One of the difficulties in explaining these requirements is that there is a difference in the terminology used by the Public Safety community and the commercial wireless and IT worlds. Here I will be talking about the use of voice radio communications for one-to-many communications that do not rely on cell sites or radios mounted on towers. This type of communications is referred to in several ways including “simplex,” “tactical,” and “talk-around” communications. There are no terms to describe these capabilities in the world of commercial wireless since none of these are available over standard commercial networks. What’s more, there probably never will be. Perhaps those of you who are more familiar with IT jargon will understand that this type of communications is peer-to-peer, or more precisely, peer-to-multi-peer.

Anyone who has used Citizens Band radio, or more recently the walkie-talkies for the Family Radio band, can relate. You talk to another unit that is within direct range of your radio without the signal being received and relayed by a cell site or tower. The range is limited, sometimes to as little as one-quarter of a mile and sometimes over longer distances, depending on the type of radio, its power, and the frequency band it uses. This type of communications is essential for the Public Safety community as well as other land mobile radio (LMR) users.

This unique form of communications is not technically possible with a cellular handset since it does not use a cell site or tower to be able to communicate with other units on the same channel. It is important to Public Safety because it enables various groups of first responders to communicate at the scene of an incident without adding to congestion on the primary dispatch channel. We all know we must be in range of a cell site for our cell phone to work. If we are out of range and have no network coverage, or are inside a building, parking structure, or other place where there is no coverage, our cell phone is merely a paperweight. This cannot be tolerated in the world of Public Safety, thus the radios must be capable of simplex operation.

Let’s consider a hostage situation in a bank as an example. The call is dispatched over the primary one-to-many dispatch channel and the first unit on the scene calls in a situation report: a bank with armed robbers inside and customers who have been taken hostage. The dispatcher sends additional units including a commander, the swat team, and fire and EMS to the scene. One person assumes the role of the Incident Commander (IC), whose job is to coordinate all of the activity on the scene: position the swat team, perhaps evacuate buildings surrounding the incident, and deploy the officers and other personnel at the scene.

If all of this radio traffic was on the primary dispatch channel, the dispatcher would not be able to dispatch other calls and the chances of people talking on top of each other would be high. Instead, those at the incident who are working as groups—the swat team, evacuation team, hostage negotiation team, fire, and EMS personnel—switch over to their own simplex or peer-to-peer channels. Each team leader listens to two radio channels, one for his/her team and one that is a direct link to the Incident Commander. None of this traffic interferes with the primary dispatch channel and each group on the scene can communicate within the group and hear all of the traffic for their own team without disrupting other communications.

The Incident Commander (or team) is in touch with the dispatch center and perhaps a higher-ranking commander and can instantly contact each of the teams on the scene. (The one caveat here is that police, EMS, and fire personnel can usually talk only within their own teams, not between teams. This means that fire personnel can talk to each other but not to police on the scene. Since they are all being coordinated by the Incident Command center, when needed, voice messages are relayed by the IC to the other units on the scene.)

At this point, in this fairly small area within a city there would be numerous channels in use. One between the Incident Commander and the dispatch center, one for the swat team, one for the uniformed officers, one or more for fire, another for EMS, and perhaps one or two more for other specialized groups on the scene. If they all had to share a common radio channel, communications would become confusing, and if someone needed immediate assistance, his/her call for help might be blocked by another person talking on the same channel. Using different and distinct channels for each team minimizes the potential for this type of communications error.

Public Safety agencies handle incidents like military operations. Each group has a commander and a mission, and it is up to the IC to make sure every field commander understands what needs to be done and works with the officers to see that the tasks are accomplished. As new personnel arrive on the scene, they are assigned to a team or a new team is formed, assigned its own communications channel, and is integrated into the incident.

Today, the only information the Incident Commander and the rest of the team have is the verbal description from the person talking on the radio. It might be a swat team sniper on a roof advising the team and commander of the situation inside of the bank and whom and what the sniper can see happening. Based on this information, the team commander and Incident Commander will make decisions about how to react.

When we add broadband and video capabilities to this scenario, it will be like giving a blind person sight. The sniper on the roof will be able to transmit video in addition to voice. The commanders will have both verbal and visual awareness of the situation, which will enable them to make decisions faster and with more certainty of the outcome. Even so, voice is still the most critical element in this type of operation.

The radios being used in this case provide speaker audio to each person on the scene so responders don’t have to hold a phone to their ear. If they need to talk, they simply use one hand and press the push-to-talk button on the radio, leaving their other hand free. Further, when they talk, they know they will be heard by others on their team. It does not matter whether they are in range of a cell site; they only need to be in range of each other. No matter where they are working, on a street, in a sub-basement, or virtually anywhere, they will have communications with at least some of their own team members to be able to provide information and receive assistance when and if they need it.

This type of communications is needed not only during a major incident but also on a day-to-day basis. The officers inside the police cars need to be able to talk to each other car-to-car or to an officer on the street and not tie up the primary dispatch channel. On busy nights, most dispatch channels are already overloaded with calls going out, officers responding, and requests for additional information. Tying up these channels with voice traffic between two officers who are only a few blocks apart is not good use of the Public Safety spectrum.

There are those, including some in our government, who believe that tomorrow’s broadband networks will support simplex communications. I don’t believe that to be true. Think about it. Commercial network operators want people to use their networks so they can charge for minutes of use and data services. It is not in their best interest to push the equipment vendors into building handheld devices that will be able to bypass cell sites, and thus networks, and communicate directly with each other. Another impediment to this is that the amount of transmitter power used in a cell phone to communicate to a cell site is far less than the power used in the handheld two-way radios carried by first responders.

Most cell phones operate in full duplex (transmit data in two directions simultaneously so both parties can talk at once) or semi-duplex mode because they transmit and receive on different portions of the spectrum. If the above capabilities were included in the handsets, another set of transmitters and receivers would have to be included. Further, transmit and receive channels are different in each of the commercial bands. This would present a real challenge to the device and chip companies and would add substantially to the cost of each device. It would also be difficult to build a product that supported enough simplex (peer-to-multi-peer) communications channels to accommodate the many incidents where simplex communications are required.

For example, during the recent fires in Santa Barbara County, the channels being used within close proximity included 18 command channels (same as dispatch channels) and 78 simplex or tactical channels. Every available frequency assigned to the local fire departments, Cal Fire, and the National Fire service was in use. These channels were augmented by commercial cellular networks, and several temporary cell sites (COWs) were brought in, but much of the need was beyond cellular coverage. In fact, some needs were beyond the range of many of the command systems. Using simplex or tactical channels, each group fighting its own portion of the fire had its own channels to operate on while Incident Commanders were able to communicate with the commander of each group.

In the world of commercial wireless, there is a huge growth in demand for data services, and networks already have to take measures to better manage their bandwidth so all of their customers have equal access to their data services. Data is gaining in usage, but voice is still the primary wireless communications tool. According to the Bank of America–Merrill Lynch 2009 survey, the average U.S. wireless customer uses 833 minutes of voice each month. Most networks keep their voice and data traffic separated with most voice traffic running over existing 2G technology networks while most data services are on 3G or wireless broadband networks. There are some 3G systems that mix voice and data on the 3G broadband networks, but voice over IP (VoIP) is not as efficient as 2G voice services, and this will be true for many years to come.

The bottom line is that none of these networks can or do provide access to direct device-to-device voice communications services without the use of a cell site. This is a key requirement for Public Safety systems and will continue to be a requirement even after the nationwide broadband system is completed. Voice, both wide-area and local-area, will continue to provide mission-critical services for the first responder community. Those who believe that broadband systems are the only way forward need to understand that voice systems will be needed for many years, and that neither today’s nor tomorrow’s broadband networks can meet the Public Safety community’s voice requirements.

Andrew M. Seybold

Many of you know from previous Commentary and my new Public Safety Advocate postings that I have been donating time and effort to assist the Public Safety Community in bringing about the reallocation by Congress of the 700-MHz D Block spectrum to Public Safety.

We are coming close to this happening with two bills pending in Congress.

In the Senate we are asking for co-sponsors and support of S. 3756, The Public Safety and Wireless Innovation Act of 2010, introduced by Senator John (Jay) Rockefeller, IV (D-WV).

In the House, H.R. 5081 introduced by Representative King, now with 68 sponsors, is the bill to support.

Another bill, introduced by Senators McCain and Liberman, is  S. 3625.

There will be some action on these bills in September and we need everyone who is willing to write their Senators and Representatives urging them to support these bills.

For more information please see the video on YouTube, which is a message from the fire service. You can sign up to support the Public Safety Community on Facebook and you can click through to see some sample letters for format and content. You can also see sample letters here.

Thank you in advance for your support.

Andrew M. Seybold

I am told that attendees will include the White House CTO, the Department of Commerce, Homeland Security, the Department of Justice, and a “senior Executive” (VP or Senior Director level) attendee from each of the network operators and broadband vendors. This list of attendees seems strange to me. If the Executive Branch is trying to help the networks and vendors with the “issues and barriers” regarding entry into the Public Safety Broadband market, shouldn’t they have invited some Public Safety people? These people could talk about Public Safety needs and requirements and promote a dialogue about how commercial entities can work together and with them on achieving a fully interoperable, nationwide Public Safety Broadband network.

I recently heard rumors that the meeting has been expanded to include Public Safety, but so far they are only rumors and I have not heard who the Public Safety representatives will be—if, indeed, they have been invited. When I muse about this meeting and its stated purpose, the first thing that comes to mind is that for some reason, the Executive Branch is trying to convince those within the commercial wireless community supporting efforts to have the D Block reallocated to Public Safety to cease in their efforts so the D Block can be auctioned instead. If auctioned, commercial operators and vendors will be able to provide additional equipment and services to Public Safety.

I have many more questions about this meeting. The attendees are supposed to be senior-level executives, one from each company. While these people are an important part of the management of their own networks and companies, most of them are not well versed in the two most important issues that face the Public Safety community: 1) What are Public Safety’s requirements for day-to-day and emergency operations of broadband systems, and 2) How, exactly, will the new commercial LTE networks deliver some or all of these requirements?

This, of course, brings up even more questions. How many of those attending are familiar with the Incident Command structure and how it is employed during routine and more serious incidents? How many attendees have actually ridden along in a police car on a Friday or Saturday night? How many have been inside a base camp during a wild land fire (let alone out on the fire lines)? How many have been directly involved during a hostage situation or a multi-vehicle wreck on the highway?

In other words, how many of those attending have any firsthand knowledge of the requirements of the Public Safety community? We all know the answer to this. It is not what they do, and Public Safety will only provide a small portion of their company’s revenue. Senior-level executives are charged with helping manage their company and this includes making sure stockholders are looked after, the bulk of their customers are satisfied with their products and services, and helping guide the company to greater profitability in the future.

I wonder what the motivation is for this meeting and who really called it. Why is the Executive Branch CTO involved, and what is the agenda? I, for one, don’t see any reason that the government should care about market-driven economics (which have been driving the wireless industry for many years), unless it has an ulterior motive. Or because those attending the meeting are opposed to the D Block reallocation to Public Safety and have put pressure on the Executive Branch to try to stem the tide of the backing Public Safety has gained with members of Congress.

One of the attending companies has given me two different answers to my questions about building product for Public Safety. The first was, “We are not interested because there is not enough volume.” The second, from a different group within the same company, was, “We can build what you need but we will need $6-8 million in non-recurring engineering money to do so.” I have to wonder which view the executive from this company will be presenting.

A representative of one of the network operators has told me on several occasions that the only reason the company wants the D Block is so it can make sure it has roaming rights on the other 700-MHz LTE networks. He fully acknowledges that the D Block with its 10 MHz of spectrum is not enough to serve its customers, but believes this is the entry point into roaming agreements with the others. This when the FCC has not yet addressed the roaming agreement issue and could, in fact, recommend that roaming agreements be put in place even if a network operator does not have 700-MHz spectrum.

This meeting, if held without Public Safety participation, will not decide anything. It cannot because those in the room, while very qualified at what they do, are not qualified to speak for the Public Safety community and its needs and requirements. If Public Safety is included in this meeting, those planning it will probably invite individuals who are not necessarily the best choice for speaking for the community as a whole and who are not knowledgeable in broadband technologies.

I have seen for myself over the past year or more how much misinformation there is about LTE and its capabilities when it comes to total bandwidth, priority access, multi-casting, and voice services. I have read and responded to a number of FCC white papers that were written by academics with no real-world knowledge of LTE or broadband, and who, therefore, made assumptions that are not valid once you look under the hood of the technology and its capabilities. I have to wonder how a group such as this can have discussions that are relevant to the issues and address the needs of the Public Safety community.

I would like to ask those setting up this meeting to define the agenda and to define what outcome they are trying to achieve. The issue of D Block reallocation is already the subject of much misinformation in many different governmental organizations, and from what I can see, this type of meeting will only add to the problem.

I believe this meeting, called on short notice, is a reaction to pressure from those who have their own agenda or are feeling the pressure from those advocating reallocation of the D Block and are looking for a way to slow down the growing public opinion that Public Safety has been short-changed long enough and it is time to provide a resource it desperately needs.

Andrew M. Seybold

It is clear to me that at the core of this debate is the issue of who will actually control the D Block and manage how it is allocated when there is available capacity. The FCC’s position is that the D Block should be owned, operated, and managed by commercial network operators that will work in conjunction with Public Safety on an as-needed basis. Access to the commercial network will be on a priority basis for Public Safety, and the FCC seems to believe priority access is sufficient.

The Public Safety side of the debate is that Public Safety should own, operate, and manage the network and where there is capacity, others should be able to use the network with Public Safety being able to take full control of all of the spectrum on an as-needed basis. Those that would be using the D Block and perhaps some of the Public Safety spectrum as well in rural areas would enter into agreements that would predefine their rights of access. They would become customers of Public Safety with a full understanding that Public Safety has complete and pre-emptive rights to all 20 MHz of the spectrum when needed.

Public Safety has said repeatedly that it is more than willing to work with others and enter into public-private partnerships but that it needs full control over the network’s daily operations. Rightfully, Public Safety questions the viability of a commercial network operator deciding where and when to grant priority access to Public Safety. This is a valid concern and neither the FCC nor the commercial operators have addressed it to the satisfaction of the Public Safety community, though Public Safety has been outspoken about how its solution would work.

The amount of available spectrum will change based on geographic area, population density, time of day, and the type and scale of incidents in which the Public Safety community is involved. Meanwhile, commercial operators continue to face increased demand for voice, text, data, and video services from their customers and it is well known that during times of major Public Safety activity, e.g., for a bank robbery or a multi-car collision that can occur any time of day, the demand for broadband and voice services spike for both commercial networks and Public Safety. Expecting a commercial operator to deny service to its regular customer base to satisfy Public Safety’s needs will be almost impossible to mandate. Even if mandated by the FCC, the commercial network operator will have to decide whether it agrees with a request for priority access on its network on an incident-by-incident basis.

Commercial networks are run by large companies with multiple layers of management and they have operations centers that may be hundreds or thousands of miles from the incident in question. Public Safety’s need for bandwidth is immediate and cannot be pre-planned. Having to request priority access and have it granted on an incident-by-incident basis is not a practical solution. Delays in providing the bandwidth could hamper personnel at the incident. On the other hand, I don’t believe commercial network operators would agree to Public Safety being able to grant itself priority access without regard to how congested the commercial network traffic may be. The units in the field that request priority service would be competing with commercial customer requests for service, so it does not appear that there would ever be true “right now” Public Safety priority access to commercial networks. The FCC’s other answer is to pre-stage additional cell capacity mounted on vehicles that can be deployed to an incident when needed. This, too, is unrealistic except for long-term incidents of major proportion such as hurricanes, floods, fires, and the like.

Therefore, the Public Safety community has presented its own idea for priority network management, which is to reverse the process of who has control. Instead of having to contact the commercial network operator or work with it on gaining priority access at some future point in time (time is critical, especially in the early stages of an incident), control over the network would be given to the Public Safety network operator and would be managed in real time. This would provide Public Safety with the assurances that it would have full, pre-emptive priority over all of the spectrum on an as-needed basis.

I believe that commercial users, knowing the circumstances of their network usage ahead of time, would sign up for service and work with Public Safety. I also believe that Public Safety will be cognizant of commercial users’ needs and would take only what additional spectrum is needed for an incident, perhaps bumping the commercial customer down to a lower data rate. If the incident grew and new bandwidth was needed, the commercial customer would be bumped down again and not have any access until such time as Public Safety’s demand for broadband services was reduced.

This method will work, and it is especially viable if you consider that Public Safety will not have to work with individual commercial customers and compete with commercial network operators. Rather, it will work with other city, county, and state agencies, rural power companies, perhaps some rural cellular companies, and organizations that want to use the network to provide broadband to commercial customers in rural America for education, medical, and other uses. These types of partnerships can provide access to both the Public Safety community and these other tenants, and reduce Public Safety’s cost of building out the network and day-to-day operations.

The business model for developing this type of network is readily apparent, as is the fact that as the networks are built out, they will provide broadband services to rural customers years ahead of anything under consideration today. A few examples of the types of partners Public Safety could work with are:

• Rural power companies
  • What they want
    • Smart grid access
    • Broadband access
    • Would like to resell broadband to their rural customers
  • What they have to offer
    • High-tension towers for site location
    • Right-of-ways for backhaul systems
    • Trucks in the field that can be used to equip their rural customers for broadband
    • A desire to partner with Public Safety on this network

• Educational institutions
  • What they want
    • To partner for broadband connections to schools and the student community
  • What they have to offer
    • Access to schools and other properties for cell sites
    • Lease agreements

• Other government agencies
  • Need broadband access
    • City power and water companies
    • Other city agencies
    • Suburban county governments
    • Rural county governments
    • State agencies
  • What they have to offer
    • Lease agreements (funding)
    • Additional sites on government-owned properties

• Tribal lands
  • Need broadband access
    • For Tribal Public Safety
    • For Tribal broadband services
  • What they have to offer
    • Lease agreements
    • Tower sites

• Rural medical services
  • What they need
    • Connections to medical facilities
    • Connections to doctors’ offices
    • Connections for visiting nurses
  • What they have to offer
    • Lease agreements
    • Access to medical buildings for cell sites

There are many more types of organizations that could be potential partners, but the above list includes enough organizations to make a solid business case for building out the network as envisioned by the FCC: 44,000 cell sites covering 95% of the population.

In most major metro areas, Public Safety will be using all of the spectrum most of the time. In smaller metro areas, suburbs, and rural areas, there should be enough bandwidth available for these other services, again with the caveat that Public Safety will have full control over the network and be able to allocate resources on an ongoing basis. One example might be in a rural area where a power company is using part of the bandwidth for meter reading at 2:00am and there is a major fire. First responders would use more bandwidth during the incident, including some or all of the spectrum normally available for meter reading, until the incident commander can release some bandwidth, at which time it would be reallocated back to the power company.

The results would be almost the same as what is envisioned by the FCC

• Funding to help with the construction and operation of the network
• Sharing of bandwidth when available
• Public/private partnerships

The ONLY difference here is that the Public Safety community would manage the broadband network. The network would be more tightly integrated for Public Safety devices and applications, and during times of need, Public Safety would not have to contact a commercial network operator to request priority access. All of the other aspects of the FCC National Broadband Plan would remain in place, including Public Safety roaming over commercial networks when there are major incidents, but this type of roaming would not be needed on a daily basis and it would fall under the FCC’s plan.

I don’t believe commercial network operators want to be in a position of having to make their networks available on a priority basis every day in major metro areas, nor do I believe the type of priority access available in the LTE specifications meets the needs of the Public Safety community. There is no guarantee of full pre-emptive priority, nor are there any mechanisms to ensure that during times of elevated demand on both commercial and Public Safety networks, Public Safety will truly have the level of priority it needs to protect and save.

Further, while LTE is a standard, there are several Public Safety application requirements that are different from those of most commercial customers. Commercial and Public Safety networks operate differently and roaming on commercial networks could result in confusion in the field at times when there is enough confusion in trying to handle the incident. Indeed, LTE is the smartest of all broadband technologies to date and there are many different ways to set allowable data rates, handle capacity, and handle traffic overflows. Most commercial network operators configure their networks to serve the greatest number of commercial customers by managing available bandwidth. Even with priority, there is a serious risk that the most important Public Safety users will be shut out of the network. This is simply not acceptable for mission-critical Public Safety communications.

Reallocating the D Block to Public Safety does not impede private/public partnerships nor does it change the fact that commercial customers can be accommodated over the network, but it does mean that Public Safety will be able to earn revenue from such usage. In fact, it does not diminish any aspect of the FCC’s vision for Public Safety, it simply changes who has control of the network so Public Safety is guaranteed full access when needed.

This seems like a reasonable modification to the FCC’s recommendations though it does prevent the government from collecting auction funds for the D Block. But in the overall scheme of things, even if the funds amount to $3 billion, that is less than one day’s growth of our national debt. Reallocating the D Block to Public Safety is the best approach for all of the stakeholders, including the FCC.

Andrew M. Seybold

Mel has been involved with public safety for more than 30 years. First as a certified practicing Paramedic, and then in the industry including the company that developed the first paramedic voice and EKG field unit. During his career at Motorola, he held a number of positions working in both the public safety and commercial cellular infrastructure markets. Today he is a consultant to several public safety entities in the Southern California area.

I attended a conference a few years ago where a noted economist was the keynote speaker. His presentation had to do with predicting the U.S. economy over the next few years. He started with a statement that applies here as much as it does in economics. “All economists’ predictions are wrong; the question is which are least wrong.”

For economics and finance, investments win and lose based on predictions. But cash is a liquid asset, and losses (or gains) can be quickly reversed. Our radio spectrum is not a tradable asset and mistakes cannot be quickly or easily corrected.

In the case of the D Block debate, we have experts on all sides making all kinds of predictions. Who will be the least wrong, and what will it take to, as the FCC says, “fix it later”?

I assert that the decision to split the D Block, made at a macro level, can have devastating consequences at the micro level. Since there is a high probability that any decision will be at least partly flawed, I believe that it is the FCC’s duty to err on the side of caution. To that end, the anticipated $3 billion raised at auction should be nothing more than a tiebreaker because it is of the least value in the entire discussion.

If you will allow me some latitude and follow my logic, I will try to clarify what I think are some points that are not being given due consideration. This is not an engineering exercise. We all know that engineers, given enough paper, can prove that “Heaven is Hotter than Hell[1]” (by the way, it took seven years to refute that argument).

As I see it, the argument here is not whether there is enough spectrum to go around—we all know there isn’t. The FCC even says in its discussion of this pending decision that by keeping the spectrum in its split form, public safety should have enough capacity to meet only its routine requirements. This is instead an argument of who will be blocked and under what circumstances.

Before I continue, I must ask the FCC, with no disrespect intended, exactly whom are you trying to serve? I always thought it was your job to create policy that is in the best interest of ALL stakeholders. At the table now, you have federal taxpayers, airwaves, yourselves, private (cellular) network operators, electronics manufacturers (hardware and software), public safety, and local taxpayers. But your deliberations and recommendations appear to be in conflict.

You told Congress that for broadband to work we need wide swaths of contiguous bandwidth. You allocated the D Block after rigorous debate and input from a myriad of sources. Even during those debates, everyone seemed to agree that from a usage standpoint, allocation of the full 20 MHz (2×10 MHz) is the most efficient. Now you want to keep the block split into smaller pieces in order to raise money? You posed this new plan without thoroughly examining the potential consequences, i.e., now you want to find out whether a guard band might be needed. Am I missing something? We have a $trillion deficit and you think you can balance the budget by auctioning $3 billion worth of spectrum that might not even be equitably divided (see below)?

Sorry, I got sidetracked. Really FCC, what is the driver for this sudden change of position? I thought government finance was the purview of the IRS and FTC. I see no logic other than this keeps a lot of very smart FCC engineers busy justifying a (new) FCC position. It’s not an industry or constituent position, and it is not in concert with accepted best practices or other FCC positions.

As with most problems, there appear to be different ways to handle this:

1. Give (auction) the entire block (20 MHz) to commercial network operators and let market forces determine how much access public safety will enjoy.
2. Assume that the commercial network operators should control half of the spectrum, public safety gets the other half, and public safety will have “priority” roaming into commercial spectrum when the need arises.
3. Allow public safety to control the entire block and allow commercial users to roam into that portion on a non-priority basis.

The first option has already been taken off the table. Item #2 is the focus today; however, I believe #3 should be considered much more seriously.

What Is an Emergency?

Getting to the heart of the question, who needs capacity and when? Well, that seems to revolve around the definition of an “emergency.” So we are all on the same page, I personally like the definition that says, “anything that cannot be handled by the person on the scene is an emergency.” The federal government has an emergency when some disaster affects thousands of people, over a wide area, and typically extends over a long period of time, usually weeks or more. For some reason, the focus seems to be on the data-passing needs of this type of emergency.

Local public safety, in every city in the nation, has an emergency when it needs to send ten fire trucks and ten police cars to a high-rise fire in downtown, or there’s a water main break that closes streets, or there’s a chase on the freeway.

What’s the difference? Widespread disasters happen perhaps a dozen times a month but in different areas of the country. The “smaller” emergencies happen every day, in every city, and “big emergencies” are made up of a cluster of smaller emergencies. The NIMS Incident Command system is in fact based on the concept that “all incidents begin and end locally.”

I submit that capacity at the local cell site/sector level is the most critical component of the communications network. If access is limited or denied at this point, all the priority routing in the world is of no value to the personnel dealing with the problem. Additionally, these local incidents cannot be predicted or planned with respect to location, time, size, or potential to grow into large emergencies.

We all agree that neither commercial nor public safety communication systems have the capacity to serve all users all the time. Blocking and “hot spots” exist on a daily basis in nearly every system, public and private, across the country.

The Fiction of Priority

When I read the National Broadband Plan submitted to Congress by the FCC only three months ago, I did not find anything that said, “public safety only needs enough bandwidth (capacity) to serve its routine requirements, and should beg for additional capacity during an emergency.”

Don’t fool yourself, “Priority Access” invoked due to capacity constraints on any system is a Hail Mary. Its existence is based on the presumption that a system was built with insufficient capacity in the first place. Priority access in any but the most exceptional cases has too many unintended consequences to be relied upon, especially during emergencies.

Let’s think about a few scenarios to get in the mood:

• Public Safety Answering Points (PSAPs) enjoy all kinds of priority service. But there are almost daily examples of calls being blocked due to incoming trunks being overloaded or being routed to a PSAP with an insufficient number of call takers. Calls do not get through, dispatch doesn’t know who needs help or where, and citizens are not served.
• Most government officials are familiar with GETS (Government Emergency Telecommunication Service). As the literature says, “once the system is accessed and a user is authenticated, their call receives priority routing” through the phone system when it is overloaded. What is not emphasized here is that if the user picks up a phone and there is no dial tone, the priority is of no value, and the call does not get through, period. The weakest link in the system is the end-point where capacity is least.
• Imagine what might happen if a local system (think at the cell site level) is built to handle “day-to-day” call loads. All local public safety and (for interoperability) all federal agencies have priority access. Something bad happens in front of a federal building that is basically served by one cell site. (I think the FCC would consider this a local emergency.) Is there a possibility that the “priority” responders could busy themselves out? Who will really have “priority,” and who needs it? Fire? EMS? Would your decision change if you were inside the building?

So can we agree that communication systems function best when they do not block calls?

How to Make It Worse

Undisputed is the fact that broadband gains efficiency (in terms of data speed and/or number of users served) as bandwidth increases. The D Block, as it is currently described, consists of two, 10-MHz slices of spectrum (aka, 2×10 MHz, or 20 MHz); one slice is for uplink and the other for downlink. What is being considered is to split each of these slices.

To make things simple, let’s talk about only one of the 10-MHz blocks. First, the LTE emission was designed to operate in 10-MHz, 5-MHz, 3-MHz, or 1.4-MHz bandwidths. It would seem as though splitting the 10 MHz into two each 5-MHz blocks would result in the same amount of capacity, right? Wrong.

I won’t even attempt to deal with the nuts and bolts of the question, “will a guard band be required, and how much?” that the FCC has most recently posed. I will simply say that if a guard band is needed, it automatically means that one or the other (or both?) of the 5-MHz pieces will in fact not be 5 MHz. Anything less than a full 5-MHz allocation means that only one 3-MHz, LTE channel can be used in that piece. Who will accept the lesser “half,” public safety or commercial network operators? It is a sure bet that the auction value will be reduced if the limitation is placed on the commercial side. So maybe it’s best to further limit public safety? After all, it can simply do a little more “priority roaming” on the commercial system. Right?

So we will ignore that little gem sitting in the middle of the room and deal with a couple more facts.

The single 10-MHz channel yields more usable capacity than two 5-MHz channels. First, channels cannot bump against each other where they meet in the middle. The usable emission is always less than the allowed bandwidth because there have to be “skirts” on the edges of each channel to reduce interference to the adjacent channel. So those two little pieces in the middle, between the 5-MHz slices, represent lost capacity as compared to a single, contiguous 10-MHz channel that can use that space.

Next, if you would like to ignore these other really inane spectrum issues, you need to know that there are all kinds of technical things that must happen to facilitate hand-offs between two different channels. So when you have multiple public safety responders in an area and some are in the public safety channel while others are “roaming” in the commercial part, there are potential prioritization and routing issues that can affect call completions (or dropped calls like we have all experienced).

Finally, can anyone prove that the true spectrum utilization is equal when you have two subscribers under the same cell site and sector receiving streaming video from the same source, but one is on the public safety block and the other has roamed to the commercial side? The logic of the FCC position on the D Block is therefore in question on this point alone since the D Block allocation is all about addressing a shortage of capacity.

Let’s face it, anything less than a single 10-MHz block allocation is bad policy, bad practice, and bad engineering. The FCC already said it needs an additional 500 MHz of spectrum for broadband over the next ten years. This spectrum is extremely valuable to public safety right now and in the future.

We know that public safety systems are expensive, complex, are not easily modified, and must stay in service for a long time in order to achieve value for the taxpayer. Artificial system constraints imposed by ill-conceived rules make these systems functionally inadequate, thus frustrating the national objectives of securing communities.

Therefore, I suggest that strong consideration be given to the concept that allocates the full 20 MHz (2×10 MHz) as a single block to public safety so the spectrum can yield its maximum potential capacity.  In the interest of the public good, and to enable tighter integration with commercial network operators, condition the allocation on agreements and system architectures being implemented such that commercial users can roam into this spectrum on a non-priority basis.

This isn’t a question of who’s right about how much bandwidth is needed. It is about what public safety does every day—making a judgment decision that errs in favor of the best interest of all involved. This is an opportunity for the FCC to make a single allocation that by some measures “might be excessive” for public safety.  Or it has the opportunity to continue down the path that says, “Well, if we’re wrong, we THINK we can find a way to fix it later.” (How does the FCC define “if,” “fix,” and “later”?)

Mel A. Samples

Dear Chairman Genachowski and Representative Waxman:

In reference to FCC Chairman Genachowski’s letter of July 20, 2010, and the answers to the questions attached to that letter, I would like to respectfully offer a different viewpoint on a few of the answers that were provided. Let me say, in advance, that the area of public safety communications and its requirements is one of the most misunderstood aspects of wireless communications in government, and many people tend to equate the use of commercial networks and their operation with public safety requirements. This is understandable as cell phones have been used in the United States since 1981 and today there are more than 280 million people in the United States and more than 5 billion around the world who use commercial networks for voice, text, data, and video services.

There also seems to be a belief that broadband wireless networks will be able to fully replace conventional and digital channelized voice services in the future. While this is partly correct, the reality is that voice services over broadband will NOT provide the ability for units in the field to communicate directly with each other without the assistance of a cell site or main radio site. The specifications for LTE[1] (Long Term Evolution) do not include the ability for units to communicate without the use of a cell site. LTE is a global standard that is being developed by the 3GPP and it is designed primarily to provide high-speed data and video services. While voice in the form of VoIP or “One Voice”[2] as it is being referred to in the commercial community will, at some point, be viable over LTE networks, the specification does not include the ability for field units to talk directly with each other. The chances of this type of provision being added into a global specification that will be implemented over multiple portions of the spectrum with multiple, varying offsets between cell site transmissions and device transmissions when there is no demand for this type of service from commercial network operators is very slim.

Therefore, it is important to realize that channelized communications networks will be needed for many years to come. Today they provide an important element in the overall communications plans for the public safety community. Channelized spectrum already allocated in the 700-MHz band for public safety[3] includes channels that are set aside for public safety today use as part of the overall interoperability solution. Some of these channels have been set aside for nationwide first responder voice networks and some are for nationwide interoperability channels for use at the scene of an incident and for command-and-control functions that do not require the use of cell sites. There are also interoperable channels for state and regional systems, and typically, each mobile device will be equipped with the local channels used for day-to-day operations as well as all of the regional, state, and national common channels. The band plan currently being implemented across the United States is key to solving public safety’s interoperability issues.

Broadband is a major requirement for nationwide interoperability, which is one reason the public safety community is asking both Congress and the FCC to reallocate the D Block to public safety,[4] but without interoperable voice systems in place as well, broadband will only solve some of the problems. The FCC was forward thinking in its allocation of the 700-MHz channelized spectrum, which is already in use in many areas of the nation, and many other systems are being planned and funds allocated on a monthly basis. If the public safety community loses the ability to operate on these channels, it will negate all of the good that will be accomplished by allocating broadband spectrum for public safety use.

I have, in the footnotes below, referenced a filing[5] I submitted to the FCC on the subject of public safety voice communications and I ask that both of you consider not only these comments but those in filings by the State of Delaware, Maryland, Ohio, and soon many others.

If you have any questions or would like to discuss this matter in more detail, I will make myself available to you, and I am sure many members of the public safety community will as well. My specific responses to Representative Waxman’s questions to the FCC Chairman and his answers follow this letter.

Respectfully submitted,
Andrew M. Seybold
CEO and Principal Consultant

Andrew Seybold’s Comments on FCC Chairman Genachowski’s Response to Questions Asked by Representative Waxman

Question 1: 1. Please provide a list of the top four vendors of public safety narrowband equipment and their respective market shares. If the FCC does not track this information independently, please use public references to provide these details.

No Comments

Question 2: Have proprietary solutions affected interoperability, innovation, cost or competition in the market for public safety communications equipment?
a. How would the greater use of open standards affect these factors?
b. What steps should the FCC take, if any, to encourage the use of open standards in public safety communications?

As mentioned in my letter, the use of channelized spectrum for voice services is not supported by current and future commercial standards. The premise for commercial networks is that each customer must be in range of a communications tower in order to use the system. Commercial standards do not include the capability for units to communicate with each other in the field when outside network coverage, and they do not provide the ability to relieve network congestion by switching to a non-network channel in order to communicate over short distances.

The issue of P-25 versus Tetra can be debated, but BOTH P-25 and Tetra are designed for channelized voice systems and both support communications via a communications tower and without a tower. Both are designed primarily for use by public safety. Further, many Land Mobile Radio users have moved to cellular systems since they do not require one-to-many or point-to-point device communications so the total available market has become significantly smaller. Commercial vendors are able to build products that sell for less simply because of the larger quantities. As you are aware, Apple recently sold more than 3 million iPads into the market at prices that vary from $400 to $900 per unit. It is the number of units sold, not the technology that sets the price of devices. The more devices a vendor builds, the less it pays for parts and materials, which means it can charge less for the devices.

Finally, I would like to point out that in addition to the difference in quantities involved, public safety radios must also be built for many different portions of the spectrum. Today’s public safety channels occupy slivers of spectrum in the 30-50 MHz band, 150-174 MHz band, 450 MHz band, 700 MHz band, 800 MHz band, and some of the larger departments are sharing TV spectrum in the 470-512 MHz band. Each vendor, therefore, builds fewer radios for each band. One reason for the difference in pricing between P-25 radios and Tetra radios is that in Europe there is a common frequency band for Tetra public safety systems, therefore the vendors can build a common radio with a much larger market, which puts pressure on the device pricing.

Question 3: Please provide information on whether the public safety interoperable voice network, governed by Project 25, has achieved true interoperability.
a. Has interoperability been hindered by a lack of competition in equipment and device availability?
b. To the extent that interoperability has been hindered, please provide specific examples.

I would like to respectfully disagree with the FCC Chairman’s response to this question. In reality, and given the budget constraints of states, cities, and counties, the public safety community, on its own, has made major strides toward voice interoperability in recent years. There was certainly a delay in the process while public safety waited for actions from the FCC and the Department of Homeland Security, but once it became clear that the first steps toward interoperability would have to come directly from within the public safety community, much has been accomplished.

As mentioned above, in the 700-MHz channelized spectrum, channels have been set aside for nationwide, statewide, and regional interoperability channels. Further, these types of channels are already designated for the VHF, UHF, and 800-MHz public safety allocations. A number of newer statewide systems have come online in the past two years and more are in the planning and development stages. There is more work to be done, some of which is hindered by the public safety channels being spread out over a vast amount of spectrum and because there are not enough channels in any one portion of the assigned spectrum to permit true interoperability. The best chance public safety has is to work toward the consolidation of systems in the 700-MHz and 800-MHz bands that are close enough to each other to permit all of the channels to be built into a single radio. It is also important to recognize that in many spectrum-starved areas of the country, 700-MHz radio frequencies have only been available for one year as public safety awaited the digital television transition last June.

Further, where Land Mobile Radio systems are not able to communicate with each other, the public safety community has been implementing and installing IP bridges so channels on different portions of the spectrum can be linked together to provide interoperability on an as-needed basis. This is not the best way to provide interoperability since each of these connections requires two or more channels to be tied together and the number of units per channel becomes an operational issue, but it is currently being deployed as a workaround.

Finally, many departments are solving SOME of their interoperability issues by installing two or more radios in each vehicle. This costs more money and is not an efficient use of resources, but it does provide for interoperability at least on a regional level. When addressing the issue of voice interoperability, some vendors are also designing and selling handheld radios that have capabilities across multiple portions of the spectrum. However, these radios, built in small quantities, are expensive and will most likely only be used by command personnel at an incident.

Question 4: Does the current structure of the public safety equipment market hinder efforts to achieve interoperability for a broadband public safety network? If so, please provide a description of possible steps the Commission might take to remedy this action.

The FCC Chairman’s answer to this question does not reflect an understanding of the differences between broadband networks and channelized communications. Once again I refer you to the attached filing with the FCC. The issue of the D Block and its reallocation is of vital importance to public safety, especially if the Commission believes that some form of voice communications will be used on this network in the future. Broadband communications in the form of LTE will not support communications between field units that are out of the range of a tower or that need smaller talk groups during an incident. During the recent Santa Barbara fires, the communications system that was set up for fire personnel made use of 18 command-and-control channels and 78 dedicated channels for operations in the mountains above Santa Barbara, and all of the commercial networks. These allocations were for fire personnel only and do not include the channels needed by law enforcement for its own operations that included massive evacuations, coordinating road closures, and crowd control. LTE is simply not designed to provide the level of communications vital to the public safety community on a daily basis.

It is my belief, and that of many expert LTE design engineers, that LTE will not incorporate standards to provide for peer-to-multi-peer communications because this is not a requirement for commercial operators. Therefore, separate channelized voice communications will be an ongoing public safety requirement for many years to come. Once again I request that you read the attached, which I filed with the FCC and that also appeared on my website and in several other publications.

Question 5: Section 101(b) of the staff discussion draft sets forth criteria for the Commission to consider in establishing rules for interoperability. How should this list be revised to ensure that interoperability is achieved in the broadband network, unlike the “failure” that occurred in the narrowband network? What technical and operational framework might be more appropriate to ensure interoperability on a future nationwide wireless public safety broadband network?

My only comment on this response is that I believe the public safety community, through representation, should be an integral part of the process. The public safety community has come together over the issues concerning the allocation of the D Block and is solidified in its desire to make this network truly interoperable from day one. It is imperative, in my view, that public safety be empowered to work with all of the stakeholders to help ensure that the result is a fully interoperable and seamless network.

Question 6: Can interoperability requirements applied to the wireless public safety broadband network be utilized to promote interoperability between narrowband and broadband networks?

Again, I respectfully disagree with the FCC Chairman. Broadband networks including today’s 3G networks and the upcoming LTE networks do not support all of the various types of voice communications that are a daily requirement for public safety. Certainly, in a few years, SOME public safety voice traffic will be able to be migrated over to broadband, depending on how the multi-cast element is implemented within the standards organization and the variations of the multi-cast capabilities.

For example, in major cities, dispatch channels are usually assigned by district or geographic areas, with perhaps a few more for citywide operation. The FCC has set guidelines as to the number of units that can be handled on a single dispatch channel for channelized voice and it should probably do the same for broadband dispatch as well.

It is also important to recognize that LTE and broadband still have not addressed some of the most basic and fundamental public safety communications issues that preclude exclusive use of broadband for all public safety communications. As but one example, LTE and the 3GPP standards still do not permit a public safety user to be instantly granted access to a radio frequency when needed. Contemporary land mobile radio systems are designed to instantly grant access to a user when an emergency is declared. LTE, conversely, provides priority access or places the user at the head of the line for access when available. This topic and broadband challenge was discussed in detail at the recent House Sub-Committee hearing presided over by Representative Richardson.

I believe that broadband voice, once it becomes available, should be first used for non-mission critical communications and administrative and cross-jurisdiction communications, and later, if it proves to be reliable, for dispatch. But again, broadband voice will not meet the needs of public safety for day-to-day and emergency scene-of-the-incident communications.

Attached:

“Incident Communications,” by Andrew M. Seybold,   http://fjallfoss.fcc.gov/ecfs/comment/view?id=6015694461

The FCC’s recommendation to Congress in its National Broadband Report submitted in March of this year was to auction the D Block without any rules requiring the winner(s) to cooperate with Public Safety as in the previous auction. Further, the FCC continued to make its case at public meetings and with the publication of white papers, one on the cost savings that would be realized in network deployment and operation costs and one that contended that Public Safety did not need more than the 10 MHz of spectrum already allocated to it for broadband services.

Prior to the events scheduled for the 21^st, Representative Peter King (R-NY) had introduced a bill (H.R. 5081) that would re-allocate the D Block to Public Safety but not provide for federal funding of the network. As of the week before the event, the bill had attracted 35 co-sponsors. There was also draft legislation being circulated by Representative Henry Waxman’s (D-CA) office providing funding for the network, BUT calling for the D Block to be auctioned to help defray the cost of the network.

No U.S. Senator had yet weighed in on the matter, and while the King bill was gaining sponsors, the Senate remained silent. Then on the morning of the 21^st as the meetings were taking place, Senator Jay Rockefeller (D-WV) issued a press release stating he would be introducing a bill that would not only reallocate the D Block to Public Safety but would fund both network construction and operational expenses with proceeds from future auctions.

Meanwhile, the PSA had obtained an advance copy of a proposed Senate bill co-sponsored by Senators Joe Lieberman (I-CT) and John McCain (R-AZ) that called for the D Block to be re-allocated to Public Safety and included funding for the network using proceeds from future auctions. It even includes a provision that the U.S. Treasury could advance funds to the Public Safety community so construction of the networks could begin without having to wait for auction proceeds to be collected.

As time for the press conference drew near, the buzz around all of this activity was giving those attending a sense that perhaps Public Safety, with the help of Congress, could really reach its goal of acquiring the D Block and funding for network build-outs. The press conference, held outdoors in 97-degree weather with no shade in sight, was well attended by Public Safety, APCO, the press, and a number of Congressional staffers who have been working with members of the PSA on these issues. The actual press conference received a real boost when both Senators Joe Lieberman and John McCain not only showed up, but spoke on behalf of the Public Safety community.

Following their speeches, various members of the PSA spoke as one at the event. It was pointed out several times that this was a historic occasion not only because of the new support from the Senators, but because this issue has solidified the Public Safety community and, through the PSA, its members are acting as a single organization. Even though the PSA is made up of a wide variety of Public Safety entities, they are all working together for the common good of the entire community. It is this unity, I believe, that has helped convince various members of Congress that this matter deserves their attention and that re-allocating the D Block and funding the networks is necessary to provide Public Safety with a true nationwide, interoperable data network that in the future will also include interoperable voice communications (but will not be a replacement for existing mission-critical voice networks).

I was included in a number of meetings with Congressmen and staffers on Wednesday and Thursday. At each meeting, we were greeted cordially, our points were listened to, and questions were asked and answered. Though not all of those meetings resulted in a promise of support, by the end of the day on Wednesday, the number of co-sponsors of the King bill had grown from 35 to 56 and it is still growing. One of the most interesting things about the political system we have in place in the United States is that we now have enough momentum behind the bill so that Congressmen are asking their staffers to sign them up as co-sponsors as well.

Shortly after Senator Rockefeller issued his press announcement about his bill introduction, the FCC sent out notices to the press that it would hold a press call. Most of the press on the call had only about twenty minutes warning so it is obvious that this call was supposed to be a swift reaction to the Rockefeller press release. Since I was in meetings and not on the call, I have talked to several people who were and they all have told me the same thing. The call was “on background” and the FCC participants could not be referred to by name, but missing from the call was Admiral Barnett, the head of the Public Safety and Homeland Security Bureau, which is the group within the FCC that has been pushing to have the D Block auctioned.

The call provided inconclusive information about a possible FCC shift in stance regarding the D Block auction, but one statement was interesting in itself. When asked about the FCC’s position on the D Block, the response was that the FCC had ALWAYS believed it was up to Congress to determine the fate of the D Block and not the FCC, since currently the FCC is under direction from Congress to auction the D Block.

The reason I find this comment so interesting is that the FCC, in the National Broadband Report and many communications and public meetings since then, has ALWAYS strongly recommended to Congress that the D Block be auctioned. The National Broadband Report states, “The FCC should quickly license the D block for commercial use, while implementing several requirements for the D block licensee(s) to maximize options for partnerships with public safety. First, the FCC should require the D block and the public safety broadband licensee(s) each to operate their networks using the same air interface technology standard. The emerging consensus of the public safety community and carriers is that 700 MHz networks will use the Long Term Evolution (LTE) family of standards.”—Contained in section 16.1 of the plan. In both the costing and capacity white papers published by the FCC after the report was submitted to Congress, the conclusions were that the D Block must be auctioned, and it must be auctioned quickly. Not ONCE in any of its written or spoken comments, has the FCC ever said that the fate of the D Block should be decided by Congress.

When the National Broadband Report first came out, I wrote about how the FCC was adamant about the D Block being auctioned and I questioned its motivation for its recommendations, stating that the FCC could have simply indicated to Congress that this was a matter that should be decided by Congress. Instead, it used its role as the telecommunications advisory organization to Congress to strongly recommend that the D Block, in fact, should be auctioned. Subsequently, the FCC reiterated that position over and over again. However, if its stance now is that it has always felt this was a matter for Congress to decide, I guess I will give it the benefit of the doubt. After all, this is not about proving someone or some agency wrong, it is about doing the right thing for Public Safety.

Timing Is Critical

I have been told by several members of the DC press that Rockefeller’s press release, in and of itself, has taken the option of a 2011 D Block auction off the table. However, I am hoping that while the pending and draft legislation is being combined in a single bill (see below), senior members of Congress will write a letter to the FCC Chairman telling him (or is that ‘suggesting’?) that the D Block is not available for auction until Congress has had a chance to deliberate and pass a bill to send to the President for his signature.

In the meantime, there are two courses of action that might be possible here. The best, as far as the Public Safety community is concerned, is that during August, House and Senate staffers convene and work out two bills, one for the House and one for the Senate that are identical or nearly identical in their wording. These bills should include, at the very least, re-allocation of the D Block to Public Safety, allowing Public Safety to lease spectrum to others in areas where it won’t all be needed (rural America), and funding for both the construction and operational costs of the series of networks that will make up the nationwide national broadband Public Safety interoperable network, and perhaps going as far as funding development of chipsets and devices to ensure that Public Safety will have timely and economical access to a variety of types of devices.

If these bills can be crafted in August and introduced in early September, there is a good chance they could be passed into law by the end of September. If this does not happen, this matter will once again have to drag on until after the elections in November. Not that the outcome of the elections will change the D Block outcome, but by the end of September, Congress will be pre-occupied with the upcoming elections and very little will get done. Since I believe the outcome will favor Public Safety, I would obviously like to see a law passed by the end of September so the Public Safety community can gear up and get the networks underway. Failing that, it is imperative that the FCC be directed to withhold the D Block from the auction block until Congress has had time to act on the pending bills.

Conclusions

There is no guarantee that Public Safety will, in fact, end up with the D Block and funding for the networks, but I believe that the chances are much better than they were only a few months ago. One Congressional staffer told me that if the right bills are introduced, they should sail through Congress since he does not believe anyone in either the House or Senate will vote against Public Safety. I hope he is correct and I am struck with the dedication of many of the staffers who are telling me that they intend to get the bills written in August for a September introduction. Nothing is for sure in Washington DC and I am certainly not declaring victory, but I am very encouraged by the happenings in Washington DC on the 21^st and 22^nd of July. I was fortunate to be a part of these historic two days. I have been working relentlessly on this, along with many others, and I believe we are about to achieve Public Safety’s goals of acquiring both the D Block and funding.

My hat is off to all those from the Public Safety community and the private sector who have worked so long and hard on this issue. It is truly amazing how everyone has come together for the betterment of Public Safety, which also translates to better Public Safety services for all of us. For my part, I will continue to push and prod whenever and wherever I feel it is needed and I honestly hope that those within the FCC who have pushed for a different outcome will not feel as though they were defeated. Our system is built on healthy debate, and the ultimate decision is still up to Congress. If the D Block is re-allocated to Public Safety, there will be no losers. We will all be winners.

Andrew M. Seybold

It appears as though the engineers and technologists working with the FCC’s Public Safety and Homeland Security Bureau (PSHSB), some within the FCC Commissioner’s office, and many staff members serving our congressional representatives do not understand the basics of wireless communications or, more specifically, the differences between commercial wireless voice and Land Mobile Radio voice systems.

This knowledge gap was evident to me during my recent trip to Washington DC and again when I saw that the PSHSB was preparing to issue a Public Notice on converting the 700-MHz narrowband voice frequencies for public safety to broadband usage. This spectrum (769-775 MHz and 799-805 MHz) was previously allocated for channelized voice communications systems using digital technologies on very narrow voice channels. Within this portion of the spectrum there are 1920 (2 blocks of 960 channels each) voice channels for use by public safety.

Those preparing to float this Public Notice don’t seem to understand several facts. First, broadband service for images, video, data, and other applications is desperately needed by the public safety community. HOWEVER, broadband services CANNOT replace all of the various requirements for voice systems, nor can LTE or any other commercial wireless technology provide all of the types of voice services needed by public safety.

Nor do these people understand that no matter how robust the broadband networks, no matter how much spectrum the public safety community has, its needs for different types of voice usage CANNOT be satisfied by LTE ( see part 1) or any other broadband technology. Even with the best broadband system in the nation, voice will remain a critical element of public safety communications.

So let’s start at the beginning:

• Public safety voice services are varied. When a call is received by a call taker (PSAP operator), it is transferred to a dispatcher who puts the call out as a voice message on the dispatch channel. The dispatch channel is monitored by field personnel and it is important that the dispatch is heard not only by the units that will be responding to the call, but also by every other unit that is in the same district or area. This type of communications is based on push-to-talk, not dialing a phone number, and while it is a directed call, it is important that everyone else on the channel, including the commanders in the field, hear the call so they know what is happening in their area of responsibility.
• The unit or units that will be responding to the call answer the dispatcher and start toward the incident. On their way, they could receive additional information either by voice or data. They might receive information about prior calls at the same address, if the subject is armed or there is a gun on the premises, or any number of other things that will help them evaluate how to approach the incident. Once they arrive on the scene, they notify the dispatcher and this communication is also heard by all others on the channel.
• After that, several things happen at the same time. If the call is for police units, the dispatcher will start a timer giving those responding a set amount of time to re-contact the dispatch center and verify their safety. Once those at the incident have had time to assess the situation, they call into the dispatch center with an initial report and if they need assistance, they request it. Since the others in the field have been listening to the voice traffic, they may have already started moving closer to the scene so they can respond faster if they are needed for backup. Once again, this is automatic based on hearing the voice traffic for the call.
• If the responders do not check in with the proper radio code within a specified period of time, the dispatcher calls them, again with the other units listening in. If there is still no answer, additional units are dispatched to the scene to check on them.
• During this time, the dispatcher may also be receiving additional information about the call and relaying it to those in the field. In many cases, another officer has some firsthand knowledge of the address or people involved and will also contact those responding to the incident or on the scene to provide that information so they can be better informed about the situation.
• During the incident, those on the scene are reporting back to the dispatcher and the conversations are being heard by others in the field as well as the commanders who are on duty and usually also on patrol.
• Once the incident is cleared, those in the field respond to other incidents in the same manner. On a busy night, the dispatcher may be handling up to 50 or 75 cars or more on a single radio channel and making sure all of the calls are being handled in order of priority.

This scenario is standard operating procedure for public safety. If the incident had been a fire, the first unit on the scene would report a condition such as: two-story residence, flames showing on the second floor. Those responding in other units would hear the report and begin preparing to take directions from the incident commander (IC) as they approach the scene. In the meantime, the incident commander has heard the initial dispatch and knows what equipment is heading toward the scene. He or she sizes up the situation and may order a second alarm, but in any event, the IC knows how many and what types of apparatus are inbound and starts giving orders over the voice network. Perhaps one engine will come to the scene, the next engine will hook up to a fire hydrant to provide water, the rescue company will come onto the scene and be prepared to search the house, and the ladder company will also come to the house and set up to gain access to the second floor or to use its hose from above the roofline to battle the fire. The EMS vehicle might be next in and positioned so it can provide medical services to anyone injured, including firefighters.

Such scenarios are standard everyday occurrences and this is the type of voice activity the FCC and others believe can be handled by broadband networks in the future. This may be the case, but the issues will be how to enable the broadband network to provide one-to-many voice communications covering only a specific area, but having the additional instant ability to broaden the area of coverage for larger incidents. Further, the devices MUST have push-to-talk in them, and they must have speakers so the handheld can be worn and used with a single hand. Even when it is not being held, the voice messages coming from the handheld’s speaker have to be heard by the person in the car or wearing the device. So now this begins to sound a little different from standard broadband communications services.

In the standard broadband world, the voice devices are designed for handheld operation and you must dial a number in order to communicate. Dialing a number connects you to a single person to talk to and does not connect you to many people at once. Further, you must use two hands to dial the number. You cannot expect a public safety first responder to use two hands for any form of communications unless it is to quickly turn a knob to change channels. There is no way a public safety field officer is going to use a device that takes two hands to operate. Next, of course, is the time it takes to dial a call. You have to select the number or remember its speed dial position and then dial, wait for the network connection and then the ring, and then wait some more until the person answers the phone. Compare this to today’s public safety communications where you depress a push-to-talk switch and talk, and within less than one-half of a second, your voice is being broadcast not only to the dispatch center, but to every field officer in your district or area.

If you are being shot at or are inside a burning building, you have time for one call for help. You need to make it quickly AND you need to know it was heard, not blocked because the network was busy at that moment. Dropped calls are NOT acceptable in public safety communications. This is one reason there are rules governing radio usage and the dispatcher or incident commander is charged with maintaining what is called “network discipline,” making sure traffic gets through all of the time, every time. They cannot tolerate a single dropped or blocked call; it could cost someone their life.

Will LTE be able to address these issues in the future? The answer is probably yes since the LTE specifications address the use of push-to-talk and Voice over IP (VoIP), and the specs refer to one-to-many or broadcast communications, although it is not yet clear if the LTE broadcast mode could be limited to only certain cell sites within a given city. The systems would need to be set up to support multiple broadcast sessions simultaneously since most public safety agencies use multiple dispatch channels based on geographic or other sets of boundaries.

A typical major city might have eight or ten different dispatch channels, each designed to provide coverage in a given segment of the city, and another citywide channel for commanders. All of this consumes bandwidth and all of these systems have to be up and running 24/7 with instant or near-instant push-to-talk capabilities.

The field units need to be able to move from one coverage area to another. The way this is handled today is to manually switch the channel or, in some cases, listen to one or more channels all of the time by scanning them. With the main channel set for priority, if they are listening to voice traffic on another channel and a call is received on their primary channel, the radio automatically reverts to the primary channel so the transmission can be heard in its entirety.

There are those who believe that public safety can make do with other ways of communicating, but they must understand that field personnel might have only a few seconds to call for help in an emergency, and they need to know with 100% certainly that their call will be heard. It makes more sense to use LTE voice capabilities when they become available in a few years for administrative and non-mission-critical voice communications while leaving the existing voice systems in place. One advantage a public safety broadband network will provide is that some of the voice traffic that can overload the system at peak hours can be moved to data requests and responses. This includes running license plates and drivers’ licenses, uploading accident reports, and receiving additional information while in route to an incident.

There is much more to public safety voice communications that cannot be addressed using a broadband network. It is in these areas where the lack of understanding of the public safety community’s needs could result in reducing effectiveness even when adding more capabilities. I will address these requirements in more detail In Part 3 of this COMMENTARY. Stay Tuned!

Andrew M. Seybold

One of the most misunderstood aspects of public safety communications is the need for peer-to-multi-peer communications when at an incident. (In Land Mobile Radio speak, this is called simplex, tactical, or talk-around communications.) It is important that those making policy in Washington, DC, those on the commercial side of wireless, and IT professionals understand exactly what this type of voice communications entails and the critical role it plays in public safety communications.

Consider this scenario: You are in a large shopping mall with your family and you each go in different directions, agreeing to meet later at the food court. You are in a store and you find a bargain that you want your spouse to see before you buy the item. You pull out your cell phone only to find that you do not have cell phone coverage in the mall, so you can’t call your spouse’s cell phone to ask him or her to meet you at the store. Your son or daughter is walking in the mall and sees someone fall down the stairs. He or she reaches for his or her cell phone to call 911, and again, finds there is no cell phone coverage, so the call cannot be made.

The problem in both cases is that you are out of cell site coverage, and without a cell site, your phone does not work. It is simply a great piece of technology that is useless when you are not in range of at least one cell site. To you this is an inconvenience, but for the person who fell down the stairs and is injured, the delay in getting assistance could be the difference between living and dying. This is not acceptable in the world of public safety communications where those on a scene need to be able to communicate, especially with each other, no matter where they are and regardless of the conditions.

There is a type of voice communications that enables public safety personnel to communicate among themselves even when they are out of range of a cell site or a tower site, and it is vital to the way in which public safety personnel on the scene of an incident operate. Using the same mall as an example, once the fire department and EMS personnel arrive, they switch their radios off of the dispatch channel to a channel that provides the ability for them to talk to each other over short distances. These voice transmissions are heard by all personnel at the incident. (To be clear, fire and EMS personnel can talk to each other, and the police, usually on another one or more channels, can talk to each other.)

This capability provides good communications between those on the scene, and if they need to contact their dispatcher they can contact someone in their vehicle outside the mall, who in turn can relay the request for additional assistance to the dispatcher. Further, if a fire fighter is on the second floor of a burning building and sees that the roof is about to collapse, he or she can make a call that will be heard by all personnel in the building, alerting them to the danger. And if the person making the call is in danger, they can provide assistance. Again, this type of communications is vital to public safety and it is used every day at many different times.

Yet this type of voice communications is not now available using cellular and wireless broadband networks, nor will it be well into the future. The devices we use to communicate over commercial voice and broadband networks are 100% reliant on being within range of a cell site. If two people are separated by only a few blocks, they still must dial a phone number and wait for an answer, which means they both must be in range of a cell site to be able talk to each other. First responders simply change the channel their radios are set to and instead of talking over the network, they talk directly to other units within range.

Those familiar with Citizen Band radios, or walkie-talkies that use the Family Radio channels authorized by the FCC, know how this type of communications works. It is based on push-to-talk, and units can talk among themselves without going through any relay towers or cell sites. This type of service is not available in the world of commercial wireless. While some people seem to think it will be available in the future, I don’t believe any wireless broadband equipment or device vendors will be building in this type of communications capability.

There are many different reasons that this type of communications is not and will not be available: There are technology challenges, network operators want their customers to make use of their networks to provide income, and there is no demand for these types of services from the general population. But those who claim public safety’s needs can be completely served by commercial-type broadband networks apparently do not understand the need for direct communications. Again, this is not a “nice to have” feature for public safety, it is a must-have requirement. Unlike the annoyance of not being able to make a phone call when you are out of cellular coverage, the inability to talk to others at the same incident can be deadly. It could result in the loss of life not only within the first responder community, but also for others involved in the incident.

I have heard several comments from those who believe broadband networks can provide all of the capabilities needed by public safety that further indicate how much this direct voice requirement is misunderstood. The first set of comments has to do with being in coverage—broadband believers suggest that there will be coverage everywhere, and where there is no coverage from a cell site, in-building communications systems will provide communications capabilities. This simply is not true. No matter how robust a network is, no matter how many cell sites it contains, there will be places where there is no coverage. Further, even if there is coverage, it does not make sense for ten, twenty, or more first responders on a scene to tie up wide-area communications channels when local-area communications will serve their needs, and serve them better.

Add to this the fact that at larger incidents that occur on a daily or weekly basis, there is also a need for multiple local channels. This is because there are a number of different groups at these incidents, all with their own set of objectives and tasks. While public safety personnel need to be able to talk within their own group, they cannot have to compete with other groups for a radio channel. A simple example of this might be a bank robbery gone bad that has turned into a hostage situation. On the scene there will be patrol officers who first responded to the incident, a swat team, a surveillance team, detectives, fire, and EMS responders. At this type of incident, each group needs at least one channel dedicated to its own team to coordinate among themselves. At the command post, the incident commander is able to follow what is going on within each team, which enables him or her to make informed decisions about how to handle the incident. The incident commander must also have a clear channel back to the dispatch center and/or superiors who are monitoring the event from remote locations.

During storms, wildland fires, and many other situations, the number of local channels that are needed must be available; having only one such channel is not acceptable. During the recent Southern California wildfires, between local, state, and federal fire agencies, there were 18 command channels (wide-area coverage) and 78 local-area or simplex channels in use. By the way, much of the area engulfed in flames was outside commercial network coverage and some was even outside areas covered by the existing public safety networks. However, because there were local communications capabilities, incident command was able to track everyone on the fire lines and if someone got into trouble, he or she knew that by pushing one switch on the radio and saying, “I need help” or “I’m in trouble,” he or she would be heard by nearby team members.

Public safety needs broadband services, but today, voice is the primary form of communications in the field. Data services will help augment the tools available in the field and will help reduce some of the voice traffic on public safety systems. Data services will also provide a common network for broadband services as well as the ability to use the broadband spectrum for push-to-talk voice services for interagency communications at some point in the future. However, the broadband network will not be capable of handling the requirements for channelized voice services, nor will any of the commercial broadband technologies be capable of providing the type of direct voice services described above.

Those who are in the process of reviewing the requirements of public safety communications need to understand that its voice requirements are very different from those that are and will be provided over commercial technology broadband networks. They also need to realize that public safety needs three types of communications: wide-area (city or region-wide) voice for dispatch and coordination, local voice communications for use during incidents, broadband services for data and video communications, and in the future, some voice for coordination and administrative purposes. Armed with this knowledge, they will understand why the planned nationwide broadband network can only augment the capabilities in the field — not replace them.

Andrew M. Seybold

Andrew Seybold also writes for Wireless Week, Fierce Wireless and Fierce Mobile Content, Mobile Enterprise Magazine, Forbes.com, and News Patterns Daily Intelligence and many of his articles have appeared in Public Safety Communications (APCO) and other industry publications.

Over the years, Andrew Seybold has spoken out about many issues that affect the daily lives of our first responders, most notably the current struggle between Public Safety and the FCC over the Public Safety 700-MHz broadband network and the inclusion of the D Block of spectrum into that system. Sign up today as this issue and others are discussed and add your own views by commenting on the articles directly on the website.

Comments on FCC White Paper on Capacity

Entitled “The Public Safety Nationwide Interoperable Broadband Network: A New Model for Capacity, Performance and Cost”

Executive Summary

In June 2010, the FCC published its second white paper supporting its recommendations in the National Broadband Plan (NBP) submitted to Congress in March of this year. The first white paper detailed the FCC’s ideas related to the cost of building and operating a nationwide public safety Broadband network. I reviewed that document and prepared my own white paper challenging many of the FCC’s assumptions and questioning its findings.

This second white paper details the FCC’s analysis of the capacity of the 10 MHz of spectrum already assigned to the public safety community and claim that 10 MHz of broadband spectrum (5 MHz by 5 MHz) will be sufficient for most public safety broadband requirements well into the future. The following is my response to the FCC’s second report.

In the introduction to the Capacity Paper, one of the authors recaps points made in more detail in the body of the paper:

“The Federal Communications Commission (“FCC”) has performed a technical analysis of the capacity and performance of the public safety broadband network assuming that the National Broadband Plan recommendations concerning this network are implemented. This analysis includes examining different emergency situations based on actual experiences and as submitted in the record of the National Broadband Plan. This analysis shows:

1. The 10 megahertz of dedicated spectrum allocated to public safety in the 700 MHz band for broadband communications provides more than the required capacity for day-to-day communications and for each of the serious emergency scenarios set forth below.
2. For the worst emergencies for which public safety must prepare, even access to another 10 megahertz of spectrum would be insufficient. Accordingly, priority access and roaming on the 700 MHz commercial networks is critical to providing adequate capacity in these extreme situations. Moreover, priority roaming is a cost-effective way to improve the resilience of public safety communications, along with its capacity, in a way that a single network cannot provide.
3. The capacity and efficiency of a public safety broadband network will far exceed the expectations of someone who has only experienced narrowband land mobile radio (LMR). This is because of the system architecture, density of cell sites, density of cell sectors per site, network and spectrum management, and the use of new and emerging technologies.
4. Public safety can make more capacity available when and where it is needed by using all of its spectrum resources appropriately and effectively, no matter how much spectrum is available (e.g., use the 700 MHz band for mobile devices and other frequency bands for fixed devices).”

In reviewing the assumptions the FCC used in reaching these conclusions, I take issue with the following:

1. The FCC is trying to equate voice with data traffic information. Voice communications requires far less spectrum per conversation than broadband data services require. Further, the types of data have a huge impact on the amount of bandwidth available and the capacity of the network within a given cell sector.
2. The FCC claims that video data rates of 256 Kbps will provide sufficient video resolution for most public safety video applications. I and many others disagree with this assumption for many of the video feeds that will be employed by public safety.
3. The FCC claims that land mobile radio systems (LMR) are underutilized most of the time. This is not a correct assumption. LMR systems, as used by public safety, do have periods of light usage, but there are many times every week when these systems are supporting voice traffic that is beyond the capacity of both the existing LMR systems and the capabilities of the dispatch centers to keep up with the demand.
4. The FCC believes that roaming onto commercial networks will occur on a sporadic basis. My research shows that having only 10 MHz of spectrum available will result in having to roam on commercial networks in at least the top 100 metropolitan areas on a daily basis, and for long periods of time for each occurrence.
5. The FCC assumes that the public safety community will have access to 60 MHz of broadband spectrum (its own and that operated by commercial networks). This assumption is not based on any current rules that mandate commercial priority roaming or type of priority roaming and assumes that the winner of the D Block at auction will make its spectrum available for use by the public safety entities, yet its current recommended rules for the D Block auction do not require such cooperation between the public and private sector.
6. The FCC based its usage models only on major scenarios spread out over large geographic areas of a city or jurisdiction. There are no assumptions that look at capacity requirements for smaller incidents that occur on a daily basis and are fairly local in nature and, therefore, will have broadband coverage from only one or perhaps two cell sectors.
7. The FCC believes that local ordinances need to be changed to require the installation of inbuilding network cells (femto, pico, or distributed antenna systems). Yet the FCC has no authority to require that local communities actually do update their existing ordinances, nor does it take into account the cost of providing this inbuilding coverage, nor how it is to be integrated into the network.
8. The FCC’s discussion of how much spectrum is already available to the public safety community is flawed in a number of ways. It counts the broadband spectrum at 4.9 GHz that provides only local-area coverage and does not penetrate buildings, it includes the 220 MHz band that is presently used in only one area of the United States because of a conflict on the Canadian border, and it does not take into account that existing channelized spectrum cannot be aggregated into spectrum that could be used for broadband because the channels already allocated to public safety are interleaved with channels assigned for other land mobile radio services.
9. The FCC claims that the public safety community’s only rationale for requesting that the D Block be reallocated to public safety is so it can build fewer cell sites and therefore a less expensive network. This assumption is wrong, since public safety is planning to make use of the same number of cell sites recommended by the FCC (44,000 nationwide). The additional spectrum being requested is to provide additional capacity for the network.
10. The FCC used the New York City report on bandwidth requirements to support its own position. However, instead of using all of the assumptions provided in that report, it chose to discount the requirements listed for video services and use its own assumptions as to the number of video feeds that would be required and the bandwidth consumption of each connection.
11. The FCC assumes for the purpose of this paper and in its general findings, that a guard band is not needed between the D Block and the public safety spectrum. However, on May 18, 2010, the FCC requested comments from interested parties to provide input on whether or not a guard band will be needed, even though the assumptions in its white paper are based on a guard band NOT being necessary.
12. The 700 MHz commercial spectrum that was already auctioned and on which networks are in the process of being built did not carry any requirements for priority access for the public safety community. It is unclear to me whether the FCC has the authority to now require these network operators to provide some type of priority roaming with the public safety community.

It is clear that those involved in preparing the FCC white paper on capacity tried to make the results fit the recommendations they already included in their National Broadband Report to Congress. In reality, this capacity study should have been prepared and released prior to their recommendations to Congress. The FCC focused only on major events or incidents and did not run scenarios based on day-to-day operational requirements. These daily incidents will occur in small geographic areas, sometimes within only a one or two block area of a city or within one-quarter or one-half mile of a jurisdiction. In many cases, these areas will only have broadband coverage from one or two cell sectors. Since this is the norm for public safety responses, this should have been the criterion for evaluation of the amount of spectrum required.

The FCC statement that capacity is based on a number of cell sectors per site, times the amount of spectrum available within each sector, divided by the frequency reuse factor, is true and correct. However, its assumption that public safety would build out fewer sites if it had more spectrum available is not correct. In the case of public safety and its planned network, doubling the amount of spectrum it has available will double or more the amount of bandwidth available within each cell sector. Therefore, the assumption that total capacity is based on other factors as well is not correct. The proper calculations should look at a single cell sector, map the bandwidth available within that cell sector, and then calculate the amount of data traffic (data and video) that will be required both inbound and outbound for typical incidents including a building fire, bank robbery, hostage situation, gang fight, and other incidents that occur on a daily basis but in random locations within jurisdictions.

Further, their discussion of cell sectors and capacity assumes that incidents will occur in areas already heavily covered by commercial network operators. This too is a flawed assumption. If we look at New York City as an example, the commercial operators have learned from experience that in the Theatre District, when the shows let out, the demand for voice and data services will peak. The network operators design and build their systems based on this type of demand, primarily in identifiable locations. The reality of the situation is that criminal events, fires, and other emergencies are not predictable by location, and in many instances the demand for public safety services will occur in areas of the jurisdiction that are lightly served by commercial operators, but bandwidth must be available for public safety.

It is my opinion that the authors of the paper were charged with reinforcing the position previously taken by the FCC that the D Block should be auctioned to a commercial operator. Instead, they should have been charged with taking an uncommitted view of the needs of the public safety community and developing a paper based on an understanding of the differences between commercial and public safety networks and requirements. It appears that this FCC white paper was developed for the purpose of further justifying a position it already recommended to Congress in the National Broadband Report. There are many discrepancies in the FCC white paper and a number of assumptions that, while they may be valid for commercial networks, are not valid for a mission-critical public safety broadband network.

The bottom line for me is that the FCC delivered a report that attempts to once again justify its position that 10 MHz of spectrum is sufficient for use by public safety on a daily basis and that during the occasional times when this is not enough, public safety will be able to make use of commercial network operators’ spectrum on some as yet undefined type of priority access. Further, the studies referenced in this report look at broadband capacity from a macro level rather than from a cell sector level. The result is a paper that does not address the real-world broadband requirements of the public safety community on a daily basis, though it does meet the FCC’s goal of justifying its recommendations already presented to Congress.

Andrew M. Seybold

Note: My full response to the FCC’s capacity white paper is below in PDF format.

AMSRebuttalFCCCapacity06-23-10