The PUBLIC SAFETY ADVOCATE

Perhaps the most difficult to explain is that Public Safety needs simplex, tactical, or talk-around capabilities on a daily basis. Most people don’t understand those terms so I use IT or computer terms such as peer-to-peer and peer-to-many peer communications.

To Our Readers:

Many of you have been very patient over the past year or so, staying with us even though you have little interest in Public Safety, the FCC, and the re-allocation of the D Block. I have devoted many of my blog and COMMENTARY posts to this topic while letting others that may have been more interesting to you slip away unnoticed.

Therefore, this will be the lastCOMMENTARY about Public Safety. Since I have a lot more to say, next week we will launch a new publication called the “PUBLIC SAFETY ADVOCATE” that will focus on issues affecting Public Safety. Like this commentary and my blog posts, this new publication will be free—all you have to do to receive it is update your email preferences by clicking the update your profile link at the bottom of any email we send you. Check the box to indicate that you want to receive the PUBLIC SAFETY ADVOCATE as well as my COMMENTARY and TELL IT LIKE IT IS blog post notices and save. If you are not already signed up for any of my emails – you can sign up here.

Next week I will be back writing about the world of commercial wireless in this COMMENTARY and Public Safety in our new publication. I hope you will stay with me here, and if you have an interest in Public Safety communications, I hope you will sign up to join me there as well.

Best regards,
Andrew M. Seybold

PUBLIC SAFETY ADVOCATE

Starting next week, articles such as the one that follows will appepar in our new publication, the PUBLIC SAFETY ADVOCATE. This new publication will focus on Public Safety communications issues and is designed for those within the wireless industry who are interested in Public Safety and the quest for interoperability. An advocate is a person who speaks up for others, and the word describes what I believe to be my mission for the Public Safety community. First, I want to stress that I am an unpaid advocate. I do not nor have I ever received remuneration for any of my advocacy on behalf of the Public Safety community concerning the 700-MHz spectrum and D Block issues. I have paid all of my own expenses for my travel to visit vendors, attend Public Safety events, and provide my views, and I will continue to do so.

As an independent advocate, I am in a position to write and speak about issues in a more direct way than many who are serving the Public Safety community who need to be able to work with the FCC and Congress on other matters that are also vital to their community. These people are cheering me on and I thank them for their support.

A Visit to DC

I was invited to be on a panel to discuss the 700-MHz broadband spectrum, Public Safety, and the allocation of the D Block. The panel was sponsored and run by the Congressional Research Service (CRS), which is part of the Library of Congress. Its charter is to work with both houses of Congress and to provide research and analysis on issues that are or will be before Congress for action. Most of the interface between CRS and Congress is via the congressional staffers and about forty staffers attended this panel. Some represented Democrats, some Republicans, and their bosses have either spoken out in favor of reallocating the 700-MHz D Block to Public Safety or are of the opinion that the D Block should be auctioned, and a few attended because their bosses are confused by the issue and are trying to make up their minds.

The Panel

The name of the event was “Interoperable Communications, Public Safety and the D Block.” The panel moderator was Linda Moore, who is the specialist in Telecommunications Policy with the Resources, Science, and Industry Division at CRS.

Panelists included Jennifer Manner, Deputy Bureau Chief, Public Safety and Homeland Security Bureau, FCC; Mike Calabrese, Vice President and Director of the Wireless Future Program, New America Foundation; Preston Marshall, Director of Wireless Networking, University of Southern California, Viterbi School of Engineering, Information Science Institute; Jon Peha, Chief Technologist, FCC; and me.

Each panelist was allotted 15 minutes to give a presentation and there were to be no rebuttals, only questions from the audience. Linda Moore introduced the topic and stated, “Our objective is for everyone present, including the panelists, to leave with a clearer understanding of the role of the D Block in meeting interoperable communications goals.”

Jennifer Manner spoke first and reiterated the stance of the FCC’s Public Safety and Homeland Security Bureau (PSHSB) that it has designed the best system possible for Public Safety broadband services. Its premise is that 10 MHz of spectrum (5 MHz for transmit and 5 MHz for receive) is enough for daily Public Safety operations and that the networks should be built out at the same time as the commercial LTE systems, sharing sites and common equipment including antennas where possible. The FCC also believes that Public Safety should be given priority roaming on the commercial networks for times when Public Safety needs more spectrum (emergencies, according to this bureau).

There was nothing new in what she had to say, but it set the stage for the rest of the panelists’ comments. One thing that puzzles me is why the PSHSB is pushing so hard for the D Block to be auctioned. I visited the FCC website and reviewed the PSHSB’s mission statement, which appears to be to help Public Safety with its communications requirements. That it has taken a position with such a strong recommendation to have the D Block auctioned does not make sense to me. I think it would have been better if the PSHSB had modified the Broadband Report and presented its thoughts on the need for Public Safety spectrum, but to ask Congress for guidance regarding the D Block and whether it should be auctioned or reassigned to the Public Safety Spectrum Trust (PSST).

The next panelist, Michal Calabrese, contends that Pubic Safety needs to change its way of thinking about spectrum. He says that Public Safety’s assumptions that it needs exclusive spectrum and proprietary networks and devices, that narrowband voice and broadband data should be on separate networks, that local agencies should have maximum control over their networks, and that today’s commercial networks and muni Wi-Fi networks have little or no role to play are old and outdated. He feels Public Safety should look toward a communications world that includes shared spectrum and infrastructure, leverages commercial and public Wi-Fi networks, converges voice and data over time onto a single network, and uses nationwide technology and standards compatible with the commercial cutting edge, meaning 4G and LTE networks.

He went on to talk about these points and stated that Public Safety really has 24 MHz of spectrum in the 700-MHz band and that if voice and data was converged onto a single network, there would be more than enough capacity for all Public Safety operations, or that sharing with the commercial network operators would provide added spectrum on an as-needed basis. He is a big proponent of muni Wi-Fi networks using unlicensed spectrum and cited the Corpus Christi, TX Muni Wi-Fi System. However, he failed to mention that Wi-Fi is unlicensed and available to anyone, that 90% of all muni Wi-Fi systems have been taken out of service, and that muni Wi-Fi is a nomadic network architecture rather than a mobile network, meaning Public Safety personnel would have to take the time to reconnect to the network every time they moved from one node to another.

He valued the existing Public Safety spectrum at $9 billion, therefore, the D Block should be auctioned (wonder what he would say TV spectrum is worth). He further stated that if it was auctioned along the lines of the 55 Public Safety regional planning areas (which have no correlation to standard FCC MTA and BTA areas), network sharing would be easier. He seems to believe that the $2 or $3 billion in revenue the government would receive from the auction would be of great importance in helping defray our national debt, which is growing at the rate of $4.2 billion per DAY. In essence, the proceeds would pay off less than one day’s debt. He also stated that the FCC should mandate commercial device interoperability but did not address the issue that if all 700-MHz devices were required to cover all of the commercial and Public Safety spectrum, the cost of manufacturing these devices would increase by about $15 or $20 each, which would mean an increased cost to the consumer of about $100 per device. Nor did he address the fact that if every 700-MHz device has these capabilities, it would not take long for hackers to find ways to breach the Public Safety broadband system and disrupt communications, either as a prank or as a way to delay Public Safety response during an incident.

He concluded by saying that the most cost-effective, multi-functional, future-proof mobile communications system will be all-IP over shared spectrum and shared infrastructure. To prove his final point he quoted, out of context, a statement by the 9/11 Commission about interoperable communications. It is clear to me, and I think it was clear to the audience, that he does not begin to understand the issues involved with Public Safety communications. His understanding of voice requirements is lacking and his belief that unlicensed Wi-Fi services can be used for mission-critical Public Safety communications is almost laughable. Even if a muni Wi-Fi system is built and works correctly, there is no guarantee it will continue to do so over time as more people add their own access points for in-building coverage. The muni Wi-Fi craze has died because there is no return on investment model and it is too difficult to keep the networks working as more access points are added by others around a city.

Preston Marshall’s presentation was very different. Instead of addressing the issues in light of today’s technologies or even tomorrow’s, he suggested that the D Block, as well as the Public Safety spectrum, be used to pioneer what many refer to as cognitive or smart radio technology. In the unproven and still-under-development world of cognitive radio, the premise is that the radios will “find” spectrum that is unused and make use of that spectrum until someone else uses it, at which time the radios find more spectrum somewhere else in the band and move to use that spectrum.

He also believes that the wireless broadband world should work like the wired world in that interference does and will occur but it is self correcting, permitting more customers to share the same bit of spectrum while suffering only “some” interference. He claims that if you plan your systems to avoid interference, you cannot design them to maximize capacity and that some interference is acceptable. I find his arguments to be interesting and very futuristic. Cognitive radio may have a place in the future of wireless, but using Public Safety’s spectrum to experiment with it and to try a new approach to spectrum management is ludicrous. If the FCC wants to experiment with the technology, it should dedicate some spectrum to it and test it—but not on a network where some interference could cost lives.

I don’t disagree that we need to look toward the future when it comes to how we manage and use spectrum. There continues to be more demand for spectrum than there is spectrum, and we cannot make any more of it. However, neither the D Block nor the Public Safety spectrum is the place to start. The premise for Public Safety has always been to adopt technologies after they are proven and in use by commercial networks to help reduce network and device costs, and to be able to provide a more cohesive network with the ability to roam onto commercial spectrum when needed (for administrative and non-mission-critical activities).

Next up was the FCC’s Chief Technologist, Jon Peha. Jon’s contribution to the panel was a presentation that centered around the idea that more spectrum does not mean more capacity, and that capacity depends on many factors including type of network architecture, technology, if the network is designed according to a coherent regional/national plan, the amount of spectrum, and the number of sites deployed.

He followed this with a statement that suggested that Public Safety is not planning to take advantage of the cellular architecture for 700-MHz broadband but rather is planning to build systems modeled after its existing voice networks with high sites and lots of power. His contention, of course, is that if the networks were built to commercial cellular standards, there would be plenty of bandwidth available in the existing 10 MHz of spectrum. He also made the case that with its current allocations, Public Safety already has 20 to 25 times more spectrum per user than commercial providers and followed that up stating that “a system operating in 10 MHz of spectrum with more sites can have more total capacity than a system operating in 20 MHz with fewer sites.”

All in all, he missed several points here. First, except for some spectrum at 4.9 GHz, which is good only for local data services, the Public Safety spectrum is not capable of being converted to broadband usage. Further, in most cases it is intertwined with other land mobile radio systems (LMR) and is not in contiguous bands. The reason the existing Public Safety spectrum was allocated this way over the last 60 years is because the FCC has not given Public Safety enough spectrum in any one band when it had the opportunity to do so. The last statement about a system having more sites and 10 MHz of spectrum having more capacity than a 20-MHz system with fewer sites is a true statement, but in this case it is a faulty argument.

All of the work that has been done in designing Public Safety broadband systems assumes the same number 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 additional 10 MHz of spectrum is the difference between Public Safety users having to roam onto commercial networks every day versus only when there is a major incident. Under “normal” circumstances, all of my research shows that even with a major accident, a hostage situation, or any number of other incidents that occur on a daily basis, 10 MHz of spectrum will not provide enough data capacity.

He also said that the FCC determined that having 10 MHz of spectrum with the ability to roam on the commercial network operators’ networks would provide plenty of capacity and it had run scenarios for several major events that proved that 10 MHz of spectrum is enough. Based on his assumptions that more spectrum does not mean more capacity, I have to wonder why the FCC is so committed to providing an additional 500 MHz of spectrum for commercial broadband use. It seems that his logic here only applies to Public Safety and not to commercial operators. (watch for my coming Commentary addressing more of these issues)

His conclusion summed up the FCC’s belief that Public Safety has enough spectrum for daily use and that with priority roaming agreements in place with the commercial operators and site sharing, the FCC plan is the best solution for the Public Safety community.

My Presentation

As I was getting into my presentation, I took a few minutes to fire back at some of the points made by the others—many of my comments are embedded above. In addition to my presentation, which you will find as a PDF file attached to this article, I argued that LTE, as it is designed today and as it is being designed for tomorrow, will not support mission-critical voice communications. I have come to realize that the differences between commercial and Public Safety voice services are both the most important and most misunderstood pieces of this Public Safety communications puzzle. Those proposing that all Public Safety communications needs to be modernized and handled on broadband spectrum do not understand the differences in requirements and capabilities and why commercial voice systems are not a suitable replacement.

People who use cell phones can talk to anyone anywhere in the world who has a phone and they don’t understand why Public Safety systems are any different. I can explain to them that one-to-many communications is vital for Public Safety because officers in the field need to know what calls others are responding to and what is happening in their area of operation to be able to prepare to render assistance if needed. They don’t understand that officers in the field don’t have time to look at a number and dial it or even speed dial. They need to be able to push a button and have near instantaneous voice communications with others on the network and these calls have to be heard by others in the field as well as the dispatcher.

Perhaps the most difficult to explain is that Public Safety needs simplex, tactical, or talk-around capabilities on a daily basis. Most people don’t understand those terms so I use IT or computer terms such as peer-to-peer and peer-to-many peer communications. I explain that when they are out of cell tower range, their phone might as well be a paperweight. However, with Public Safety equipment, personnel in the field can talk to each other over short distances without going through a tower or cell site. Even if they are in range of a tower, there are times when local one-to-many communications is preferred. For a more complete explanation, read the letter I wrote to an FCC Commissioner explaining Public Safety’s special communications needs.

Conclusion

Given the fact that the panel was stacked against the Public Safety community and its wants and needs, I think I managed to get a few of the staffers thinking from a different perspective about many of the issues that were presented. Judging by the number of staffers who came up to me afterward wanting to talk about various aspects of the presentations, I would have to say that they are trying to engage, understand the differences, and weigh the issues fairly. I hope they are able to help their bosses (Congressmen and women) become more informed about this important issue since there is a bill in the House of Representatives that would reallocate the D Block to Public Safety.

I will continue in my efforts to be heard above all of the politics and misinformation that is being bandied about on the Hill. In a future column I will discuss my meeting with the FCC’s Public Safety and Homeland Security technology experts where I was, once again, outnumbered, and I’m not sure my arguments in favor of the D Block reallocation made a difference. I did suggest that they might want to soften their position because no one wants this battle to result in one party having to be proven wrong. I don’t know if they heard that, either.

Andrew M. Seybold

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