Have you noticed that almost every new proposal for spectrum use presented by almost anyone includes the term "first responder" in the makeup of the customer base? This is very strange to me. We are trying to move toward a first responder world of better interoperability, not less, yet here we are. It started with Muni-Wi-Fi systems being "good" for all of a typical city's needs including police and fire (never mind that Muni-Wi-Fi systems are failing and that they are not true mobility networks). Next came Sprint and Xohm with their WiMAX play, and now Clearwire, stating that the WiMAX network at 2.5 GHZ will also support first responders. Then we have Google et al pushing for unlicensed white space spectrum usage and talking about how it can also serve the first responder community. Now comes the proposal from M2Z, and the FCC, for using AWS Phase III spectrum at 2.1 GHz, which would also make an ideal system for first responder communities.

I have to wonder why we need ALL of these networks to take care of the three million first responders and the three million "second responders," as I call them, for support functions for first responders. I also have to wonder why, since the FCC appears to be committed to a nationwide 700-MHz private/public network for first responders, all of the companies promoting these networks and technologies seem to think that by using the words "first responders" they will win points with the FCC and/or the public safety community, or that it even makes a difference.

Even the 700-MHz nationwide network will not solve the most significant interoperability problem, which is voice. All the networks mentioned above are primarily for data and, oh, by the way, they probably plan to offer VoIP. Providing MORE network choices for the first responder community, all with about the same capabilities, does not make any sense to me. While I agree that if I were in charge we would be looking at a nationwide network in the 450-MHz band, clearing that band would take forever, and there are many first responder systems already on that spectrum. Ideally, we should clear TV channels 2-6 or 14-17 and build out a combination voice-and-data network on that spectrum since these frequencies are far better for covering large areas. But that won't happen, so let's work with what we have (almost), which is the 700-MHz D block and associated public safety spectrum allocations.

Data, video and even VoIP on a common network will help some of the incident command and information issues but, as I have said many times, it certainly will not help with voice dispatch and on-scene voice communications. Many departments already have data interoperability and several types of data systems are being used in the first responder community. Some are on frequencies licensed by the city or local government, but most of these provide slow-speed data (19.2 Kbps) and the equipment is so old it is no longer being built. But there are some newer systems that will work on existing first responder channels including the Tyco M/A-Com Open Sky system, also with data rates of 19.2 Kbps.

In the mid-1990s, many public safety departments decided to use commercial networks to handle their data requirements. You might recall CDPD or Cellular Digital Packet Data that ran on analog cellular systems, or RAM Mobile Data (now Velocita) and ARDIS. All of these systems offered data rates of between 8 and 19.2 Kbps and all were used to offload some of the voice traffic associated with first responder dispatch, incident control and reporting functions by adding data capabilities.. The primary reason many departments chose to use commercial data services is that they did not have enough radio channels for their voice services, and mixing voice and data (pre-IP days) on the same network was not very effective. Data was used for running license plate numbers, checking on subjects and driver's licenses and routine tasks handled by a dispatcher sitting in front of a computer. Even today, when things get busy, some departments dedicate one dispatch channel and one dispatcher to run all of the licenses and wants and warrants requests (data), freeing up other dispatchers to handle voice.

Today, CDPD, RAM and ARDIS have given way to EV-DO Rev A and UMTS HSPA, and many more first responder agencies are using commercial wireless broadband services. While they may be sending and receiving more information, most of the data traffic is information that is important to field personnel, but it is in addition to voice, their primary form of communications.

Because we are living in a nearly all-IP world today, it is possible to provide data interoperability between units or mobiles that might be on different networks using email (which can take a while), Instant Messaging, direct IP bridges between agencies and other methods. There are several things to keep in mind here: There is no need for a policeman in Dallas to talk to a fireman in Boston; there might be a need for a fire incident commander to share information with law enforcement on the scene; or, in a police incident, for the commander to share location information with the swat team. Today, data services are vehicle-mounted and not available on handhelds used by most first responder personnel, which means data can be shared between agencies only by those who are in or near their vehicles.

This, too, is evolving. Just as we went from cellular car phones to handheld wireless phones, first responders have gone from vehicle-mounted two-way radios to handheld radios for officers, to handheld radios for virtually all field forces. One difference though, is that they have NOT abandoned their vehicle two-way radios because they have handhelds (except in a few cities such as Cincinnati).

First Responders have had voice communications on their belts for a long time and data in their vehicles since the late 1970s in some cases. We are now moving toward an era where they will have both voice and data capabilities on their belts, but unless they have heads-up displays built into their helmets, they won't be looking at a data screen in the middle of an incident. Think about a swat team with a group of bank robbers trapped inside a bank with hostages. Do you think the snipers and others whose job is to look for shots of opportunity will take their eyes off their targets? No, but they will hear voice commands and they will be able to respond via voice without being distracted by looking at a screen.

Likewise, firemen inside a burning building wearing breathing equipment are able to talk on the radio but, again, unless they have a heads-up display, you can bet they won't be looking at a screen. I assume that at some point heads-up displays and the like will become commonplace and all first responders will have access to this technology. But today, they can't even afford to upgrade their ten to fifteen or twenty year old radios.

Part of the reason to share a public/private network is to reduce the cost of radios for first responders. Going from $3,000 for each radio to less than $500 with additional features and functions would make a huge difference, but that will take volume commitments, which means the technologies will have to be used by both first responders and the public. If each network that claims it is ideal for first responders has a few on its network instead of on a common public/private network, such prices will remain elusive.

The comments I filed last week with the FCC are based on sharing the cost of a common network among all of the existing network operators, including those in rural America, and providing rural America with wireless broadband to homes and offices. This could easily be done using the 700-MHz spectrum and 3G and then 4G technology. In rural cities and towns, the 700-MHz network could serve as the backbone with femto cells or other technologies deployed where there might be a density issue. The point is that I believe we will better serve both our first responders and rural America by working together to build a common network-not four or five different networks, none of which can survive the competition in metro areas, let alone in more rural areas of our country.

It appears as though the FCC is bound and determined to make sure we have so many networks that none but the largest will survive. That is what market forces are all about. I have to wonder what would have happened if NextWave had been able to build out its nationwide 1900-MHz network that was to be a resale network. You might recall that MCI had agreed to pre-pay for a lot of minutes of service and other others were willing to do the same. It never got off the ground, so we will never know. What I am suggesting is that we use the D block and the first responder spectrum to build this type of network for all of America-not to take business away from the incumbents, but to use the existing wireless broadband networks to bring more of the first responder community up and running more quickly and then switch them over to the new network as it is deployed.

I question whether the FCC really wants to make this public/private venture work or if it understands it is undermining the success of such a venture by moving ahead with its "95% free coverage" AWS Phase III plan, the White Space initiative and even more unlicensed spectrum, making it tough for anyone to make money, even if subsidized with advertising revenue. It is one thing to let the free market decide what do to and how to do it, and another to jumpstart the free market and then throw in other chunks of spectrum to undermine the free market. I guess since it is unlikely any of the existing FCC Commissioners will be in office as all of this shakes out, they don't really care one way or the other and are bending in the wind. Unfortunately, the wind is being created by those who, I think, don't understand the true costs or competition facing them.

One organization that has cried foul to the AWS III "free" broadband for 95% of the United States is the Rural Telecommunications Group, Inc. (RTG), which is made up of 36 rural wireless operators that built a network to provide wireless coverage to rural America when no one else would. These people are already being squeezed by larger network operators and the Wi-Fi and WiMAX hype, and they certainly don't want to see this new "free" network built (I am doubtful it ever will be). My comments on the 700-MHz D block include this group and the other rural operators that own licenses but have not yet built out their areas. They are struggling to make ends meet, yet they believe in serving the people in their areas. I, for one, don't believe they should be pushed aside because some politicians think they can get someone to build a $40-plus billion network and give service away for free.

This Commentary started out asking why everyone is mentioning first responders when they want to get more spectrum. If first responders have become merely a sales tool for others to get what they want, which is access to more spectrum, and none of these efforts end up helping the first responder community, we will have all lost a great deal, and will have missed our opportunity to provide the tools so desperately needed by the first responder community to help protect our lives and property.

Andrew M. Seybold