FCC Spectrum Plan Based on Faulty Logic

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.

Editor’s Note: Just as we were preparing this for publication, Representataive Peter King (R-NY) and others introduced the “Broadband for First Responders Act” (HR 5081) which has now been sent into committee. The bill, if passed, will require the FCC to turn over the D Block to public safety. However, simply because there is now a bill in congress does not mean we should let up the pressure. The bill makes no mention of funding to build out the network, but it is a very good start!

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.

Organization	30 MHz	150 MHz	450 MHz	700 MHz	800 MHz	1.9 GHZ	2.1 GHz	2.5 GHz	Total	Broadband
AT&T	0	0	0	20	25	34	12	0	91	100%
Verizon	0	0	0	32	25	21	13	0	91	100%
T-Mobile	0	0	0	0	0	27	27	0	54	100%
Sprint/Nextel	0	0	0	0	17	36	0	0	53	100%
Clearwire	0	0	0	0	0	0	0	150	150	100%
Public Safety	6.3	3.6	3.7	24	9.5	0	0	0	47.1	21%

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