCI supports has been available to all public safety agencies for over 20 years and only about 4% of those agencies use 4.9 on a limited basis for specific needs such as back haul.  If Critical Infrastructure (CI) were to get broad access to this spectrum, we would lose it forever.  Think about all those industries that fall under this category.  Directly from the CERCI webpage they say, “The 4.9 GHz band should be confined to public-safety use and other critical infrastructure uses like utilities, energy and transportation, not commercial uses”.  Think about this and look for yourself. This link allows you to see for yourself the broad definition of CI, https://www.cisa.gov/topics/critical-infrastructure-security-and-resilience/critical-infrastructure-sectors.  Specifically, transportation includes highways, highway works, trucking, airlines shipping and the list goes on.  The utility industry is mostly made up of for-profit companies, making billions of dollars and want access to your spectrum for free, so they can build it out for their own uses.  Another interesting point is the current FCC regulations allow local public safety to share with utilities, and for over 20 years there has not been a documented case where this occurred.  If CI were to gain access to this spectrum, we would lose it forever.  Not only would there be no local control, but it also means losing control of what was already granted to public safety by the FCC.   

CERCI does not have a roadmap for funding the build-out, a plan for spectrum management, a guarantee that you won’t ever lose control of our spectrum or a vision for the evolving organic growth needed to support new technologies.  Most importantly, private locally controlled networks could be steered toward other industries not related to CI or the public safety sector.  We would have no guarantee of priority use on their network, let alone the need for a public safety-grade network for us.  This would leave public safety communications crippled for future growth and innovation.

It is of critical importance for public safety to maintain control of our 4.9 GHz spectrum within the public safety community to ensure its effective and reliable use for emergency communications and applications going forward. The decisions made on this matter now, will be felt for decades to come…positive or negative for public safety.  The only entity with a plan and a true promise of local control is FirstNet.

I am a retired police supervisor, Director, from the Las Vegas Metropolitan Police Department.  I have had years of implementing and maintaining various technologies based around public safety communications.  My experience always comes back to these two takeaways:  communications is the most vital issue of day-to-day operations and for any critical incident.  Next is always the discussion of cost and long-term budgets to support these technologies.  I urge you to support protecting 4.9 GHz for public safety and designating the band license to the FirstNet Authority.