FCC mandates (very) minimum interoperability level for initial broadband public safety network deployments

While stakeholders continue to debate the best approach to building a nationwide mobile broadband public safety network, the FCC’s Emergency Response Interoperability Center (ERIC) recently issued what it called “requirements for a baseline technical framework” for that network. The framework applies only to 700 MHz public safety mobile broadband networks in individual states, cities and counties that are approved for early deployment. But it provides a glimpse into how ERIC and the FCC are thinking about the network.

Tellingly, the new guidelines sidestepped two issues that are at the heart of the ongoing debate about a nationwide broadband public safety network.

The first issue is whether the public safety community will be given the 700 MHz D-block in addition to the 700 MHz spectrum already under its control. The public safety entities that are approved for early deployment are planning to use only their current 700 MHz safety holdings for those deployments. But the Public Safety Spectrum Trust, the license-holder for public safety’s current 700 MHz spectrum, has argued that it needs additional spectrum to support its requirements.

The second issue is which, if any, additional 700 MHz bands public safety will inter-operate with. Despite the National Broadband Plan’s recommendation that public safety network users should be able to roam onto commercial 700 MHz networks, the only thing the guidelines say is that entities making early deployments must support roaming with one another.

Will funding cover rural America?

Perhaps the biggest issue of all about an interoperable nationwide public safety network is how it would be paid for. The National Broadband Plan recommends that Congress raise $6.5 billion over 10 years for that purpose but some have argued that the actual cost would be higher and that Congress may be reluctant to allocate the necessary tax dollars. Those who recommend auctioning the D-block argue that the money raised in that auction would be the most viable way to fund nationwide public safety network construction.

Considering the costs involved, Rural Cellular Association President and CEO Steve Berry told me this week that he is skeptical about whether there will be sufficient funding to build out the public safety network throughout rural America. To increase the likelihood that the network will be constructed, the RCA advocates raising funding by auctioning the D-block. “If public safety gets the D-block, they will be house poor,” Berry said. “They won’t be able to build and sustain the network.”

The RCA’s most critical concern, however, seems to be about roaming requirements. In rural areas, Berry said, “our idea is let’s use LTE and leverage the build-out” that wireless companies already are undertaking. LTE supports various forms of traffic prioritization that could enable public safety traffic to have priority on commercial networks, he noted.

Berry questioned the definition of interoperability used in the new ERIC requirements. “Many [people] would think public safety should be able to talk to other public safety users and anyone else outside the public safety arena, but that’s not the definition they use,” he said.

The device dilemma

But if rural public safety users rely on commercial wireless networks, devices would have to be created that could work on those networks as well as in the public safety spectrum bands in order to achieve the goal of nationwide interoperability. And carriers such as Verizon and AT&T, which own the lion’s share of commercial 700 MHz spectrum today, argue that it would be impractical to build devices operating at more than a few spectrum bands. They also argue that their 700 MHz devices must be backward compatible with 3G networks and should support international roaming.

Neither AT&T nor Verizon has chosen devices that support the public safety band for initial 700 MHz rollouts, Berry said. That effectively puts the burden of developing devices capable of operating in the public safety band on the public safety community, he said. And considering that the public safety community includes fewer than five million users nationwide, the per-device cost for devices capable of operating in the public safety band could be in the range of $5,000 to $6,000 apiece, Berry said.

“What do you do in a rural area when many public safety users are volunteers?” he asked. “How are you going to make sure they have communications? Are you going to buy everyone a unique phone for $5,000 or $6,000?”

Berry argued that it is possible for commercial 700 MHz devices to support the public safety band and downplayed AT&T and Verizon’s arguments to the contrary. “If you don’t want to do it, you can find excuses not to do it,” he said. “If you want to do it, you can find a way.”

Berry hinted that AT&T and Verizon’s attitude illustrates the need for an auction of the D-block. “If you auction the D-block and have the funds go to public safety, you would bring more competitors into the marketplace demanding devices that operate on 700 MHz,” he said.

Dueling white papers

The two opposing camps on the public safety network have created two opposing organizations to promote their views.

The Public Safety Alliance--which has the backing of more than 20 public safety associations as well as AT&T, Verizon and some telecom equipment manufacturers--wants the D-block given to public safety. Arming that camp with technical data detailing why public safety needs the D-block is wireless consultant Andrew Seybold, who has penned several white papers supporting that view. Spearheading the opposition is Connect Public Safety Now, whose supporters includes The Fraternal Order of Police and The International Association of Fire Fighters, as well as Sprint Nextel, T-Mobile and other wireless carriers who would like the opportunity to obtain 700 MHz spectrum through a D-block auction. Former FEMA Director James Witt also recently issued a statement in support of the group.

Connect Public Safety Now has its own technical champion, technology consultant and Illinois Institute of Technology Vice Provost Dennis Robertson, who has penned his own white paper arguing that public safety’s current holdings should be sufficient to support the public safety community’s needs.

The real question

Initially I was leaning toward the Public Safety Alliance camp on this one because I saw all the support the group had from the public safety community and I didn’t see any motivation for that community to demand the extra spectrum if it wasn’t really needed. But Berry raised some important concerns about giving the D-block to public safety, particularly for rural Americans.

And like the Connect Public Safety Now people, I’m a pragmatist. I have little faith in the ability of Congress to reach consensus even on something as vital as a national public safety network. So if there is some way for public safety to get by without the D-block, I have to admit that a D-block auction probably would be the best way to raise funds to build a nationwide public safety network.

Ultimately, the issue of how much spectrum public safety really needs is critical, and I’m not a wireless expert who can make a judgement about which of the dueling white papers holds the correct answer. If any readers with a deeper knowledge of wireless technology would care to look those papers over and weigh in on them, that information could be very valuable and I encourage you to share it.