Is Net Neutrality dead? The FCC seems to be backing off, Verizon and Google are not talking, Congress is still interested, and some think the entire issue will result in the resignation of the FCC Chairman. At least one “Google-ite” in the Executive Branch seems to have been caught exchanging emails with the folks at Google using his private Gmail account, so perhaps the push from the Executive Branch will not be quite so forceful going forward.

What is Net Neutrality anyway? In essence, it is an idea that all customers have equal access to the Internet and that there are no special toll roads or high-occupancy vehicle (HOV) lanes available to those willing to pay more. Do we need it? What would it really do to our existing access systems, and more importantly, what would it do to wireless broadband if the concept were extended to wireless? No one seems to have any specific answers to these questions, and it is not clear if today’s tiered data access pricing would be in violation of Net Neutrality. In the world of DSL, you can select your data plan and pay more for faster access. In the world of cable modems, where bandwidth is shared across a neighborhood, you can still pay extra for faster download rates, but the upload data speeds are usually fixed, at one or two lower speeds.

So far, different data speeds are not available on all networks, but more are charging by the amount of data used. We do not yet know what will happen with the LTE networks where Quality of Service (QoS), will make it possible for network operators to charge both by the amount of data consumed and levels of access speeds if they so choose. Recently the Wall Street Journal carried an article reporting that both Google and Verizon (wired not wireless) have recommended to the FCC that it push for laws for Internet access that would outlaw blocking or slowing specific content and would permit “private” service agreements on designated networks. This sounds like something I wrote about some time ago when I mentioned that I thought Google, which owns more dark (not yet used) fiber in the United States, wants to build its own Internet superhighway or toll road for the best possible access to the Internet.

Regardless of what type of access each of us has, at some point along the way there is a potential bottleneck for bandwidth and data speeds. I believe the sensible thing would be to enable network operators to manage their own networks. Typically, they will opt for management controls that will provide the best possible access levels to the majority of their customers. But they do need to be able to manage data hogs, peer-to-peer video, and probably streaming video data rates. It doesn’t make sense to me for networks that provide services to a broad base of customers not to be able to throttle back the hogs, but it doe make sense for me to have faster access if I am willing to pay more.

One of the most pressing issues I see is that even with network management on the access routes to the Internet, there is no direct Internet traffic management beyond what is built in. I see very little investment in new infrastructure for the Internet and I believe that video and other services will have a huge negative impact on Internet performance at some point. It is a juggling act to be sure, and I, for one, don’t have a simple solution—this discussion will continue for a long time to come.

Business Customers and Today’s Smartphones

The consumer is now king of wireless broadband. Not too many years ago, new devices and technology were first designed for business customers and then found their way into the consumer marketplace. RIM’s BlackBerrys still follow this business model, but as we rolled out 3G broadband systems, the uptake in the corporate world was dismal and took too long. The network operators that had invested $billions in their new broadband networks grew tired of waiting and shifted their focus to the consumer world where data uptake has been huge.

Companies did follow soon and dongles and broadband wireless built into notebooks drove most of that business. Then smartphones other than BlackBerrys began to make their way into the corporate world as well. The first version of the iPhone was NOT a business phone, but in its subsequent releases it has grown more business friendly, except for the fact that in order to install software onto the device, it has to be available via the Apple Apps store. This works for Salesforce.com, WorldMate Live, and many other business applications that make use of the cloud, but it does not permit company-specific applications to be used to any great degree. Most companies are working around that by using browser or applet forms of communications with their servers, but the BlackBerry is still king of the corporate world.

If I rank the Blackberry a 9 (on a scale from 1 to 10, lowest to highest) for being business friendly, I would rank the iPhone as a 7 (up from a 4) and would give the lowest ranking, a 4, to smartphones built on the Android platform. Android phones are lacking in many respects when it comes to being business friendly, yet since the Android platform is supposedly more open than the Apple platform, it would seem to me that Android devices would be more acceptable to the corporate world.

Tablets

From what I can see, the same situation will occur in the fast-moving world of tablets, led again by Apple with its iPad. The promise of other tablets also seems to be aimed at consumers, but there is pent-up demand from executives who want to travel and leave their laptops at home. I wrote an article for FierceMobileContent about this subject, and the response was mostly in agreement with my views that today’s tablets are not really aimed at the business marketplace.

On August 10, Dell announced it would be launching its own tablet. Called the Dell Streak, it has a 5-inch screen and runs the Android operating system (version 1.6 to start). It includes 3G connectivity using the AT&T network, Wi-Fi, and Bluetooth. The device sells for $299.99 with a 2-year AT&T contract, and $549.99 with no contract.

As I was writing this, Ralph de la Vega, President of AT&T Mobility, was delivering a speech in Boston and stated that he expects to see a big growth in the number of business applications that become available for tablets and believes there is pent-up demand for such applications. I agree, and in the meantime, my in-flight research (asking people carrying iPads) shows that those of us carrying iPads when we travel are still carrying our notebooks when we are away for extended periods of time. We do use the iPad for viewing email, especially messages with attachments. It was great to hear Mr. de la Vega address the issue of business applications for these devices and I, for one, hope he is correct.

LTE

Verizon appears to be on track with its Fourth Quarter launch of LTE in 25 to 30 markets covering about 100 million people (out of a U.S. total of slightly more than 300 million). It is now stating publically that LTE data speeds will be 5-12 Mbps down to devices and 2 Mbps from the devices to the network. It is great when a company the size of Verizon is realistic about data speeds. There are too many press releases from others claiming the “completion of a 50 Mbps or 100 Mbps call over LTE.” I find it refreshing that Verizon is coming out ahead of its LTE launch to set appropriate expectations. The range of data rates is due to there being a number of variables that play into the exact rate that will be available to a customer.

The distance the customer is from the center of a cell sector plays a big part in the speed, the amount of spectrum Verizon has available also limits the total speed, and of course, since wireless broadband is shared on a cell sector by cell sector basis (usually 120 degrees from a cell site), speeds will also depend on how many users are located within the same cell sector and the type of data they are using. If everyone in the sector is browsing the web or taking care of email, the available data rates will be faster than if some of those in the cell sector are downloading, uploading, or streaming video.

Too many times during the almost 30 years of commercial wireless, the hype preceding the launch of a product or service has set false expectations leaving customers disappointed. If you go back in wireless history, there are literally hundreds of examples of this. These include Cellular Digital Packet Data (CDPD) systems in the mid-1990s, the first 3G UMTS systems, the Apple Newton, the WiMAX community promising incredible data rates with incredible coverage per cell site, the Google Nexus One phone, and many others. I have found that when people are given conservative estimates of performance and features they are usually happy with the results once the product or service hits the market. However, when expectations are set too high in advance of a new device or service, disappointment is rampant and the company loses credibility and sometimes fails to recover.

Having become steeped in LTE as a technology because of my work with public safety broadband systems, I fully appreciate Verizon’s statements concerning expected data rates and applaud them. It is also important to understand that LTE is designed to be deployed in 1.4, 3, 5, 10, 15  and 20-MHz chunks of spectrum. Verizon’s nationwide LTE system is being built in 11 MHz (11X11) of spectrum so it will be a 10-MHz LTE system. In some areas, Verizon owns additional A and B Block spectrum so it will probably add another 5X5 LTE system to the first one over time in heavy-demand areas.

AT&T, on the other hand, has a lot of A and B Block spectrum that is 6X6 and will support a 5X5 LTE system. AT&T also purchased 700-MHz spectrum prior to the auction in a number of markets, and during the auction it bought numerous A and B Blocks that can be aggregated together. Therefore, I expect to see nearly the same results from AT&T when it launches its own LTE network. Both companies will be upgrading their systems over time as the next LTE standards are released, so this first foray into the world of LTE will be the minimum speeds achievable and future releases will add more speed and capacity to these networks.

While I am discussing LTE, it is important to understand that since LTE was designed from the ground up as a broadband data technology, there are many variables that can be used by network operators to set the parameters for the system. There are three different data rates down to devices, and these are usually set as follows: near the cell center, faster speed; mid-cell, medium speed; and far cell (edge of cell), the slowest speed. However, network operators may set downlink data speeds to optimize the performance across most of the cell by choosing the mid-rate for more of the cell sector. There are other variables that affect the performance of an LTE system as well, including the number of data blocks assigned for a user. This could depend on the type of data being used and a number of other parameters, some of which will be fixed to provide the best performance across as much of the network as possible. Some may be variable on an as-required basis; it simply depends on how the network is to be managed and the criteria for data that the network operator establishes as the norm.

LTE is a powerful wireless broadband technology and it remains to be seen how it will be optimized by the various network operators. I think we will see a number of tweaks to the LTE systems as they are deployed and network operators learn more about the best ways to optimize the systems so they can serve the most customers with the best data rates available.

Some Final Comments and Updates

For those of you who are interested in what I am doing in the public safety sector with broadband and traditional networks, we have launched a new section on our website called the Public Safety Advocate. You can sign up for the postings and for the weekly news recap for free. If you are already a subscriber to our Commentary, send an email to info@andrewseybold.com asking to be added to the Public Safety Advocate list. If you are not, when you go to www.andrewseybold.com to sign up, you can check the boxes for any or all of our free electronic publications.

Also, we have moved our annual Wireless Dinner this year to CES in early January. The Consumer Electronics Show is becoming more wireless friendly all the time, and organizers have been gracious about working with us on this Dinner, our 21^st. We still have sponsorships available. If you are interested, please contact us at info@andrewseybold.com and we will be in touch with you.

Don’t forget that our Andrew Seybold Wireless University is coming up on October 5, the day prior to the CTIA event in San Francisco. This all-day educational session is totally revamped this year and we are adding a lot of new content. Even if you have attended before, you owe it to yourself to consider attending this fall’s session.

Finally, I am now writing for Forbes.com. My articles have more of an investor’s twist to them but I am submitting blog articles several times a month. You can find me under the “Intelligent Investing” section of the Forbes.com website.

Until the next Commentary,

Andrew M. Seybold

Apple certainly set the bar with the iPad. It is sleek and has a great screen, the battery life is acceptable, and it is easy to carry, take out, and turn on for use. It does not have to be taken out of my bag when I go through security at an airport, and I can carry a smaller briefcase, which makes life easier both on the road and going to meetings. But it has a number of limitations for business use, and these limitations are opportunities for those planning to introduce tablets in the near future.

The iPad belongs to Apple’s closed environment almost exclusively. I say ‘almost’ because I can use it to connect to the Kindle store and buy books without having to go through iTunes, but in order to load pictures or documents, I have to either go through the Apple Store or email them to myself, which is a multi-stage process. The email client on the iPad does integrate with my Exchange Server and provides me with synchronized email, calendar, and phonebook, although the calendar and phonebook are separate applications and not available via the email client.

The Apple versions of word processing, spreadsheet, and slide presentation software are not fully compatible with the Microsoft versions, as Barney Dewey indicated in his early iPad Blog. When you import slides from PowerPoint, you have to spend time reformatting them. Many of the applications that are available for the iPad  were ported over quickly from iPhone applications and do not incorporate much in the way of iPad capabilities. They are simply the same program on a bigger screen, and some of the apps do not support both horizontal and vertical views. I have been unable to find a real expense program written by someone who actually travels and understands that ease of entry is a key to success. For example, many of us stay at the same hotel for multiple days and we might have a hotel room price limitation so we need to be able to report the room taxes as a separate entry (taxes are excluded from per-night restrictions placed on us by some companies).

Apple has its reasons for providing a more closed system. It still surprises me that only a few years ago many people who now carry iPhones and iPads were screaming that the wireless operators were forcing them into walled gardens where the network operators controlled the content and applications, yet they gladly accept Apple’s walled garden approach in order to have the latest in supercool technology. Apple has been successful with all of the “i” devices because of iTunes and the Apple Store and because it is selling more than simply an “i” device, but I believe this also opens up many opportunities for those who will be following Apple into the market.

These new tablets will have to be just as slick with great screens and easy to use. They will have to avoid the Windows problem of long boot-up times, and they will need to be coupled with stores and services so they are ready to go out the door.

Beyond that, there are many great options available to offer a better product that will be more attractive to both consumers and business customers. From a business perspective, every person I come across while traveling on business who is using an iPad has the same vision: Use the tablet instead of my notebook while on the road. It is lighter, the battery life is better, and it is easy to turn on and use. ALL of these people share my frustrations with the world of Apple and its lack of understanding of the needs of business travelers.

Today my smartphone (BlackBerry) can handle most of my business needs on the road but there are times when I want a larger screen for email attachments, to show a presentation or pictures related to my business activities, take notes on while at a meeting, organize my travel, and track my expenses. Today my laptop sits on my network connected to my main computer using a software product called Memeo and the two are constantly synchronizing with each other. When I grab my notebook and put it in my briefcase, I know I have all of the latest files; I don’t need to worry about forgetting a file and not having access to it.

I cannot do this with the iPad, nor can I set up a series of client files that are the same on both my desktop and my iPad without a lot of extra work. I am sure Apple’s vision for the iPad is the same as for the iPhone—iTunes is your Home and for everything else there is the Internet. This does not work in the business world. What is interesting to me is that the iPad is actually the third generation of tablet to hit the market. While the earlier tablets were merely laptops with larger screens and no keyboard or an add-on keyboard, they were designed for the business community first. If they had been successful (they were not), they would have then moved into the consumer space.

Over time, the vendors’ focus has shifted from the business world first to the consumer world first. There is a good reason for this since there are many more consumers in the world than business people and certainly more consumers than business travelers. In the early days, business customers were the ones who spent the big bucks for technology because they could quickly see the advantages cell phones, pagers, notebooks, and other mobile devices provided for them, and how these devices would improve their lives and make their tasks easier to complete. Today, the consumer is king and the business customers, for the most part, end up having to adapt to consumer products even though they are not nearly as good as business tools. This is the main reason I am a loyal BlackBerry user. It provides what I need for business very well, and on the few occasions when I put on my consumer hat, it does what I need it to do.

As this new round of tablets is being rolled out, led by the iPad, I am sure they will all be consumer-oriented products and they will offer some access into the business world, but business customers will have to learn to adapt to the tablet and make do. However, there is still a need to continue to provide devices designed to aid business customers and I believe that if these new tablets are to be truly successful against the iPad, their manufacturers will have to make them more business friendly.

This is a tough call for a company such as Dell, HP, or Lenovo that is selling lots of laptops, netbooks, and smartbooks into the corporate world. Tablets will eat into this market and could replace a large number of these units at lower prices with shorter margins. But someone will get it right and I have always believed that if your products are to be cannibalized by another product, your company should be the one cannibalizing your products, not one of your competitors. As an aside here, one company is in an ideal position to win in the corporate tablet space and it is RIM. It doesn’t make laptops or notebooks, only great smartphones for the business and consumer markets. Think about how much RIM knows about business customers and what they want and need. Suppose it came to market with a tablet that was capable of sharing information between a BlackBerry and the tablet, of keeping files and applications that work together on each, and of having the two fully synchronized all of the time so that no matter which device you use when, it is always up-to-date.

The corporate world might not have the same number of potential buyers as the consumer world, but if you look at the history of both mobile computing and wireless usage, business users tend to spend more money on technology and services than consumers. Business customers have fewer real choices in the way of smartphones today since Android-based phones are almost exclusively consumer-oriented and tied to Google for many features and functions. Google has also built its own walled environment, but it has been very clever and convinced many handset companies to build the devices that work better with Google services. Business customers who want to make use of an Android phone are left to find ways to make it work for them.

And as we move into what people are calling “cloud” computing, consumers are much more likely to embrace the “everything is in the cloud” concept than business customers. We have learned over the course of a long time that having information at our fingertips regardless of whether we are within coverage or not is critical to our success. I have many reservations about the Internet based on the fact that it is not a mission-critical network, and that wireless is great but I am not always in range. During a recent trip to D.C., I was carrying my BlackBerry on T-Mobile and my Verizon phone, and while in and out of the various offices on Capitol Hill, coverage was spotty in some places, great in others, and non-existent in others. Wireless operators do the very best they can and are moving toward more in-building coverage using many different types of systems, but the fact remains that we continue to be in an always-on and most-of-the-time-connected world (up from a sometimes-connected world only five years ago). Given the characteristics of wireless networks, and people not wanting cell sites in their own backyards, I believe we will remain in this world for a very long time.

The iPad is a great device and I am not at all sure I have much faith in Microsoft’s ability to get its own tablet operating system right, but I am hoping that if it does, there will be many more hooks into the business world than are available in the iPad and any future tablets that might be based on the Android operating system. It makes economic sense to build devices with consumer appeal, but there will continue to be many great opportunities in the business world as well and I hope some of the tablet vendors will study the iPad’s shortcomings and provide platforms that are more work friendly. I, like many people, am in business first so I can afford to be a consumer at other times, not a consumer who occasionally needs to interact with the business world.

Andrew M. Seybold

What I have not seen are discussions of the overall issue of antennas and their placement on wireless devices. A number of interwoven issues contributed to the problems encountered on the iPhone 4. First, the antenna, its effectiveness and its location, is the weak link in any wireless or radio system. If you watch TV with an outside antenna and disconnect the antenna from the TV set, there is no reception. If the antenna on your car breaks, you don’t have any AM or FM reception. This is because these systems are designed with the understanding that there will be an external antenna.

In analog cellular days, every phone had an external antenna, which gave the device better range when communicating with cell sites. When we switched to digital but analog was still operational, antennas were still external. Today, our wireless network operators have built out many more cell sites—AT&T and Verizon each have more than 40,000 sites to cover the United States. Still, we don’t have good coverage inside buildings or in areas where the nearest cell site is at a distance. But since coverage is many times better than it was earlier, the handset vendors and network operators decided to hide the antennas inside the devices to make them more appealing and easier to carry. However, this has had the undesirable effect of making them less sensitive than earlier devices that had external antennas.

Better coverage is the primary reason you will find external antennas mounted on police, fire, and other vehicles that make use of two-way radio. You will also find external antennas on family radio walkie-talkies and handheld two-way radios used by first responders and others. Nextel employed external antennas on its phones (and some still have them) to enable customers to receive and send wireless information when in lower signal areas.

We are not talking here about a single antenna for the iPhone or for any other wireless device. Antennas have to be matched to the frequency on which they operate. The match has to be such that as much power as possible is transferred from the transmitter to the antenna. A mismatched antenna can result in poor radio coverage, heat build-up inside the radio and, therefore, shorter life for the device. Antenna experts are very good at designing antennas to be as efficient as possible, but in the confines of a handheld device, there are trade-offs that must be made.

Radio waves are absorbed by our bodies, by walls, and even by vegetation. Some of you might have experienced different performance from your wireless devices in the same location in the winter than in the summer. This is because leaves and even pine needles can soak up a radio signal and cause the overall system to degrade during the spring and summer. Also, since radio waves sometimes arrive at your device not directly from the radio tower but rather by being bounced off a building or hill, these signals may be much lower in strength than if you had a clear line-of-sight view to the cell site.

All of these factors affect the performance of our wireless devices, but we need to add yet another parameter to all of this: Today’s wireless devices need multiple antennas in them. A typical “world phone” operates in four to five different portions of the spectrum from 800 MHz through 2.1 GHz or higher. Then there is the antenna needed for Bluetooth, another for Wi-Fi if it is built in, and one for the GPS receiver. If you have mobile TV capabilities built in, there will be another antenna to receive, say, MediaFLO TV signals on 700 MHz. Soon, Verizon first then AT&T and others will be adding the 700 MHz band to these devices and the number of antennas needed inside a wireless device will increase again. Most LTE systems will make use of two antennas in each wireless device to increase both the coverage and the data speeds.

As I mentioned, antenna design engineers have become very good at what they do, but since each antenna must be electrically matched to the transmitter and receivers, it has to have certain characteristics that differ from the antenna for another portion of the spectrum. Today, these engineers have been able to design fewer antennas into these devices by making one antenna do the work of several, but there are limitations to what can be done. All of this also means that any company designing and building devices that does not have access to engineers who really understand the antenna systems that are required will have a problem building a device that works as well as someone else’s device with a better antenna system.

Some of you might remember when Wi-Fi was first being built into notebook computers. My company, as well as many others, ran tests to determine range and speed and found significant differences (the weaker the radio signal, the less data speed). Today, all of these notebooks offer about the same level of coverage, but in those days there were huge differences. What we found was that the computer companies that hired or brought in antenna experts had products that performed better than those that thought they could simply build an antenna and put it inside a notebook. Not only is the length of the antenna important, where it is placed inside the device is just as critical. Since it is radiating radio signals, it could interfere with the device’s receiver, or some of the radio waves could be absorbed by other components and even more can be absorbed by the placement of a hand over the portion of the phone where the antennas are located.

As you can see, the entire issue of antenna design and placement is critical to the performance of a wireless device. What Apple was trying to accomplish was twofold. First, Apple was trying to gain room inside the iPhone 4 to make it thinner and to hold a larger battery. Second, it was trying to move the antenna(s) outside of the device, as if using an external antenna sticking out the top. I have not tested an iPhone 4 in our lab, but will be doing so once Apple resolves the software signal strength issue, but it is easy to understand why it was caught off guard by the complaints about poor coverage.

There is one more variable that needs to be taken into account. When your car radio receives an AM or FM broadband signal that is all that is happening—it is receiving the signal. However, depending on the technology your network operator is deploying, it is possible that your phone is both transmitting and receiving at the same time. This creates additional problems in design because the same antenna that is “listening” for a signal is also transmitting a signal on a different portion of the spectrum at the same time. Unless these systems are designed carefully, the transmitted signal can cause noise in the receiver and it will not be nearly as sensitive.

Perhaps the matter of receiver sensitivity deserves a mention about now. Receivers are designed to hear signals that are received by their associated antenna and then process these signals. However, if there is a lot of noise (interference) on the channel the receiver is listening to, it cannot detect the signal intended for it because it is covered by noise. Also, different types of receivers have different degrees of sensitivity. To better understand this, visualize a single grain of sand. Hold that grain of sand between two of your fingers and you will hardly feel it. However, if you put it into your eye, it will feel like a boulder! In this case, your eye is a more sensitive “receiver” than your fingertips. The more sensitive a receiver, the better coverage the customer will experience.

Normally, when testing these devices the first tests are performed in a controlled environment where other radio signals are blocked (in a screen room) and the device is mounted in a test fixture, not held in someone’s hand. The final tests, just as the product is ready for market, are the field tests. It is very possible that the differences in coverage were not noticed because the same person was testing the iPhone 4 as a standalone device and NOT against other devices in the same area. Once again, it is important to understand that antenna design needs to be carefully developed, and even then it is part science and part art. The antenna experts who work on these devices clearly understand the art part.

The transfer of radio signals to and from the antenna and the radio receiver and transmitters, and the efficiency with which that is accomplished, determines how well the device will perform. For voice, the difference will be a clean completed call or a noisy dropped call. For data services, the better the signal strength, the higher the data rate in both directions. If your device is not designed properly, your results will not be as good as those of someone standing next to you with another, better-designed device.

I am not saying the iPhone 4 was not designed properly; I have not had one in my hands nor seen the antenna configuration. But it does appear to me that Apple’s goal was to provide for better performance and a better data experience for its customers. If the “fix” is to put a rubberized case around the device to keep hands from touching the metal portion of the phone, that is simple enough. If this type of fix does not prove to be workable and there is something more involved, I am sure Apple and the network operators will figure it out and come up with a more satisfactory solution.

The point of this commentary is not to beat up Apple for what might have been a design mistake. The point is that the entire issue of antenna design and placement is extremely complex, and the antenna is the weakest link between our wireless device and the cell sites. Further, I am not talking about a single antenna here, but rather multiple antennas each needing to be the best they can be, stuffed inside the device in the smallest possible space without interfering with each other or the radio and computer components inside the same box.

It is truly amazing to me that we have engineers who possess the knowledge and skills necessary to make all of these variables work together, and I suspect that moving forward we will find more examples where new antenna placements might be tried—some will work and some will fail. Regardless of how good a computer model you build to prove out the performance of these antennas, until you put them on or in the device and turn it on, you cannot be 100% sure of what the results will be—that is the art that goes along with the science.

Andrew M. Seybold

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

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

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

Best regards,
Andrew M. Seybold

PUBLIC SAFETY ADVOCATE

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

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

A Visit to DC

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

The Panel

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

All of the work that has been done in designing Public Safety broadband systems assumes the same number of sites for both a 10 MHz and a 20-MHz system (using the FCC’s own guideline of a total of 44,000 sites). In this case, the additional 10 MHz of spectrum does equate to more capacity. However, the additional 10 MHz of spectrum is the difference between Public Safety users having to roam onto commercial networks every day versus only when there is a major incident. Under “normal” circumstances, all of my research shows that even with a major accident, a hostage situation, or any number of other incidents that occur on a daily basis, 10 MHz of spectrum will not provide enough data capacity.

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

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

My Presentation

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

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

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

Conclusion

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

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

Andrew M. Seybold

LOCPanel06-03-10

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

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

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

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

What This Means

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

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

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

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

Guard Bands Update

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

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

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

Timing

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

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

Turning 5X5 into 10X10

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

Designing the Networks

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

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

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

Network Funding

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

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

Conclusions

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

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

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

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

Andrew M. Seybold

To set the record straight, I am NOT currently being paid, nor have I been paid at any time during the past two years, by any entity, commercial or government, for my involvement in the issue of public safety and broadband interoperable networks in the 700-MHz band. Quite the contrary, I have spent my own money and my own time on this because I believe this is an extremely important opportunity to finally provide the right tools for the public safety community. I have paid all of my own expenses for travel, for my speaking engagements, and for my writing. I have not taken a single penny from any organization or commercial interest for my work on the D Block on behalf of public safety. 

Those who are trying to discredit me have not done so by pointing out any flaws in my logic or recommendations, rather, they are trying to make it appear as though I am a hired gun and that I am saying what others want me to say to help them further their own cause. Nothing is further from the truth. Not only have I given of my time and resources to a cause I believe in, I have actually lost clients because of my stance. I have been willing to give up this income because I feel so strongly that the public safety community needs at least one independent voice that might be heard above all of the rhetoric and politics. 

Over the past 30 years, I have provided consulting services, white papers, and educational sessions for many companies around the globe. These include most of the major network operators within the United States, Canada, Japan, China, France, the UK, New Zealand, and elsewhere. I have also provided these services to handset vendors, software developers, and equipment suppliers. I have also worked with and for a number of public safety organizations on a local level, helping them plan to take advantage of the coming broadband opportunity. 

During the past two years, I have talked to many companies in the wireless industry to gain a better understanding of commercial technology and the equipment being developed that could help public safety.  And I have done this without any compensation or reimbursement for my expenses. 

There are some in Washington, DC who cannot understand why a person would spend as much time and effort on behalf of the public safety community without being compensated, and some say very generously. Over the past 40 years, I have been deeply involved in public safety communications issues from a vendor perspective, from a consulting perspective, and from a user of public safety communications systems. I spent more than 15 years helping the major public safety radio companies design and sell systems in many different parts of the nation, and after I went into practice for myself, that experience has proven to be invaluable to me and to my clients. The public safety community is fighting a battle it needs to win, and if I can assist in that effort I will gladly do so, perhaps as a way of giving back to a community that has been good to me over the years, but also because I have been personally involved and I have walked in their shoes. I know of their frustrations when trying to coordinate activities in the field on a daily basis when they cannot even talk to each other. 

I am disappointed that those whose ideas I have challenged have decided that my credibility now must be challenged. However, I believe in what I am doing and saying and I will not make this personal or attempt to challenge their credibility.  All I am doing is trying to convince them to rethink their position based on different input, more facts, and more accurate data than they have had at their disposal. This is not about a government agency winning. But it is about the public safety community losing at a time when we need its services more than ever. I will continue to work tirelessly on behalf of public safety regardless of the consequences to my reputation or my business. Deep in my heart I know it should not have to be this way—but it is, and I will take whatever lumps lie ahead for me.

Andrew M. Seybold

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

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

Executive Summary

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

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

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

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

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

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

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

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

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

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

Andrew M. Seybold

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

The FCC chairman has repeatedly stated that his Commission’s actions will be based on data and facts. This may be true, but in the Broadband Plan it submitted to Congress on March 17, the FCC seems to have used its own brand of logic to mold the data to fit its own agenda for public safety.

The FCC and many others believe that broadband systems are the way forward when it comes to wireless spectrum usage. Therefore, it stated in its report to Congress that we need to find the commercial wireless community 500 MHz of additional spectrum over the next ten years—300 MHz of it within the next five years. The same document also stated that public safety’s existing 10 MHz of spectrum is sufficient for their use, however, it has told the public safety community that if it is wrong about this it will “find” additional spectrum, but not in the 700-MHz band where public safety’s existing 10 MHz of spectrum is located.

The FCC is planning to find additional spectrum (500 MHz) for commercial operators because demand for wireless data access is growing rapidly and is expected to continue to increase at even higher rates. According to Cisco and others, demand for broadband data services over wireless grew by 160 percent in 2009 to a total of 90 petabytes a month (enough data to fill 23 million DVDs). YouTube videos account for 10 percent of today’s usage and according to Google, video demand today accounts for 40 percent of all Internet traffic. Video services are predicted to account for 66 percent of all data traffic by 2014.

These numbers clearly show that commercial network operators will have to have more spectrum, use their existing spectrum more efficiently, and manage their network loading to satisfy this immense new demand for data.

At the same time, the FCC is convinced that public safety does not need any more broadband spectrum than has already been allocated and points to empirical data it has collected from network operators, equipment vendors, and the public safety community itself. The data I have seen tells a very different story.

Today, commercial wireless operators have holdings in up to four different portions of the spectrum: 800 MHz, 1900 MHz, 2100 MHz (AWS), and now the 700-MHz band. Both AT&T and Verizon Wireless are licensed to use an average of 91 MHz of spectrum in all of these bands combined. Today they are using some of it for second-generation (2G) voice and slow-speed data services, and the rest for third-generation (3G) voice and broadband data services. The new spectrum they acquired at auction will be for fourth-generation (4G) data, followed by voice services.

Yes, they will need more spectrum in the next five years because of the growing demand for broadband services, but since all of the spectrum that is already licensed to the commercial operators is contiguous and in large chunks that will support 3G networks and that can be upgraded to 4G networks, any and all of the current spectrum can be converted, over time, to provide 4G services. To be more precise, the top two commercial network operators have spectrum holdings in every band that can, over time, be used for 4G services.

The public safety community, on the other hand, has spectrum holdings in the 30 MHz, 150 MHz, 450 MHz, and 800 MHz bands and the spectrum assignments are NOT contiguous or large enough to be combined for 4G broadband services. So while commercial operators will be able to convert their entire spectrum to 4G broadband, public safety will not. Only 21 percent of public safety’s total spectrum allocations can be used for broadband.

The chart below shows that most of public safety’s spectrum holdings are small slivers of spectrum as opposed to commercial operators’ holdings of contiguous spectrum that can be used for both 3G and 4G networks.

Spectrum by Band: Average per network operator in 100 top major markets

Time after time, public safety has proven its need for at least an additional 10 MHz of spectrum with hard facts based on New York’s existing 2.5-GHz broadband network as well as the amount of data currently being used in other parts of the nation on the commercial networks. The FCC says it will make sure public safety can spill over or roam on the commercial network when it reaches capacity on its own network, and further, that this roaming or spillover will be provided by the commercial network operators using priority access. However, priority access is not the same as spectrum assigned specifically to public safety. In times of major emergencies, even on a local level, the demand for services comes from both the private and public safety sectors at the same time. While the FCC seems to be convinced that priority access on a 4G network will provide public safety with enough bandwidth, the technology to implement this is untested and theoretical at best.

Some of the best and well documented data concerning public safety broadband usage comes from Motorola, which is a major supplier for both public safety and commercial broadband systems and the acknowledged leader in the public safety sector. According to a presentation Motorola gave to the FCC as recently as April 12 of this year, the FCC’s analysis of data traffic is flawed and not based on real-world usage. For example, the FCC’s presentation to public safety states that 10 MHz of spectrum (already licensed to public safety) will provide an average uplink speed of 256 Kbps while the Motorola presentation clearly makes the case that the minimum required speed for a tactical decision-enabling video is 1.2 Mbps. Motorola further points out that several agencies already require 1.2 Mbps or higher for public safety quality video transmissions. It is obvious from the FCC’s own average uplink speed that a cell sector will not support even one video feed from the field back to a command center. Motorola’s document also included pictures representative of the video quality that could be delivered via wireless broadband. Even at 384 Kbps, the video would be Quarter VGA format (320×240 pixels) rather than VGA quality video that requires a minimum of 1.2 Mbps on the uplink or downlink.

And this is only the video part of the equation. It should be noted here that none of the commercial network operators will be deploying their 4G systems in less than 12 MHz (6X6) of spectrum, which means they will be able to occupy a full 5 MHz of spectrum for both the uplink and downlink, while the public safety spectrum would accommodate less than 5 MHz of bandwidth in each direction, especially if the D Block, which is adjacent to the public safety spectrum, was being used by a commercial network operator. Additional, “dead” spectrum is required for a buffer between different systems and must be built into the equation when discussing how much capacity and bandwidth will be available for public safety use.

So now you know why I consider the FCC’s decision to be based on faulty logic. But wait! There’s more! When public safety responds to the many larger incidents that occur every day, a lot of resources are thrown at them. A bank robbery might mean a response from multiple police personnel including a swat team, the fire department, and at least one EMS vehicle and personnel. The same is true for multiple-vehicle accidents, a gas tanker spill, and the many other incidents that are not considered to be “major” but are normal during a typical day in the life of the public safety community.

Once again, the input to the FCC detailed many of these incidents. A typical response for some might include anywhere from 15 to 50 vehicles and 50 to more than 100 first responders. Resources for these incidents will include full-motion video back to the command center from one or more unit at the scene, video or other large images such as building layouts or schematics down to those at the scene, plus GPS to track the location of personnel, photos of suspects, perhaps fingerprints and other evidence found at the scene, and many other images. While many of these broadband services have not yet been implemented, there is no doubt that they will be, and as the network is deployed, there will be more applications.

Several other points were also missed or neglected by the FCC in its recommendations. The first is that today, all of the broadband data usage is to and from the first responders’ vehicles. As we move toward the broadband network, data requirements will move from the vehicle to the person, just as we have seen them move from the home to the individual as commercial broadband services have become available. This means that there will be double or more the number of devices that need to send and receive data, and that will quickly generate more traffic on the network.

And since most incidents are confined to a single building or street, chances are that the coverage for broadband will be from a single cell sector or two at most. Since wireless broadband is a shared resource, the more people who are congregated within a cell sector, the less data speed and capacity each one will have. Having 20 MHz of spectrum available per cell sector would more than double both the capacity and data speeds that will be available at an incident. The FCC’s rationale is that by making use of commercial network cell sites, first responders will have access not only to their own 10 MHz of spectrum but, on a priority basis, to all of a commercial network operator’s cell sites and public spectrum as well.  

Public safety personnel cannot and should not assume that commercial network bandwidth will be available for them. One of the major differences between commercial voice services and public safety voice services today is that commercial customers are subject to network overload and dropped calls. First responders know that when they need to use their radios, the call will go through and be heard by others. The FCC’s answer to this is that 4G technology (LTE) can provide a high priority level for the public safety community. During a large major incident, this additional bandwidth and capacity could perhaps be used for administrative and routine purposes, but all of the information to and from the incident needs to be handled on a public safety-grade system—not a system that is shared with commercial customers.

Cell systems for commercial network operation are designed and built for peak usage times while public safety networks are designed and built for the worst-case scenario. It is not acceptable for public safety responders to have to vie with the general public for available capacity and bandwidth during an incident. If this was a once-a-year occurrence, the general public and commercial network operators might be understanding and willing to cede their access to the first responders, but with only 10 MHz of public safety controlled spectrum, these service interruptions will happen on a daily basis, at least in the top 100 major urban areas.

Why does the Secret Service use two-way radios and why is its spectrum available to this department and no one else on a 24/7 basis everywhere in the United States? The answer is that when they need it, they really need it and they can never be in a position where they would have to share it with anyone else. This is true for the FBI, the DEA, and all of the federal law enforcement agencies. Why does the FCC think it is okay to treat local public safety any differently?

After reviewing other data as well as data provided to the FCC, it is clear to me that if public safety only has access to 10 MHz of broadband spectrum, it will exceed the capacity of its system every day handling normal level 1 responses, meaning it would need to use commercial spectrum for each and every one of these incidents.

The FCC does not seem to think that demand for wireless broadband services will grow in the public safety sector as well as in the private sector. It acknowledges the rapid growth in the private sector but states that the first responders have not demonstrated that they will experience the same type of growth. But there is no way to “demonstrate” this kind of growth until the first responder community has the types of devices and wealth of applications that are available to commercial customers today. Once its network is being built, public safety will begin expanding its use of broadband and the number of applications and services will skyrocket in the same way it has in the private sector. Even so, for now, the FCC seems determined to base its assumption that 10 MHz of spectrum is enough on today’s limited broadband usage, which does not represent the highest and best use of broadband data for public safety.

Additional numbers from Motorola for uplink and downlink capacities and speeds are also provided in its presentation to the FCC and it is important to point out once again that figures for speeds and capacity per cell sector are the maximum possible for a single user within a specific cell sector. As more users enter the sector, the data speeds for each will diminish, and if a number of streaming videos are being sent back from the field or down to those in the field, the capacity is eaten up in a hurry and data speeds will suffer accordingly.

Motorola predicts that using 10 MHz of spectrum, the maximum data speed per sector from the field will be 3.5 Mbps, and down to field devices will be 8.4 Mbps. However, if public safety has access to 20 MHz of spectrum, speed and capacity per cell sector more than double. The uplink becomes 8.0 Mbps and the downlink 17.7 Mbps, providing public safety operated capacity that should be sufficient bandwidth for both level 1 and 2 incidents (but would need to be augmented for level 3 or higher incidents).

Conclusions

Ever since 9/11 and Katrina, attention has been drawn to the fact that first responders cannot always communicate with each other. Units from one department might have radios on one portion of the spectrum while adjacent units might be on a totally different portion. This came to be because over past 30 years, each time the FCC opened up more spectrum for wireless communications, public safety was given another sliver of spectrum in the new band and never enough to consolidate its communications into a single band segment.

Over the years, public safety has struggled with the issue of interoperability and has had to be creative in working around the problems. One way the problem was partially resolved on their voice services was to install two or more radios in each vehicle so they could communicate with neighboring departments. Using this approach, the investment in radio equipment can reach multi-thousands of dollars per vehicle. Compare these costs and lack of flexibility with today’s smartphones that cost less than $200 each, many of which can make and receive calls across the United States and to almost anywhere in the world. These same smartphones provide access to thousands of applications and full access to the Internet. The observation that criminals have better communications capabilities than law enforcement has never been more true than today. Even today’s teenagers have wireless devices with more capabilities than first responders have.

Since 9/11, the federal government in general and the FCC in particular have pledged time and again to fix the communications issues faced by the public safety community on a daily basis. Today, ten years later, what is being offered up is once again too little, and if the D Block is put out for auction and developed by a commercial network operator, it won’t be too many years before the public safety community will once again have to return to the FCC and beg for additional broadband spectrum.

Public safety is about safeguarding life and property by responding to crime, fires, and medical emergencies, and first responders’ communications systems MUST be able to provide both the voice and the data services they need to do their job more effectively. The FCC and congress have it within their power to make sure that this time around they provide the tools to solve many of the interoperability issues that have been facing public safety for more than 30 years.

Public safety communications require two different types of communications services: one for voice and one to exchange digital information, including video, in real time. The commercial networks cannot provide the types of voice services that are needed, and they can only provide the data side of the equation as part of their own commercial data services. Therefore, the public safety community needs its own broadband spectrum and it needs more than the 10 MHz now allotted.

The public safety community and the commercial sector have already begun working together to form a variety of public/private partnerships and as the public safety networks begin to be built, these partnerships will provide the best of both worlds—without the FCC’s involvement. The two communities have come together to make it happen and they will, but congress and the FCC must reallocate the D Block to the public safety community today. Public safety has been short changed over and over again when it comes to spectrum allocations. It’s time to do the right thing!

Andrew M. Seybold

Apple Bites

Let’s start with Steve Job’s battle with Adobe. Jobs claims Adobe’s Flash product has some problems and therefore should not be permitted on the Apple iPhone and iPad platform. Why not work with Adobe? I would like to remind Steve that in 1985 when he, my brother Jonathan, and Paul Brainard of Aldus were discussing the new laser printer and what could be done with it. Out of that came Desktop Publishing in which Adobe played a very big role in helping set the standards for typefaces and other related products. Had it not been for Adobe and its work directly with Apple (and others), DTP as it was known in those days would have taken longer to mature and revolutionize the typesetting and document layout industry.

Speaking of Apple, I wonder why an operating system that was born inside Apple and spun out in 1990 (General Magic) never had any real influence on today’s wireless operating systems or applications. The General Magic Magic Cap operating system was first developed inside Apple and later Marc Porat, Bill Atkinson, and Andy Hertzfeld left Apple to complete the project. Marc’s vision in 1990 was that handheld devices (or “Personal Intelligent Communicators” as he called them) would require a combination of computing and communications collaboration. Magic Cap had some really interesting elements in it, one of which could be of great value today with our approaching broadband capacity issues.

Information could be stored within the operating system and programmers could invoke it from another Magic Cap device. The first demo of this was to send just a few bytes to another device that activated a little guy who walked across the screen carrying a birthday cake and candle with “Happy Birthday” above it. This type of intelligent programming makes a lot of sense even today and could be used across iPhones/iPads, Android phones, and even BlackBerrys. We all need to focus on the fact that in the communications and computing chain, the weak link is still bandwidth and that won’t change anytime soon. Employing this type of shorthand could greatly reduce the amount of information that needs to be sent across a network.

iPad Precursor

And then there is all of the great work done by GO in the development of the PenPoint operating system, and EO in building the EO Personal Communicator based on PenPoint. Together they produced one of the first wirelessly-enabled tablet computers. AT&T bought the companies, merged them, and let them die a slow death. The merger was not based on wireless, it was based on AT&T being in the chipset business then and both the EO 440 and 880 using the AT&T Hobbit processor. This product was introduced prior to AT&T’s involvement in the Cellular Digital Packet Data (CDPD) end of wireless and it did have a standard cellular modem built in. AT&T killed both the product and the company in 1994.

How Will the iPad Do?

The answer seems obvious since Apple sold somewhere between 300,000 and 500,000 of the Wi-Fi-only version in less than a week. I suspect it will be a hit and that it will do some harm to both the netbook and smartbook markets. It might hurt Amazon’s Kindle sales as well. I have one of the original Kindles and I am looking to upgrade, I thought to the newest Kindle. Now that there is a Kindle app for the iPad, I am looking at this as an alternative, but it would have to be the full-blown iPad: 64 GB with both Wi-Fi and wide-area wireless. I cannot see myself having to hunt around for Wi-Fi and then sign up for service in zillions of locations and I certainly don’t want to pay Boingo $9.95 or even $7.05 per month to use the iPad. The Kindle has spoiled me as far as wireless subscriptions go since none are needed. I can download books almost anywhere, and while I do know the Kindle uses Sprint (EV-DO Rev A), I don’t even have to know that.

I think Apple should have made a deal with AT&T to “hide” the network if all I am doing is downloading books and applications that don’t need the network for anything else. It seems to me that Kindle got more than the device right, it also got the wireless portion right. Why can’t there be wide-area pricing for the iPad that is perceived as free? Simply include the network usage fee for the download in the cost of the books and applications.

Microsoft Joins “Community” Party

Or at least that is what I call a smartphone that is more than a phone and the entire user experience is assisted by a smart backend. The BlackBerry was the first to accomplish this community effect with its BES server and then tools for IT managers. These tools enabled an IT shop to download, configure, and erase BlackBerrys on a corporate-wide basis. Apple migrated some of these management functions to the consumer market, and an iPhone user can now pretty much set up the iPhone (or iPad) on the website and download the changes to the device.

Microsoft has partnered with Verizon and Sharp to launch two new devices, the KIN One and KIN Two. These phones are designed for those who like to live in a fishbowl and want everyone in their group of friends and/or associates to know what they are doing every minute of every day. I am sure some folks will really have to have this phone. The main screen connects you to Microsoft and third-party sites such as Facebook, MySpace, and Twitter, and displays them all on a single screen. The service (or is it the phone?) also enables you to access your information that is stored not only on your KIN but also in the cloud so you can organize, retrieve, and erase content. Microsoft says KIN phones will be the first Windows phones to provide what it calls the “Zune” experience, including music, video, FM radio, and podcast playback. Once you acquire a Zune pass, you will be able to link the KIN to your Zune account and have full access.

The New Phone Challenge

One of the problems with launching a new phone or services that require a new phone is that all of the network operators have been busy selling us two-year contracts that accommodate one phone upgrade during the contract period. Or, as I have been told by one network provider, I can upgrade today and my contract will be extended for two more years. Many teens and tweens who might want these new phones won’t be able to buy them anytime soon because of their existing contract or their family’s contract if they are part of a family plan.

This is not only true with the KIN, it applies to any phone. I know that a lot of people decided to buy an iPhone regardless of what it cost to get out of their old contract on AT&T or another network but that was because the iPhone was so radically different. In most cases, however, if networks want their new phones with new services to be a huge success, they will have to revise their thinking and learn to bend a little to facilitate uptake. Unless the KIN becomes a large community like the iPhone community, it will have a difficult time capturing enough of the market for the services to be “cool” enough to warrant moving to a new device. On the other hand, if there aren’t enough KINs in use out there, the service won’t catch on.

Each and every network operator is trying its best to find ways to attract and keep its customers. It appears that the evolving strategy is to find great new smartphones and add some sizzle to them. Android phones are hot products now, the iPhone continues to be hot, and of course the folks at RIM continue to up the ante with their new BlackBerrys. If, as rumored, Verizon ends up with its own iPhone and then iPad, it will be interesting to see how it handles the issue of people wanting these devices versus their existing contract obligations. And it will be interesting to see how many iPhone customers leave AT&T for Verizon if the rumors are true.

Network Upgrades

Meanwhile, AT&T is working hard on its network upgrades and making real progress. Part of the issues with the iPhone had to do with making it a better citizen on the AT&T network (and other networks in other parts of the world). It appears from the reports I have been getting that AT&T has made great strides in network capacity including in San Francisco and New York. Of course, we have to understand that it takes time to build out more cell sites. I have been working with the local AT&T system engineers on finding some new sites in my area and relocating others. As with any large wireless service provider, it has to find the sites, pass recommendations up the management chain, and get approval and a budget before it can even approach local planning commissions. If you add the time it takes to win corporate buy-in to the time it takes to process sites through planning commissions, it can take a year or two and sometimes longer for site approval and then build-out. Fixing capacity issues is not an overnight project.

This is one reason a number of operators are really excited about Femtocells. These are small access point devices placed in homes and offices to provide in-building coverage. Femtocells are becoming popular with the networks because they take customers off the main networks’ wide-area radio systems (cell sites) by offloading traffic to the in-building network. These in-building cells connect to the network’s back-end via your own DSL or cable broadband connection.

CTIA Recap

Our Wireless University held the day prior to CTIA shows, now in its 15th year, was filled to overflowing and became a standing-room-only event. We received a lot of positive comments about this year’s content, but we ran out of printed course materials due to the many people who showed up on Super Passes. We had to scramble to get a PDF of the slides up on a private area of our website so it could be downloaded since we never did find the 15 or so USB dongles that had been pre-loaded with the presentation. Even after returning from Las Vegas, the dongles remain among the missing.

We also held our 20^th Anniversary Wireless Dinner at CTIA Wireless 2010 and it was also well attended with more than 300 invited guests. The “entertainment” portion of the program was a roast of me, but it wasn’t really a roast since those taking part only said nice things about me. I appreciated each of the roaster’s remarks and judging by the many comments, a good time was had by all.

Newsletters

I have been writing newsletters and articles since 1980. A few years ago, we put together binders with copies of all of them including my Mobile Emergency Communications newsletters from 1980 through 1982, The Seybold Report on Professional Computing that was part of the family business until I took it over in 1985, and all of the newsletters I have written since for my own company as well as the three years of our joint newsletter with Forbes, and then back to our own again. When I say newsletters, I don’t mean 8-pagers (except for the Forbes newsletter). Most of our newsletters were between 28 and 36 pages and reviewing them is like taking a walk through personal computing and wireless history. I have wanted to find a way to get all of these publications posted online, but I never seemed to get around to this project.

A few months ago, RIM came to me and asked if it could have the newsletters scanned and turned into searchable PDF files. I was delighted with this proposal and I now have PDFs of all of the newsletters. Our plan is to post this library on our website and charge a small fee for each issue and to also sell a license for access to the entire library. It certainly makes my research easier now that I can search in digital form instead of having to read through printed copies. Needless to say, I have been doing a lot of searching. I will let you know when they are available online.

Final Thoughts

One indicator that the economy is improving is the growing number of companies that contact us about consulting, white papers, and speaking at upcoming events. When the economy goes south, we often lose customers that cut back first on consulting services and then by lowering head counts. If the first quarter of this year is any indication, we are well on our way to returning to better times.

The wireless industry is changing and growing rapidly with more participants than ever before. Companies that hadn’t even thought about wireless a few years ago are now in the thick of things having recognized that wireless expands their horizons with more and better tools and accessibility to their devices or content. These folks are becoming regulars at the wireless shows held throughout the year and more trade shows, conferences, and meetings are including sessions on wireless as it applies to specific industry segments. Wireless will continue to grow quickly and those who are looking toward us, as a community, to help them understand how wireless connectivity can add value to their products and services will find most of us ready and willing to help.

Andrew M. Seybold

On Tuesday, March 9, 2010, the FCC met with a number of public safety executives and members of the vendor community in Las Vegas. Not an open meeting, this was by invitation only and the group was kept small. Since all of these types of meetings must be on the record, the FCC published the slide presentation it gave as well as an Ex Parte that discusses the meeting in some detail. While I was not invited to the session, I have talked with a number of people who were there, read a number of reports, and reviewed the FCC’s slides.

It did not take the FCC long to get to the bottom line of its recommendations to be included in the March 17 broadband report to congress, nor did it take long for both the public safety and vendor communities to push back. Unfortunately, it appears that the recommendations are based on faulty assumptions topped with major political pressure from a variety of sources including the executive branch of the government.

One of the first slides of the FCC presentation recapped its recommendations:

The entire slide deck can be viewed in PDF format attached to this COMMENTARY. In this recap slide, we see that the FCC is recommending that the D Block be auctioned AND that it be auctioned without any of the previous public/private partnership requirements that were attached to the failed D Block auction. Instead, the FCC offered up the idea that in addition to the PSST 10-MHz block of spectrum, public safety would be able to roam across all of the commercial operators’ networks so load sharing could be employed. Apparently the FCC was unimpressed by the NYPD white paper and the filings of several major carriers that proved, to me at least, that 10 MHz of spectrum is not enough. The FCC’s reported response to this data was that it did not feel what had been submitted made a compelling case for more spectrum today, but if more spectrum is needed later, perhaps some 600-MHz spectrum could be allocated. (Spectrum spread out all over the bands is the primary reason first responders HAVE an interoperability problem to begin with!)

I find it interesting that while the FCC seems to be measuring public safety data usage by today’s use patterns (mostly on commercial networks with limited access), it is at the same time acknowledging commercial operators’ “great need” for broadband spectrum into the future and is committed to allocating another 500 MHz to broadband over the next ten years. The data I have reviewed from NYPD, AT&T, and Verizon show heavy and growing data usage today and, like the commercial side, the number of new applications is increasing. Further, if the D Block is to be auctioned with no requirement to share with public safety, my discussions with network equipment providers indicate that a guard band will be needed between the D and PSST blocks of spectrum. Since the FCC has not included any spectrum for a guard band, it will have to come either from the D Block, the PSST block, or both. This would mean that the PSST block would be capable of only 3.75 MHz of LTE and not the 5 MHz that should be available.

Further, many commercial operators I have talked with admit that the value of the D Block is questionable for the same reason: 5 MHz (5X5) is not enough spectrum for LTE in metro areas. The network operator would have to have existing 3G capabilities to be able to switch customers between 3G and LTE. If a new network operator were to purchase this spectrum, it would not serve its needs for very long. The fact is that 5X5 is not enough spectrum for either the public safety community or a commercial operator. However, 10X10 would work for the public safety community and it could use all of the spectrum without having to provide a guard band. It could also be used in rural areas on a shared basis to provide broadband to rural America, for the Power Grid, for education and healthcare, and for governmental agencies.

The FCC asked for data on data usage. Now that it has received lots of data, it is negating it because it is based on usage of one dedicated network (New York City’s) and on existing commercial 3G networks on a shared basis. And projections for future data growth, mission-critical voice, and other services are being discounted. This shortsighted view is exactly why the public safety community continues to receive less than what it needs to effectively do its job. If I were a skeptic, I would think the commissioners’ attitude is that most of them won’t be around when the FCC has to face the issue of public safely not having enough spectrum, yet again, or that this thinking is coming directly from the executive branch’s experts in the form of the four or five Googlets working with them. (Google CEO Eric Schmidt has said publically that we are not approaching a spectrum shortage because “there’s enormous spectrum becoming available through licensing programs, better radio design, faster computers, and so forth.” This is a common view from those who do not understand radio and the spectrum, and don’t take into account the backhaul from zillions of radio sites.)

Back to the Meeting

The FCC also put forth some figures. The first was that the public safety grade system to cover 95% of the population would require 41,000 cell sites. This is probably a good number, but it claims that because many of these sites are already established either as commercial or existing public safety sites, the total capex for this construction would be just over $6 billion. I don’t have a clue where it came up with that number but I dispute it. First, even if that covers the cost of site improvements and radio systems, it does not include the backhaul (fiber or microwave) that would be needed at non-commercial sites or many of the other requirements of what are considered to be public safety hardened sites. The FCC also claims that this work can be completed by 2015, which is a departure from its usual “it will take 10 years” and this would probably be a realistic timeframe if the public/private partnerships were in place today and work had begun today. However, it appears that none of this will be formally resolved this year so it will drag into 2011 (ten years after 9/11). By then, the two major network operators will have already completed a great number of their urban sites so co-locating on them will cost more money for retrofits (commercial operators cannot be expected to harden their sites based on some future FCC requirement).

The FCC is making a serious mistake in recommending in its broadband report that the D Block be auctioned, and further, auctioned with no requirements for public safety sharing of any kind. I think there are capacity issues for both the public safety community and the D Block winner and there are guard band issues that will take spectrum from one or both. If this happens, it will take only a few years to prove that the FCC usage models were wrong, but by then the public safety community will have received the short end of the stick yet again. For any in the government who point to the D Block auction as paying down the national debt, think about this: If the D Block sells for $3.75 billion, and I think that’s high, it will pay off exactly ONE DAY of our national debt!

Sharing Networks

The FCC states that it will make sure all of the commercial operators are required to share their spectrum on a nationwide roaming basis with the public safety community. There is flawed logic in this as well. First, there is the issue with building devices that can cover the entire 700-MHz spectrum. It appears from work we have done in this area that in order to cover the A, B, C, D, and PSST blocks of spectrum, each device will require multiple diplexers, filters, and other components that will drive up device costs. But it does make sense to have this capability built into radios. It also makes sense to have 3G capabilities built in for the next five or so years so that during network construction, public safety customers could roam on both 3G and 4G as needed since it will take a number of years to build these networks, even with the help of the commercial operators.

The biggest problem I have with commercial network sharing is that if the PSST block is not enough spectrum, sharing will occur on a daily or weekly basis for what can be considered normal incidents. Fires, bank robberies, airplanes down, and all sorts of local emergencies will tax the PSST band to the point where some of the units will have to be moved over to commercial services. However, at the same time PSST systems require the use of peak resources, commercial operators will be busy with peak demand levels from the public and the news media. The issue here is what level of priority public safety customers will really have. In one type of priority, they have to wait until there is capacity in their cell sector, meaning someone else has to drop off. But when there is an incident, commercial customers grab onto a wireless connection and don’t let go for fear of not getting it back. The ONLY way to provide true priority for public safety is to require what is known as “pre-emptive” priority, which means that when public safety needs spectrum, commercial users’ sessions can be terminated to make room for public safety. None of the network operators like this idea because their customers would take issue with this policy.

In short, there are both technical and operational problems with the FCC’s vision of network sharing and the public safety community. While it is logical to shift some of the load away from the public safety network (administrative and other non-mission-critical communications) it is not logical to assume that public safety will have sufficient access to commercial networks during times of major incidents—even local incidents. This is one more reason that this FCC recommendation to congress regarding the PSST and D Block is not the correct recommendation.

My analysis of the FCC’s comments at this meeting is that it is recommending that public safety providers receive federal funding to build out their nationwide system ONLY if the public safety community agrees that the D Block should be put out to auction. The FCC will not support public safety in it efforts to convince congress to hand over the D Block and it will not support funding unless the D Block is auctioned.

If I had been given the task of writing the recommendation for congress for the public safety portion of the broadband plan, it would have gone something like this:

When the D Block was first put up for auction, it was envisioned that there would be a true partnership between the public safety community and the winner of the D Block. However, no bid was received from a commercial operator due to many factors including the restrictions placed on the spectrum to ensure public safety access. If there had been a successful bid, both the commercial and public safety community would have had access to a full 20 MHz of spectrum (10X10 MHz) during normal conditions and public safety would have had access to more than its own 10 MHz of spectrum during major incidents through priority access to the D Block.

At that time, wireless data usage was still in its infancy and data requirements were modest for both public safety and commercial operators. Since then, the demand for data has more than doubled each year and on the commercial side it is now 5000% higher. Based on the data provided by the public safety community and the commercial network operators, *the commission* now believes 10 MHz of spectrum will not be sufficient for the public safety community.

Based on the information* the commission* has analyzed, the data usage models provided to us, and the fact that over time this spectrum will also be used for mission-critical voice as well as data services, *the FCC* now recommends the following:

1. Congress no longer require that the D Block be auctioned.
2. Congress direct the commission to license the D Block on a nationwide basis to the holder of the existing Public Safety 10-MHz license.
3. Congress appropriate $12-$16 billion for construction of the new public safety broadband network.
4. Congress provide tax incentives to commercial network operators that are already licensed in the 700-MHz band to enter into private/public partnerships with regional public safety entities.

If congress acts favorably on these recommendations, *the FCC* will quickly make the following changes to expedite the construction of this nationwide interoperable network:

1. Permit the nationwide license holder to grant region-by-region approval for network construction by cities and counties.
2. Promote by incentives the close cooperation between commercial networks and the public safety community to work together in network deployments.

*The commission* respectively requests that the above recommended actions for congress be given priority and the legislation needed to make these changes be completed during the current session of congress. Two of the major commercial network operators are in the process of building out their own 700-MHz broadband networks and it is imperative that the public safety community be able to work with these network operators to form private/public partnerships on a regional basis in a timely fashion.  
*my words, not those of the FCC*

Of course my wording is not flowery enough for a document from the FCC to congress, but it does get the point across. One closing thought I cannot let go of is that the recommendations the FCC is making to congress in its broadband report are not based on data and information as the FCC chairman has said he would require going forward. Rather, politics have once again stood in the way of reason. I am not sure if this pressure on the commission came from the executive branch or others within the Internet community who are not conversant in the issues of bandwidth sharing and finite spectrum resources.

The public safety community has always had an interoperability problem, caused largely by being given too little spectrum in each band segment as it became available. The FCC and congress has an opportunity to change that this time around—but indications are that neither will act and once again the next FCC and congress will face the problems created by the current FCC. There is no doubt that these recommendations are both shortsighted and the wrong thing to do. Many within the FCC know and acknowledge this, but their hands are tied since some commissioners, including the chairman, have made their wishes known.

I wrote my first newsletter article about the interoperability issues facing the public safety community in 1981, and I have written about this problem almost every year since. What I would really like is to be able to write about how much progress we have made in building out the public safety broadband network, the new interoperability capabilities it brings to public safety, and some of the innovative ways it is being used to speed response times, solve crimes, and provide our first responder community with the same tools an 16-year old has today with an iPhone!

Andrew M. Seybold

FCC PSHSB-Las Vegas 030910