Allocate the D Block to Public Safety
Wednesday, July 14, 2010 | Comments
 
By C. Douglas Jarrett
 
The D block should be allocated to public safety, not auctioned as contemplated under Section 337 of the Communications Act. When aggregated with the 10 megahertz licensed to the Public Safety Spectrum Trust (PSST), public safety would have 20 megahertz of contiguous spectrum in the upper 700 MHz band. The favorable propagation characteristics of 700 MHz spectrum enable wider area coverage from transmitter sites, lowering the costs of initial rollout and deployment in rural areas. This 10 megahertz is a fraction — well less than 5 percent — of the additional 500 megahertz recommended for wireless broadband in the national broadband plan.
 
Challenges with the Revised Private/Public Partnership
Allocating the D block to public safety is consistent with the vision of the original public/private partnership crafted by the FCC and the public-safety community several years ago. This vision would make available adequate bandwidth and access for peak period public-safety requirements. Revised earlier this year, the public/private partnership has been recast to provide public-safety priority access on and roaming across all 700 MHz broadband wireless networks. Minimum service levels for access to and service quality on commercial networks were neither specified nor discussed.
 
Public-safety advocates have said repeatedly that priority access isn’t ruthless pre-emption. It’s first-in-line status for available bandwidth on commercial networks. As noted by Motorola, Long Term Evolution (LTE) technology isn’t capable of isolating cell sites for exclusive or pre-emptive public-safety access. Public-safety users will not have assured access when required. The other lynchpin of the revised public/private partnership, roaming across all 700 MHz commercial networks by public-safety users, faces the following significant hurdles:
 
  • The two carriers holding the preponderance of the 700 MHz commercial spectrum — AT&T and Verizon Wireless— are deploying handsets based on equipment standards developed during the past several years that permit handsets to operate on one of the four 700 MHz frequency bands. The carriers are vigorously defending their commitments to deploy handsets that operate solely on their respective 700 MHz bands, in part to support handset backward compatibility to their respective 3G networks operating on other frequency bands.
     
  • The public safety and D block spectrum is part of a separate 700 MHz frequency band (band 14). Based on recent filings submitted to the FCC, handsets are being designed and built to operate solely on one of the four 700 MHz frequency bands.
     
  •  A coalition of other wireless carriers is calling for a halt to product development based on these previously developed equipment standards and that the commission require devices be capable of operating across all 700 MHz frequency bands. The coalition is also requesting the upper A block and D block be combined and then auctioned so that devices in this band can be backward compatible with non-700 MHz wireless networks, implying that if these blocks aren’t aggregated, the commercial value of the D block is severely undermined.
     
  • Over and above the technology issue, Verizon Wireless and AT&T submitted filings in June in the commission’s roaming proceeding, arguing the commission lacks statutory authority to require wireless broadband service providers to enter into broadband roaming agreements or set the terms and conditions of these agreements. 
 
In short, public-safety priority access and roaming across commercial 700 MHz networks are highly problematic. Allocating the D block to public safety is the essential prerequisite for an interoperable broadband network. It will provide the preponderance of public safety’s projected wireless broadband requirements in terms of supporting applications such as high-quality video, meeting public safety’s incident-driven, peak-period requirements in a manner superior to the revised public/private partnership, and enabling interoperability consistent with the purpose and objectives of the Emergency Response Interoperability Council (ERIC). Handsets, air cards and smart phones having the desired functions and form factors for public safety can be built based on existing industry standards.
 
Public-Safety Broadband Demand
Consumer acceptance of iPhones, iPads and smart phones based on the Android operating system, particularly the bandwidth-intensive nature of supported applications, is straining the carriers’ networks, creating substantial challenges to reliable service and carriers’ financial resources. As part of the carrier’s strategy to manage demand and modulate capital expenditures, AT&T announced tiered pricing based on data use and is including Wi-Fi capabilities in its handsets to lighten the demands placed on its licensed spectrum. Usage growth is expected to continue as service providers deploy their 700 MHz networks.
 
Demand for sophisticated applications and bandwidth will arise on the public-safety broadband network as well. While the public-safety network must be responsive to the needs of its users, this community will more likely reach consensus on and modulate the demand for applications based on network capabilities, interoperability requirements and that network capacity be available for major incidents and emergencies.
 
The public-safety user community sees wireless broadband as an increasingly important tool in providing essential public services. This is reflected in the waiver petitions being filed with the commission on a weekly basis by state, regional and local governments. The waiver requests are largely consistent with the criteria set out in the commission’s May 12 waiver order, which builds on the conditions recommended by the PSST. The PSST recommended commitments to adhere to uniform technology interfaces and the interoperability requirements being developed by ERIC, along with system deployment and reporting obligations. 
 
Clearly, funding for a nationwide interoperable network will remain an overarching consideration. While proceeds from a D block auction would be a benefit, the loss of this spectrum would severely limit the viability of a nationwide interoperable broadband public-safety network. Numerous waiver petitions highlight that funding isn’t an insurmountable obstacle, but clearly suggest that multiple funding options should be explored and encouraged.
 
 

 
Douglas Jarrett is a telecommunications attorney with Keller and Heckman, representing critical-infrastructure industry (CII) companies, state and local governments, and other entities before the FCC and on related telecommunications matters. As part of Jarrett’s wireless practice, he represents CII firms in acquiring spectrum to meet voice and broadband communications requirements from FCC auction winners and advises CII firms on spectrum opportunities, including FCC spectrum auctions. Contact Jarrett at jarrett@khlaw.com.
 
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