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However, it appears as though there are some who want to continue to stir up the D Block issue, using what I consider to be false and misleading statements.

Too Many Cooks Stirring the D-Block Pot

Monday, April 13, 2009

For years, the public safety community has been short-shifted when it comes to spectrum. The idea of making use of 24 MHz of 700-MHz spectrum for both channelized and broadband services makes sense and this is the last chance we have as a nation to help the first responder community solve its interoperability issues, and to drive the cost of its equipment down to more reasonable levels. The idea of auctioning the D Block and the winner building out both the D Block and the first responder's 10 MHz of spectrum is a failed idea. It is time to find a better way to enable the first responder community to build out this spectrum and I believe there is momentum toward a solution that could be quickly and fairly inexpensively implemented. Unfortunately, there are others who have taken pen to paper who appear to want to disrupt this process and I have to wonder about their motives.


At the IWCE show in mid-March, Verizon Wireless and then AT&T called for the 700-MHz D Block to be given to the first responder community instead of being put back on the auction block. Many within the public safety community have been advocating this action for a very long time now, and it seems like a logical move to me.


However, it appears as though there are some who want to continue to stir up the D Block issue, using what I consider to be false and misleading statements. The arguments against handing the D Block over to the first responder community and my response to them are as follows:

According to several recent articles, the smaller (tier 2 and tier 3) wireless network operators in the United States believe that if the D Block is assigned to the public safety community they would be locked out of access to this spectrum. 
Many of these smaller network providers, and new entrants, ended up with some of this spectrum after the auction. MetroPCS, Cox Wireless, Inc., Century Telecom, Cellular South, Vulcan Spectrum, Union Telephone Company, Manti Telecom, Bluevalley Communications, EchoStar and a number of other companies stepped up at the last 700-MHz auction and came away with spectrum.
Further, the 700-MHz spectrum will not be the last spectrum to be auctioned. More will become available including the ASW-2/3 Block, so this is not the last chance for commercial operators or new entrants to win spectrum at an auction. However, it is the ONLY opportunity to assign contiguous spectrum that can be used for the first responder community's channelized communications systems, providing for services that commercial network operators cannot supply today.
The A and B Blocks are 12 MHz of spectrum (6X6) while the D Block is 10 MHz (5X5), which is not enough for a new nationwide network or even for use on a regional basis in the top 100 markets.
Congress would like to see another nationwide network to provide another level of competition to the incumbents.With the exception of Sprint, all of the other nationwide networks started out as regional networks and over time acquired other regional networks to build out nationwide service. If there is indeed market demand for more nationwide operators, this same type of merger and acquisition strategy could be used again to put together a new nationwide network. I do not believe any new player could enter today's market with only 10 MHz of spectrum and be able to afford to build out a nationwide network.
Some believe that if the D Block is not auctioned, the feds will lose a significant amount of new revenue for the general fund.
The reality is that the 700-MHz auction brought in almost 75% more money ($20 billion) than had been projected. Selling off this 10 MHz of spectrum might bring in another few billion, but if there are first responder build-out restrictions, the likelihood of network operators, big or small, wanting to spend their money for spectrum with strings attached is slim to none.
An article published recently in Communications Daily states that, "The plan is raising concern among public safety groups [unnamed] and outright opposition by small carriers [again unnamed] who see the proposal as a way for the two heavyweights to guarantee that the 10 MHz of spectrum doesn't fall into each other's or competitors hands."
As mentioned, a number of A and B Block licenses in the 700-MHz spectrum did not go to the two largest network operators, and most of the top markets will have at least one new competitor over the course of the next few years based on the AWS-1 or 700-MHz spectrum, or a combination of both.
Please tell me who within the public safety community is opposed to gaining access to the D Block of spectrum? It is easy to write an article and offer up thoughts that there is opposition, but it would carry more merit and weight if the sources were identified and even quoted. The author of this article failed to do either when talking about first responders and small network operators who, he says, oppose turning this spectrum over to first responders
Whenever I read an article like this, I have to wonder who has been talking to the author and what their agenda might be. Part of the issue with the D Block and first responder spectrum is that almost everyone involved has one or more hidden agendas, and thus far the first responder community has been the loser as the battle over this spectrum continues to evolve. Yes, AT&T and Verizon probably have their own agendas as do those in public safety who represent major U.S. cities. But something that doesn't seem to be being reported or doesn't seem to sink in is that while AT&T and Verizon are advocating that the D Block be turned over to first responders, they are also offering up their own back-end systems for the first responder network.
The most costly part of any nationwide network in the first ten years is running the backhaul and the back-end management and billing systems. What both AT&T and Verizon have said is that they will "rent" part of their mission-critical back-end systems to the first responder community as a private back-end network that will not be compromised by commercial customers. This means that the first responder community can move forward and purchase the radio equipment for the cell sites and have it installed, knowing that backhaul costs will be operational expenses as opposed to both capital and operational expenses. This makes a lot of sense to me, and while it does provide income for AT&T and Verizon, there is no reason Sprint, T-Mobile, Leap, MetroPCS, and others cannot also bid for these back-end service contracts.
All of the above-mentioned network operators have announced that their next-generation technology will be LTE, and you might remember that in addition to nationwide spectrum that can be used for first responder services, first responders want to use this new spectrum to move to wireless technologies being used in mainstream wireless services, which will lower their cost of devices from $2,000-$5,000 to $200-$700, which is a huge savings-of our tax dollars, by the way.
Turning the D Block over to the first responder community would require an act of congress and cannot be done by the FCC.
I am not an attorney, so I assume there is some truth to this statement. However, I also know that if the first responder community wants the D Block to add to its own 5X5 MHz spectrum, it must present a unified front and go to congress with the request. Only after such a request should any of the public network operators convey their support. It is very important, at least from my vantage point, that the first responder community take its request to whomever needs to approve it and no one else. Once the idea has been suggested or "floated," it will then be time for those who support it to come forward and help get it passed. I don't for a moment believe that congress or the FCC will have a problem "giving up" the revenue from the D Block since we have been on this "let's fix the first responder interoperability" kick for at least seven years if not longer with nothing happening on the federal level and a lot happening on the local and regional level because the first responder community is tired of waiting to see what type of roadblock will be thrown up this time around.


Let's Be Real Here


10 MHz of spectrum is not enough for a new nationwide or even regional network. In urban areas (85% of the U.S. population), even the first responders' 5X5 MHz isn't enough. This is one of the reasons the FCC's original proposal was to combine the two into a 10X10 MHz band giving first responders priority access not only on its 5X5 MHz, but on the D Block as well.


Regardless of which technology is chosen, LTE or WiMAX, 5X5 MHz is not enough spectrum for either one to be as spectrally efficient as they could be in 10X10 MHz. 5X5 MHz could be used in some of the less densely populated areas of the United States, but all 20 MHz will be needed in many of the urban areas if the first responder community is to have access to the types of data, video, and future PTT and voice services it is planning for this spectrum. Without access to the D Block, the first responder community will have only 10 MHz of spectrum, which is not enough for its needs.


If the FCC puts the D Block out to bid again, even as regional spectrum, the regions will be considerably larger than the A and B Block regions were, meaning small network operators will be at a bigger disadvantage than during the A and B Block auctions. With the additional encumbrance of requiring auction winners to build out this spectrum as well as the 10 MHz of public safety spectrum, there will be no bidders from smaller existing wireless companies and no interest from the big four or five. The only bidder might be the WiMAX community, trying to get a foothold at 700 MHz. In my opinion, that would be the worst possible scenario for the first responder community. The idea of the public-private auction failed once and there is no reason to believe it would be successful a second time around.


But there is a way to make this work for first responders and others that could use the spectrum, especially in rural and remote areas. Below you will find my ideas for how to get the first responders their network in a timely and cost-effective way and, at the same time, use this spectrum to help solve several other problems: broadband to rural America, broadband for the education system both in and out of schools, broadband for remote healthcare diagnosis, treatment, and monitoring, and many other services that are scarce or non-existent outside of urban and suburban areas. The issues for rural America are very different from those for urban areas where there are six to eight choices for broadband services, and the primary issue has always been a return on investment that will incent companies to build networks where the direct population is not large enough to support it. Even the so-called Broadband Stimulus package of $7.2 billion, won't solve these problems. However, if we put together a system of services that make use of broadband, rather than concentrating on broadband as a solution, we can make this all work.


So here is how I think we can accomplish this. It won't be easy as there will be a lot of politics to deal with and some feathers will probably be ruffled, but if this project is managed, instead of left to happen, it can be done. And it can be done within a short period of time. What would I do? I'm glad you asked.

  • I would give the D Block to first responders. It would be used for local and regional systems and the existing 10 MHz of spectrum would be held by a central license holder and assigned to local agencies, or the PSST, for example, would retain the right to oversee the networks to ensure a common wireless technology and that the broadband spectrum is not carved up for more channelized services, which would defeat the entire concept.
  • Commercial network providers would offer up their backhaul and back-end services that are already in place and/or are being developed. Each region or area would accept bids for these and perhaps other services from the commercial network providers-not only AT&T and Verizon, but other network operators as well. This would provide an opportunity for additional income for some of the smaller operators as well as tier 1 networks.
  • The regional public safety agencies would contract for back-end services, radio sites if needed, and radio equipment and maintenance, or they could elect to purchase their own base radios (RSNs), install them, and maintain them.
  • All networks would be required to employ the same wireless technology, and the back-end of each system would be all IP. The interface between systems would be managed, and interconnection would be permitted using existing commercial broadband services as the system is being built out and, in the future, to handle routine, non-emergency traffic.
  • In non-urban areas, licenses would also include consumer access for broadband services, services for schools and students, for medical use, and other uses that will help pay the ongoing costs of the networks. These rural networks could be managed and run by local cell companies, by a not-for-profit organization such as the NRTC, educational institutions, and others. First responders and those associated with providing services to the first responder community would be given first priority on the network. The original deployment could be either 5X5 MHz or 10X10 MHz depending on the number of partners and funding sources. This will require a new mindset in DC and elsewhere that broadband is an enabler, not an end in and of itself. Deployment and long-term operation of these networks would be paid for with federal money, including but not limited to Broadband Stimulus funds, and again, the networks would make use of commercial backhaul and back-end services where available. Using this model, there will need to be safeguards in place to ensure that the spectrum is not simply leased to existing commercial operators but is shared by the services mentioned above, perhaps on an assigned basis, with the key public safety organization overseeing the build-out and use of the spectrum.
  • Ideally, some of the funding would be in the form of tax credits, existing rural telco and power company grants, and educational fund assistance.
  • Wherever possible, rural companies such a power companies, rural telcos, railroads, and others would provide right-of-ways and access to existing towers, high-tension towers, and other assets. These companies would also purchase services to replace their aging command and control systems and could, in the future, become part of the Smart Grid that is being discussed at great length.

The net of all this is that in urban areas, this 20 MHz of spectrum will be treated as a broadband network for first responders (a broader definition of first responders is needed), and in rural areas, it will become part of a number of overall service-based solutions. There is no reason to limit access in rural areas strictly to first responders, and the more services that are included, the better the long-term return on investment.




The article in Communications Daily got me started on this Commentary, and the more I got into it, the more I realized that everyone who has anything to say about first responder networks has an agenda-some obvious and some not. But if the first responder community is to benefit from this once in a lifetime opportunity to get a handle on their emergency communications on a local, regional, and nationwide basis, the D Block and its 10 MHz of spectrum is the last available solution. It would be a shame to continue the bickering and better to change the mindsets of those working on this problem. Wouldn't it be great to put everyone's own agendas on hold? We only have one chance to get right and do something that gives back to our communities, states, and nation; something that might, someday, just save our lives.


As I have said, this is the one and only shot that the first responder community has to put together a nationwide system or a series of regional systems tied together to solve some of the problems of interoperability. It is the right thing for us to do. The spectrum is available and the technology is upon us. Sharing the build-out costs, making use of existing backhaul and back-end services, combining public safety with other needs in rural America, solving some of the first responders problems, and providing services and opportunities for those who live where it is not today financially feasible to do so is a rare opportunity we cannot afford to squander.


If we fail the first responder community now, when the next major flood, fire, hurricane, tornado, or man-made disaster hits, the first responder community will figure out how to communicate as they have always managed to do. But it would be far easier and faster if they had the right tools available to them and I believe that now is the time to work together toward this goal. And this should not be a ten-year process. A lot can be accomplished in a very short period of time given the assets that are already deployed. Instead of building a new network, we should be extending wireless. It makes sense and it is economically feasible. All we need now is for those who can make it happen to get onboard.


Andrew M. Seybold


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