White Paper Response to FCC White Paper

We believe that the FCC white paper is based on flawed network assumptions and design and, therefore, the financial calculations are also flawed. In the body of this paper, we will prove that the entire FCC white paper is based on faulty and unsupported logic.

An Andrew Seybold, Inc. White Paper
Comments on the FCC White Paper: Federal Communications Commission
Omnibus Broadband Initiative”

Below is the Executive Summary of the comments on the FCC White Paper referenced above, which I have posted to the FCC’s Comment section (06-229). The entire paper is available in PDF format at the end of this COMMENTARY.

“A Broadband Network Cost Model: A Basis for Public Funding Essential to Bringing Nationwide Interoperable Communications to America’s First Responders,” Published by the Federal Communications Commission April 2010

Executive Summary

The March 2010 FCC National Broadband Plan (NBP) was completed and presented to Congress. A portion of this plan (Chapter 16) was devoted to broadband for the public safety community (Public Safety Broadband Network) for first responders and other public safety personnel. The FCC’s recommendations included:

  1. “Creating an administrative system that ensures access to sufficient capacity on a day-to-day and emergency basis;
  2. Ensuring there is a mechanism in place to promote interoperability and operability of the network; and
  3. Establishing a funding mechanism to ensure the network is deployed throughout the United States and has necessary coverage, resiliency and redundancy.”

Prior to and after the NBP being presented to Congress, the public safety community as a whole expressed many reservations with this plan. These reservations included concerns about the amount of spectrum that was allocated solely for public safety broadband use based on the FCC’s findings that public safety does not need more spectrum for day-to-day operations, the assertion that under this plan, the public safety community would have priority access to all of the spectrum licensed and operated by the 700-MHz commercial operators, and the FCC’s projected funding requirements. 

In subsequent speeches and presentations,[1] the FCC Chairman and staffers embarked on a campaign to 1) garner support from the public safety community, and 2) defend the recommendations made in the plan. The public safety community was and remains adamant that the NBP as presented does not address the needs of the public safety community for an interoperable nationwide broadband network.[2] It has requested that changes be made to the report and that the members of Congress introduce legislation to correct these deficiencies. Congress has responded with the introduction of H.R.5081[3] on April 20, 2010, and has sent this bill to committee for action. 

The FCC’s tenor when discussing the NBP report with the public safety community[4] appears to be that if the public safety community wants FCC support for funding the network build-out, it needs to accept the rest of the FCC’s recommendations in the NBP report.

The public safety community has responded that the funding is immaterial without enough broadband spectrum to build out the network and has concentrated on pointing out the need for additional spectrum, the willingness of commercial operators to work with public safety, and the fact that even the funding model used by the FCC is flawed.

In its latest effort to convince others that its vision for a nationwide public safety broadband network is correct, the FCC has published a white paper[5] that recaps and further explains its rationale for its funding estimates.

Our response takes issue with many of the FCC’s assumptions, calculations, and recommendations. For clarity, we have chosen to model this rebuttal on the white paper that was released by the FCC on April 23, 2010, and to discuss these points so they may be easily compared to statements included in the FCC document.

In addition to the issue of funding for construction and maintenance of a nationwide broadband network for the public safety community, there remain a number of other issues including, but not limited to, the amount of bandwidth the FCC believes should be allocated to a standalone public safety network and its assumption that the public safety community will have total, complete priority access to all of the commercial spectrum within the 700-MHz band as it is deployed by the license holders. These issues have been addressed in other articles[6] and publications but have not had as much of an impact on the overall FCC plan as the funding model.

We believe that the FCC white paper is based on flawed network assumptions and design and, therefore, the financial calculations are also flawed. In the body of this paper, we will prove that the entire FCC white paper is based on faulty and unsupported logic.

Andrew M. Seybold

Download a copy of the entire White Paper Comments-FCCWP-Final April 27 2010

[1] http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-296504A1.pdf; http://www.fcc.gov/pshs/docs/speeches/Jamie-Barnett-Comm-Sector-Remarks-04072010.pdf
[2] http://www.npstc.org/documents/PERF-SubjectToDebate.pdf
[3] http://www.opencongress.org/bill/111-h5081/show
[4] http://andrewseybold.com/1518-fcc-a-political-organization
[5] http://download.broadband.gov/plan/fcc-omnibus-broadband-initiative-(obi)-technical-paper-broadband-network-cost-model-basis-for-public-funding-essential-to-bringing-nationwide-interoperable-communications-to-americas-first-responders.pdf
[6] http://andrewseybold.com/1548-fcc-spectrum-plan-based-on-faulty-logic

3 Comments on “White Paper Response to FCC White Paper”

  1. tom says:

    The deployable systems are a joke. The assumption that carriers will charge a per port cost (but will ensure backhaul capacity is available particulrly during incidents when traffic peaks!!) is absurd. The carriers will have to deploy backhaul dedicated to public safety, and that will add tremendously to the cost.

    This paper – with the flaws, omissions and gross mistakes you point out – suggests the commission was less than intellectually honest when developing its proposal.


  2. PMA12 says:

    As you implied, the FCC should have published an RFI and/or RFP, soliciting proposals for different technologies and/or shared bands, rather than essentially issuing technology and business model mandates.

    For all they know, a combination of 700MHz and AWS-1, or 2.xGHz, and Wimax or advanced 3G might give a better outcome on balance. Maybe even public safety’s own 4.9GHz spectrum could play a valuable role. There are many possible alternatives. They did not solicit info on any of them.

    It appears they use press releases and vested-interest vendor claims on the state of readiness of standards-based LTE for 700MHz. None of this information gathering was done out in the open, subject to much-needed rebuttal, as far as I know.

    Openness and transparency seems lacking in many respects.

  3. […] of sites for both a 10 MHz and a 20-MHz system (using the FCC’s own guideline of a total of 44,000 sites). In this case, the additional 10 MHz of spectrum does equate to more capacity. However, the […]

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