Narrowbanding: The Countdown

Wondering how much time you have left to complete narrowbanding compliance? Take a look below.



The clock is ticking!  If your agency has yet to fully comply with the FCC's narrowbanding mandate, avoid losing your license and facing fines by contacting EMR to find out how we can help.

Releases from the FCC

From the June 28 - 30, 2011 Daily Digests

1. Released: 06/28/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU APPROVES REGION 31 (NORTH CAROLINA) 700 MHZ REGIONAL PLAN. (DA No.
11-1126). (Dkt No 02-378 ). PSHSB
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1126A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1126A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1126A1.txt

2. WIRELESS E911 LOCATION ACCURACY REQUIREMENTS. Clarified certain
issues regarding the content of Exclusion Reports and extending the 90-day period for filing Exclusion Reports by 30 days, until July 28, 2011. (Dkt No. 07-114 ). Action by: Chief, Public Safety and Homeland Security Bureau. Adopted: 06/28/2011 by ORDER. (DA No. 11-1125). PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1125A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1125A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1125A1.txt

3. Report No: 6966 Released: 06/29/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ASSIGNMENT OF LICENSE AUTHORIZATION APPLICATIONS, TRANSFER OF CONTROL OF LICENSEE APPLICATIONS, DE FACTO TRANSFER LEASE APPLICATIONS AND SPECTRUM MANAGER LEASE NOTIFICATIONS, DESIGNATED ENTITY REPORTABLE ELIGIBILITY EVENT APPLICATIONS, AND DESIGNATED ENTITY ANNUAL REPORTS ACTION. PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-308086A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-308086A1.txt

4.

Released: 06/30/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU EXTENDS 800 MHZ REBANDING NEGOTIATION PERIOD FOR WAVE 4 BORDER AREA NPSPAC AND NON-NPSPAC LICENSEES ALONG THE U.S.-MEXICO BORDER. (DA No.
11-1147). (Dkt No 02-55 ). PSHSB . Contact: Brian Marenco at (202) 418-0838, email: Brian.Marenco@fcc.gov http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1147A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1147A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1147A1.txt

5. Released: 06/30/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU SEEKS COMMENT ON NPSTC'S PETITION FOR RULEMAKING TO ALLOW AIRCRAFT VOICE OPERATIONS ON SECONDARY TRUNKING CHANNELS IN THE 700 MHZ BAND. (DA No.
11-1146). (Dkt No RM-11433 ). Comments Due: 07/15/2011. Reply Comments
Due: 07/25/2011. PSHSB . Contact: Brian Marenco at (202) 418-0838,
email: Brian.Marenco@fcc.gov
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1146A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1146A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1146A1.txt

6. Released: 06/30/2011. FCC REQUESTS NOMINATIONS FOR MEMBERSHIP ON OPEN INTERNET ADVISORY COMMITTEE. (DA No. 11-1149). (Dkt No 09-191 07-52 ). CGB . Contact: Ellen Satterwhite at (202) 418-3626, email: Ellen.Satterwhite@fcc.gov
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1149A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1149A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1149A1.txt

House Committee Blocks FCC's LightSqured Spending

The House of Representatives Committee on Appropriations voted to block the FCC's approval of LightSquared's LTE plan, until the GPS interference issues are resolved. 

LightSquared has been in headlines in recent months for reports of GPS interference and rumors of a long-term network sharing deal with Sprint.  The decision was made July 24h to insert language into an upcoming spending bill that would prevent the FCC from spending any money approving or even considering any LightSquared network until all GPS interference issues have been resolved. 

The Committee on Appropriations, which holds a great deal of power along with the authority over the national Treasury, holds that even time spent considering the LightSquared network while reports are still showing blatant interference issues would be futile.  This is quite a victory for GPS advocates, such as the Coalition to Save Our GPS, who have been working to prevent GPS interference to preserve this critical first responder tool.

Releases from the FCC

From the June 21-27, 2011 Daily Digest

1. FCC CONSUMER TIP SHEET, LIFELINE PROGRAM & NEW REFORMS. Consumer Advisory. News Media Contact: Mark Wigfield at (202) 418-0253, email: Mark.Wigfield@fcc.gov WCB
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307786A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307786A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307786A1.txt

2. DEADLINE FOR FILING COMMENTS AND REPLY COMMENTS EXTENDED TO AUGUST 24TH FOR SIGNAL BOOSTER PROPOSED RULING AMENDMENT OF PARTS 1, 2, 22, 24, 27, 90 AND 95 OF THE COMMISSION'S RULES TO IMPROVE WIRELESS COVERAGE THROUGH THE USE OF SIGNAL BOOSTERS.
Extended the deadlines for filing comments and reply comments concerning the Commission's Notice of Proposed Rulemaking proposing to adopt rules that facilitate the development and deployment of well-designed signal boosters. (Dkt No. 10-4 ). Action by: Deputy Chief, Wireless Telecommunications Bureau. Comments Due: 07/25/2011. Reply Comments
Due: 08/24/2011. Adopted: 06/20/2011 by ORDER. (DA No. 11-1078). WTB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1078A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1078A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1078A1.txt

3. FCC WAIVER ALLOWS MISSOURI DISASTER VICTIMS TO KEEP THEIR PHONE NUMBERS WHILE REBUILDING; NORMAL RULES WOULD HAVE FORCED DISCONNECTION OF PHONE NUMBERS AFTER 90 DAYS. Carriers Also Encouraged to Waive Call Forwarding, Voicemail Charges for Disaster Victims. Advisory. News Media Contact: Mark Wigfield at (202) 418-0253, email: Mark.Wigfield@fcc.gov WCB . Contact Ben Childers at (202) 418-1418 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307845A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307845A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307845A1.txt

4. Released: 06/22/2011. EMERGENCY ACCESS ADVISORY COMMITTEE ANNOUNCEMENT OF JULY 8, 2011 MEETING. (DA No. 11-1092). CGB . Contact:
Cheryl King at (202) 418-2284, email: Cheryl.King@fcc.gov or Patrick Donovan at (202) 418-2413, email: Patrick.Donovan@fcc.gov, TTY: (202)418-0416
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1092A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1092A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1092A1.txt

5. FCC ANNOUNCES TENTATIVE AGENDA FOR JULY 12TH OPEN MEETING. News Release. News Media Contact: Neil Grace at (202) 418-0506, email:
Neil.Grace@fcc.gov OCHJG
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307812A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307812A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307812A1.txt

6. CONSUMERS GAIN NEW PROTECTIONS AGAINST FRAUDULENT CALLER ID "SPOOFING". Violators Face Substantial Fines. News Release. News Media Contact:
Mark Wigfield at (202) 418-0253, email: Mark.Wigfield@fcc.gov CGB WCB .
Contact Lisa Hone at (202) 418-0869
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307891A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307891A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307891A1.txt

7. Released: 06/22/2011. CHAIRMAN GENACHOWSKI RELEASES UPDATE TO 2009 RURAL BROADBAND REPORT. (DA No. 11-1095). (Dkt No 11-16 ). WCB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A2.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A2.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A1.txt
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1095A2.txt

8. Released: 06/27/2011. FCC FURTHER EXTENDS DEADLINE AN ADDITIONAL THIRTY DAYS FOR MEMBERSHIP NOMINATIONS FOR THE INTERGOVERNMENTAL ADVISORY COMMITTE. (DA No. 11-1114). CGB . Contact: Gregory Vadas at
(202) 418-1798, email: Gregory.Vadas@fcc.gov or Steve Klitzman at (202) 418-1763, email: Steve.Klitzman@fcc.gov http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1114A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1114A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1114A1.txt

9. BROADBAND FOR ALL: A NETWORKED AND PROSPEROUS SOCIETY, GRUNEWLADSALEN CONCERT HALL, KUNGSGATAN 43, STOCKHOLM, SWEDEN. OCRMM . Keynote on Technology and Democracy, The Honorable Robert M. McDowell, Federal Communications Commission, Technology and the Sovereignty of the Individual http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307998A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307998A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307998A1.txt

10. IMPROVING PUBLIC SAFETY COMMUNICATIONS IN THE 800 MHZ BAND. Dismissed
the Petition for Partial Reconsideration. (Dkt No. 02-55 ). Action by:
Deputy Chief, Public Safety and Homeland Security Bureau. Adopted:
06/27/2011 by ORDER. (DA No. 11-1112). PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1112A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1112A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1112A1.txt

11. Released: 06/24/2011. PSHSB ANNOUNCES REGION 28 (DELAWARE, EASTERN PENNSYLVANIA, AND SOUTHERN NEW JERSEY AREA) PUBLIC SAFETY REGIONAL PLANNING COMMITTEES TO HOLD 700 MHZ AND 800 MHZ NPSPAC MEETINGS. (DA No. 11-1110). (Dkt No 92-287 ). PSHSB
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1110A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1110A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1110A1.txt

We'll See You in August!

EMR Consulting, Inc. and EMR Consulting Group, LLC will be at two conferences coming up this August:  the 77th Annual APCO International Conference and Expo and the National Association of Women Law Enforcement Executives (NAWLEE) Conference. 

The EMR booth at APCO will be accessible throughout the conference.  Come by to discuss Public Safety matters, learn more about our services, and pick up an EMR t-shirt.

EMR President and CEO Sandra L. Black will be speaking at the NAWLEE Awards Dinner on August 6th, 2011 in Milwaukee.  The NAWLEE conference is a fantastic networking and education opportunity for women in law enforcement who wish to further their careers.  Sandra will be speaking on "Breaking the Glass Ceiling."

NPSTC Creates Video Technical Advisory Group

The National Public Safety Telecommunications Council (NPSTC) announced its new technical advisory group today.  Current members are invited volunteers who are interested in video quality in Public Safety, but anyone wishign to participate is welcome to complete a Volunteer Form. 

The Video Technical Advisory Group (VTAG) will provide valuable input to the Department of Homeland Security Video Quality in Public Safety (VQiPS) Initiative.  Video is emerging as a new tool in Public Safety, providing critical information in transportation, crime solving, and public works efforts.  The DHS's Office for Interoperability and Compatibility began the video quality project in 2009.  The first VQiPS conference investigated applicable standards and produced a Users Guide, definitions standard, and user requirements framework. 

The purpose of the advisory group is to provide practical advice and input to the DHS VQiPS Working Group.  Current members include senior practitioners from technology and public safety with great insight and experience, who work for effective use of quality video of first responders. 

EMR President and CEO Sandra Black at NAWLEE

Sandra Black, Founding President and CEO of EMR Consulting, Inc. and EMR Consulting Group, LLC, will be speaking at the National Association of Women Law Enforcement Executives (NAWLEE) Conference.   The conference will take place August 3 - 6, 2011 at in Milwaukee, Wisc. at the Hyatt Regency.  Ms. Black will be speaking on "Breaking the Glass Ceiling" at the Awards Ceremony and Dinner in the Regency Ballroom on August 6, 2011. 

For more information on NAWLEE or the conference, visit http://www.nawlee.com/.  See contact info below.

What's Next for Sprint?

Sprint Nextel's dance with various data network providers has bloggers and analysts wondering what the company will do next.  Sprint plans to reveal its 4G strategy this summer, and speculations of LTE over WiMAX have been floating around.

Alcatel-Lucent, Samsung, and Ericsson all signed a deal in December to help improve Sprint's network.  Clearwire has historically been a WiMAX provider for Sprint, and now, despite conclusive reports of GPS interference, reports say Sprint plans to become a wholesale user on LightSquared's pending broadband network.  Sprint has neither confirmed nor denied a LightSquared deal, and Clearwire owns enough spectrum to deploy LTE as well as WiMAX. 

To read more, visit Urgent Communications.

LightSquared's Solution Plan Met with Criticism

LightSquared announced plans to rework its nationwide broadband network, migrating to the lower 10 MHz of its L-band spectrum holdings as a solution to multiple reports of GPS interference.

LightSquared was recently granted an extension on studies required by the FCC on the company's alleged interferenced with GPS signals, and the company cosummated a $20 billion network sharing deal with Sprint Nextel. 

Although the company plans to be a major player in the future of LTE, their network has been plagued with GPS interference since its first tests.  Instead of using the satellite spectrum adjacent to GPS channels, LightSquared recently worked a deal with Inmarsat, allowing it access to the lower band sooner than expected.  This solution could possibly save the company's business plan to launch its network in the first half of next year. 

In its statement, LightSquared claims that its tests have shown that the lower 10 MHz of spectrum is "largely free" of interference.  The company admits that some high precision GPS devices are specifically programmed to operate on the channels owned by LightSquared, and their studies show these devices will be still be affected. 

Although the FCC declined to comment, one of the founders of the Coalition to Save Our GPS was very outspoken in his response to LightSquared's plan.  Jim Kirkland of Trimble claims that the spectrum still interferes with many GPS devices, including the aforementioned high precision receivers. 

The second part of lightSquared's solution involves amending its FCC license to reduce its maximum authorized base-station transmitter power by 50%. 

The company claims that this plan is one that will allow them to proceed with the launch of their network, while protecting GPS signal.  Although the FCC has continually backed LightSquared's progress towards the launch, Coalition and other GPS advocates still hold that critical GPS capabilitiers will be compromised.

Sprint Goes to Bed with LightSquared

According to fiercewireless.com, Sprint Nextel signed a 15-year deal with LightSquared to build and share the company's nationwide network.  The agreement is worth an estimated $20 billion and will secure a spot for Sprint as a wholesale user of LightSquared.  Sprint will help to develop, deploy, and operate the new 4G LTE network, according to Philip Falcone of Harbinger Capital Partners, which funds lightSquared's project. 

Sources such as the Wall Street Jouranl and the New York Times also reported on the partnership, which will make serious waves in the wireless communications industry.  Sprint competitors Verizon Wireless and AT&T Mobility are already in the process of deploying their LTE networks.  Sprint's current partner Clearwire provides use of its WiMAX network, but market analysts say the LightSquared partnership is a step back from the long-time agreement.  It has also been hypothesized that Sprint will continue its use of WiMAX as a support to its long-term data needs.

The recent reports of GPS interference from LightSquared are somewhat reminiscent of the ten year old reports of Public Safety interference from Sprint, cause of the long, grueling nationwide rebanding project.  For the sake of a company that has a significant history of interference with critical infrastructure spectrum, here's to hoping LightSquared is successful in finding solutions to the interference issue.

Releases from the FCC

From the June 14 - 20, 2011 Daily Digest

1. The FCC recently granted a broadband waiver to the State of Texas.
The Public Safety and Homeland Security Bureau seeks comment on a May 26,
2011, petition from the Harris Corporation requesting that the Commission
"clarify that it does not endorse any procurement model for building an
interoperable public safety broadband network on a local, regional, state or
nation-wide basis."

PUBLIC SAFETY AND HOMELAND SECURITY BUREAU SEEKS COMMENT ON PETITION FOR
DECLARATORY RULING ASKING TO CLARIFY LANGUAGE IN ORDER GRANTING 700 MHZ
PUBLIC SAFETY BROADBAND WAIVER TO THE STATE OF TEXAS. (DA No. 11-1059).
(Dkt No 06-229 ). Comments Due: 07/05/2011. Reply Comments Due: 07/15/2011.
PSHSB . Contact: Jennifer A. Manner at (202) 418-3619, email:
mailto:Jennifer.Manner%40fcc.gov
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1059A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1059A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1059A1.txt

2. LightSquared granted extension on final GPS interference report.
LightSquared granted extension on final GPS interference report -
FierceBroadbandWireless
<http://www.fiercebroadbandwireless.com/story/lightsquared-granted-extension
-final-gps-interference-report/2011-06-16?utm_medium=nl&utm_source=internal#
ixzz1PS8HFWb7>
http://www.fiercebroadbandwireless.com/story/lightsquared-granted-extension-
final-gps-interference-report/2011-06-16?utm_medium=nl
<http://www.fiercebroadbandwireless.com/story/lightsquared-granted-extension
-final-gps-interference-report/2011-06-16?utm_medium=nl&utm_source=internal#
ixzz1PS8HFWb7> &utm_source=internal#ixzz1PS8HFWb7

3. FCC CHAIRMAN JULIUS GENACHOWSKI REMARKS ON A NATIONWIDE PUBLIC SAFETY
NETWORK, AS PREPARED FOR DELIVERY, THE WHITE HOUSE. OCHJG .
WASHINGTON, D.C
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307659A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307659A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307659A1.txt

4. Released: 06/17/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU APPROVES LONG TERM DE FACTO TRANSFER SPECTRUM LEASE AGREEMENT FILED BY THE STATE OF TEXAS TO ESTABLISH A 700 MHZ INTEROPERABLE PUBLIC SAFETY WIRELESS BROADBAND NETWORK. (DA No. 11-1074). (Dkt No 06-229 ). PSHSB . Contact: Jennifer Manner at (202) 418-3619 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.txt

5. Released: 06/17/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU APPROVES LONG TERM DE FACTO TRANSFER SPECTRUM LEASE AGREEMENT FILED BY THE STATE OF TEXAS TO ESTABLISH A 700 MHZ INTEROPERABLE PUBLIC SAFETY WIRELESS BROADBAND NETWORK. (DA No. 11-1074). (Dkt No 06-229 ). PSHSB . Contact: Jennifer Manner at (202) 418-3619 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1074A1.txt

Andrew Seybold: Will LightSquared Survive?

The following commentary was posted on June 6, 2011 on AndrewSeybold.com:
Okay, so LightSquared has the blessing of the FCC Commissioners to build out a wholesale LTE network using satellite spectrum that is mostly terrestrial and a small part satellite (the data rates for satellite will disappoint for sure). It is obvious to me that the FCC Commissioners never asked the Chief Engineer or his staff if there would be any problem with the service in the next band down, which happens to be the GPS band, before issuing the waiver to LightSquared.

GPS is a receive-only service that relies on the ability to “see” three or more satellites to report a current location. If more satellites are in view, the system can also determine the altitude of the device and the speed and direction of its travel. However, if the GPS signals are being interfered with near LightSquared’s cell sites (it is proposing more than 50,000), those who rely on GPS will have problems. Recent tests of the LightSquared network in New Mexico verified that interference issues do exist.

If people cannot receive a GPS signal, actually multiple GPS signals, then the system does not function. Not only do the people with GPS receivers no longer know where they are, neither does their boss. If they have to call 9-1-1 for an emergency, those answering the phone don’t know where they are either. The radio signals from satellites (GSP satellites and others) are not very strong and any interference to them will wipe them out and prevent them from being received. Except for those designed for military service, GPS receivers don’t have very good receivers. They are not able to filter out interference well (they have not needed to in the past), and in order to get the price point for GPS systems low enough to be built into every cell phone and handheld and dash-mounted device, the receivers have not been built to reject signals in the next band over. So if LightSquared is permitted to move forward with its nationwide rollout, the consequences could be devastating to anyone who relies on GPS services for location, attitude, speed, and direction of travel.

Adding all of these things together, my outlook for LightSquared is bleak to say the least. If I add in the fact that its spectrum, which has the potential to interfere with GPS receivers, has therefore lost most of its value as an asset, it is difficult to understand how the company believes it can succeed.

First responders use GPS on a daily basis for finding locations. For example, medevac helicopters are directed to a location to pick up seriously injured patients. If they cannot use their GPS system they are blind and don’t know where to respond. Taxis use GPS so their location can be known to the company, truckers use GPS to find locations, FedEx, UPS, and other delivery services use GPS, and many of us have GPS systems built into our vehicles or we own a GPS device that sits on our dashboard. If the LightSquared spectrum is built out, the chances of wide-spread interference are very real.

Since the FCC issued the waiver to LightSquared, the company contends that it can minimize any interference, but the Department of Defense, the Federal Aviation Administration, and other Federal Government agencies have called for the rescinding of the LightSquared waiver to operate a terrestrial system in spectrum that was originally set aside for satellite communications. Even Congress is now in the battle with more than 30 Congressional leaders calling for the FCC to revoke the waiver. In recent New Mexico tests this interference was confirmed.

Meanwhile, LightSquared has indicated that it is heading for an IPO and that it has contracts to provide wholesale fourth-generation broadband to a number of smaller network operators including SI Wireless, Cellular South, Leap Wireless, and others. These companies, none of which have enough of their own spectrum to build out LTE or 4G networks, are planning on wholesaling network capacity from LightSquared. But if the spectrum LightSquared is counting on for its network is not available, what does LightSquared do and what does its partners do?

Well, LightSquared is in talks with AT&T and Sprint to wholesale 4G capacity on these networks. This seems like a logical idea until you step back and look at the economics involved. If LightSquared buys capacity from AT&T, for example, then LightSquared becomes, in reality, a Mobile Virtual Network Operator or MVNO. If it then sells this capacity to its partners, its partners will have to pay a premium for the capacity they could probably obtain directly from AT&T for less than they will pay LightSquared and LightSquared’s business model becomes even more tenuous than it was before.

If LightSquared builds out its network, even with tower sharing and other cost savings, a nationwide network will cost it about $15 billion to build and that is on the low side. Verizon has stated that it has already invested that much and it has existing infrastructure to use to help lower the costs of deployment. Once the network is built, the average monthly cost per cell site for rent, power, insurance, and other costs will be about $6K per month and that is also on the low side). This means LightSquared’s monthly site costs will run about $24 million or nearly $300 million per year. That is before profit and does not include company overhead and other costs. LTE requires either fiber or microwave to and from each cell site and that cost will also be substantial.

If LightSquared leases capacity on someone else’s network it will not have to pay construction or ongoing operational costs, but then its margins will be a lot slimmer, having to buy capacity and then resell it to its partners. I don’t think this business model is very viable either, and if the demand for broadband continues and the company LightSquared is buying capacity from starts having capacity issues of its own, will LightSquared actually get all the capacity for which it has contracted? My guess is that LightSquared becomes a secondary citizen on the network and that if capacity becomes an issue, it will be the first to have to give some up. The other capacity issue is that if LightSquared resells this capacity to four or five other network operators, will they have enough capacity to service their own customer base as broadband demand continues to increase? Either way, it seems to me that this is a very risky business model.

The history of MVNOs is littered with failures. The ones remaining have, for the most part, been purchased by the network operator that was providing capacity to the MVNO in the first place, and once it was determined that the business model was flawed, the MVNO either folded its tent and went home or its customers were absorbed into the parent network. Historically, the MVNO business has not been successful and I don’t see this model as one that leads me to believe things will be different this time around.

Adding all of these things together, my outlook for LightSquared is bleak to say the least. If I add in the fact that its spectrum, which has the potential to interfere with GPS receivers, has therefore lost most of its value as an asset, it is difficult to understand how the company believes it can succeed. Yet It remains bullish and is talking about a future IPO and how bright its income future is. I, for one, don’t believe LightSquared will remain a viable entity. It appears to have been blinded in its judgment by the fact that wireless broadband is growing rapidly, there is no end in sight for this increased demand, and the FCC has recognized that more broadband spectrum will be needed as soon as possible.

The FCC and others in the Federal Government seem to believe we need additional competitors in the wireless space; having more competition will continue to drive down the cost of voice and data services to business and consumer users. In reality, today’s wireless customers in the United States continue to pay some of the lowest rates for wireless voice and data services in the world. Yes, we are entering a new era where unlimited data plans are being withdrawn in favor of plans that limit the amount of data allocated to a single user on a monthly basis, but this is necessary in order for network operators to provide more of their customer base with more access to broadband, and it is one way that broadband demand can be managed in order to accomplish this goal.

The FCC continues to look for additional spectrum as it should since we do need it and we need it as soon as possible. I am sure that LightSquared’s proposal to the FCC was met with much enthusiasm since it would provide additional broadband capacity at the very time it is needed. But if the LightSquared spectrum is deemed unusable for terrestrial broadband service, as I believe it will be, then LightSquared does not bring additional capacity with it when it launches its service. It will simply place a bigger burden on the existing spectrum in terms of capacity demand.

LightSquared would be better served to try to purchase spectrum that is not being used for broadband at the moment. Clearwire has a lot of unused spectrum in the 2.5-GHz band and it needs money, the FCC can auction the AWS-2 and 3 Bands, and the FCC already has spectrum in a number of areas in the country that did not sell at auction or that was taken back because the winning bidder either did not meet the payment requirements of an auction or did not meet the build-out requirements.

We need more wireless spectrum for broadband and we need it soon; the AT&T/T-Mobile merger is about spectrum assets just as the Cingular/AT&T merger was before it. There are only a few ways to obtain more broadband capacity for customers—use more spectrum if it is available, build more cell sites closer together, or a combination of the two. Spectrum is, indeed, a finite resource and demand for wireless broadband services is growing quarter-over-quarter, but that does not mean we should jeopardize an important system such as GPS in order to help fill the void. Instead we need to look at how to get more spectrum that is better suited for wireless broadband into the market as quickly as possible.

We should learn from our past. When Nextel was born by converting spectrum used for land mobile radio systems (LMR) to a cellular architecture, the network caused a lot of interference to existing Land Mobile Radio systems in the same portion of the spectrum. The fix was to reband this spectrum and put all of the Nextel channels together so they would no longer interfere with LMR customers, many of which are public safety agencies. This fix has been in the works for more than five years, has cost Sprint/Nextel more than $3 billion, and will not be completed in some areas of the United States for a few more years. We cannot afford to have this type of interference issue surface again because a company or a federal agency believes that more broadband competition is vital to our wireless broadband future.

LightSquared should not be permitted to build a network in the spectrum adjacent to the GPS service. Every transmitter ever made transmits not only on the portion of the spectrum for which it was designed, it also injects noise into the adjacent spectrum. This is simply the way radio frequency devices work. If there are two broadband systems next to each other most of the time, this interference can be minimized. However, when you put a broadband system right next to the GPS service on which the receivers are searching for low-powered signals from multiple satellites, you are asking for trouble. The goal should be to provide additional spectrum for broadband without causing problems for other services. I do not believe that can be accomplished in this case.

Andrew M. Seybold

Used with Andrew Seybold's permission.

Releases from the FCC

From the June 10-13, 2011 Daily Digest

1.  Released: 06/09/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ANNOUNCES THAT FIRST EVER NATIONWIDE DIAGNOSTIC TEST OF THE EMERGENCY ALERT SYSTEM WILL OCCUR ON NOVEMBER 9, 2011 AT 2 PM EST. (DA No.11-1030). (Dkt No 04-296 ). PSHSB . Contact: Lisa Fowlkes at (202) 418-7452, Tom Beers at (202) 418-0952, or Gregory Cooke at (202) 418-2351
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1030A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1030A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1030A1.txt

2. Released: 06/09/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ANNOUNCES REGION 55 (NEW YORK - BUFFALO) PUBLIC SAFETY REGIONAL PLANNING COMMITTEES TO HOLD 700 MHZ REGIONAL PUBLIC SAFETY PLANNING AND 800 MHZ NPSPAC REGIONAL PUBLIC SAFETY PLANNING MEETINGS. (DA No. 11-1036). (Dkt No 92-287 ). PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1036A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1036A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1036A1.txt

3. PREPARED REMARKS OF FCC CHAIRMAN JULIUS GENACHOWSKI, JUNE 2011 OPEN AGENDA MEETING, STATEMENT ON INFORMATION NEEDS OF COMMUNITIES by Statement. OCHJG http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307448A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307448A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307448A1.txt

4. STATEMENT OF COMMISSIONER MICHAEL J. COPPS ON RELEASE OF FCC STAFF REPORT "THE TECHNOLOGY AND INFORMATION NEEDS OF COMMUNITIES" by Statement. OCMJC http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307421A1.doc
http://hraunfoss.fcc.gv/docs_public/attachmatch/DOC-307421A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307421A1.txt

5. Released: 06/10/2011. COMMENT DEADLINES SET FOR NOTICE IF INQUIRY ON ACCELERATING BROADBAND DEPLOYMENT BY IMPROVING PUBLIC RIGHTS OF WAY AND WIRELESS FACILITIES SITING POLICIES. (DA No. 11-1047). (Dkt No 11-59 ).
Comments Due: 07/18/2011. Reply Comments Due: 08/30/2011. WCB .
Contact: Claudia Pabo at (202) 418-1595, email: Claudio.Pabo@fcc.gov http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1047A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1047A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1047A1.txt

6. CHAIRMAN JULIUS GENACHOWSKI, REMARKS ON INFORMATION NEEDS OF COMMUNITIES, COLUMBIA SCHOOL OF JOURNALISM. OCHJG . New York, NY http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307456A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307456A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307456A1.txt

Releases from the FCC

From the June 7, 8, and 9, 2011 Daily Digests

1. Released: 06/06/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ANNOUNCES REGION 53 (TEXAS-SAN ANTONIO) 700 MHZ REGIONAL PLANNING COMMITTEE INITIAL MEETING. (DA No. 11-1004). PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1004A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1004A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1004A1.txt

2. Released: 06/08/2011. FCC ANNOUNCES REESTABLISHMENT OF THE TECHNOLOGICAL ADVISORY COUNCIL. (DA No. 11-1020). OET . Contact: Walter Johnson at (202) 418-0807, email: Walter.Johnson@fcc.gov. News Media Contact: Bruce Romano at (202) 418-2124 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1020A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1020A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1020A1.txt

3. Report No: 6912 Released: 06/08/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ASSIGNMENT OF LICENSE AUTHORIZATION APPLICATIONS, TRANSFER OF CONTROL OF LICENSEE APPLICATIONS, DE FACTO TRANSFER LEASE APPLICATIONS AND SPECTRUM MANAGER LEASE NOTIFICATIONS, DESIGNATED ENTITY REPORTABLE ELIGIBILITY EVENT APPLICATIONS, AND DESIGNATED ENTITY ANNUAL REPORTS ACTION. WTB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307252A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307252A1.txt

4. Report No: 6910 Released: 06/08/2011. PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ASSIGNMENT OF LICENSE AUTHORIZATION APPLICATIONS, TRANSFER OF CONTROL OF LICENSEE APPLICATIONS, AND DE FACTO TRANSFER LEASE APPLICATIONS, AND DESIGNATED ENTITY REPORTABLE ELIGIBILITY EVENT APPLICATIONS ACCEPTED FOR FILING. PSHSB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307248A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307248A1.txt

5. DELETION OF AGENDA ITEM FROM JUNE 9, 2011 OPEN MEETING http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307407A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307407A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307407A1.txt

6. FCC WORKING GROUP DELIVERS NEW REPORT: INFORMATION NEEDS OF COMMUNITIES. News Release OSP http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A2.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A2.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A1.txt
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307411A2.txt

D-block: Momentum Builds as Commerce Committee Passes S.911

News pieces this week point to imminent reallocation of the D-block of 700 MHz spectrum.  This is big news for those who have been working towards legislation for Public Safety spectrum in recent months and years.  It took only one day for the Senate Commerce Committee to finish its markup and pass the D-block bill (known as the S. 911, the Public Safety Spectrum and Wireless Innovation Act, or just Spectrum Act) yesterday. 

The first-responder community had qualms about language in one version of the bill requiring agencies to give up existing narrowband spectrum in auctions to help fund the new Public Safety LTE networks.  Most are wary of the proposal, but not entirely opposed to it, provided their narrow-band efficiency is not lost with the transfer to newer technologies.  APCO's position on giving back spectrum is that Public Safety will need 30 MHz of broadband spectrum, so the spectrum in question should be migrated to broadband, not given back. 

Amendments to the bill, suggested by Sens. John McCain and Joseph Lieberman, would change the language to requiring the FCC to review whether migrating Public Safety from below 512 MHz makes sense technologically and economically.  Sean Kirkendall, spokesperson for APCO, says this is much more acceptable than giving back the spectrum. 

According to the TV News Check article, the Spectrum Act includes the following key points:

• Setting the groundwork for a nationwide, interoperable, wireless broadband Public Safety network
• Allocating the 10 MHz of D-block 700 MHz spectrum to Public Safety
• Directing the FCC to set a standard of efficiency that will allow Public Safety networks to be loaned out to non-Public Safety during times of non-use
• Allowing incentive auctions, providing licensees the ability to relinquish currently unused spectrum, and allowing auction funds to pay for construction and maintenance of the new Public Safety network
• Directing the National Science Foundation and National Institute of Standards and Technology to conduct critical research on ground-breaking technologies

The passing of this bill is a significant stride, but the bill still has the obstacle of passing the whole Senate, and some say it will meet more opposition in the House.

Ranking member of the Committee, Sen. Kay Bailey Hutchison has high hopes for the legislation, saying, "The Commerce Committee has come together to move forward the most significant piece of telecommunications legislation in a decade. It is imperative our communications infrastructure be ready to handle the growth and innovations of the future. We have a bipartisan agreement that will build, without taxpayer funds, a 21st century public safety network that gives first responders the tools to do their jobs. Our bill will spur job creation, generate hundreds of billions in economic activity, and drive research and development while bringing down the national deficit. This is a commonsense approach to a national priority, and I hope the Senate will pass S. 911 without delay."

Public Safety: New Standards in the Works from FM Approvals

According to Urgent Communications, FM Approvals submitted a proposal requesting tohe authority to make changes to the "intrinsic-safety" standards of landmobile radio (LMR), to ensure radios work even under harsh conditions.  The proposal was published by the American National Standards Institute (ANSI) on March 25, 2011, and since FM Approvals has received no negative feedback from ANSI, they have initiated the process. 

The proposal stems from criticism of the new IS standards, effective January 1, 2012.  Voth vendors and Public Safety officials have been outspoken about their opposition of the standards.  There are currently no devices certified in the U.S. that are compliant with the new IS standard.  Portables that meet the standard would be required to use significantly less output power, which would reduce coverage of LMR systems.

FM Approvals currently has a team working on the changes, and they plan to publish them this August.

Releases from the FCC

From the June 1,2, and 3, 2011 Daily Digests

1.

 FCC CHAIRMAN JULIUS GENACHOWSKI ANNOUNCES JONATHAN ZITTRAIN AS FCC DISTINGUISHED SCHOLAR.  News Release. News Media Contact: David Fiske at

(202) 418-0513, email: David.Fiske@fcc.gov  OCHJG http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306932A1.doc

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306932A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306932A1.txt

2.

 IMPLEMENTATION OF SECTION 224 OF THE ACT/A NATIONAL BROADBAND PLAN FOR

OUR FUTURE.   Denied the Stay Request. (Dkt No.  07-245 ). Action by:

Chief, Wireline Competition Bureau. Adopted:  06/01/2011 by ORDER. (DA No. 11-980).  WCB http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-980A1.doc

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-980A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-980A1.txt

3.

 FCC TO HOLD OPEN COMMISSION MEETING, THURSDAY, JUNE 9, 2011 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306971A1.doc

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306971A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-306971A1.txt

4.

 REMARKS OF COMMISSIONER MICHAEL J. COPPS ON RECEIVING THE KAREN PELTZ-STRAUSS PUBLIC POLICY AWARD, 19TH BIENNIAL INTERNATIONAL CONFERENCE, TELECOMMUNICATIONS FOR THE DEAF, INCORPORATED, AUSTIN, TEXAS.  OCMJC http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307024A1.doc

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307024A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-307024A1.txt

Public Safety: Possible Solution for GPS Interference

A network synchornization company, Symmetricom, proposed a solution to the recent claims of interference by new technology from LightSquared.  The company plans to launch a nationwide LTE network using existing L-band satellite spectrum, which may cause problems for first responders, as well as anyone using GPS.  Other options such as installing filters and moving GPS antennas have been considered, but Symmetricom recommends using a packet-based primary-reference source synchronization solution (PRS), such as its Time Provider 1500 product, which uses utilizes IEEE 1588 Precision Time Protocol (PTP). 

Because GPS is not required at Packet PRS locations to ensure accurate timing, Symmetricom believes the solution will completely eliminate any interference.  Time Division Duplexing (TDS) has formerly been the standard for synchronizing networks, but networks migrating to ethernet has "broken the chain of synchronization," and requires implementing real-time clocks to sync. 

To read more about Symmetricom's proposed solution, see last week's Urgent Communications article.

Public Safety Voice Interoperability

from Andrew Seybold's Public Safety Advocate e-newsletter:

On March 18, 2011, the Congressional Research Service (CRS), which is a part of the Library of Congress, submitted a memorandum that has been used by some in the House to level charges that since 2001 the Public Safety Community has wasted $13 billion in grants and wasted spectrum resources as well. Below is my response to this memo.

Public Safety Voice Interoperability

Some in Congress and on the House Energy and Commerce Committee are pointing to a March 18, 2011 memo from the Congressional Research Service (CRS)[1] to assert that the Public Safety Community has wasted more than $13 billion in federal grants for radio communications systems since 2001. In reality, the grants have totaled less than $4 billion and they have, in fact, provided for a higher level of Public Safety interoperability than ever before. In order to fully understand the impact of these grants, it is important to understand the many and varied issues that must be addressed if the ultimate goal of nationwide interoperability is to be achieved for both voice and data services for Public Safety.

Interoperability between various Public Safety agencies had been an issue long before it was brought to public attention during 9/11, Katrina, and other disasters. Articles dating back several decades have pointed out both the need and the issues that must be overcome in order to provide the Public Safety community with interoperable voice and data.[2] Indeed, Public Safety and the Big 7 state and local government associations initially secured the 24 MHz derived from digital TV transition in the wake of the communications failures first responders experienced at the site of the domestic terrorist bombing of the Alfred Murrah building in Oklahoma City in 1994. At that site, firefighters and police officers conducting search and rescue could not speak to each other on their radios within different floors of the building and had to resort to talking to dueling command centers set up outside the site, and couriers running back and forth between the two command centers.

Three major factors have significantly hindered Public Safety’s efforts to achieve mission-critical voice interoperability:

1.    Public Safety’s currently allocated spectrum is in small segments spread out over at least seven different portions of the radio spectrum.

2.    Because this spectrum has been in use by Public Safety for many years, interoperability must start at the local level, then the regional, state, regional interstate level, and finally at the national level (and at international borders as well).

o    Most of the money expended to date has resulted in better interoperability on a local, regional, and state level, interstate regional, and on international borders, but because of the lack of enough spectrum in any given FCC allocation, this process is slow, tedious, and expensive.

o    The Public Safety broadband network will be built on greenfield, that is, unused spectrum. Therefore, it will be possible to design and implement this new network as a fully interoperable network from the beginning, something that has never before been possible for the Public Safety community.

3.    Within each portion of the allocated spectrum, different Public Safety departments make use of different types of radios and radio configurations to meet their own individual coverage requirements.

The main reason for a lack of Public Safety voice interoperability is the fact that while the FCC has continued to allocate more spectrum over the years for use by the Public Safety community, these new allocations have been in very different portions of the spectrum. Today, Public Safety voice communications are authorized in small segments of the spectrum from 30 MHz up to 800 MHz, and except for the spectrum in the 700 and 800-MHz bands, the Public Safety channels are comingled with channels used by business, taxi services, truckers, paging services, and others. In short, there has never been an allocation of enough spectrum in a common radio band to permit all of the various Public Safety agencies to migrate to a single portion of the spectrum and be able to interoperate between all agencies.

Frequency Band	Type of Radio Channels	Band Shared with other Users?
30-50 MHz shared spectrum (6.3 MHz of spectrum)	Narrowband voice channels	Yes, business, utilities, government others
150-170 MHz shared spectrum (3.6 MHz of spectrum)	Narrowband voice channels	Yes, business, paging, utilities, other
220 MHz channels (only one area of U.S. near Canada)	Narrowband voice channels	No
450-470 MHz shared spectrum (3.7 MHz of spectrum)	Narrowband voice channels	Yes, business, alarm, utilities, paging, local government, others
470-512 MHz (shared TV channels certain areas only)	Narrowband voice channels	Shared with TV station and business radio/wireless mikes
700 MHz narrowband (12 MHz of spectrum)	Narrowband voice/data	No—contiguous spectrum
700 MHz broadband (10 MHz of spectrum)	Broadband data	No—contiguous spectrum
800 MHz narrowband (9.5 MHz of spectrum)	Narrowband voice/data	N0 AFTER rebanding is completed
4.9 MHz broadband (50 MHz of spectrum)	Low-power data	Suited only for local use and does not penetrate buildings

As the chart above illustrates, today’s Public Safety mission-critical voice channels are spread across seven vastly different portions of the spectrum. It should be noted that except for the 700 and 800-MHz voice allocations, all of the other portions of spectrum allocated to Public Safety are shared with other services. It should also be noted that a radio system operating on the 30-MHz band, 150 MHz, 450 MHz, or 800 MHz will have different coverage capabilities on each; the higher in the spectrum that you operate a system, the more infrastructure is required to cover the same given geography.

When those outside the Public Safety community look at the spectrum allocations already made, they oftentimes do not take into account that the 4.9-GHz spectrum (50 MHz) is not suited for wide-area broadband service. In reality, it is designated for low-power, local communications just as today’s unlicensed Wi-Fi bands are allocated for citizens’ use. The average coverage of a single 4.9-GHz access point is 300 feet or less, and in most systems today, this spectrum is used for point-to-point communications for video transmissions from fixed-location cameras, or for on-scene local broadband services. This spectrum is not available or useful for Public Safety as part of the nationwide broadband network that is being planned to provide wide-area coverage across the nation.

Today, in many urban areas there are not enough radio channels in a given portion of the allocated spectrum to meet the requirements of Public Safety. Radio signals do not stop at city, county, or state (or international) boundaries, therefore the channels in use in a given area must be coordinated with adjacent users to prevent or minimize interference between systems. In many areas this means, for example, that the police departments will operate in the 450-MHz portion of the spectrum while fire and emergency medical services (EMS) units will operate in the 150-MHz portion of the spectrum. Providing interoperability between police, EMS, and fire in these areas requires either specialized equipment in the dispatch centers to patch channels together or the installation of two or more radios in each vehicle; which is an expensive and ineffective method of obtaining interoperability between systems.

If Public Safety had been allocated sufficient spectrum in any one of these bands to satisfy the number of radio channels required for true nationwide interoperability, the result would have been twofold:

1. We would, today, have a truly interoperable voice system nationwide.

2. The cost of Public Safety radio equipment would be at least 50% less than what it is today because it could have been built to operate on a single portion of the spectrum, providing[3] economies of scale and reducing per unit price for Public Safety radios. Today, equipment vendors must build radios for a specific portion of the spectrum, and therefore the quantities they produce for each portion of the spectrum are less.
Other Factors Hindering Mission-Critical Voice Interoperability

Because the narrowband voice spectrum is already heavily used, nationwide interoperability cannot be achieved until it is first made available on a local, regional, and then statewide basis. Much of the funding that has been granted to Public Safety since 2001 has in fact resulted in better regional and statewide interoperability. From 2001 until today, the number of new regional and statewide systems constructed and operational has grown rapidly as the various jurisdictions have sought out their own ways of providing mission-critical voice interoperability.

For example, in California, technology advances have provided fire service with the ability to purchase and install radios capable of more than 300 channels in the 150-MHz band. There is a standard plan in place so that most of the fire departments can and do have interoperability not only between city, county, and state fire units, but also with federal government fire units. However, in major cities such as San Diego, Los Angeles, and San Francisco, there are not enough of these channels to provide for day-to-day fire operations, so fire departments are operating on other portions of the spectrum. During major incidents, agencies responding from out of the area are not able to directly communicate with fire equipment from the large cities without either a second radio in each vehicle or some other form of non-automatic channel sharing equipment.

Many regions have built and installed regional radio systems that are used as interagency communications systems during mutual aid situations. Many of these serve as overlay systems since very few have the channel capacity to serve all of the various local entities. This also requires multiple radios in each vehicle. Several states such as Wyoming, Florida, Vermont, Montana and others have recently built or are in the process of building statewide interoperable mission-critical voice systems in order to provide statewide interoperability, but in many cases, these systems augment rather than replace the local systems that are still needed on a daily basis to meet the capacity requirements of each local Public Safety agency.

In a recent memorandum from the Congressional Research Service (CRS)[4] dated March 18, 2011, the data used as a baseline was taken from a survey conducted by the National Emergency Management Association (NEMA).[5] This report was, in fact, based on Emergency Management Association directors’ estimates of funds thought at the time to be necessary for states to achieve full statewide interoperability and did not, as portrayed in the CRS report, reflect actual amounts of funding received by the states and local agencies. Further, specific grant programs put requirements on accessing the funds that led to an emphasis on local, regional, and statewide interoperability (as opposed to nationwide), and there were conflicting requirements among and between grant programs causing a lack of greater interoperability.

When working toward the goal of both voice and data interoperability as is the desire of the Public Safety community, it should be stated again that trying to provide interoperable voice services when the agencies are already using spectrum spread out over seven different portions of the spectrum and on which, today, during peak hours, there is already severe network congestion that must be approached from a local, then regional, then statewide basis. However, the opportunity, with the 700-MHz broadband network is to design and implement it on spectrum that is unused, therefore, the network can be constructed from the ground up based on the requirement for nationwide interoperability.

Different Types of Systems
In addition to the shortage of radio channels in any given portion of the allocated Public Safety narrowband spectrum, there is yet another issue that makes mission-critical voice interoperability even more difficult. Namely, over the years, each local city, county, and region has built out different types of radio systems using differing technologies. Therefore, even two agencies in the same geographic area operating within the same portion of the spectrum are not always able to communicate with each other. Mission-critical voice communications systems, today, make use of two very different air interfaces. Many are still using the 30-year-old voice technology referred to as analog or FM voice communications. Newer systems have moved to the digital voice standard known as P25 or APCO project 25, which is a standard for digital voice systems. However, even within these two different types of voice systems, there are many variations of how they are deployed. Small rural areas might use a simple radio base station and radios in vehicles. Larger departments might elect to repeat all of the traffic on a given channel using repeater stations, while others have tied a number of repeaters together in what are called simulcast systems. Still others are grouping between five and twenty radio channels together into what is known as a trunked radio system. Not many of these radio systems are compatible with the other types, and, in many areas, the common way to provide interoperable voice communications is to use unit-to-unit, direct, or off-network voice channels so those on the scene of an incident can communicate with each other (provided they are all operating in the same portion of the spectrum).

The chart below reflects the complexities of working toward the goal of providing full interoperable mission-critical voice communications. As it shows, there are many variables that must be considered, and the grants have been provided on a city, county, regional, or state basis with no substantial coordination between grants or agencies receiving the grants. The reality is that the grant funds already provided to Public Safety have advanced the state of interoperability with an emphasis on local-to-statewide interoperability, and so only achieved on a local, regional, and statewide basis.

Possible Combinations of Systems that need to be Interoperable:

Frequency Band	Analog FM	P25 Digital	Base to Mobile	Repeater	Simulcast		Trunked
30-50 MHz	X		X	X	X		X
150-174 MHz	X	X	X	X	X		X
220 MHz	X	X		X			X
450-470 MHz	X	X	X	X	X		X
470-512 MHz	X	X	X	X	X	X
700 MHz NB	X	X	X	X	X	X
800 MHz NB	X	X	X	X	X	X

Public Safety needs the D Block spectrum and it needs federal funding in order to accomplish this goal. If enough spectrum is not made available this time, or if funding is lacking, the only option is to duplicate the mistakes that have resulted in the lack of nationwide interoperable voice and the problem and issues described above.One reason Public Safety must have enough contiguous spectrum on a nationwide basis for broadband services is to make sure that systems being built adhere to nationwide standards, use the same technology, adhere to the same system design and, therefore, provide for full interoperability from the very beginning.

Public Safety can never again be placed in the position it has been in over the last thirty or more years where spectrum is not contiguous, there is not enough to handle the demands in major metropolitan areas, and there is a lack of financial resources to build the nationwide interoperable broadband network that will, for the first time, provide Public Safety with the resources it needs to accomplish the goal of true interoperability while realizing the cost savings of using a worldwide air interface standard (LTE) to provide Public Safety with economies of scale for the first time.

Given (1) the number of different portions of the spectrum in use today for Public Safety mission-critical voice communications, (2) the insufficient amounts of spectrum within each portion of spectrum provided to Public Safety, (3) the multiple types of systems in use within each portion of spectrum and throughout all of the different portions, and (4) the focus on interoperability for mission-critical voice on local, then regional, then statewide, and only recently on a nationwide level, the funds provided to Public Safety have been used wisely and have achieved much improved interoperability within and among voice systems in most localities in the United States.
Conclusions

The Public Safety community has neither wasted the grants allocated since 2001, nor wasted any of the valuable and very limited spectrum provided. The Public Safety community has accomplished much with the little it has had to work with over the years. Today, more regions of the country have interoperable mission-critical voice communications than ever before, but full nationwide mission-critical voice interoperability is not achievable over the course of the next decade or two given the multitude of spectrum allocations, the differences in technologies being deployed, and the lack of a nationwide long-term plan.

We also believe that given enough broadband spectrum (20 MHz) and funding, Public Safety can and will build out a nationwide, mission-critical broadband network that will provide the level of interoperability needed on a daily basis for data and video services. Over time, this network will serve as a model to solve the nationwide voice interoperability issues that remain.

Andrew M. Seybold
CEO and Principal Consultant
Andrew Seybold, Inc.

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