Kudos to the FCC (Sort of)

...the FCC has acted in a timely manner in handling waiver requests from cities and states that want to start building out their own public safety broadband networks.

This may seem like a strange title for an article from me about the Federal Communications Commission since I have published numerous articles taking it for task on its stand of auctioning the D Block instead of asking Congress to re-assign it to the public safety community. However, the FCC has acted in a timely manner in handling waiver requests from cities and states that want to start building out their own public safety broadband networks.

On May 12, 2010, the FCC granted conditional approval of 21 petitions by cities, counties, and states to build Interoperable broadband networks. The “condition” is that these networks be deployed under a common interoperability framework in coordination with the FCC’s Emergency Response Interoperability Center (ERIC). This will assure that all of the networks being deployed are technically compatible and will be fully interoperable. Other conditions of the order include the following.

• Comply with certain initial technical requirements, including:
  • Nationwide network interoperability;
  • Mandatory use of the Long Term Evolution (LTE) air interface standard, recognizing the unique circumstances associated with the 700 MHz band and the need to achieve interoperability;
  • Network support for certain applications, including access to the Internet, to an incident command system, and to field-based server applications; and
  • Use of certain system characteristics, including security features.
• Submit technical deployment and conformance testing plans to ERIC, specifically including plans for achieving and maintaining interoperability with all public safety broadband network deployments in the 700 MHz band. Petitioners must also implement all phases of technical requirements adopted by the Commission.
• Participate in demonstration network testing being sponsored by the NIST/NTIA Public Safety Communications Research program and the District of Columbia.
• Offer service and/or access to all designated public safety agencies within the network coverage area.
• Enter into a standard form spectrum lease with the Public Safety Spectrum Trust (PSST), which holds the national license for the public safety broadband spectrum. The PSST may charge a limited administrative fee as part of the lease arrangement, but only after first submitting a proposed budget for public comment and approval by the Public Safety and Homeland Security Bureau.
• Submit quarterly progress reports to the Commission, in consultation with the PSST.

The FCC documents made it clear that the FCC was not endorsing LTE as an air interface standard but that it was reasonable to require LTE in order to ensure interoperability.

Waivers were granted to 21 applicants including New York City, New York State, LA County, The San Francisco Bay Area community (Oakland, San Francisco, and San Jose), and others, all of which have expressed their interest in moving forward as quickly as possible to put systems in place. There were some other requirements in the order as well, but nothing that would prevent those who applied for the waivers from moving ahead.

What This Means

First of all, the FCC did the right thing in issuing its order so these networks can be designed and built, and if I am correct, there will be some other implications for both the public safety community and the FCC.

The order does not require that each of these systems build in a guard band, so they can use the full 10 MHz (5X5) of spectrum already allocated. This is good news since there are questions about the proximity of the D Block to the public safety spectrum, and many believe that if the D Block is auctioned there must be some form of guard band between the two blocks of spectrum. Since it appears that the public safety community will be able to build its networks first (see below), it also appears that if the LTE experts who do believe a guard band is necessary are correct, the winner of the D Block will not be able to make use of its full 10 MHz of spectrum. It will probably have to build its system using no more than 4X4 MHz, leaving a half-MHz guard band on either side to avoid interference.

If this proves to be the case, and I believe it will, then the value of the D Block spectrum will be diminished and perhaps that will make it easier for the public safety community to convince Congress to allocate the D Block to public safety. It is important for the first responder community to have the D Block because my research shows that if the public safety community is limited to 10 MHz of spectrum (5X5), it will have to make use of commercial spectrum on a daily basis (D Block, AT&T’s, and/or Verizon’s). Some believe that the 10 MHz already allocated is sufficient for public safety and they will only need to roam on the commercial spectrum on an occasional basis.

As these new public safety networks come online, as devices become available, and as applications for public safety broadband services are deployed, we will have some real-world case studies that will prove that 10 MHz of spectrum is not enough to meet the needs of the public safety community. Encroachment onto commercial spectrum, on a priority basis, will occur much more often and will be disruptive to commercial networks and their customers as well as to the public safety community.

Guard Bands Update

As I was writing this COMMENTARY, the FCC issued a request for comments on several items under PS Docket No. 06-229 on May 18, including if guard bands (spectrum between the D Block and the public safety spectrum) will be needed. Comments are due by June 17. It is disheartening to those of us who raised this issue many months ago that this question is only now being asked when in fact it should have been resolved before both the broadband report and approval of the waivers. If guard bands are necessary, it would have a huge impact on both the public safety spectrum and the D Block unless the D Block is folded into the public safety spectrum.

My research has convinced me that guard bands will be necessary. I have heard from others that because the European agencies did not require guard bands, it was assumed that they were not needed. However, the European allocations include a sufficient amount of spectrum for each network operator to use some of it to provide guard bands.

If guard bands are needed for both the D Block and the PSST spectrum, and the allocations are left as they are today, neither of these allocations will permit a full 5 MHz of use. In fact, the available bandwidth will be 4 MHz or less, significantly impacting the networks’ capacity and data speeds. Why wasn’t this addressed many months ago?

Timing

I have heard many comments about the waivers, and the consensus is that even though the waivers have been granted, if Congress does not intervene, the public safety agencies will not be able to complete their networks and show real-world results to the FCC before the D Block is auctioned. I don’t share this view. I have learned that a number of vendors are ready to move forward almost at once with cell site equipment and at least notebook dongles to bring these systems into their pilot phases quickly, and that some networks have been in the planning stages for months or years and could actually be in operation before the middle of next year.

Even if these networks are not fully built-out by then, we will be able to begin accumulating real statistics about these departments’ broadband usage, we will have mobile devices and new applications available for testing and use, and the data the FCC says the public safety community has failed to provide (another point I disagree with) will become available prior to the D Block auction. So while this is a great move by the FCC, it is also a move that could help the public safety community continue to build its case for acquiring the D Block.

Turning 5X5 into 10X10

Another concern I have heard is that if these systems are built out using the 5X5 MHz of spectrum available today, how much more would it cost to upgrade to a 10X10 MHz system if the D Block is reallocated? There is good news, or perhaps great news on that front. With the cell site and mobile equipment being designed and, in some cases, ready to be delivered, the upgrade path is related more to software than having to rip out and replace radios. One advantage for the public safety community in using LTE for broadband is that the commercial operators will make sure whatever they install will be capable of being upgraded with additional bandwidth, and with additional releases of software to accommodate advances in LTE over the next 4-5 years. This will ensure that the public safety community has upgrade paths for both additional adjacent spectrum and future revisions to LTE. These revisions, by the way, will provide additional functionality, increase data speeds and throughput, and at some point, permit voice communications across the networks.

Designing the Networks

This will be a challenge for those that received the waivers and will require close cooperation with vendors that have and are deploying commercial networks as well as commercial network operators that have publically stated that they are willing to assist the public safety community in many different ways including providing backhaul and back-end services. If the public safety network can be built using the commercial backbones, the capital expenditures for these networks will be far less than if the city, county, or state elects to build a completely self-contained system.

Some in the planning stages of these networks have indicated that they want a core number of sites to be fully owned and operated by the agency or joint agencies involved, but that they will then work on additional shared sites with commercial network providers. This approach makes sense. In case of a major failure on the part of the commercial networks or back-end congestion, the basic LTE broadband system will be fully managed and controlled by the agencies involved. This approach will cost more money up front but operational expenses for those sharing back-end services will be considerably less.

The bottom line is that the public safety community has a lot of learning to do and the FCC’s order approving the waivers and allowing 21 organizations to start work will help with the learning curve and these systems should serve as models for all future systems. I expect that in this group of 21, we will see almost every possible combination of standalone and shared with commercial provider types of networks as are possible, and those that follow will have a wealth of knowledge and real-world experiences to help make the next networks even better.

Network Funding

Shortly after the FCC approved the waivers, the NTIA said it would open up a round of funding for these networks with the $4.2 billion of the $7.2 billion in stimulus funds it controls. While this is great news for the public safety community, it will mean that many of the applications for rural broadband services will not receive the money that was intended to provide broadband services in areas where it is not available.

Perhaps the NTIA should ask Congress to increase the fund so it can provide funding to those who have already spent time, effort, and their own money applying for these funds as well as funding for the public safety build-outs.

Conclusions

So kudos to the FCC. It did the right thing in this case and I am pleased that it did. We will learn how to integrate these networks so they not only interoperate with each other, but that they also can interoperate with commercial networks. We will learn how many different levels of priority access will be needed (hint, it’s more than one), how to work with commercial network operators, and how to design systems based on commercial standards modified for mission-critical public safety communications.

However, the FCC’s recent request for comments indicates that it is discovering a number of unresolved issues—issues that had been raised many times prior to the issuance of its National Broadband Report. Specifically, the need for guard bands between the PSST spectrum and the D Block could have huge ramifications for both the public safety community and the winner of the D Block auction if the spectrum does go out to auction. This is even more reason that the D Block should be reallocated to the public safety community for its exclusive use.

The sooner the public safety community can begin building these networks, the better off it will be. The vision of a nationwide broadband interoperable system is a great one, but it will take years to accomplish. What we learn from these 21 systems, both large and small, will help make the rest of the networks easier and more cost effective to build. And we will learn how to meld back-end services not only for these broadband networks, but to include and incorporate existing and future voice networks that will be deployed on the channelized spectrum in the 700-MHz band.

We will be able to prove to both Congress and the FCC that 10 MHz of broadband spectrum is not enough even with today’s applications. Therefore, it does not begin to be enough for the future when we will have an even wider variety of devices and applications. The FCC has kick started the dream of the public safety community—interoperable communications and broadband services not possible before now. The FCC is to be commended and while the public safety community needs to continue its fight to have the D Block reassigned to public safety, what we learn in building and operating these networks in real-world situations will go a long way toward helping us achieve that goal.

Andrew M. Seybold