Before I get into my tirade about the FCC and its meeting this week, I want to let you know that you now have the ability to comment directly on this Website on both my new blog, “TELL IT LIKE IT IS™,” and my Commentary. You will first need to register for member access with a user name and password and other information (it’s free), and please be assured that we do not sell or distribute this members list and you will only receive information you signed up to receive. If you are already a Commentary or InifiniG (formerly 3G Today) subscriber, you will still need to register (not just log in) and choose a new password so the system will recognize you. I hope you enjoy this new addition to our Website and I look forward to receiving your comments.

On to the FCC and 700 MHz

As predicted, the FCC fumbled around in its meeting, dropping the 700-MHz ball a number of times, delaying the meeting for hours and, finally, late at night voted to provide a mix of small, medium and large wireless licensees and to enforce strict geographic-based build-out requirements. It also agreed to put out a request for comments for the Frontline LLC proposal, but two of the commissioners were not that thrilled either with the results of the meeting or the Frontline proposal. Commissioner Michael Copps said, “I will need strong assurances—much stronger than any we have been provided thus far—that the plan will actually work before I can support it, and by work for public safety, I‘m talking about an interoperable network—built and configured to public safety standards—that police officers, firefighters and EMS technicians and other first responders all across the nation can actually afford to use.”

Well Michael, I don’t think anyone at Frontline can give you the assurances you need. What I think we need is first responders on spectrum (the 24 MHz already allocated plus more?) with the ability to make use of commercial spectrum for administrative and other non-emergency traffic. Frontline seems to believe someone will actually build out a public safety-capable network that is shared by resellers because it is a shared network and because it is “open.” How many of the commercial customers will really pay for service that could be denied to them at any time because of a first responder emergency? Priority can happen in only two ways on these networks. The first way is that when an emergency is designated, all existing traffic is shut down and the first responders gain full access to the network. The second way is to let existing calls (data sessions) continue until completed and then once dropped, make the spectrum available to the first responder community. How many customers are going to sign up for services based on the first criteria and how many first responder organizations are going to be happy with the second criteria?

Mixing public safety and commercial traffic is not a great idea—you never know when there is going to be an emergency. I remember when I was in LA working for Motorola and the LA County Sheriff had applied for additional frequencies so the FCC decided to do a survey of existing channels. The FCC sent out a number of monitoring vans and put them on hilltops. They listened to the traffic on the existing channels for three days and concluded that the Sheriff’s department was not fully using its existing spectrum, therefore, it did not need additional channels. The FCC listened during weekdays, not over the weekends, and from 9-5 during the day, not at night, and missed the fact that during peak times the existing channels were so congested that there were delays in dispatching, even to emergencies, in the order of 10 minutes or more.

Had it done its homework, the FCC would have understood the fact that channel loading is related to time of day, section of a city, if there is a full moon (seriously) and a number of other factors. But it did not. The Secret Service has a bunch of nationwide channels it uses, yet when the President is not in the area these channels go unused. Should the channels be given up to commercial uses until he decides to visit New York or Chicago? I don’t think the Secret Service would agree to that arrangement. The point is, commercial traffic peaks at the same time as emergency traffic, and that will create a problem no matter whether the spectrum is controlled by AT&T or a special agency that provides sharing capabilities with first responders and public safety. When there is an emergency, all first responder channels need to be available. During the bad fires in California a few years ago, the fire service actually ran out of channels to use. How do you balance between first responder and commercial needs? How do you tell a person who is trying to contact his/her family that he/she will have to wait for hours because all of the channels are being used by first responders?

During the Loma Prieta earthquake in 1999, I was a volunteer communications operator for the California Department of Forestry and on the amateur radio channels we handled the traffic that overloaded the first responder networks, and we did it well. The phone system was not working anywhere in Santa Cruz County and the cell sites were jammed with traffic. If the first responders were sharing spectrum with commercial interests, no one would have been able to communicate. Is this where we are heading? I certainly hope not!