The Federal Communications Commission (FCC) has announced the membership of a committee to define the requirements for interoperability that need to be incorporated into the network. Once this task has been completed, the FCC will review the resultant recommendations and if it agrees with them it will forward them to the National Telecommunications Information Administration (NTIA) for use by the new governance organization known as FirstNet. I hope the FCC and the committee will draw on all of the great work that came out of the Waiver Recipients Working Group and several of its broadband committees within the National Public Safety Telecommunications Council (NPSTC), and the Association of Public-Safety Communications Officials (APCO International) with its Broadband Committee. Thousands of hours of work were put in along the lines of the FCC charter and with the short deadline imposed on the FCC by the law. In my mind, it would be counter-productive not to make use of all of the information that came out of these efforts.

The same goes for the FirstNet organization, which is to be named and in place by August 20, 2012. I hope it too will take full advantage of the knowledge that has come out of the above-named organizations and others. NPSTC, for one, has set up numerous sub-committees under its broadband committee with some of the best minds in Public Safety communications contributing to the work that has been completed and that is still in process. The Waiver Recipient Working Group’s sub-committee on interoperability has also done sterling work. FirstNet should also consider the recent APCO Broadband Committee work on a nationwide network roadmap, which differs somewhat from the exact language in the law. I believe this roadmap will give both states and local entities more choices in how to move forward, and this can be very helpful when striving for agreement among the various organizations that will make use of the network.

Measuring Success

Once this early work is finished and the requests for proposals and other details are worked out, it will be time to start building out the network. As it is being built and Public Safety agencies come online, I believe that from the very beginning we need to track answers to the following questions as a minimum:

• How much of the area now covered by Public Safety mission-critical voice networks is covered by the mission-critical data and video network?
• In each area that is built out, how many users (actually customers) are signed up to use the network and what is the projection for more users moving forward?
• What is the cost per user? How much of that is for local network use and how much goes to FirstNet?
• How well does the network serve the needs of the agencies using it?
• How good is the in-building coverage?
• What types of applications are being put into service?
• How has the network helped keep first responders safer?
• How has the network helped contain incidents from becoming larger?
• How much of rural America is actually served by this network?

I am sure we should be measuring other parameters as well, but for purposes of this discussion, I want to convey the fact that we need to document and track the advancement of the network, its use, and its contribution to the success of the first responder community. We need to make sure that as we move forward there are ways to demonstrate to all that the vision of adding data and video capabilities to our first responders’ voice capabilities is paying dividends and that as the network evolves and new applications and services are brought online, the network is successful.

Recommendations

This brings me to some recommendations I would like to offer for a successful network and assurance that technical aspects of the network are not overshadowed by politics and other distractions. This network needs to be built and used by all first responders in order to provide the maximum benefit to the Public Safety community.

Waiver Recipients

I believe that those that have already obtained waivers from the FCC for early build-outs should be permitted and even encouraged to build out their systems as planned. Those that have funds from grants should be encouraged to move forward as quickly as possible in order to meet their deadlines, and those that have waivers but no grant funding should be allowed to move forward if they are interested in self-funding prior to the nationwide build-out.

FirstNet and the States

As the law is written, FirstNet will be working with states on the implementation of the network, and it is assumed that states will consult with local entities to provide for the best deployment within each state. Eventually, each governor, hopefully with the input and advice of the statewide Public Safety community, will need to decide if that state wants to opt out of the FirstNet plan and take on the responsibility of building the Radio Access Network (RAN) in that state.

The big issue here is that some states are struggling with their own budget deficits and won’t be able to augment the FirstNet Radio Access Network deployment within their state. Further, during the past three years, very few states have been engaged in the process or are even aware that the new Public Safety Broadband system is law and that there is funding for it. It would behoove FirstNet to meet with the appropriate representatives from each state to educate them and to determine how they plan to move forward. This is vital since there are some political issues in a number of states and in some the relationships between local communities and the state are not as good as might be assumed. Therefore, I am hoping that FirstNet will assure that states involve the local Public Safety community in the decision about how to move forward.

The Network

The vision of the law appears to be that FirstNet will build, operate, and maintain the entire network. I am not sure this is a truly realistic vision. FirstNet cannot possibly know, down to the local level, what is required and the specific circumstances in each area. I would hope that FirstNet will, at the very least, allow operational control of the network to be handled by the local entities. The broadband network, even with 20 MHz of spectrum, will need to be managed during major local incidents and it is not realistic to assume that FirstNet will be able to manage, on a real-time basis, the local demand for bandwidth, priority levels, and Quality of Service.

Another issue that needs to be addressed is the concept of the Evolved Packet Cores (EPC). A broadband network based on LTE needs EPCs in order to function. It appears as though FirstNet will include some number of EPCs deployed across the United States and that the local and state Radio Access Networks will all be connected to these central EPCs. This is how commercial networks are deployed and it generally works well. However, even with this approach, a few of the nationwide operators have experienced nationwide outages. One of the differences between a commercial broadband network and the Public Safety Broadband network is that the Public Safety network MUST be “always on” and capable of mission-critical data services.

One of the weak links in a nationwide network architecture is that if a connection to and from the EPCs fails, or is disabled by an earthquake or other disaster, the RAN that has lost the connection is out of service. Since the EPC provides the “brains” to verify users, keep track of them, and locate them within the system, if the EPC connection is severed the RAN is useless and the system, in that area, will be non-functional until the connection(s) have been restored. Further, unless local applications servers are permitted, the EPCs will not only have to be capable of signaling data, they will have to handle very large amounts of data that for the most part should be handled on a local level.

Several committees have studied these issues in great detail and discussed them with LTE experts in the commercial world. What I consider to be a better approach would be to design the system to be more flexible. My preference would be to see the augmentation of the nationwide cores (EPCs) with two or more additional types of EPCs or cores. The first would be EPCs set up and run as EPCs hosted by a commercial vendor that could connect to the nationwide cores and serve a number of different agencies. Next I would permit major metropolitan areas concerned about having to access the nationwide core in a remote location to be able to purchase their own EPC, or at least the elements necessary to provide the minimum capability to maintain connectivity in the event of a service outage. I would also recommend that the system include the ability for local agencies or groups of agencies to host their own applications servers to minimize the amount of data traffic that must be routed through the nationwide EPCs. This would also save a considerable amount of money in terms of fiber and microwave backhaul costs and it would reduce the network’s operational expenses.

The bottom line for me is that while FirstNet is the organization charged with designing, building, maintaining, and operating the nationwide network, if the network is to succeed in its goal to bring mission-critical broadband to all first responders, some flexibility may be required in order for some states and many local Public Safety organizations to buy into the network. I am hoping that FirstNet does not interpret the law based on the exact meaning of the words but decides that some flexibility is needed to ensure the success of the network.

Public/Private Partnerships

This is also an area that, while referred to in the law, is neither explicit nor clear and I have some concerns about how it will be implemented. If FirstNet interprets this part of the law to mean that all public/private partnerships must be set up and maintained by FirstNet and/or that these partnerships be on a nationwide basis, it will be a disservice not only to the network but also to potential local and regional partners that want to work with the Public Safety community. If FirstNet interprets this to mean that it is left to each state to work out public/private partnerships, in my estimation, this also will not provide the flexibility that is needed to assist in building the network quickly and in many suburban and rural areas.

There are, of course, some obvious partners that already provide commercial broadband services across the nation: AT&T, Sprint, T-Mobile, and Verizon Wireless. There are also many smaller wireless providers including Metro PCS, Cricket, members of the Rural Cellular Association (RCA), and a number of other independent wireless companies. A more regional approach to partnerships would permit electric and other utilities as well as the regional telcos to work with Public Safety. Many of these companies have infrastructure in the way of tower sites, high-tension towers, and other facilities for the location of cell sites. Many of them already make use of fiber and microwave for backhaul services, and some, including rural power co-ops, are sitting on a lot of money that could be helpful going forward.

Partnerships should not be viewed as one-size-fits-all, nor should they be viewed as statewide. I believe they should be viewed on a local or regional basis. Many telcos and power companies provide services across state borders, thus statewide partnerships would not always serve the majority of the population as well as partnerships based on a more regional approach. This is a complex issue that will have to be managed properly but it can be done and the more of these partnerships FirstNet is willing to consider, the further the $7 billion will go and the sooner we can obtain additional income to pay for additional build-out and operational expenses.

Cost Per User

This issue needs to be dealt with head-on and early. I have heard all kinds of numbers tossed around for this. It is assumed that in order to make the network self-sustaining over time that there will be a per-user monthly fee. Where this monthly fee is set will have a huge impact on the number of users, and therefore the income for the network. What we don’t know at this point is whether there will be a single nationwide fee per user or if states will be permitted to tack on an additional fee. In either case, if the goal of the network is to help it grow and provide broadband services to as many users as possible, the monthly fee will have to be reasonable. But what is reasonable?

One of the numbers tossed around by one of the waiver recipients in California when talking to a city council was a per-user fee of $72. This is much too high and will hold down the number of users any city or county will be able to have on the network. The result could be that the only users permitted by a city or county would be the senior officers of each department. This will not be enough to support the network. A price this high will also mean that some cities and counties will simply keep their current commercial broadband contracts and not move over to this network. This would not promote the nationwide, fully interoperable concept that was at the foundation of the network concept.

What do I think is a fair price to charge? That is a tough question to answer, but if I could set the price it would be less than $20 per user per month. However, I suspect that $40 per month per user would be acceptable to most departments. So the issue then is how many users are needed at $40 per month. Of course the other question that needs to be addressed is whether local cities and counties have to pay for the electricity, backhaul, and other operational costs associated with the network in their area or will FirstNet have to pay for these? If the locals have to pay, could they add a surcharge to the FirstNet fee in order to offset some of the costs? For example, could FirstNet decide to charge $40 per user and a city add $2 per user per month on top of this charge? If that model works, what are the right numbers?

Remember that there are no roaming costs associated with using the network anywhere it is built. The only roaming costs that will be incurred will be when a Public Safety device roams onto one of the commercial networks.

Another pricing issue for me is whether it would be better to charge per device. The network will start out with vehicle-mounted devices but over time, handheld devices will be added so that when personnel leave their vehicles they will still have broadband capabilities. Will we reach a point where there will be no vehicle-mounted devices and they will be on the person only?  I am not so sure of that. A police car with a single officer in it would equal two devices or $80 per month. With two officers in the vehicle the monthly cost for that vehicle would jump to $120 per month. In a fire engine with a crew of four and one device mounted in the engine, we have a total cost of $200 per month.

I don’t have any concrete answers to the pricing issue, but it will have to be addressed and in some ways it is the same issue the commercial operators face when they set data pricing. How much can you charge per month and still attract users? However, in the case of a commercial operator the cost is borne by the individual subscriber or the company and not by a city or county that already has to make drastic budget cuts. At one point it was suggested that a fee be added to every commercial wireless user, just as there is today for 911 services. However, that was discarded by Congress a long time ago and would, I believe, be difficult to implement and track today. Still, the ongoing costs of the network will to have to be paid for somehow. The trick will be to set the price low enough that more Public Safety users will be on the network.

Conclusions

FirstNet has its work cut out for it, not only in the areas mentioned above but in many more as well. There is no way that those who authored the bill could have addressed all of these issues as well as others that will pop up once the system is underway. The bill could have been ten times longer and still not have covered all of the issues that will need to be dealt with. Therefore, it will be up to FirstNet to move forward and I hope its members will keep in mind that the goal here is to build the first ever, fully-interoperable, mission-critical broadband network for Public Safety.

There is no doubt in my mind that this group will have to be made up of very dedicated individuals with a broad range of knowledge including Public Safety requirements, network technologies and capabilities, and, of course, the financial aspects of getting this done. It will be a daunting task and the Public Safety community will need to stay unified in its effort to help FirstNet accomplish this goal in the fastest, fairest, and most financially sound way possible. I look forward to learning who is on the FirstNet board and how they plan to move forward. They will, in large part, determine the success or failure of this network. We cannot allow it to fail and I trust they will fully understand that as well.

Andrew M. Seybold

1)     Reallocation of the 700-MHz D Block to Public Safety. In conjunction with the existing Public Safety broadband spectrum, there is now 20 MHz of contiguous spectrum for a nationwide Public Safety broadband network.

2)     $7 billion for the construction of the network with this money coming from future spectrum auctions.

1. $135 million for state and local implementation (administered by the National Telecommunications and Information Administration or NTIA) to assist in this process
2. $115 million for Next-Generation 911 grants (NG911)
3. $100 million for research and development to be conducted by the National Institute of Standards and Technology (NIST), with up to $200 million more depending on how much money is raised during the spectrum auctions

3)     Governance

1. The NTIA is to establish the First Responder Network Authority (FirstNet), an independent authority within the NTIA that will hold the license for the D Block and the existing 10 MHz of broadband spectrum already allocated to Public Safety

4)     Board – FirstNet will be headed by a board consisting of

1. Three federal members (Secretary of Homeland Security, Attorney General, Director of the Office of Management and Budget) and
2. Twelve members appointed by the Secretary of Commerce (at least three representing state and local interests and three representing Public Safety)

This means that all of the work that has been done by and on behalf of Public Safety over the last five years has been rewarded with the spectrum, the funding needed to start building out the nationwide network, and funding to provide for governance of the network. It also means that Public Safety will have a say in this governance. This bill is a win since it doubles the amount of spectrum allocated to Public Safety for the construction and operation of the Nationwide Mission Critical Public Safety Broadband network. This network will first provide for data, image, and video capabilities to those in the field and later, perhaps, it will enable the use of on-network mission-critical voice (more on that later).

The spectrum giveback is the downside to the bill. This part of the law requires the giveback of the T-Band spectrum (470-512 MHz) that is occupied primarily by TV Channels 14 to 20 and is used by Public Safety on a shared basis. While it is shared, this spectrum has provided relief in thirteen metro areas of the United States by providing for additional narrowband voice communications systems. The bill gives those who now use the T-Band up to nine years to plan the move to the other spectrum and then two more years to implement the plan. The bill does not state which portion of the existing Public Safety spectrum they will have to move to though there will be funding available to assist with the relocation.

I want to note here that the Public Safety community fought hard not to have to give back any spectrum during the negotiations that have taken place over the past two-plus years. However, at the eleventh hour some members of Congress added the requirement that Public Safety give back some spectrum as a condition to receiving the D Block and funding.

The Public Safety community had no choice but to agree to this spectrum giveback for the good of the entire Public Safety community and to ensure that the Nationwide Public Safety Broadband system would have sufficient spectrum and funding.

During the past two-plus years, various members of Congress suggested that Public Safety would have to give back some spectrum. At first they were looking at ALL spectrum between 150 and 512 MHz. Those within the Public Safety community working on the issue convinced Congress that this was not feasible, nor was its next suggestion of giving back spectrum in the 420 to 470 MHz band. Before Congress settled on the T-Band, it had also proposed that Public Safety give back the entire 700 MHz narrowband spectrum. None of these options were viable, and as much as Public Safety tried to stay the course, at the end of the day, those within Congress who insisted on a spectrum giveback settled on the T-Band. It was NOT offered up by Public Safety and at no time did the Public Safety community agree to this giveback. However, it is in the bill and Public Safety, as a community, will have to look at all of the options available.

Who Is Impacted by the T-Band Giveback

The answer is any Public Safety agency that is using the 470-512 MHz frequency band in or around the following cities:

Boston, Los Angeles, New York
Chicago, Miami, Dallas/Ft. Worth
Philadelphia, Detroit, San Francisco/Oakland
Houston, Washington DC/Maryland/Virginia, Pittsburgh

For those into numbers, there are currently a total of 808 issued licenses in these cities and 34 are pending approval.

Where They Can Move

There is nothing in the law that requires those using the T-Band to migrate to 700 MHz narrowband. However, with all of the new 700 MHz systems being built, many regional in nature, if spectrum is available it would be the most logical choice. For those that have already asked my opinion on options, I have been recommending the following:

If your T-Band system is older and needs replacement in the near term

1)     Determine whether any 700 MHz narrowband channels are available in your area

1. If there are, build the new system on 700 MHz instead of replacing your existing T-Band equipment
2. Build out and accept the new system PRIOR TO moving your T-Band users to the new system

2)     If there are no new 700 MHz channels available today

1. Wait for the narrowbanding deadline of January 1, 2013, and search for channels in the 150-170 MHz or 450-470 MHz band
2. Look for available 800 MHz narrowband channels
3. Wait until 2016 and apply for the new 700 MHz narrowband channels

If your T-Band system has already been narrowbanded and/or the equipment is newer

1)     Review what other narrowband channel options you have today on 700, 150, 450, and 800 MHz

1. Review them again after narrowbanding deadlines have passed
2. Consider building an overlay 700 MHz narrowband system over the course of the next five to seven years
   i.     This will enhance voice interoperability and make the transition easier when it is required
3. If you are in the process of replacing your existing T-Band system with an upgraded one, as many areas are, I would advise that you continue on that path since the proposed funding to move T-Band systems to other portions of the spectrum won’t be available until the T-Band spectrum (or TV channels vacated by T-Band LMR users) is auctioned. A   lot can happen within Congress and the FCC over the next eleven years and this decision could be modified or changed after this year’s election or the 2016 election.

2)     Watch developments for the LTE nationwide broadband network and the introduction of push-to-talk over broadband as the network is developed over the next four to six years. It is possible that during this time mission-critical push-to-talk on the Public Safety broadband network will be proven to work and be effective. HOWEVER, please note that I said ON-NETWORK as opposed to off-network, normally referred to as talk-around, simplex, or tactical channels. We have no information on whether off-network voice will be supported over LTE. I am sure that some of the R&D funds set aside by this bill will be used to work on this issue. For additional information see my recent article on Voice Over LTE. (link)

The Public Safety community, led by the Public Safety Alliance (PSA) and APCO Worldwide, are working to find answers to several questions including funding availability and whether T-Band systems will be exempt from the 2013 deadline for narrowbanding. In reality, it will be some time before we have a reaction or direction from the Federal Communications Commission (FCC) on this issue so the best course of action is to wait until we have answers to these questions.

Back to Broadband

Now that Congress has passed the bill giving the D Block to Public Safety and $7 billion in funding, there is a lot of work to be done. First we will have to see how the NTIA moves forward, then how long it will take to get organized and form the group that will begin the network planning and build-out (FirstNet). I, for one, hope the NTIA will review all of the work that has been done by the Public Safety Communications Research program (PSCR), waiver recipients, the National Public Safety Telecommunications Council (NPSTC), the APCO Broadband Committee, and others.

Then of course is the issue of the federal funding. $7 billion may seem like a lot of money but it does not begin to be enough to build out the network nationwide. The total cost of the proposed network is not known, but AT&T and Verizon have invested about $30 billion each in their upgrades to LTE and they already had all of the cell sites and infrastructure. There are a number of options available to raise additional funding. In major metropolitan areas all of the broadband spectrum will be needed on a daily basis. However, in less populous areas what makes the most sense is to form private/public partnerships with existing wireless network operators or perhaps with rural power co-ops (which provide power to rural areas in 47 states today) and others interested in sharing the spectrum on a secondary basis, which is permitted by the law.

While the PSA and APCO have been focused on working with Congress, a significant amount of work has been going on in committees across the country. There is already activity by the waiver recipients on determining how to interconnect the waiver sub-networks; work by PSCR on network architecture, testing of network components, and network devices; NPSTC has been busy on many fronts; and the APCO Broadband Committee has been working on a suggested nationwide network architecture that could serve as a model for FirstNet. I am hopeful that the thousands of volunteer man hours (or people hours) that have been put into these projects won’t be ignored and will be considered as we move forward.

Other issues that must be resolved are when the FCC will issue the new license for all 20 MHz of spectrum, how the Public Safety Spectrum Trust (PSST) will transition the work it has done, and how it will hand over the license for the 10 MHz of Public Safety Broadband spectrum it now holds. There is also the issue of whether the waiver recipients will be permitted to build out on the full 20 MHz of broadband spectrum. Permitting this makes sense to me since the cost of building out a 20 MHz network as opposed to a 10 MHz network is negligible but having to go back and build out the additional 10 MHz of new broadband spectrum could cost some waiver jurisdictions additional funding.

There are many more issues that need to be addressed and they will be. I am hopeful that the Public Safety Alliance will continue to work on issues as we move forward. This organization, which was formed to show Public Safety unity, and APCO have been the two primary advocates for obtaining the D Block and funding, and these organizations have gained recognition in Washington DC so it seems logical to stay together and focus on the next steps in this process. The network won’t be built overnight. In my estimation, we have three to five years of hard work ahead of us as we build out this network, put together public/private partnerships, and gain experience from the first sub-networks that come online.

During this more than two-year adventure to convince Congress of the need for additional Public Safety broadband spectrum and funding, a number of Public Safety agencies supported the effort by making their leaders available to travel to DC, attend countless meetings, and spend many hours on conference calls. Organizations that do business with the Public Safety community supported the effort through financial contributions, technical expertise, and lobbying efforts, but not all of the commercial wireless network operators participated. There are too many to thank in this article, but they know who they are and what they did and they will have the Public Safety community’s gratitude for a long time.

There are some who were opposed to the D Block going to Public Safety for whatever reason and they did their best to convince Congress to let the FCC move forward with the D Block auction. Some federal agencies were not in favor of the D Block allocation either and their voices were also heard over the past few years. However, in the end, the law of the land now says that Public Safety has the D Block and funding, and it is my belief that everyone, regardless of which side they took in the arguments and discussions, thought their view to be valid. I hope all of this can be put behind us. This is not about one side winning and another side losing, it is now about moving forward to make the Nationwide Public Safety Broadband network a reality as quickly as possible. There is much to be done and some of those who helped Public Safety in its quest will expect to be rewarded, while some who opposed these efforts might be concerned that they could be discriminated against. The way I see it, some of those who had different ideas about the D Block can become great partners in moving this network forward and I, for one, will be looking at each organization not for the stance it took prior to the bill being passed, but as a potential partner going forward.

For my part I will keep writing and providing information in the Public Safety Advocate and I will continue to play whatever role I am asked to play in the next steps. The passing of the bill marks the end of Chapter One of this saga but there are many chapters yet to be written before the final one. Some of these we know about and some we will discover in the days to come. Today we have been empowered to move forward to turn the concept of a nationwide, fully interoperable, mission-critical Public Safety network into a reality.

Andrew M. Seybold

If you are interested in finding out more about Public Safety Broadband and LTE, this is the event to attend. You can attend the in-depth sessions on Monday and Tuesday for a fee. The rest of the week, for the price of conference admission (and in some cases for free) you can attend one or more of the sessions dealing with Public Safety Broadband and an open APCO Broadband Committee meeting, and find out more about the various National Public Safety Telecommunications Council (NPSTC) committees and sub-committee and what they are working on.

Monday
On Monday, the sessions of interest are “What Does IP Mean to Radio Communications?,” a half-day morning session, and “Land Mobile Radio for IT Professionals” a half-day afternoon session. This is a great course for those who are becoming involved in the world of two-way or Land Mobile Radio and have an IP background. There is also an afternoon course called “The Softer Side of Communications: Software Applications over IP.”

Tuesday
The choices for broadband education on Tuesday include one of the morning sessions, “Wireless Backhaul from Microwave to IP/MPLS, or 4G, LTE and Broadband,” which is an overview. In the afternoon, the choice for broadband information is a session on Mobile Data and Multimedia fundamentals.

These two days of seminars are pre-conference activities and are presented by commercial firms and course experts.

Wednesday
On Wednesday, the full conference kicks off with a keynote by Martin Cooper who is a wonderful speaker. Among other things he invented the first handheld cellular phone while he was at Motorola in the 1970s (yes, several years before the first cellular systems came online in the U.S.). He is a true innovator and futurist and I always enjoy listening to him speak.

The exhibit hall opens at 10 a.m. on Wednesday and stays open until 7:00 p.m. while the show’s own sessions start at 11 a.m. The first one on LTE, entitled “What Is LTE?,” is a panel discussion that I am moderating, and from 12:30 p.m. to 1:30 p.m. there is a free keynote address called “LMR/LTE Vision for the Future” conducted by experts from Raytheon, Harris Public Safety, and Motorola. Starting at 1:30 p.m. there is a panel called “Voice over LTE and Broadband: Will it Replace LMR?,” which I am also moderating. I suggested that the title be changed to “The Myth of Mission-Critical Voice over LTE” but the organizers decided not to take my suggestion.

During the 3 p.m. time slot there are several panels of interest including “IP in an LMR World” and case studies on next-generation communications in airports. During the 4:30 p.m. sessions there is a panel on “Deploying LTE and Broadband Wireless in a Rural Setting” as well as one on a somewhat related topic of GPS interference and its effect on aviation, transportation, and defense, and my guess is that this panel will deal with the current LightSquared threat to GPS systems. From 5 p.m. until 7 p.m. that evening there is a network reception on the exhibit hall floor that is always fun to attend.

However, the 3 p.m. to 5 p.m. slot is also when the APCO Broadband Committee will hold its open meeting. I am vice-chair of this group so I will be there. Last year we had a great session. It is open to everyone who wants to attend and you will hear a report on our activities as well as the first public discussion on our sub-committee’s work on the design for a nationwide network. There will also be a presentation by the waiver recipients working group on interoperability choices and you will have an opportunity to take part in the open discussions as well as ask questions.

Thursday
On Thursday the day starts out with a general session at 8:30 a.m. called “Technology, Governance and Funding. The Challenges of Building a Nationwide Broadband Network.” This panel includes a host of non-government and government officials who will provide us with insight into how the broadband network might play out. Then at 9:45 a.m. I am on another panel called “Turning 700 MHz Narrowband into Broadband.” Have you noticed that I get the panels that are really unpopular with Public Safety because the ideas make no sense?

The next series of sessions includes one on developing standards for broadband applications. The lunch and learn session is called “The CIOs Speak Out: The Connected City through Technology.” The three CIOs are all deeply involved in LTE deployments for Public Safety and include Seattle, Boston, and Richardson, Texas and it should be a great session. The first of the afternoon group of sessions include one called “Public/Private Partnerships Part 1: Adventures in Joint Venturing,” which should be very good. This is followed at 3:30 p.m. by the second part of this session as well as a panel on broadband spectrum options for critical infrastructure industries.

For any of you who are members or would like to join the Yahoo group Private Wireless Forum, which is a great sig of LMR professionals, attorneys, government radio professionals, vendors, and others with an interest in LMR and Public Safety radio, the creator of the PWF will be hosting a cocktail reception at a nice location within walking distance of the convention center. Contact me directly if you would like an invitation to attend; it is a great place to meet some of the best minds in the wireless business.

Friday
Friday, the last day of the conference, is a busy one. The General Session is a panel I will be participating in and the subject matter is the move from P25 to LTE, Co-existence, Migration and Timing. But it is also the day NPSTC hosts its all-day session to bring everyone up to date on the activities of its multiple committees working on broadband subjects. I will be joining this meeting right after the general session, but if you won’t be attending the NPSTC meeting there are three supersessions: one that deals with the various digital technologies; one that is about lessons learned on integration and interoperability; and the final one that discusses how to navigate the mobile road and control bandwidth, connections, and data consumption. The conference is over just after noon on Friday.

Summary

As you can see, it will be a full week for broadband at IWCE but there are also many sessions dealing with LMR issues including narrowbanding, systems design and others aspects of planning, building, operating, and maintaining LMR mission-critical Public Safety networks. The show floor will be full of companies waiting to talk to you about what they have to offer and what is next. Some of the companies I will be visiting include Alcatel-Lucent (broadband systems), Anritsu Company (test equipment for broadband systems), APCO (because I am a member), AT&T to see what is new in its world of broadband, Cassidian Communications, General Dynamics, Harris, Kenwood, Motorola, the Push-to-Talk organization, Radio Club of America (I am on the board), Radio IP Software, Raytheon, Rockwell Collins, Tait Radio, ThermoBond Buildings (the last building I purchased was from them and it is great), Twisted Pair Solutions (a bright bunch of folks), Wilson Electronics, and I will stop at many other booths that catch my attention as I walk the floor.

IWCE is co-sponsored by Urgent Communications and it is a great show. For the record, I am not paid by anyone for my participation in any of the sessions nor am I paid by IWCE or Urgent. This article was written to provide our subscribers with an overview of the broadband focus of the show and not to promote the show. IWCE is a good event that is a lot of fun and I hope I will see many of you there!

Andrew Seybold

The Public Safety community has come together over a most important issue: Obtaining the needed spectrum, funding, and governance structure to build and operate a nationwide, fully interoperable, broadband network to add data and video capabilities to its existing voice and slow-speed data capabilities. Today’s commercial networks offer these services but are not built to be mission-critical, which is a requirement of the Public Safety community. This paper discusses the issues and the differences between the U.S. Senate bi-partisan approach and the U.S. House of Representatives’ majority leadership approach to solving this problem.

Over the course of the past two years, the members of the Public Safety Alliance (PSA) have, time and again, met with numerous Members of Congress and their staffers in an effort to explain why this issue is so important for the first responder community and why it must be resolved before work can begin in earnest on the first fully interoperable data and video broadband network to provide mission-critical services to the Public Safety community.

Last year Senators Rockefeller and Hutchinson introduced Senate Bill 911, a bipartisan bill that would reallocate the D Block to Public Safety, provide $11billion in funding, and set up a governance non-profit corporation to manage both the construction and the operation of the nationwide broadband network while providing local control over day-to-day operations. Late in 2011, the House introduced several bills, one of which was subsequently attached to the Omnibus tax bill, which while reallocating the D Block to Public Safety missed the mark on both funding and governance and contained a spectrum give-back provision that is opposed by the Public Safety community.

As the 2011 session of Congress ended, both houses dropped the spectrum auction portions of the tax bill and a temporary tax bill was passed. As Congress starts its 2012 session, the Public Safety spectrum issue has yet to be resolved and September 2012 will mark the 11^th anniversary of the tragic events of 911 and the 7^th year since the release of the 911 Commission report that called for Public Safety communications interoperability. Congress still has not acted on this one remaining item listed by the 911 Commission as an item that needs to be addressed.

The Public Safety community has been patient and has provided all of the data and information asked of it so that those in Congress would have the information it needs to pass the legislation that is required to move the Public Safety interoperable broadband network from a goal to fruition. As we begin 2012, an election year, the Public Safety community remains solidified in its desire for the proper legislation to be passed. The issue of the reallocation of the D Block to Public Safety has now been addressed by both Houses of Congress and by both parties within both houses. However, there still remain some differences between what the Senate has proposed in S911 and what the House majority leadership is promoting. The differences are major. On the one hand the Senate bill provides for a governance organization and Federal funding that is acceptable to Public Safety while the House bill does not. Further, the House bill requires the return of 700-MHz narrowband spectrum, which is spectrum that is vitally needed and being used to provide interoperable voice services across the United States today.

The Public Safety community is strongly in favor of the terms provided in S911 with the exception of the proposed shared broadband/narrowband use of the currently allocated narrowband spectrum. It is strongly opposed to the governance, funding model, and spectrum give-back included in the most current House bill that was attached to the Omnibus Tax bill passed by the House. It is now a new year and an election year. The Public Safety community is requesting that the two Houses of Congress agree to a bill that reallocates the D Block to Public Safety, provides sufficient funding to build and operate the network, and provides for a governance organization that gives the Public Safety community a majority say in the construction and day-to-day and emergency operation of the broadband network. Moreover, the Public Safety community opposes any legislation that imposes an arbitrary give-back of spectrum based on information provided by a third party (such as an Administrator) and not directly by those involved in the operation of Public Safety networks.

If the Public Safety community is to continue to provide the services to keep America safe, to protect life and property, it needs to advance its communications systems beyond voice and it needs to provide for a nationwide data and video network as it continues to move toward interoperable voice services over its existing narrowband voice service spectrum. The idea that broadband networks can provide voice, data, and video services on a mission-critical basis is a laudable vision, but unfortunately this capability does not currently exist and has not yet been shown to even be achievable.

The Public Safety community is once again calling on Congress to act, to work out the differences between S911 and the House bills, and to reach a conclusion that is in the best interests of the Public Safety community and, therefore, the best interests of all of the citizens of the United States. The Congressional session that begins in January of 2012 should be the last session of Congress to have to address this issue and the outcome should be one that is of maximum benefit to the First Responder community as well as the citizens of the United States.

Introduction

After more than two years of effort on the part of a cohesive Public Safety community, Congress has once again failed to act on providing Public Safety with the additional broadband spectrum it desperately needs, the funding to build a nationwide network, and a governance structure that would permit the Public Safety community, which is solidified behind this effort, to be an important part of the organization that will oversee both the construction and the operation of the broadband network.

The Public Safety community is solidly behind the resolution of these issues as outlined in Senate Bill 911 introduced by Senators Rockefeller and Hutchinson that passed the Commerce Committee with a bipartisan vote of 21-4 in 2011. The House bill, including the bill that was attached as Title IV of the Omnibus spending bill H.R. 3630, is not acceptable to the Public Safety community for many reasons. First is the provision in this bill that requires the give-back of both the 12 MHz of 700-MHz spectrum now being heavily used for narrowband voice communications as well as the 2 MHz of guard bands that were designed to protect not only this spectrum but the Public Safety broadband spectrum from interference. Next is the funding model for the Public Safety broadband network that is less than half what has been proposed in S. 911 and is not sufficient to build the network. Finally, the governance proposed in the House bill that would award the governance of this network to a private firm called an “administrator” that would not be required to listen to, or take direction from, the Public Safety community or those who will be using this network.

The Spectrum Issue

The Public Safety community is appreciative of the fact that the House of Representatives has now acknowledged that the Public Safety community needs the 700-MHz D Block to be reallocated to it. However, there also appear to be some who do not understand that the broadband network is to augment the use of current Public Safety mission-critical voice communications and not to replace this capability anytime in the near future. It is the long-term goal of Public Safety to continue to work toward better voice interoperability while building out a new data and video-capable nationwide and fully-interoperable data and video network.

At some point in the future, if and when mission-critical voice capabilities become available over the Public Safety broadband network, the Public Safety community will be more than willing to sit down with members of Congress and/or the FCC to review the Public Safety spectrum allocations with the goal of returning some portions of the spectrum now used for narrowband mission-critical voice to the Federal Government. However, this cannot be accomplished until such time as all of the requirements for mission-critical voice included in the National Public Safety Telecommunications Council (NPSTC) document[1] can be met using the spectrum allocated for broadband services and equipment that will provide mission-critical voice services over the broadband network are readily available at an affordable price.

The spectrum that could then be returned to the Federal Government would have to be carefully determined and a timeline for its return developed to provide for the relocation of those Public Safety agencies now using that spectrum. The timing would have to be long-term such as to not place an additional financial burden on state and local communities. In any case, the current 700-MHz narrowband voice spectrum is today, and well into the future, playing an important role in providing interoperable mission-critical voice communications systems for states, regional, metropolitan, and other Public Safety voice communications systems. In reality, this spectrum should be the last portion of the existing Public Safety narrowband spectrum to be considered for reallocation for non-Public Safety use. It is on this spectrum that the most progress has been made toward providing the Public Safety community with interoperable mission-critical voice communications services.

This spectrum only became available to the Public Safety community in June of 2009 and already several $billion have been spent deploying systems all across the United States that are, today, providing multi-agency interoperable mission-critical voice communications. The mere fact that its “give-back” is included in the House bills has caused many agencies to halt their plans to build new networks on this spectrum until the issue has been resolved. Until the give-back of this spectrum is taken off of the table, Public Safety agencies are not willing to invest in the new, much more interoperable voice communications systems they need. The end result is that the potential give-back of this spectrum has done serious damage to the implementation and planning for hundreds of Public Safety mission-critical voice systems. Since this spectrum became available only two years ago, the Public Safety community has done more to solve the interoperability issues for mission-critical voice with this spectrum than has been done by any Federal organization. And while some of the funds have been provided by Federal grants, most of the funding has been from the local communities that are committed to providing the best possible mission-critical voice systems to their first responders. Taking this spectrum away now will set the Public Safety community back to the days when Interoperability was only a vision rather than a goal that is now being realized in many areas of the United States.

Mission-Critical Voice Over Broadband

There are apparently many people within the Federal Government who believe that mission-critical voice over wireless broadband services (LTE) is only a few short years away. This is a misconception. In reality, no one knows when or even IF LTE can and will support mission-critical voice, and at what cost. Today none of the commercial LTE network operators in the United States (AT&T, Verizon, Metro PCS, and Leap Wireless) or around the world have deployed standard non-mission-critical voice on their LTE networks. Commercial operators are still making use of their second-generation (2G) and third-generation (3G) networks for voice and most of them have no plans to shift this voice usage to their LTE networks for a number of years.

Yes, there is some experimentation with what is known as Voice over LTE (VoLTE), which is based on Voice over IP, but no network operator is ready yet to mix voice and broadband data services over LTE. It will be a number of years before they are ready to make this transition and they realize that adding voice to their LTE networks will reduce their broadband services capacity. They lived through their inability to provide enough broadband capacity on their existing 3G networks and are going to be slow to move voice to LTE because of the impact it will have on broadband capacity. For the time being, it is also less expensive to continue to use their 2G and 3G networks for voice services. The voice that will eventually be implemented over these commercial networks will NOT be mission-critical[2] in nature but rather the same type of voice services in use today on the 2G and 3G networks.

When a smartphone or other wireless device on a commercial network is out of range of that network or if the network is overcrowded as happens during major events (most recently the earthquake on the east coast followed by the hurricane), the device is useless to the customer. Likewise, if the customer is inside a building or in a basement where there is no coverage the device does not work and there are no communications at all. This may be acceptable to commercial network customers but it is NOT acceptable for the first responder community. First responders need to have communications all of the time whether they are in range of a network or not. When they are out of range of a network today they have the ability to communicate device to device, something that is not available on any commercial wireless network. This is only one, but one very important attribute of mission-critical voice communications. Another is one-to-many communications that are needed for day-to-day and emergency communications. This is not possible, today, over any commercial network except by using push-to-talk services that are not widely used and are not, in any case, mission-critical in nature.

Will it be possible to provide for full mission-critical voice communications over the Public Safety broadband network? It is hoped that it will be possible at some point in the future, but as of today there is no assurance that it will be possible or how far in the future it will be before it might become available. Therefore the idea of requiring the give-back of essential mission-critical voice spectrum in the 700-MHz band is not and will not be something that the Public Safety community or state and local government entities can support. Further, in the House version of the spectrum bill the determination of when mission-critical voice will be available over LTE would be made by a private company administrator and not by the Public Safety community—something that is totally unacceptable.

Another issue that has not been addressed by those who believe mission-critical voice over LTE is just around the corner is the fact that mixing voice and data services on the same broadband network means that some of the broadband capacity normally used for data and video services will be taken up by voice users. In major incidents, which tend to occur within confined areas that may only be covered by one, two, or three cell sectors, it is possible or even probable that mixing voice with broadband data and video will reduce the data and video capacity at a given incident enough that the data and video capacity will not be sufficient to meet the requirements of the incident.

One final note regarding the spectrum issue and the give-back of narrowband spectrum: If those within Congress and the Federal Communications Commission believe that broadband services will be able to handle voice, data, and video applications going forward, why is the FCC moving forward with its unfunded narrowbanding requirement for all land mobile radio (LMR) users between 150 and 512 MHz? This requirement with a January 1, 2013 deadline means that land mobile radio users including Public Safety are spending millions of dollars modifying existing equipment or buying new equipment in order to meet the mandate of operating wireless voice communications systems in even narrower portions of the radio spectrum. The implication is that while broadband is important for broadband services, narrowband voice systems will be in use for many years to come and therefore the FCC is requiring the narrowbanding of these land mobile radio systems in order to be able to add more voice radio channels within those portions of the spectrum affected by this order. If broadband is, indeed, the only future of wireless that is important, then why is the FCC moving forward with this unfunded mandate?

Public Safety Network Funding

Senate Bill 911 calls for designating $11 billion to be used for building the nationwide network plus $100 million per year for four years for Public Safety research and development. The amount of funding in the House bill is a minimum of $5 billion with an upside, depending on spectrum auction revenue of $1.5 billion for a total of $6.5 billion. In reality neither of these amounts is enough to build out the entire nationwide network, but the $11 billion number contained in S911 is a lot closer to what the final bill will be than the $6.5 billion contained in the House bill. Further, the money included in S911 for research and development can be used to help determine if mission-critical voice over LTE will be practical and within what timeframe. Without this funding the commercial industry would have to foot the bill for R&D and in today’s uncertain financial climate this type of research is unlikely to be a priority for any of the companies that have the knowledge and expertise to make that determination.

The funding requested in S911 is closer to the figure arrived at by the FCC[3] and is by far the most realistic of the two amounts. In recent years cities, towns, counties, and states have already expended $billions in Public Safety voice system upgrades, in narrowbanding its systems, and in deploying voice systems within the 700-MHz narrowband spectrum. In order to make this network a true nationwide and fully interoperable network to add data and video capabilities that will bring Public Safety communications into the 21^st Century they will still have to spend additional $millions if not several additional $billions more. If the amount made available from the auctions is reduced even to the $6.5billion level, the time needed to build this network will more than double and in some areas of the United States it may never be built at all.

The reality is that the funds it will take to build and operate this network need to be made available from the proceeds of the spectrum auctions and they must be sufficient to ensure that the network is built in a timely manner and provides the 96% population coverage envisioned. This funding will have no direct impact on the national debt, and once the network is built and put into operation there are provisions in S911 that the network will become self-funded through public/private partnerships moving forward. The required funds need to be viewed in the proper context. This is an investment in Public Safety and first responders’ ability to perform the tasks they face every day protecting our lives and property.

Governance

Senate Bill 911 calls for the establishment of a non-profit governance organization known as the Public Safety Broadband Corporation. The board of directors of this organization would be made up of four Federal members and eleven non-Federal members. The non-Federal members would be made up of three members that represent states, localities, tribes, and territories; three Public Safety members; and five members with specific expertise in finance, technology, and other disciplines required by the BOD.

While the Public Safety community would rather see more representation from within the Public Safety community, the organizations making up the Public Safety Alliance believe this is a workable model and will provide for meaningful Public Safety input on the construction and operation of the network. The House bill, on the other hand, calls for a private company that would become the network administrator. This administrator would have the sole responsibility of building and operating the network and would not be required to have any oversight or control from the Public Safety community—the very community that will be using this network for mission-critical data and video applications.

There are a number of issues with this approach. Public Safety would have minimal control over this administrator model and would have to go to Federal District Court to challenge any decisions made by the administrator that ran counter to the needs of the Public Safety community. It is doubtful that any of the firms that typically provide this type of administration and oversight for Federal or local government networks have the qualifications to know and understand the requirements of the Public Safety community, which are different from requirements for non-mission-critical network construction and operation.

The Public Safety community currently has an appointed administrator to oversee the 800-MHz rebanding required because of interference to Public Safety communications by Sprint/Nextel. This arrangement has proven that in many cases the needs of the Public Safety community have gone unmet and that the administrator actually slowed the process down and added $millions to the cost of the rebanding. This rebanding cost is borne by Sprint/Nextel but the cost overrun for the rebanding has added several significant costs to the final price tag for this project and has contributed to delaying completion of the process.

The Public Safety community is not in favor of the administrator approach to network construction and operations. The vision of the Public Safety community is that the proper governance organization modeled after the one contained in Senate Bill 911 is the best way to provide the governance needed as well as oversight of the network funding. This network is being built for use by the Public Safety community, and while it will be nationwide in scope, most of the day-to-day operational requirements will be met at the local level. Having a network administrator dictating how the network will be constructed and operated is not viewed with favor by the Public Safety community.

Conclusions

There is now a bipartisan consensus in both Houses of Congress, the 700-MHz broadband spectrum known as the D Block should be removed from the auction block and reallocated to the Public Safety community. The issues remaining to be settled have to do with the appropriate amount of funding, the governance of the nationwide network, and the fact that Public Safety should not be required to give back spectrum as part of the bill that ultimately passes Congress.

Public Safety is committed to working with Congress and the Federal Communications Commission to discuss spectrum give-backs in the future, after the broadband network is operational and research has been conducted on the feasibility of providing mission-critical voice over LTE. It is too early at this juncture to require that a specific portion of the Public Safety spectrum be given back, especially if that determination is to be made by a network administrator.

More than ten years after the tragic events of 911, tremendous progress has been made by the Public Safety community to provide better interoperability between agencies. It is now time for Congress to act to add mission-critical data and video capabilities to the communications tools available to the first responder community. To that end, the Public Safety community is asking that Congress come together and support a plan that is fair for Public Safety and allocates it the spectrum, funding, and governance it needs to provide these important augmented services to first responders. Enabling first responders to go anywhere and be able to exchange data and video, and letting them retain the narrowband voice spectrum they need to continue to improve voice interoperability more than ten years after 911 is still of concern to those who provide assistance to the citizens of this nation 7 days a week, 24 hours a day.

Andrew M. Seybold

The end-goal of a single network that will provide voice, data, and video services across the nation is also a goal shared by the Public Safety community. However, this is a complex issue and a number of obstacles must be overcome in working toward that goal. In the meantime, those who believe the Public Safety LTE broadband network will soon be able to provide all of these services, making the 700-MHz narrowband spectrum obsolete, need to be aware of these issues and what needs to be done to overcome them.

This requirement that is contained in the bill presently in the House would, in reality, cripple the Public Safety community and negate all of the progress that has been made toward interoperable voice communications over the past ten years. The 700-MHz narrowband spectrum, which has only been available to Public Safety since the sunset of analog TV in June of 2009, has already seen a number of local, regional, and statewide systems built and put into operation. There are also many more agencies in the planning stages of making use of this spectrum for narrowband communications in order to further the ability to achieve voice interoperability, which has been lacking in Public Safety for more than thirty years and was brought to the public’s attention during the attacks on 9/11 and the Katrina earthquake.

The assumption is that when the broadband spectrum supports  mission-critical voice, Public Safety will be able to consolidate voice and data services on the broadband spectrum. While this is certainly the goal of the Public Safety community, it is premature to assume that mission-critical voice will be available on the LTE broadband network. The decision by Congress to include the 700-MHz narrowband spectrum as a “give back” in the House bill is, I believe, based on a lack of understanding of all of the implications this would have on existing and future Public Safety voice communications. While this is a goal that is sought after by both the federal government and the Public Safety community, there are many other factors that must be taken into consideration before definitive dates can be placed on this giveback.

The definition of mission-critical voice services may not be fully understood by those involved in the decision-making process. Public Safety mission-critical voice is vastly different from voice services being offered over traditional commercial broadband networks. Verizon has stated, for example, that it is trialing voice over IP (VoLTE as it is called) and could be ready to deploy it on its LTE network starting in 2013. However, what Verizon will be offering when it is ready for commercial service is traditional voice for those who want to make and receive voice telephone calls. This type of voice service only provides one of many of the features and functions required within the Public Safety community.

Therefore it is important that those crafting legislation that includes the giveback of the 700-MHz narrowband spectrum fully and completely understand the differences between voice and mission-critical voice.

The National Public Safety Telecommunications Council (NPSTC) recently published what is becoming the standard definition for mission-critical voice not only over LTE but also over any wireless interface.[1] The Executive Summary states that the key elements for the definition of mission-critical voice include the following:

• Direct or Talk Around: This mode of communications provides public safety with the ability to communicate unit‐to‐unit when out of range of a wireless network OR when working in a confined area where direct unit‐to‐unit communications is required.

• Push‐to‐Talk (PTT): This is the standard form of public safety voice communications today ‐ the speaker pushes a button on the radio and transmits the voice message to other units. When they are done speaking they release the Push‐to‐Talk switch and return to the listen mode of operation. 

• Full Duplex Voice Systems: This form of voice communications mimics that in use today on cellular or commercial wireless networks where the networks are interconnected to the Public Switched Telephone Network (PSTN).

• Group Call: This method of voice communications provides communications from one‐to‐many members of a group and is of vital importance to the public safety community. 

• Talker Identification: This provides the ability for a user to identify who is speaking at any given time and could be equated to caller ID available on most commercial cellular systems today.

• Emergency Alerting: This indicates that a user has encountered a life‐threatening condition and requires access to the system immediately and is, therefore, given the highest level or priority. 

• Audio Quality: This is a vital ingredient for mission critical voice. The listener MUST be able to understand without repetition, and can identify the speaker, can detect stress in a speaker’s voice, and be able to hear background sounds as well without interfering with the prime voice communications. 

A Comparison of these requirements and those available on today’s 3G and 4G commercial networks is provided in the chart below:

As can be seen from the above comparison chart there are a number of key differences between commercial voice and mission-critical voice today, and the functions that are NOT a part of broadband commercial voice or cellular voice systems today are the most important aspects of mission-critical voice for Public Safety. While it is possible that these functions can be designed into the LTE broadband technology going forward, there remain several issues:

1. What is the timing for these functions to be incorporated into LTE?
• Would they have to be approved by the world standards bodies?
• Would there have to be on-off modifications to LTE for Public Safety only?
2. Would one-to-many voice communications require the addition of what is known as eMMBS or enhanced Multi-Media Broadcast Services? If eMMBS is required, it will add substantially to the cost of the Public Safety LTE Network.[3]
3. Even if LTE can be modified to provide one-to-many push-to-talk, group call, emergency alerting, and off-network or peer-to-peer communications, can the Public Safety broadband LTE network support the number of voice paths that are needed?
• See details on voice paths below.
4. Today there is no definitive design document outlining and detailing all of the Public Safety requirements for mission-critical voice. Therefore, it is not possible to know for certain if all of these requirements can, in fact, be included in the LTE technology and if they can be, how long it will take before these changes could be made and devices become available.
• Will there be non-recurring engineering costs (NRE) associated with the development of these functions? Would these costs be paid by the federal government?
5. If LTE can be modified to meet all of the requirements for mission-critical voice at some point in the future, who will pay for the following?
• The move from 700-MHz narrowband systems to the Public Safety broadband system.
• The replacement of all existing LTE broadband devices in use by Public Safety on the broadband network until the time that mission-critical voice becomes available.
• These replacement costs will run into the multiple $millions. Will these costs be included in the relocation fees that the federal government will pay out from the proceeds of the 700-MHz narrowband spectrum auction?

It should be noted that most of the Public Safety requirements for voice services have little or no value to commercial operators. Thus, unlike the existing LTE standard, changes to the standards to permit mission-critical voice over LTE will have to be incorporated into the LTE standard for the Public Safety community only, or if the standards body elects not in include off-network voice and data communications into the standard, the standard will have to be modified for the Public Safety community, which is counter to the original purpose of making use of a commercial standard to reduce device costs.

There is also the issue of the qualifications of those promoting the use of mission-critical voice over LTE. Are they engineers with a complete understanding of mission-critical voice? Do they have any firsthand experience with Public Safety mission-critical communications? Many people assume that the requirements of commercial voice and mission-critical communications are the same. However, as demonstrated above, there are a number of significant and important differences. When a cell phone is out of range of the network on which it operates or out of coverage, the device is useless to the person holding it. In the world of Public Safety that is not an option. Voice communications is and will continue to be the lifeline for our Public Safety professionals. They need to know that when they need help, they can make a simple push-to-talk voice call or push their emergency button and regardless of where they are within network coverage or outside of it, deep inside a building or simply out of range of the network, that their call for assistance will be heard and acted upon. Therefore, those who are making statements regarding voice over LTE must have a solid grounding in what the definition of mission-critical voice is and how it can be applied to the LTE technology. Unless and until all of the various forms of mission-critical voice communications can be provided by LTE, the need for narrowband spectrum and channels will remain.

There are two sets of issues that need to be considered when making a decision about when and if Public Safety narrowband spectrum can be reallocated. The first set of issues is to fully understand the requirements of the Public Safety community for mission-critical voice. The second is to look at what within the LTE technology will have to be changed, modified, or invented from scratch.

Understanding the requirements for mission-critical voice should be the first priority for anyone seeking to determine if and when voice over LTE will be able to provide all of the different types of voice services required. Again, Public Safety requirements go well beyond the simple use of voice for voice calls. It is, therefore, vitally important that those making statements about the use of mission-critical voice over LTE have a complete understanding of all of the requirements. Below is a list of suggested qualifications that should be used to determine whether those providing the information about voice over LTE are qualified to render their opinions.

1. They have read and understand the National Public Safety Telecommunications Council (NPSTC) document: Mission Critical Voice Communications Requirements for Public Safety (MCV Functional Description). This document is also being presented to ANSI to be certified as the standard definition for mission-critical voice.
2. They understand and can explain
• The use of both on and off-network voice communications.
• Why off-network voice even when within the coverage area of a network is important to Public Safety.
3. The range requirements (distance) of mission-critical off-network voice.
• How this will be accomplished when replacing traditional handheld and mobile narrowband voice devices that operate with a transmit power of from 5 to 100 Watts with LTE devices that are today transmitting at a peak power of ¼ watt.
4.  The terms one-to-one, one-to-many, talk groups.
5. How many independent voice circuits or channels are required for any incident.
• Typically during an incident, each sub-group makes use of its own voice channel so it does not interfere with the others. The Incident Commander normally communicates with each sub-group leader and has a communications path between the incident and the command or dispatch center.

To my knowledge, beyond the NPSTC definition document referenced above, no group or individual has developed a set of specifications or a requirements document that could be provided to potential vendors to obtain feedback on the feasibility of adding all of the requirements of mission-critical voice to LTE before making a determination:

1. That LTE will be able to support mission-critical voice.
2. At what point in time these functions will be available for deployment within the Public Safety LTE network.
3. When devices will be available that will provide all of the functionality required for mission-critical voice over LTE and at what cost.

It is essential that a requirements document be drafted and that input from the chip vendors, device vendors, and software vendors be sought. Statements that are not based on specific requirements are not helpful to those who must make decisions that will impact the day-to-day operation of the Public Safety community.

That brings up the issues that must be understood and for which technical solutions must be found before there can be a determination of the “if and when” of mission-critical voice over LTE. Some of these are:

1)   What are the range requirements for off-network voice communications?

• Today’s narrowband voice devices range from 5-Watt handheld radios up to and including 100-Watt mobile radios. LTE devices today have a transmit power of ¼ Watt.
• Further, narrowband voice devices make use of more efficient external antennas while today’s commercial broadband and voice devices have much less efficient internal antennas.
• What is the range of these devices for in-building communications when required?

2)    How many simultaneous on and off-network voice channels are required?

• Many cities require multiple voice channels for dispatch. Today they normally have one to three citywide channels and then divide the city into districts with each having its own dispatch channel. They need additional voice channels on a district or multiple district basis for the units responding to an incident. The FCC’s guideline for the number of vehicles that can be managed on a single radio channel state that depending on the narrowband technology, between fifty and ninety vehicles can be dispatched and managed on a single voice channel. In many cities the number of vehicles in a fleet runs into the thousands.
• In addition, each incident usually requires multiple off-network voice channels for the various types of responders. These channels are important since they enable the individual groups to work together while keeping voice traffic off the on-network voice channels.
• The number of off-network voice channels will depend on the type of incident. In a major wild land fire as many as eighty or more of these channels are pressed into service as the incident grows in scale.

3)    How the channel is changed on the voice device.

• On a typical LTE network, the network controls the channel assignment of the device. The device itself has no provisions for changing to a different channel.
• In today’s narrowband voice systems, the channel assignments are given to those arriving at an incident and they manually switch their radios to the desired channel. Further, many field devices are set up to receive not only the assigned voice channel but also to monitor several other channels by using a scanning system with priority.
• Therefore when a device is making use of off-network voice some method of channel changing must be provided. Today’s radios are usually multi-channel capable and many have several hundred voice channels pre-programmed into them for use during both local and mutual aid incidents.

4)    Transmitter power output requirements.

• Today’s handheld Public Safety devices have transmitter power output levels of 2 to 5 Watts and make use of an external antenna. Mobile devices have a transmitter power output of 20-100 Watts and also make use of an external antenna.
• Today’s LTE devices have a transmitter power output of up to ¼ Watt and make use of internal antennas that are less efficient than externally mounted antennas. Further, the power level of the transmitter is controlled by the LTE network depending on the distance from the cell site to the device.
• The requirements for off-network voice communications call for these devices to be able to communicate with each other over a distance of several miles or between devices when one user is on the street and others are located within a building including in basements and other internal areas.

5)    Audio output.

• Today’s voice devices include device-mounted or external speakers and audio output is sufficient for users to be able to hear the voice traffic on the selected channel without having to hold the device in their hand.
• Today’s LTE devices are designed for handheld use or use with a Bluetooth device. Usual operational requirements are that the users hold the device.
• Public Safety voice devices can be listened to without having to pick up the unit. Transmissions can be made by pushing the PTT switch on an external microphone or on the side of the radio. This is very different from today’s commercial devices that require one and sometimes two-handed operation. Public Safety cannot EVER be required to use a device that takes two hands to operate. In many conditions they cannot afford to have a device that has to be held in order to hear the voice traffic on the channel.

Conclusions

The Public Safety community would like nothing better than to have a single, nationwide swath of spectrum that would enable true interoperability for all of its voice, data, and video needs. However, this must be balanced with the amount of spectrum required for day-to-day operations within large metro areas and the amount of voice, data, and video traffic that will ride on the wireless network. Overloading a commercial cellular network, as has happened on numerous occasions, results in blocked or dropped calls and dropped data sessions. This is not an option within the Public Safety community.

Going forward there must be a balance of existing voice spectrum and its usage with that of the new broadband spectrum. The 700-MHz narrowband spectrum is vital in this regard. As we move forward over the next five years and the Public Safety broadband network is built out, it will provide interoperable data and voice communications services. However, to expect it in the short term to also provide fully interoperable voice communications to replace that which is presently on the Public Safety narrowband channels is not realistic.

It is hoped that someday this can be accomplished. The issue is when that day will come, what must be done, and how much money must be invested before we get there. There are many questions and few answers, thus planning the obsolescence of the Public Safety 700-MHz narrowband voice channels is both premature and unwise. Today the best solution for providing as much voice interoperability as possible lies within the 700-MHz narrowband spectrum allocation. To plan now to reclaim it will stop, dead in its tracks, all further development of 700-MHz narrowband voice systems that are of vital importance. Public Safety does not have enough narrowband spectrum to operate on a day-to-day basis. Planning to reallocate the narrowband spectrum at some future time essentially stifles all future development of 700-MHz narrowband systems. Cities, counties, and states will not invest $millions building out new networks that could be taken from them in the next five or ten years. Public Safety systems are built to last for decades, not years, and local governments are struggling to find the resources they need to provide for all of the public services they normally must provide. Even for Public Safety, a vital community function, they won’t invest in a network that will solve an interoperability problem today that will be shut down within a decade.

The optimists believe that mission-critical voice over LTE is just around the corner, the engineers and LTE system planners believe it will be at least a decade, and others are not convinced that LTE, as a broadband technology, will ever be able to replace narrowband mission-critical voice. From my perspective, we are better off revisiting this issue after a set of requirements has been vetted with the technical community and feedback has been provided by those responsible for the design and advancement of broadband technologies.

Further, it should not be up to anyone except the Public Safety community to decide if and when mission-critical voice over LTE will satisfy its requirements. Public Safety personnel are in the field every day to serve all of us, and they are in harm’s way much of that time. They have the right to expect that when they call for help on their radio that call will be heard and help will be on the way. If they cannot trust their communications systems to work all of the time, every time, we have no right to ask them to put themselves in situations that endanger their own lives.

Andrew M. Seybold

This draft report is being circulated and the entire report is below in PDF format. I have written the following document and submitted it to the committee for review.

Note: These comments are being made by Andrew M. Seybold as an individual and do not reflect the views of any Public Safety organization at this point in time.

General Comments

The vision of this report is certainly a vision that is shared by the public safety community: Having complete interoperability on a mission-critical basis nationwide. While this is a worthy goal and one that should be worked toward, this report needs to be viewed in light of a long-term vision and the road to that vision will mostly likely be measured in decades as opposed to years. There will have to be some major and fundamental changes concerning spectrum policy and allocations, there will need to be major advances in both cognitive and software-defined radios, and operational changes. It is not clear from this report that the authors truly understand the complexities of today’s public safety voice and low-speed data systems, nor the implications of adding a single slice of broadband-capable spectrum to these allocations.

Unlike the Internet where bandwidth can be added with routers and additional fiber assets when needed, the wireless spectrum is finite in nature and at present is totally occupied by many different types of communications services. Existing services that now require additional bandwidth cannot simply expand the amount of spectrum they utilize but must rely on other techniques to add capacity, such as adding sites spaced closer together. This is a time-consuming and expensive proposition. In some portions of the United States it can take as much as three years to add a single site because of zoning and permitting issues. The goals stated in this report, therefore, should be considered as goals worth working toward but on a long-term basis and decisions regarding operational considerations and network capacity should be taken completely within the context of wireless spectrum and the constraints placed on capacity growth, which are very different from those within the wired community.

This document is well intentioned but it appears as though the authors are trying to fit the intricacies’ of public safety voice, data, and video communications into a mold that was developed and is known as the Internet, which is based on the Internet Protocol (IP), rather than framing the values of an IP architecture within the constraints of the bandwidths associated with the current spectrum holdings of the public safety community. These spectrum holdings are spread out in multiple small segments of the spectrum from 30 MHz up to 800 MHz, and on narrow voice channels that are often intermingled with other narrowband voice channels for business and industrial radio services. Further, the 700-MHz broadband allocation for public safety at this point in time is only 10 MHz (5X5 MHz). Even when Congress reallocates the D Block to public safety, the new public safety broadband spectrum will only be 20 MHz (10X10 MHz). As noted in the report,[1] during incidents in confined areas this is not enough spectrum in which, today, to operate voice, video, and data.

This report recommends a number of items that are important and some things that are not practical to accomplish during routine but sizeable incidents that occur on a daily basis. For example, the use of deployables, mesh technologies, and replaceable network segments will, indeed, be valuable for incidents such as earthquakes, wild land fires, tornadoes, hurricanes, and other disasters that occur over wide areas and where emergency communications are needed for days, if not weeks. However, none of these capacity increasing capabilities are possible for most local incidents that occur on a daily basis and are of short but intense duration.

Further, unlike the wired Internet, the broadband spectrum currently assigned to public safety using the LTE technology has a spectrum re-use pattern of one-to-one, that is, each site uses all of the broadband spectrum, thus sites can and do cause interference to each other unless they are properly engineered. Even then, adding new sites requires extensive planning in order to minimize this interference and this type of network does not lend itself to ad hoc or mesh typologies that are put up and taken down. Mesh may in fact play an important role in public safety communications over time but must be viewed in the context of the interference it could generate. Using LTE, it is possible to deploy additional devices or nodes and have these nodes cause interference to the existing infrastructure, thereby actually degrading network performance.

The authors refer to the first hour of an incident as the “Golden Hour.” During this time those involved in the incident are busy managing the incident and taking action to prevent it from escalating beyond its current level. They have no interest, time, or ability to manage communications links as part of their tasks. To reiterate a statement made above, the first responders are USERS of communications technologies and do not have the time or the training to make changes to the infrastructure during incidents. The job of those involved with planning, building, and operating these networks is to make sure our first responders have all of the communications capabilities they need, when and where they need them.

The premise that is most important for first responders is that their communications links are invisible to them, they are mission-critical, taken for granted, and designed and implemented by others on their behalf and these links are expected to work wherever the incident is regardless of how many people are on the scene of the incident. Unlike the Internet, which is neither a mission-critical network nor a managed network, these wireless communications networks must be both mission-critical and managed. Management in the case of first responder communications does not mean managing the communications links but rather the traffic across those links. This is normally the purview of the dispatch center but it can also shift to the incident commander or communications emergency van at the scene. It is the job of those who manage the traffic to assign channels of operation that enable each sub-group involved in the response to be able to communicate among themselves and for the system traffic manager to be able to monitor and interact with all of this traffic be it voice, data, or video.

This report seems to expect the first responder community to become conversant in the various forms of communications needed and to be able to ask for what they need when they need it. In the Internet world that this report is based on and that is used as a comparison of the state of public safety communications, those who use the Internet have no involvement with its development or its deployment and do not have the ability to ask for and receive more bandwidth on demand. They are USERS who make use of the Internet to communicate. We must keep in mind that first responders are USERS of the voice and data networks they need and they are not trained communications engineers nor are they communicators. They are users of an infrastructure that has been designed and built to mission-critical standards for them by others who work with the first responder community every day and who are well versed in the needs of this community. Further, when this infrastructure is not available, all of the field devices are capable of one-to-one and one-to-many communications over fairly long distances and deep into buildings. This is not an attribute of either the Internet or commercial broadband networks where connectivity between devices must be managed by the network.

Further, the idea presented in this report that there should be a central “single entity in charge across the entire public safety enterprise” does not exhibit an understanding, as stated elsewhere in the report, that most incidents are local in nature or start as local in nature. Further, this statement does not take into account the fact that those who provide public safety services within a given service area have an understanding and a knowledge of their requirements, which in many cases are unique to their own environs and cannot possibly be transferred to a single entity. Having a nationwide organization to govern the overall network architecture is important going forward, but retaining local control over the day-to-day operations of the public safety community is of paramount importance.

Specific Comments

Observations and Context

1.1  Scope of Public Safety Community

This section states: “At least one commentator observed that achieving public safety is hard because the effort is fragmented across the country. No single entity is in charge across the entire public safety enterprise, and solutions are expensive. Leadership is needed and costs need to be reduced. The classic “name a Czar” solution is not likely to work, either. Frameworks for cooperation that can build on common planning, standards, technology, budgeting and practices seem to be the most productive avenues for progress.”

Are the authors calling for a nationwide public safety force or are they calling for a nationwide body to govern the use of public safety spectrum? It is difficult to tell from this paragraph. If it is the latter they should also be aware that it is the goal of the public safety community to have a nationwide broadband network that is a single license holder, and governance for the nationwide aspects of the network’s deployment and operation. Beyond that the local jurisdictions must have the ability to manage their own portion of the network. A nationwide governance organization cannot know what the local requirements are, what the local coverage requirements are, and how the local jurisdictions are managed.

My view is that it would be almost impossible to place the control and operation of the existing narrowband channels under such an organization. The local, regional, and state public safety agencies have been working diligently to make their voice systems more interoperable and many local jurisdictions are now served by regional and even statewide networks or overlay networks to provide for interoperability. Yet in each case the autonomy of the local jurisdictions remains in place, as it must, now and into the future.

Savings for all can certainly be enjoyed by combining networks and consolidating 911 and dispatch functions, but at the end of the day it is the chief of each service in any given area who is responsible for the actions and day-to-day activities of those who serve beneath him or her. It is the local feet-on-the-street first responders who understand their needs, their terrain, their population, and their problems. Trying to manage them and consolidate them into larger and less autonomous groups is not an option now or in the future. As important as technology is to these departments, local control of their resources is more important. The issues of technology advancements need to take into consideration the politics involved in the public safety community as in every other community. It is necessary to balance technology and achieve cost savings by aggregation of resources with the very real world of resource management and this must be accomplished from the ground up as opposed from the top down if it is to succeed.

1.2  Modern Communications

This section discusses the fact that voice communications is not enough in this day and age and that voice, data, and video are needed. Then it goes on to declare that the world of packet does not care what is being carried inside a packet—in other words, bits are bits. The statement goes on to say that first responders need access to the world-wide-web, which is a true statement. However, the authors do not address the fact that the world-wide-web, which is accessible only via the Internet, relies on a wired network that is neither mission-critical in design nor a managed network. It is a first come, first served network that is subject to not only local but international congestion, and today the Internet is the vehicle being used by hackers and purveyors of malware intended to cripple sites, invade even the most secure of sites, and otherwise wreak havoc with communications. Nor does this statement address the fact that within public safety voice must always have absolute priority during incidents. Data and video are great new enhancements that will assist the public safety community and provide better service for the general public but the first and last line of defense is and most likely will continue to be voice communications.

Even fighter pilots with millions of dollars worth of sophisticated data communications gear, heads-up controls, radar, and other modern day electronics ignore all of this technology when two or more of them are involved in a dog fight. Instead, voice between the pilots is how they communicate, coordinate, and survive a battle. Voice must have absolute priority over all other forms of communications, not only on-network voice but off-network as well. Perhaps in the future IP-based systems will be able to handle all of the requirements of public safety mission-critical voice but the road to the ideal will include a number of smaller steps along the way. It is ambitious and commendable to have an end goal, but voice over broadband for public safety will come in much smaller steps. It will start with non-mission-critical telephone voice and push-to-talk services. It will evolve to include IP bridges between voice over IP and existing P25 and analog networks, and it will continue to evolve over time. The ultimate goal is still in the distant future, not on the horizon.

The following is the last paragraph of this section: “Implicit in these observations is the apparent need for standards that will permit interoperation of communication devices and systems across a broad swath of actors in the public safety landscape. That these standards would benefit from international scope should be apparent, in the interest of facilitating responses to nondomestic emergencies, and taking advantage of larger markets to drive costs down through economies of scale.”

Public safety’s choice of LTE and its FCC-mandated use on the public safety broadband network were made because LTE is based on standards of an international scope. In the realm of existing narrowband voice technologies there are no international standards. Some of the world makes use of a voice technology known as Tetra while in the United States there is a standard for digital voice known as P25, a term used by the authors in other parts of this paper.

It should be noted that LTE as a standard is worldwide and many public safety agencies around the world are seeking spectrum over which to deploy the LTE standard for public safety broadband. It should also be pointed out here that even within the world of commercial LTE deployments, this technology, so far, will be used on more than 41 different portions of the spectrum in both the more common Frequency Division Duplex (FDD) version and the newer Time Division Duplex (TDD) version. Therefore it is doubtful that there will be any LTE devices capable of commercial use on a global basis, let alone within the public safety community. However, several countries including Canada are following the lead of the United States and asking for spectrum within the same band as that which will be used within the United States.

1.3  Resilience, Robustness and Recovery

This section deals primarily with the issues related to major network failures due to such things as loss of power, loss of infrastructure, and lack of operating personnel and recommends the caching of such equipment that is based, again, on standards. The authors are perhaps not aware that today there are already caches of voice-capable radios for the various services across the United States and that they can and are deployed on an as-needed basis, as was mentioned above. However, it takes time to move these caches into position and deploy them. Time is not available for short-duration incidents but these caches are certainly a valuable resource during longer-term incidents due to natural or man-made disasters. Deploying temporary broadband infrastructure when required depends upon many variables, some of which are time consuming. First is the issue of network-inflicted interference if the new infrastructure is not deployed properly and second, there is the issue of the backhaul from the temporary sites. Backhaul for broadband will require between 30 and 50 MHz of capacity from each cell site back to the network core, and this backhaul will need to be low latency connections that, in many cases, rule out the use of satellite services.

Unlike standalone voice communications equipment, the broadband network must be deployed as a network complete with several working databases and other back-end infrastructure. If a new network or network core is deployed to replace one that is out of service, it must either be connected to the nationwide network in order to be populated with the list of approved and authorized devices or such a database must be built in the field at the scene of the incident. This is a long and involved process, yet until it is completed the broadband network is totally unusable in the field. If the Internet were to lose all of its name servers, users would not be able to traverse the Internet without knowing the specific IP address of the device they want to communicate with, and this is also true within an LTE broadband network.

Authors note: During Katrina both the commercial and public safety equipment and service providers quickly shipped equipment and personnel to New Orleans. Within 48 hours of the hurricane most of the wireless communications infrastructure could have been rebuilt, portable radio batteries recharged, and some of the commercial networks placed back into service. However, those in charge of the incident would not permit the equipment or the personnel in attendance to install it into the city because they were not deemed “first responders” and therefore were excluded from the area.[2]

Having deployable caches of equipment is a critical part of public safety communications as long as there is a realization that this equipment will take time to transport and set up. If those trained in its deployment are excluded from the incident it will be of little use to those who need it when they need it.

The last paragraph in this section states: “At least one participant in the public meetings suggested the creation of self-supporting “Regional Resilience Networks” acting as emergency communications utility companies that could be interconnected, possibly through commercial backbones. Such systems in the 25 largest coastal metropolitan areas would cover approximately 100 million of the 330 million U.S. populations. In a related observation, the incorporation of private sector facilities, organizations and resources into national scale planning for public safety could lead to cost sharing and increased coherence.”

It should be noted that this idea was brought forth by “at least one participant in the public meetings” and was not consensus-driven. Using commercial backbones during an emergency has proven time and time again to be an unworkable solution for emergency communications. The public networks and their backbones become overloaded during emergencies, which is one of the reasons cited by public safety as to why it cannot successfully make use of bandwidth on commercial networks. Further, if the Internet is the method of connection, it should be pointed out again that it is not a secure network, it is not a mission-critical network, it is not a managed network, and it has no priority capabilities built into it.

1.4  Security, Authentication and Access Control

I have few comments regarding this section but the authors have previously argued for a nationwide system and here they are saying that, “Again, the need for broadly applicable standards is clear, as are distributed methods for authentication to avoid the potential clumsiness and latency of overly centralized management.” [Emphasis added]

1.5  Cost

This section deals with the costs of equipment for public safety systems. One of the reasons public safety chose to make use of the standard LTE technology was to take advantage of the cost savings because of the volumes of devices that will be built for LTE over the course of the technology’s life. However, it should be noted that the public safety allocation is in the portion of the 700-MHz spectrum known as Band 14, which is not the same as the Verizon allocation (Band 13) or the AT&T allocation (Band 17). The result is that while the basic chipsets are designed to operate across the entire 700-MHz band of spectrum, software, filters, duplexers, and other components are specific to one or two of the bands but not all three.

The ultimate goal of the public safety community is to evolve the LTE broadband network in such a way that it meets most of the goals of the report, but again the operative word here is “evolve.” The first LTE broadband devices are being designed as data modems. Some will support one or two of the commercial portions of the 700-MHz spectrum and some will also include support for both the 1900 MHz and 850-MHz commercial bands for roaming on existing 3G broadband networks. Over time, handheld devices will become available and it is hoped that these will evolve into combination LTE and P25 or narrowband voice units with dual functionality, and perhaps in the future evolve further into devices that will provide both data and voice services over the public safety LTE spectrum. It is certainly the goal of the public safety community to encourage vendors to develop products that move along this evolutionary path.

The comments in this section regarding the adapted and augmented use of commercial off-the-shelf equipment will be address in section 1.6 below.

1.6  Interoperation with Commercially Deployed Systems

Paragraph one of this section discusses the needs for the public safety network to extend beyond the capabilities of the commercial networks and the commercial evolution of LTE. One of these attributes that goes beyond the commercial standards deployed to date has to do with peer-to-peer or off-network (called simplex or tactical communications within the public safety community). If LTE is truly to become the voice, data, and video network of choice for public safety this is one of the critical needs that will have to be solved. Off-network, even when network coverage is available, is one of the most important forms of voice communications used by the public safety community.

There are a number of technical issues that must be overcome before LTE devices can provide this type of communications. Without going into the details, one of the issues concerns the very different transmit power levels between existing narrowband voice systems (5 watts to 100 watts) and LTE devices (typically ¼ of a watt). This difference in transmit power will make it extremely difficult to use LTE devices to provide one-to-one and one-to-many communications over the distances required and within the confines of buildings. In addition, today’s LTE devices are 100% dependent upon the intelligence built into the network with regard to their channel assignment. Finally, there is the issue of how many separate and distinct talk paths are needed during a given incident. Some may require only a handful of separate voice paths and some such as wild land fires may require eighty or more individual talk paths.

The last point made in this section deals with the adaptation of commercial equipment to serve emergency needs for the cost savings if nothing else. This is a good thing to aspire to but consideration has to be given to making the public safety spectrum available on commercial devices. If there are commercial devices in existence that have the capability to make use of the public safety dedicated spectrum, even if that portion of the spectrum is “locked out,” this could give rise to hackers who can and will find a way to unlock the spectrum, access it and, for fun or for malicious purposes, perhaps hack into the public safety network.

1.7  Role of 911 and Other Online Public Safety Systems

This section discusses today’s 911 system and its upgrade to Next Generation 911. There will be synergy between the use of public safety broadband services and NG-911, and the conclusions drawn in this section are worthy of inclusion in the future planning of the entire public safety ecosystem.

1.8  Frequency Allocations

The first paragraph of this section comments on the existing 700-MHz allocations for both broadband and narrowband public safety services. However, the last sentence in paragraph one states, “The use of 700 MHz spectrum for public safety applications is attractive because of its propagation and penetration characteristics.” This is accurate when weighed against the commercial use of 850, 1700, 1900, and 2100-MHz spectrum but is not a true statement when weighed against existing public safety spectrum in the 30, 150, and 450-MHz bands. Replacing existing narrowband voice systems in these three bands will require two to three times the number of radios sites and infrastructure in use today to provide for the same propagation. In reality, the 150-MHz band has become the gold standard for fire communications because of its propagation characteristics.

The balance of this section discusses the use of the public safety licensed 4.9-GHz spectrum as well as the use of the unlicensed 2.4 and 5 GHz or Wi-Fi spectrum. While there is some merit in using the licensed 4.9-GHz spectrum for public safety mission-critical applications, even though it is being used today for point-to-point camera and data services, it would be foolhardy for the public safety community to consider the use of the unlicensed and public 2.4 and 5-GHz Wi-Fi spectrum. This spectrum is already heavily used by many organizations and relying on its availability, especially within commercial buildings or even homes, would have the same result as trying to rely on commercial wide-area networks. Neither band offers any form of priority and the 2.4-GHz band is so heavily used, especially in metropolitan areas, that the range of existing commercial devices has deteriorated over the course of the past few years and indications are that this deterioration will continue.

Television white space, the latest type of unlicensed spectrum to be released for public use, is also discussed in this section. It too should not be considered as an option for any form of public safety mission-critical communications. The portion of the spectrum available for white space use varies from metro area to metro area and therefore defeats the goal of nationwide interoperability. If in order to reclaim additional spectrum in the future the FCC requires TV broadcasters to vacate additional spectrum in the 500 and 600-MHz bands, then availability of TV white space for use by anyone is in doubt. Therefore TV white space should not be considered as a long-term solution for public safety, or the public for that matter.

1.9  The Role of Wired Communication

I agree with this section’s premise that public safety may not have to build out all of the required backhaul but might be able to rely on others for some of it. This is a good concept and one that public safety has embraced. Companies such as AT&T, Verizon, Sprint, Harris, Motorola, and others have existing private broadband networks in place that if previsioned properly could in fact become part of the nationwide public safety broadband network. However, the use of the public Internet by the public safety network for any part of its backhaul requirements should be strictly forbidden.

2.0 Desirable Features of a Public Safety Network Design and System

2.1 Flexible System Architecture

The premise of this section is correct, but I take exception to the authors’ belief that, “One can also imagine the use of packet encapsulation and encryption methods to extend the reach of a secured public safety network across commercial backbones to increase the scope and resilience of the system.” Public safety simply cannot afford to trust the Internet even with the use of packet encapsulation and encryption. The Internet is not a secure network, it is not a managed network, and it has no provisions for priority access or priority traffic routing. Further, it is a worldwide network and millions of users have access to it including those who would bring harm to the United States.

2.1.1 Use of Internet Protocols

This section deals with the Internet and IP and suggests that IP is the solution to all communications issues, thus all public safety traffic should become IP-based so it can be transported in more ways in a more efficient manner.

These statements are all true and correct, but unmentioned is that packets rely on broadband capacity, especially when the packets are carrying video traffic, and that mission-critical voice requires absolute priority all of the time. The vast majority of the public safety narrowband spectrum is in eight different portions of the spectrum. In the spectrum below 512 MHz (for public safety that includes 150, 220, 450, and 470-512 MHz) each voice channel must be converted from a 25-KHz channel to two 12.5-KHz channels by January 1, 2013, and sometime in the future to 6.25-KHz channels. In a world that is enamored with broadband, public safety and other Land Mobile Radio (LMR) customers are being required to reduce the bandwidth of their voice channels. Add to this the fact that these channels are intermingled with channels used by business and industrial LMR systems and you can see that it is not practical, today, to replace these systems with broadband systems. There simply is not enough available spectrum for the public safety community.

The authors clearly show their bias for the Internet and the IP protocol in this section. While it is agreed that IP is the future of communications, there are a number of issues that need to be resolved before public safety can reliably and economically convert its existing narrowband voice systems to IP-based, packet-only systems. As an ultimate goal this is on target, but this paper does not address how a transition from today’s technology to an all-IP system could be accomplished, what the cost of doing so would be, or how the transition could be made in an orderly fashion.

2.1.2 Backward Compatibility

It is unclear exactly what the authors’ point is in this section except to discuss the use of multiple radios within a single device. This type of development is already underway and voice products are available.  Multiple radios in commercial devices are commonplace today. The issue not discussed is how to transition from today’s multi-band environment to an all-IP future vision.

2.1.3 Mesh or Mobile Ad Hoc Networking

This section discusses the use of mesh networks. There is value in making use of mesh networks as extensions of other networks or as standalone networks. Mesh technologies, balanced with the potential of interference, should certainly be part of the long-term vision of the public safety broadband network.

2.1.4 Robustness and Recovery

This section is basically a restatement of section 1.3 and the same comments for that section apply to this one.

2.2 Security and Authentication (entire Section)

A restatement of the issues raised in section 1.4, again the same comments apply to this section.

2.3 Standards Applications and/or Development

I agree with the statements in this section and various organizations within the public safety community have recognized the need for the use of common APIs and the vetting of applications from the development community, both within and outside of the public safety community. However, there is the question of the type of back-end infrastructure that will be employed within the public safety broadband network. If the entire system is based on an IMS core technology then SIP-based applications, including push-to-talk, will be viable on a fully interoperable basis. However, if some of the local or regional networks are deployed without IMS in the core, in order to save money, there will be compatibility issues across the network. SIP-based applications require IMS in the core to function properly.

2.4 Ruggedization

I concur with the comments in this section.

2.5 Sensor and Location Systems

For the most part I concur with this section. However, I question the use of commercial Wi-Fi as a method of in-building location. There is research underway today that could provide a more robust solution than relying on unlicensed spectrum devices for in-building location.

Further, while the use of sensors will be very helpful within the public safety community, care needs to be taken and if these sensors need to “talk to” the network then perhaps an aggregation of sensors within a location with a common connection to the network should be explored.

2.6 High Density Radio Operation

It is well known within the public safety community that incidents usually occur within confined areas and that the number of first responders can place a capacity burden on any communications network in use within this confined area. This is one reason off-network voice communications is so important in public safety. Moving off the network, even when within the range of the network, provides relief for the main network while permitting those on the scene to communicate as needed. In this case, multiple voice paths and/or data paths for peer-to-peer communications will be necessary.

No matter how robust networks are or how much spectrum is available to them, there will remain a need for off-network communications for precisely that reason. As the incident grows in size, the need for additional off-network channels for voice will also grow. Data services should also be able to operate off-network in the same manner. However, congestion must be managed. Congestion on a voice network is managed by the person assigned to the incident as the incident commander; in the case of off-network communications it is handled by the head of the group on that channel. It is unclear how off-network data capacity issues will be handled in the future and they should be taken into consideration during the long-term planning stages.

2.7 Next Generation 911 Emergency Services IP Networks

This section states the fact that both NG-911 and the public safety broadband network are based on broadband technologies and that there are probably some (or many) synergies developing between these two. I agree with these statements.

3.0 Prototyping, Collaboration and Testing

It is the view of the authors in this section that test beds must be employed in order to prove concepts and operational requirements and that the public safety community must be privy to these test beds and be able to provide their input. I concur, though some of the examples cited are from the military, which so far has been unwilling to share its findings and its research with members of the public safety community. I would assert that much of the work done for the benefit of the military has a direct correlation to public safety and that closer cooperation between the two groups would prove to be of great value.

4.0 Multiple Stakeholders

This section of the report acknowledges that there are many different public safety-related stakeholders and this is a correct statement. It goes further to point out that funding cycles are different and that many of the decisions made regarding communications do not take into account the need for interoperability. I would contend that now, more than ever, interoperability provisions are being included in system designs around the nation. Even so, more needs to be done. The key issue here is funding and its availability to provide the basis for more interoperable systems.

5.0 Programmatic Considerations

5.1 Public Safety Network Interoperability Panel (PSIP)

This section recommends that a PSIP be established to promote better public safety interoperability. It does not address the issue that interoperability is made more difficult because existing voice systems are spread out over eight different portions of the spectrum. For example, typically, in California the highway patrol operates in the 30-MHz portion of the spectrum while most fire agencies operate in the 150-MHz spectrum. Fire, police, and EMS are also assigned spectrum in the 450-MHz band, 700-MHz narrowband, and 800-MHz narrowband spectrum.

While a PSIP could probably help solve some of the interoperability issues, public safety has taken its own steps to rectify the situation. The use of 700-MHz narrowband networks as overlays for use by all agencies has been successful where they have been deployed, but again, funding these networks is a major issue. The idea that a panel of experts can solve problems created over thirty years of diverse frequency assignments is not a practical solution to the problem. There are others that are more viable, including additional funding for 700-MHz overlay systems. While these systems are not ideal, they are better than what is in place today.

5.2 Coordinated Research, Development and Testing

I agree that coordinated research and development and testing are required as we move forward. However, not one of the agencies mentioned in this section is qualified or has the knowledge of what the public safety community really needs to be able to perform its tasks. So far these test beds have been long on spending funds and short on accepting input from those who will benefit from the technologies.

In addition, between and among the agencies mentioned there are ongoing turf wars that impede progress and the desire to understand the requirements of the public safety community. One lesson that should have been learned by the Federal Government is that there needs to be input from those being served by these agencies. Instead they seem to be intent on building their own empires and moving forward to obtain funding which, frankly, could be better used by the public safety community.

Further, some of the tasks identified in the report should be the purview of the public safety community and NOT various organizations within the Federal Government. I would like to ask how many of those involved in this research have ridden along with police and fire units on a Friday or Saturday night. Perhaps I should also ask that of the authors of this report. Until those involved have a real understanding of the day-to-day issues that need to be resolved, they cannot, even with all of the testing in the world or all of the money in the world, be successful in developing standards that will provide the type of communications services needed by the public safety community.

The public safety community goes in harm’s way every day. The most dreaded call that can be given to a police officer working a beat is a domestic violence call. Why? If you have never been in the field or talked to those in the trenches you won’t understand why that is the case but it is true. Public safety communications is not about the nation. Yes, we need to be able to move people and equipment anywhere in this nation at a moment’s notice and have the communications systems work. On a daily basis it is about the cop, the firefighter, or the EMS paramedic who needs help and needs it right away. That is who we should be addressing in our plans for this next generation of networks, not a group of theorists who suddenly embrace IP and the wonders of the Internet.

5.3 National Incident Management System (NIMS)

I am in full agreement with the statements made by the authors in this section.

5.4 Training and Evaluation Program

Training must happen on a local level. Yes, there should be input from the nationwide network organization but different levels of training are needed in different areas. One size fits all training will not be sufficient in this case.

Repeating my comment regarding the network and public safety communications in general, the USERS of these communications networks are public safety professionals. Communications is one tool they have at their disposal. They do not need to be, and should not be required to be, experts in communications technology. The most important thing to remember is that the MOST IMPORTANT type of communications begins with the emergency button on the radio. If that button is pushed, the request for help MUST be heard and must be acted upon.

6.0 Conclusions and Recommendations

For this final section of the report my comments are below each of the recommendations.

1. A Public Safety Capability organization should be selected or created to orchestrate the detailed design, development and coordinated operation of a new, national public safety communication system. It should include a Public Safety Interoperability Panel and resource management capability.

A “new” network? Public safety has legacy voice systems that will be in operation for many years. 10 MHz or even 20 MHz of LTE spectrum is not sufficient to provide all of the voice, data, and video services required by public safety.

It would be better to involve the public safety community in the EVOLUTION of its existing systems into the future than to try to design a “new” communications system. It is not possible to build such a network and simply declare that on a certain date everyone will suddenly move over to the new network. Even the Internet evolved over many years into its present form and it is still evolving.

2. The architecture of the new public safety network should:

a. Incorporate commercial technology where appropriate.

Agree at least for the broadband portion of the network.

b. Extend commercial technology to achieve robustness.

Agreed except that traffic on the commercial networks should be relegated to non-mission-critical traffic along the lines of administrative or logistical support of an incident. Mission-critical traffic should never be routed over a commercial network.

c. Provide for backward compatibility or interoperability through standards adoption and/or development where feasible. Including interoperation with existing and new 911 systems.

Within reason, broadband and the Internet and IP is not always the best technology available for voice traffic, at least in the near future. Technologies can be intermingled to provide the best of all worlds for the first responder community, but the most important criteria is that it works every time regardless of where they are.

d. Give high priority to cost-effectiveness and affordability.

Agreed but NOT to the point of short-changing the requirements of the public safety community.

e. Take advantage of Internet and other packet-based technologies to support multi-media communication and mobile ad hoc network formation.

Agreed that IP is the future of SOME communications systems but not all, and with the caveat that NO public safety mission-critical communications ever use the public Internet for transport.

f. Incorporate assigned public safety spectrum and other data communication spectrum assignments and include opportunity for sharing where feasible.

Because the spectrum below 512 MHz assigned to public safety is intermingled with other Land Mobile Radio users this is neither always practical nor achievable. Sharing of public safety spectrum with others is not a good idea. Would the Secret Service be willing or should they share the spectrum they use to coordinate the protection of the President and other Government officials? Public safety needs dedicated spectrum; they never know when the next incident will occur or the magnitude of the incident. Perhaps they should be able to share spectrum in use by others on a non-mission critical basis but they should NEVER be required to share their spectrum even when not in use with others unless public safety has full pre-emptive authority to override non-public safety users.

g. Incorporate strong, federated authentication and other security technology to positively identify and authorize personnel and equipment permitted in the system.

Agreed, this is important for the public safety community.

h. Incorporate advanced position location capabilities, including indoor and underground location.

Agreed but NOT by making use of unlicensed consumer-grade Wi-Fi or other types of networks.

Conclusions

I attended and participated in the session conducted by the authors of this report in Philadelphia in August of 2011. It was obvious to me and others who attended that those leading the session were Internet and IP-centric and were not conversant in the intricacies of public safety communications. During this session we tried to convey the points that there are differences in spectrum assignments, that mission-critical voice is a necessity, and that off-network or peer-to-peer and peer-to-many peer communications is vital within the public safety community.

This report is a reflection that we failed to convince the authors that:

1. Public safety had already embraced a commercial technology in the form of LTE.
2. That network capacity is and will remain an issue.
3. That mission-critical communications requires a different set of criteria than the Internet, which is not a mission-critical network.
4. That IP is the future for all broadband communications, but narrowband communications is and will remain needed for a long time.
5. That the public safety community is willing to adopt new technologies and move into the 22^nd century but cannot sacrifice the attributes that are critical to its success and safety.
6. That a grounded understanding of the requirements of public safety is vital to the success of any new technology deployment.

It is difficult for those who created the Internet and grew up with its influence to understand that there are several types of communications with needs that cannot be met simply by embracing the premise that the Internet and IP-based packet systems can solve everyone’s needs all of the time.

I would like to recommend to the authors of this report that if they are to change the way public safety communications are implemented today for the better, that they immerse themselves in the day-to-day operations of the first responder community. They should ride along with a metro police agency on multiple Friday and Saturday nights. They should also ride along with a fire unit responding to countless EMS and fire calls, and with paramedics who are often rerouted from one incident to another deemed more life threatening.

It is not possible to understand the unique and complex nature of public safety communications in any other way. You cannot simply host a number of meetings nor can you simply listen to a few first responders. You have to live it in real time. You will come to understand that in many instances the radios first responders wear on their belts are their only lifeline to safety.

I have provided my comments and narratives in the hopes of assisting the authors in moving forward. Public safety communications is not about P25, it is not about IP or the Internet, and it is not about today versus tomorrow. It is about a lifeline between those who go in harm’s way every day and those who can ensure they remain safe and who support them in their efforts.

Andrew M. Seybold

Now Public Safety wants the D Block reallocated to Public Safety control and is perfectly willing to work with private partners in order to build out the network. These partnerships will be different from the ones envisioned by the FCC as they will most likely be regional in nature but they will accomplish the same thing in different ways. The result will be the same for the commercial partners but it will be far better for Public Safety, which will actually control the network and the assignment of priority access.

Different Types of Partnerships

It has always been the vision of the Public Safety Community to work with commercial wireless network operators to provide off-loading of non-emergency traffic onto commercial networks when needed, and to further work with commercial network operators with cell site sharing and even network backhaul and perhaps back-end services sharing. All of this is possible once the D Block has been reassigned to Public Safety and the nationwide (as opposed to national) governance organization is in place.

In the meantime, other partnerships are being formed between Public Safety vendors and commercial network operators and between Public Safety land mobile radio vendors and broadband infrastructure companies. The first of these vendor/network partnerships to be announced was between Motorola Solutions and Verizon Wireless. It is a non-exclusive agreement for the two companies to work together to provide better interoperability between Public Safety and commercial networks. Under this arrangement, Motorola provides network infrastructure and devices, and Verizon serves as a roaming partner when a user leaves the Public Safety network RF footprint, and cell site and back-haul partner for Public Safety.

More recently, AT&T and Harris formed a non-exclusive partnership that will provide a closer relationship between these two companies while better serving their Public Safety customers. This alliance is different from the Motorola-Verizon partnership as AT&T is taking the lead in LTE network build-out, leveraging its commercial LTE domain vendors in the construction of dedicated Public Safety networks that would be provided as a managed service. Unfortunately, some who read the press release announcing this partnership read it as a statement from AT&T Wireless that it considers its existing commercial network as being mission-critical. When I heard these comments from a few concerned Public Safety officials I contacted AT&T and asked about this partnership and, more specially, if it considers its network to be mission-critical. The answer was no, AT&T does not believe that its commercial network is mission-critical as defined by the needs of the Public Safety Community but that its new partner, Harris, did build mission-critical Public Safety land mobile radio equipment and that together their vision is to enable Public Safety customers to easily move from the Public Safety mission-critical broadband network to the AT&T broadband network(s).

Sometimes those who write press releases and those who try to explain what the release should convey to the world are not talking the same language. I have worked side-by-side with both AT&T and Verizon Wireless in the effort to have Congress reallocate the D Block and both of these providers have made it clear that while their wireless networks are as robust as they can possibly be in order to serve their commercial and consumer clients, neither provider believes that its network is up to the standards required by the Public Safety Community. They understand the differences and are offering their networks for use while the Public Safety broadband network is being built and after it has been deployed but ONLY to off-load non-essential, lower priority traffic in order to relieve potential congestion on the Public Safety broadband network.

Neither network provider offers Public Safety pre-emptive priority access to their commercial networks. In truth, no network operator would want to displace its own customers in favor of Public Safety during emergency incidents. There is always the possibility that the person whose call is terminated is trying to call 911 to report another emergency. It is unfortunate that the AT&T press release left a doubt in anyone’s mind that AT&T knows the capabilities and the limitations of its network (as do the other operators) when it comes to providing Public Safety voice and broadband services.

At the same time, the commercial network operators can work closely with their Public Safety equipment vendor partners to help make the move from the Public Safety network to the commercial network and back as seamless as possible. They can also assist the Public Safety vendors with a better understanding of the world of broadband wireless. While both worlds are basically the same, they are also very different. For years, the Public Safety Community has relied on voice-only systems that provide many voice capabilities that cannot be provided by commercial network operators, and the commercial network operators have, for a number of years, been providing business and consumer customers with wireless broadband access that has never before been available to the Public Safety Community.

During the past 2+ years that Public Safety has been trying to gain control of the 700-MHz D Block by asking Congress to reallocate it to Public Safety, several commercial broadband network operators, namely AT&T and Verizon, have helped educate both the Public Safety Community and the Public Safety vendors about the differences between land mobile radio voice and wireless broadband services. While both use the radio spectrum, they are based on different technologies. Simply because a person is conversant with one does not mean he/she will also be conversant in the other. Even the technical language used within each of these wireless communities is different, and it is always interesting to me to watch a commercial network engineer and a Public Safety communications engineer try to talk about wireless and fully understand what the other is saying.

Partnerships in General

The Public Safety Community has always been self-sufficient to a point. However, partnerships with federal government agencies, vendors, and those who assist Public Safety in its day-to-day activities and during emergencies (utility companies and even towing companies) have been important partners for Public Safety. Now that broadband for Public Safety is upon us, these partnerships are broadening. Commercial broadband operators, new vendors, existing vendors, private rural telcos, rural power companies and others are working together with the Public Safety Community to help make their jobs easier and safer, and to provide an even better level of service to those they serve.

Recently at the IACP conference in Chicago, I saw a demonstration of some great applications for the Public Safety Community. One was to help identify missing and exploited children, and another was to create a database of gang-related tattoos. The software vendor that is developing these applications is the FBI, and it is doing so for the good of the entire Public Safety Community.

Going forward, many different types of partnerships will be needed and welcomed by the Public Safety Community. Those who fight terrorism and crime, put out our fires, and treat and save our relatives when they are sick or injured need all of the support they can get through partnerships: Broadband is different from land mobile radio services. I applaud all of the organizations and companies that are forming such partnerships. They are doing so to increase their own business but they are also doing so because they know there are major differences between LMR and LTE and they are partnering with those who can help deliver both sets of services to the Public Safety Community. This is as it should be.

Andrew M. Seybold

The D Block, (758-763 MHz and 788-793 MHz) is the 10 MHz of spectrum (5MHz X 5 MHz) that sits next to the Public Safety 10 MHz of spectrum (5 MHz X 5 MHz) presently licensed to the Public Safety Spectrum Trust on a nationwide basis. On the other side of the D Block is a guard band that is 1 MHz wide. This guard band is licensed for itinerant use and was included in the 700-MHz band plan in order to provide a buffer zone between the C Block (licensed to Verizon Wireless on a nationwide basis) and the Public Safety spectrum.

The question before Congress at the moment is what the value of this 10 MHz of spectrum is to various stakeholders. In reality, this translates to what is the highest and best use to which this spectrum can be put and who will benefit from this decision. There are presently two options on the table for the D Block:

1. Auction the spectrum and apply the proceeds to reduce the national debt.
   a) Although the current law requires the money to be deposited directly into the U.S. Treasury. If it is to be used for deficit reduction a revision in the law will be required.
2. Auction the spectrum and use the proceeds to help build out the Public Safety network on its existing 10 MHz of spectrum.
   a) This too would require a change in the current law.
3. Reallocate this spectrum to Public Safety so it has 20 MHz of contiguous spectrum available on a nationwide basis.
   a) This also requires a change to existing law and is part of the current S 911 bill waiting to reach the floor of the Senate for a vote.

Those who favor auctioning the D Block point to the fact that this spectrum, at auction, is expected to generate between $2.6 and $3 billion in revenue for the Federal Government. (The Congressional Budget Office set the price for the D Block at $2.75 billion in its scoring of Senate bill 911.[1])  They also believe that auctioning this spectrum will create another broadband competitor in the 700-MHz band, most of which (but not all) is licensed to AT&T and Verizon Wireless.

Those who favor the reallocation of the D Block to Public Safety point to a number of reasons this should happen:

• The existing 10 MHz of spectrum is not sufficient to provide first responders with the broadband capabilities they need on a daily basis.
• The D Block is contiguous to the existing Public Safety spectrum and the cost of adding this additional spectrum to the Public Safety spectrum would be minimal whereas adding additional spectrum in the future in a different portion of the spectrum would be very costly.
• If Public Safety is, ultimately, to move voice onto the broadband spectrum and give back some of its existing narrowband spectrum, the additional bandwidth provided by the D Block will be needed on a daily basis. Without it, it will not be possible to migrate mission-critical voice to the broadband network.
• It is an investment in Public Safety communications and will provide the first fully interoperable nationwide broadband network for Public Safety communications.

This paper looks at both sides of this equation and sets the true value of the D Block if it is auctioned in order to provide a clear picture of the two choices presently under consideration. It is important that those in a position to make this decision have all of the facts on both sides of the debate available in order to be able to make the correct decision moving forward. On the one hand is the extreme need to reduce our national debt and on the other hand is the issue of providing the first responder community with all of the tools it needs to protect the citizens of this nation and itself.

Realities of Spectrum and Broadband

Before attempting to place a monetary value on the D Block, it is important to understand exactly how much of this spectrum is really available for use by the winning bidder(s), the capacity of that spectrum, the implications of building out a commercial network, and the cost of doing so. It is also important to look back at the previous 700-MHz auction in which the D Block was first offered as part of a public partnership with Public Safety and the reasons it failed to attract any serious bidders.

When deploying broadband for either commercial or Public Safety use, the broadband radio signals cannot be deployed to occupy the entire portion of the allocated spectrum. Broadband networks have to be designed so there is some unused spectrum on either side of a broadband carrier in order to protect the spectrum user in the adjacent portions of the spectrum. This is the same premise that was used when first deploying TV stations across the nation. There could not be two TV stations using channels adjacent to each other in a given area since they would interfere with each other and the TV sets would not be able to receive either signal without interference.

Knowing this, when the FCC first defined the various blocks within the 700-MHz band it did so in a logical fashion making each block—with the exception of the D Block and the Public Safety spectrum—large enough so each block that was carved out for auction was wider than the broadband signal that would be used in that portion of the spectrum. Therefore, the Lower A and B Blocks are each 6 MHz X 6 MHz or 12 MHz, and the Upper C Block is 11 MHz X 11 MHz or 22 MHz wide. This permits a network operator to deploy a 5 MHz X 5 MHz broadband system within each Lower A and B Block and a 10-MHZ system within the Upper C Block and still provide their own buffer zones of ½ MHz on either side of their block of spectrum.

However, the D Block and the Public Safety spectrum were each allocated 5 MHz X 5 MHz or 10 MHz total of spectrum because it was envisioned that the system built on these two portions of the spectrum would be a combined public/private system and therefore the FCC inserted two 1 MHz X 1 MHz bands between the C Block and the D Block on one side and between the Public Safety Block and the D Block on the other side. This spectrum was sold at auction and is to be used for itinerant communications systems across the United States, which would have made it easier for the entire 20 MHz of spectrum to be available for broadband services. However, if the two networks are separate, that is a commercial network on the D Block and the Public Safety network on the existing Public Safety allocation, then both networks will have to reduce the size of their broadband signals in order to provide for their own guard band between the two systems just as commercial network operators have had to do.

The chart below depicts the 700-MHz spectrum blocks and the amount of usable spectrum within each one:

Existing 700-MHz Band Spectrum Blocks

Note: D Block and Public Safety maximum data capacity is calculated at 20% reduction over 5 MHz X 5 MHz spectrum numbers. 

If the D Block and the Public Safety allocation are combined, the total available spectrum and the capacity available on a per cell sector basis is as follows:

Combined D Block and Public Safety Spectrum

Note: Because the A1 and GB1 spectrum guard bands are already in place the full 20 MHz of spectrum could be available for Public Safety broadband communications.

Impact on Spectrum Value

Because the D Block did not receive a qualifying bid it was not awarded to any operator and the concept of a public/private partnership did not come to realization. This leaves us with two 10 MHz (5 MHz X 5 MHz) portions of the 700-MHz spectrum directly adjacent to each other. This means that if this spectrum continues to be divided into two separate allocations, one for commercial use and one for Public Safety, the amount of spectrum available for use on each of these segments will NOT be 10 MHz but will be only 8 MHz (4 MHz X 4 MHz instead of 5 MHz X 5 MHz), which means that the available spectrum for both the D Block and Public Safety will be reduced by 20% from what should have been available.

This 20% reduction will do a number of things to both the value and usability of this spectrum:

• It will reduce the value of the D Block by at least 20% if not more.
• In order to regain the lost capacity, both networks will be required to build out many additional cell sites (20% or more).
• The overall cost of a network on the D Block will be higher than a similar network built on the A and B Blocks (6 MHz X 6 MHz). Therefore, the price any commercial entity would be willing to pay will be substantially less.

If we compare a 20% reduction in spectrum value with the expected revenue of $2.8-$3 billion, then the D Block is now worth no more than $2.24-$2.4 billion at auction. In reality, since additional cell sites and infrastructure costs will be incurred by the successful D Block bidder(s), and this cost will be substantial, the probability is that the D Block, if auctioned as a standalone portion of spectrum, will be won for less than $2 billion. Meanwhile, because Public Safety will not be able to use all of the 10 MHz already allocated to it and will also have to reduce the broadband bandwidth to 4 MHz X 4 MHz, the cost of the Public Safety network will increase by at least 20% if not more AND with only 8 MHz of spectrum available for data, the ability to employ this spectrum for video services during routine incidents will be greatly diminished as well. Further, with only 8 MHz of spectrum available on a nationwide basis, it will not be possible to migrate mission-critical voice to this network while still retaining the ability to use it for broadband services.

The results of auctioning the D Block and reducing the overall available bandwidth in the Public Safety portion of the spectrum will have additional implications both for the commercial and Public Safety side. On the commercial side, the overall network, even with additional cell sites being added to make up for the capacity, will not have sufficient capacity to provide commercial broadband services to the number of customers needed to provide a decent return on investment (ROI) for the commercial network operator. Those that would be interested in bidding on the D Block will factor this into their calculations of the value of the D Block if it is offered for auction.

On the Public Safety side, the additional costs will be significant. Today, the FCC and others have stated that in order to provide Public Safety broadband communications to 96% of the U.S. population, between 41,000 and 44,000 cell sites[2] will be needed. If the D Block is not available to Public Safety then the number of sites—each of which adds several hundred thousand dollars in capital costs as well as additional network operation costs—will have to grow to between 49,200 and 52,800 sites. This will result in a network that will cost taxpayers more, take longer to construct, and will still not provide the Public Safety community with enough broadband spectrum for its day-to-day needs[3] or to be able to be used for both mission-critical voice and data. The result is that any spectrum that might have been made available by migrating the Public Safety community to broadband for mission-critical voice will still be required by Public Safety. Therefore, any auction income from this spectrum will not be available. It is conceivable that the revenue lost to the Federal Government would be two or three times the value of the D Block auction price.

It should also be noted that the cost to build out either a 10 MHz or 20-MHz Public Safety nationwide broadband network are identical. However, the cost to build out a 10-MHz Public Safety network and then, within a few years, augment it with additional spectrum in another portion of the spectrum will double the total cost of the Public Safety network AND will require all Public Safety entities to discard their broadband devices and acquire new broadband devices that will cover both portions of the spectrum.

Conclusions

There is a perception among some within the Federal Government that the benefits of auctioning the D Block make this an obvious choice. However, the reality is that putting the D Block up for auction will, within a few years, have the following results:

• Cause the costs to build and maintain the Public Safety network to climb by at least 20% if not more.
• Cost the auction winner(s) more to build out their own networks making it more difficult for them to be competitive in the commercial market.
• Provide less capacity for both a commercial operator and for Public Safety than on other portions of the 700-MHz band.
• Would not meet the needs of either a commercial network operator or the Public Safety community in terms of broadband capacity.
• Would preclude Public Safety from migrating mission-critical voice to the broadband network when it becomes available, which in turn will result in none of the existing Public Safety spectrum being available to be reclaimed for future broadband expansion of commercial services.
• Cost taxpayers much more when in a few years Public Safety must return to the FCC and ask for even more spectrum allocations in order to provide the types of services it needs to function on a day-to-day basis.

It has been demonstrated that even the broadband capacity provided by a full 10 MHz of spectrum (5 MHz X 5 MHz) is insufficient for day-to-day Public Safety broadband communications.[4] Reducing the available network capacity by 20% as detailed above will only acerbate the issues surrounding the lack of capacity. As has been shown many times, the idea of having priority access to the commercial networks is unworkable and not reliable.[5] Therefore, Public Safety must have sufficient broadband capacity available to it on a daily basis. The use of broadband for video, data, and at some point in time mission-critical voice[6] demands that Public Safety have sufficient broadband capacity available and under its control.

The idea of auctioning the D Block, which is directly adjacent to the Public Safety broadband spectrum, might seem attractive to some in the short term, but in the long term the financial implications are that it will cost much more, over time, in taxpayer funding to build a second network for Public Safety broadband use because the spectrum presently allocated is not sufficient. Commercial broadband demand is growing exponentially and once the Public Safety network is in place this same type of increased demand for broadband services will occur within the Public Safety community as well.

The Congressional Budget Office has provided its estimate of the amount of money from auctions for the spectrum identified by the FCC. Its estimate is that it will generate $24 billion[7] in revenue and after incentive payments to TV license holders, and deducting the cost of the Public Safety broadband network, the net funds available to reduce the deficit will only be in the $6 billion range. (It should be noted here that the CBO also projected revenue from Auction 73, the 700-MHz spectrum auction, to be about $10 billion and the actual amount raised was more than $19 billion.) However, based on the last two spectrum auctions, the AWS-1 and 700-MHz spectrum auctions, industry estimates put the total value of the spectrum already identified, without the D Block, at between $40 and $54 billion. Using the same costs for incentive payments and funding the Public Safety broadband network, these numbers will yield between $20 and $30 billion for deficit reduction purposes.

Therefore, the perception that auctioning the D Block is the right way to proceed is contradicted by the realities outlined above. The true benefit to the United States as far as economic growth, job growth, and providing Public Safety with the advanced broadband tools it so badly needs to do its job and protect all of the citizens of the United States lies in the reallocation of the D Block to Public Safety and for the Federal Government to fund some of the cost of building the nationwide network from funds that will be realized from the upcoming auctions of spectrum already identified by the FCC. It should also be pointed out that in the FCC’s broadband plan[8] it has stated that it will find and make available a total of 500 MHz of additional spectrum over the next ten years. Therefore, these first auctions will be followed by others that will result in more money with which to continue to reduce the national debt.

Reallocating the D Block is logical, it meets the highest and best use criteria for spectrum allocations, and for the first time it results in providing nationwide interoperability for the first responder community from coast to coast and border to border. It will also result in broadband for rural America faster and less expensively than any other proposal presented so far by any branch of the Federal Government.

Andrew M. Seybold

The East Bay Region is one of 21 jurisdictions that received waivers from the FCC to operate a broadband network on the 10 MHz of 700-MHz spectrum already allocated to Public Safety. The license is currently held by the Public Safety Spectrum Trust (PSST) and the waiver recipients not only have a waiver from the FCC to build and operate their portion of the nationwide network, they have all entered into lease agreements with the PSST for use of the spectrum.

The San Francisco Bay Region came together and formed a joint powers authority, the BayRICS Authority, to develop and operate the broadband network. The BayRICS Authority is currently negotiating an agreement with Motorola to provide the system. Motorola received a $50 million grant from the broadband stimulus funds (BTOP grant) to build out the network. A previous grant funded Project Cornerstone as a proof of concept for the larger LTE network planned for the Bay Region, and this was the network we tested. The report goes into detail about the network, test procedures, actual tests, and results. We have also included more details on all phases of the testing in seven appendices.

The tests were based on real-world incidents that are typical in both metro and suburban areas on a daily basis. The number of first responder personnel assigned to each incident and their functions at the incident and in the command center have been vetted by many within the Public Safety community and, in reality, the number of first responders assigned to the incident for our tests represents a conservative set of personnel on the scene.

It should also be pointed out that these tests were made under ideal conditions. There was no other network traffic, each test was conducted at the center of a single cell sector, multiple times, and the mobile devices were mounted in vehicles using roof and trunk-mounted outside antennas. The backhaul between the cell sector and the network was 30 Mbps and cannot be considered as a choke point in the network. Further, the testing server was physically located at the network center or core so there were no additional data links that could have skewed the results.

A paragraph taken from the conclusions section of the report sums up our findings:

“Based on these real-world tests, we strongly recommend that public safety be provided with at least 20 MHz of contiguous spectrum (10 MHz by 10 MHz). The only way to accomplish this is to reallocate the 700-MHz D Block to public safety and this should be done prior to the build-out of the waiver recipients’ portion of the nationwide network. The cost to build out 10 MHz of spectrum and 20 MHz of spectrum is identical at the time of construction. Later, the addition of this spectrum would add to the cost of the network and require device redesign, adding to the cost of the user equipment. The entire premise of providing public safety with broadband spectrum using a commercial technology is to provide public safety personnel with capabilities they do not have presently at a lower cost than its existing voice communications equipment.”

The full report, as it was submitted to the FCC, is attached to this column in PDF format and will also be posted on our website for future reference. We believe our testing methodology is solid and that the tests, which were repeated multiple times for each incident, were conclusive. In addition to our own findings, Anritsu America was taking off-the-air measurements with its test equipment to verify the total traffic being sent over the network. We thank Anritsu for its support and assistance. I would also like to thank Motorola, the provider of the network, for its cooperation in working with us on this project. Finally, a big thanks to Panasonic, which provided us with seven identical Toughbooks running Windows XP. These units are identical to thousands of Toughbooks that are installed in police, fire, and EMS vehicles around the United States.

The bottom line: Public Safety needs the D Block and the funding to build out the nationwide Public Safety network. If the D Block is not reallocated, Public Safety will end up with a network that will not provide the types of information and videos it wants and needs on a daily basis for incidents that occur multiple times a day in both major metro areas and their surrounding suburbs. Senate bill S.911 provides both the spectrum and the funding that is needed by the Public Safety community. This bill passed through committee with a strong 21-4 bipartisan vote and it needs to be introduced on the floor of the Senate as soon as possible. This will put pressure on the House of Representatives to pass a similar bill and send it to the President for his signature.

Ten years after 9/11, there is no excuse for not providing the Public Safety community with the tools it needs to better serve all of us. This becomes even more important when the Public Safety community has seen layoffs at a local level because of a lack of funding. Doing more with less takes the right tools, and in this case the right tool is a robust Public Safety-only broadband network that has 20 MHz of spectrum available.

Andrew M. Seybold

Cornerstone09-14-11FNL

My view is that our channelized voice systems will be around and needed for at least the next 5-10 years, therefore, continued investment in these systems not only makes sense, it should be a requirement. Progress is being made as you will see below, but even with the definition of mission-critical voice in place I know of no work being done to determine the specific requirements regarding the number of dispatch, coordination, or simplex, talk-around, or peer-to-peer voice channels or circuits that will be required. It is possible that there will be mission-critical voice capabilities on LTE and other broadband networks but that these broadband technologies may not be able to provide the number of voice channels that are used today for major incidents such as wildland fires, etc. It is also possible that broadband voice will not be able to support the number of dispatch areas or zones in use today in major metropolitan areas. It is also possible that the combination of voice and data services will give Public Safety the ability to make changes in the operations to streamline the dispatch and tactical aspects of incidents as well as to operate as it does now.

Where We Are Today; Where We Are Going

As the 700-MHz waiver recipients begin building out their portion of the nationwide 700-MHz broadband network, and as the various committees of the various Public Safety organizations meet and discuss issues, one that keeps coming up is the use of the broadband network for mission-critical voice. I have been saying for a long time now that mission-critical voice (as defined by a recent NPSTC document) is still a long way from becoming real over the LTE broadband network.

However, some progress has been made in recent months. One of the most important elements of Public Safety-grade mission-critical voice has to do with off-network or tactical communications, sometimes referred to by the IT world as peer-to-peer communications. Simply stated, this means the ability for two or more field devices (mobile or handheld) to communicate with each other without having to use a cell site or radio tower system. Many who have discussed this include it as a must-have for times when field units are out of coverage of a network. However, in most cases this type of off-network communications is also a requirement of field units even when they are within network coverage.

Call it what you will—tactical, simplex, talk-around, peer-to-peer—it is the ability for units in the field to be able to communicate directly with each other without any infrastructure required. Today’s Public Safety voice devices all include this feature as standard, but cell phones do not support this mode of operation. I have been skeptical that commercial network operators or others within the LTE broadband community would get behind this mode of communications, but recently, simplex mode communications was introduced at the 3GPP standards body and has been endorsed by some commercial network operators including AT&T, as well as by the U.S. National Institute of Standards and Technology (NIST). In other words, now at least the beginnings of this function are being incorporated into the 3GPP standard for LTE and other broadband wireless technologies. BUT, and this is a big but, it may take years for this to work its way through the 3GPP and be voted on by the membership.

Several federal agencies have funded development work on mission-critical voice over LTE and broadband in general, and several of the bills to reallocate the 700-MHz D Block to Public Safety include additional funding for this type of research and development. However, to date there is no real specification that outlines the number of voice circuits that are or will be needed going forward. If we look back at past major incidents and add up the number of voice circuits that were used at a given incident, is this really the number of voice circuits that will be needed when combined with broadband data services?

For example, if we look at one of the major wildland fires in Southern California over the past few years it is possible to determine how many incident and non-incident voice channels were in use during the incident, but does that translate to how many voice circuits will be needed when we add broadband capabilities into the mix?

The Incident Command System (ICS) clearly defines the roll-out of both the ICS management system as well as the Communications Structure. During a major incident today, the communications leader or someone appointed by him usually completes an ICS form 205, which is the Incident Radio Communications plan that lists the incident name and then radio channel utilization. In most cases, this form is filled out by hand, usually at the staging area where vehicles arriving at the incident report to receive their assignments.

The number of voice radio channels used depends on the size of an incident. During the Tea Fire in Santa Barbara that started on November 13, 2008, burned 1,940 acres, destroyed 210 residences (130 in Santa Barbara, 80 in the county), and caused 30 firefighter injuries, the total number of radio channels in use at the height of the fire was 18 command-and-control channels and 72 tactical or simplex channels used for the fire and by police and other first responders directly involved with the firefighting efforts. Normal operations used an additional 4 dispatch channels and 6 tactical or simplex channels.

The good news is that in California almost all of the fire units that responded from federal, state, and local agencies had multi-channel VHF radios so there was a good amount of interoperable communications available. However, this did not include police, sheriff, highway patrol, and other agencies that were also involved in the firefighting. Coordination between these agencies and the fire command was handled via the dispatch centers and/or the emergency operations center. As you can see, there were a large number of radio channels in use and of these, some of the channels were federal, some state, and others local channels. One of the questions that need to be answered as we add broadband services (data and video) to these types of incidents is how much of the traffic on these channels would be reduced and could a future incident get by with fewer voice channels. Another question is that since this fire covered a large area, could some of the voice channels, in the future, be reused in different sectors? These are questions that can only be answered by those who plan for these types of major incidents and it is their input that will be critical to the development of the requirements for mission-critical voice over broadband systems.

One of the reasons so many voice channels are required during major incidents has to do with the fact that each group assigned to the incident has its own specific task to complete. Since each of these groups must have instant and complete communications capabilities, each group is generally assigned its own voice channel with the commander of each group monitoring both the local working channel and the channel on which they then talk to the next higher ranking officer at the incident. This system has worked well for many years and has provided a highly reliable way of ensuring that anyone who needed help could get on a radio and ask for it, and that someone else, either local to them or within radio range, could hear the call and respond accordingly. Without this type of reliable communications there might have been more injuries or even deaths as a result of someone calling for help and that call being unanswered.

In an ideal world it would be wonderful if every first responder had all of the capabilities needed to do their job and protect themselves and the public in a single device. Such a device would give them all of the voice, video, and data capabilities they need, when they need it. But we don’t have this type of device today. First responders cannot take the time to dial a phone number, and many times they do not have two hands available to change the status of the wireless device or make a menu selection. They need to know that simply by pushing an emergency button or calling for help their location and their need for assistance has been heard and that help is really on the way.

Technology is advancing rapidly and the first responder community, for the first time ever, is embracing a commercial and readily available technology for broadband (LTE). Hopefully, Congress will give the first responders the spectrum they need to build out a nationwide broadband network that will provide fully interoperable communications from border to border and coast to coast. Broadband will provide video for those responding to an incident, which is like giving sight to the blind. It will enable a swat team commander to see, on a mobile device, exactly what his snipers are seeing through their high-powered rifle scopes, all of which translates to better protection for both the citizens they serve and for themselves.

In the future, there is no doubt in my mind the Public Safety community will be able to have a single device that will permit voice, data, and video, but when will that future be? There are, at the moment, about 100 different answers to that question. The general consensus from those working with the technology is that some level of mission-critical voice can and will be available over LTE broadband networks. The remaining questions are how many of the mission-critical voice requirements can actually be met with LTE broadband or future broadband technologies, and how long will it take to be able to prove to the Public Safety community that LTE broadband can provide both voice and data services?

The bottom line is that today’s mission-critical channelized voice systems, and the new systems being deployed, developed, and planned, need to continue to be funded to ensure that when the time comes, the capabilities of LTE broadband can be weighed against the needs of the Public Safety community. If there is a perfect fit, the transition from channelized to broadband mission-critical voice should begin. Perhaps some of the channelized spectrum could be returned to the FCC for reallocation to others but this process should not, today, be viewed as something that will happen overnight but rather that it could take years to accomplish.

Is voice coming to LTE broadband? Yes, it’s the when that is in question. Is mission-critical voice coming to LTE broadband? I hope so, but in the meantime, not maintaining or building new mission-critical Public Safety voice systems should not be an option considered by any local, state or federal agency!

Andrew M. Seybold