MAKING THE CALL ON A NATIONAL PUBLIC SAFETY WIRELESS NETWORK A white paper from L.R. Kimball May 2010 866.375.6812 info@lrkimball.com www.lrkimball.com ARchitecture Engineering Communications technology aviation civil Construction services data systems environmental facilities engineering geospatial networks public safety transportation L.R. Kimball (SM) is a service mark of CDI-Infrastructure, LLC.
Page 2 Establishing a national interoperable network is a goal that would make public safety operations more effective and flexible but is complicated by costs, commitments and commercial interests. A National Broadband Wireless Network for Public Safety Rarely has the reallocation of broadcast frequencies generated such diversity on opinions from varying perspectives as the Federal Communications Commission s current effort to reassign the 700MHz public safety broadband spectrum. The confusion centers on the FCC s vision to establish a nationwide interoperable public safety broadband wireless network for first responders. L.R. Kimball believes establishing a national interoperable network is a goal that certainly would make public safety operations more effective and flexible. This summary of the history and current activities behind the assignment of the spectrum and choice of technologies is intended to assist our clients understanding of the opportunities and applications that will be presented by these activities. There is agreement that public safety agencies need more bandwidth for wireless communication to support high-speed data and video. Next generation 9-1-1 networks focus on upgrading capabilities relating to calls coming into PSAPs. However, the wireless broadband network foreseen by the FCC would give expanded capacity to dispatchers, providing a pathway for data intensive information transport to support applications such as video, maps and graphics, real-time information sharing, texting, IM and other services. The Public Safety Spectrum Trust (PSST) a not-for-profit coalition of public safety associations and the FCC-designated national public safety broadband licensee has pointed out that agencies increasingly are relying on wireless delivery of data for officers and other responders in the field. PSST asserts that public safety should be able to deliver secure text messages, documents, photos, diagrams and streaming video without relying only on commercial services. A Hardened, Flexible Network in the 700MHz Band In an August 2009, presentation, PSST Chairman and former FBI Deputy Assistant Director Chief Harlin R. McEwen affirmed that public safety s goal is a wireless broadband network as envisioned in the proposed 700MHz Nationwide Public Safety Wireless Broadband Network, that would include: Broadband data services like photos, video and texting Hardened infrastructure that can withstand local natural hazards, including strengthened towers and backup power with fuel supplies Nationwide roaming and interoperability for local, state and federal public safety agencies and related services Access to the Public Switched Telephone Network (PSTN) similar to current commercial cellular services
Page 3 The FCC anticipates that the national network will be built on a county and regional basis with each jurisdiction bidding the system locally. Push-to-talk, one-to-one and one-to-many radio capability to back up traditional public safety land mobile voice systems Access to satellite services where terrestrial services do not exist or are out of service The FCC s plans to provide the necessary bandwidth to allow for such spectrum-consuming services have focused on the 700MHz band within the radio spectrum, a portion of the spectrum that is 60MHz wide. Until recently, the lower frequencies within this band had been allocated to analog TV channels 52-59 and the higher frequencies to channels 60-69. In 2006, however, Congress mandated that television broadcasters clear the 700MHz band, and these stations all moved to digital broadcasts through a different portion of the spectrum. The 700MHz band incorporates two adjacent sections of spectrum. One of these sections, 10MHz wide, was allocated to traditional narrowband land mobile radio voice systems. It is situated immediately adjacent to the 800MHz band that has been used by public safety agencies and thus makes adding channels to these existing 800 MHz systems a relatively simple proposition. Higher Data Speeds and 4G System Flexibility A second 10MHz slice initially was envisioned for wideband rather than broadband data to provide public safety agencies with wider channels that would allow higher data speeds than previously available. At the same time as these reallocation plans were being developed, commercial wireless carriers made clear that they were moving toward fourth-generation (4G) systems designed specifically for broadbandtype transmissions of video and other data. The FCC and public safety agencies began considering the possibilities for using these same technologies to support public safety broadband applications, and in 2007 the FCC decided to designate this 10MHz slice of the 700MHz band strictly for broadband use. This same rulemaking also determined there would be a single licensee of the spectrum; with the idea that a single licensee representing all of public safety would insure selection of a common technology and platform for constructing the nationwide interoperable network. In late 2007, the Public Safety Spectrum Trust (PSST) was designated as this licensee. The 2007 rulemaking that modified the 10MHz of public safety spectrum from wideband to broadband use also defined a plan to create a public private partnership to construct a public safety broadband network, and making available an additional 10MHz of spectrum, known as the D Block. The D block was placed with the other upper 700MHz commercial spectrum block (A C) blocks for auction in Auction #73 in 2008. Unlike other portions of the commercial spectrum, however, D Block came with some digital strings attached. ARCHITECTURE ENGINEERING COMMUNICATIONS TECHNOLOGY AVIATION CIVIL CONSTRUCTION SERVICES DATA SYSTEMS ENVIRONMENTAL FACILITIES ENGINEERING GEOSPATIAL NETWORKS PUBLIC SAFETY TRANSPORTATION
Page 4 17 counties and cities have submitted waivers to the FCC requesting permission to begin construction of their own broadband systems on the PSST spectrum block, regardless of the D-block outcome. Graphic Showing the current 700MHz Bandplan, and assignments for Public Safety narrowband operations, Public Safety Broadband allocation and the D Block. The bottom line shows the original TV channel designations. The wireless carrier that won the bid would need to commit to working with the public safety community to build a national public safety network that used the D block frequencies. Furthermore, the network would need to be sufficiently robust for the winning carrier to sell off excess capacity to businesses and other users to provide funds to help support the public safety portion of the network. In the 2008 auction, the FCC set minimum bid amounts for each spectrum block. The minimum bid for the D block spectrum was set at $1.3 billion. There was only one D block bidder, who put forth an unacceptable offer substantially under this minimum. The FCC s plans for both the D block and PSST block were put on hold in the wake of the unsuccessful auction. A decision was made not to begin construction of systems in the PSST block until the D Block issue was finally resolved. A Special Request from Public Safety Since then, public safety agencies and their associations have been requesting that the FCC reallocate the 700MHz band and devote all of D block plus the initial PSST 10MHz allocation to public safety. These public safety groups argue that 10MHz is barely enough bandwidth to operate the 4G wireless systems planned for the national network. These systems are especially designed to handle the transmission of video and other high-speed data. Public safety says it needs the additional 10MHz to fully take advantage of the potential speeds that current wireless broadband technologies can support. PSST reports, for example, Many local and state public safety agencies are implementing or planning to implement locally managed and licensed land mobile systems in the other 10MHz of this spectrum for additional mission-critical public safety narrowband voice channels. Due to the lack of action by the FCC, 17 states, counties and cities have submitted waivers to the FCC requesting permission to begin construction of their own broadband systems on the PSST spectrum block, regardless of the D block outcome. All of these waiver requests contain the provision that these systems will utilize the technology designated by the FCC, and meet the FCC s final interoperability requirements. A Change in Direction, An Uproar from Public Safety Prospects for additional public-safety bandwidth became even murkier in February 2010, when FCC Chairman Julius Genachowski announced that the National Broadband Plan, would include plans by the FCC to
Page 5 A large list of agencies and organizations have announced their support of the re-allocation of D block bandwidth solely to public safety. auction the D block for commercial purposes without any of the public safety requirements that had been incorporated in the first auction. Instead, the FCC envisions that public safety agencies will be granted access by the commercial carriers to the entire 700MHz band for roaming and priority access. However, the new FCC stance did not require the winning bidder on D block to partner with the PSST (the public safety broadband licensee). Chairman Genachowski s position amplified and further defined the opposition to this allocation in the public safety community. Earlier, PSST Chairman McEwen had contended that commercial services often are not available when public safety needs them most. Current commercial services also lack the security features, priority access and coverage needed by public safety. In a paper released a month before Chairman Genachowski s announcement, Dr. Alan R. Shark, executive director of the Public Technology Institute in Washington, D.C., agreed, noting, Public-safetygrade service demands special requirements that simply cannot be found in commercial systems. Commercial providers do not offer hardened network operations centers or hardened towers/repeaters, power surge capabilities, or quality-of-service outside of major Interstates and other high-density population centers. These voices were rapidly joined by municipal groups that also felt that moving forward with auctioning the D Block to commercial interests would present considerable challenges for the delivery of the enhanced public safety information. In mid-april 2010, the chairpersons of four committees in the U.S. House and four in the Senate received a joint letter from the National Governors Association, the National Conference of State Legislatures, the Council of State Governments, the National Association of Counties, the National League of Cities, The U.S. Conference of Mayors and the International City/County Management Association, all supporting re-allocation of D block bandwidth solely to public safety. The letter asked the FCC to abandon plans for a commercial auction of D block. The letter asserted, Allocating the D block directly to public safety is the only way to ensure a robust, modern and reliable nationwide interoperable network. Furthermore, the letter claimed, While the Federal Communications Commission s National Broadband Plan proposes to provide public safety roaming and priority access on other commercial 700MHz networks for a fee, this proposal relies on untested technologies and new regulations that cannot ensure reliable and resilient communications capabilities to meet stringent public safety needs. A Lower Price Tag for a Shared Network In fact, the FCC s April, 2010, estimate of a price tag as low as $6.3 billion to build the national network is based on an assumption that the ARCHITECTURE ENGINEERING COMMUNICATIONS TECHNOLOGY AVIATION CIVIL CONSTRUCTION SERVICES DATA SYSTEMS ENVIRONMENTAL FACILITIES ENGINEERING GEOSPATIAL NETWORKS PUBLIC SAFETY TRANSPORTATION
Page 6 The FCC sees its plan as an opportunity for commercial carriers to share infrastructure with public safety to lower the cost of building the network. network will operate in conjunction with a commercial carrier. Public safety agencies would pay a monthly fee lower than commercial rates for use of the network. Industry sources observe that, if the public safety network and a commercial network are deployed simultaneously, economies of scale would accrue from installation teams visiting each site once instead of twice to deploy infrastructure. If the national broadband wireless network were to be built from scratch, it is estimated that the cost would more than double to $15.7 billion. The FCC further estimated that operating costs for the first decade of a shared network would total $6 billion to $10 billion, but a separate network would cost $25 billion to $30 billion over that period. Reaching an early decision on this key issue is crucial. Verizon, one of the likely partners in a sharing arrangement, expects to launch its 4G service with Long-Term Evolution (LTE) technology by the end of 2010. The industry also expects AT&T to launch 4G service soon. If these companies move ahead with their network build-outs without a resolution to the sharing issue, public safety and the FCC may miss their opportunity for network and cost sharing. An Unresolved Difference of Opinion The FCC contends that public safety does not need the D block spectrum of 10MHz, because it will have access to the entire 80MHz of the commercial carrier market far more than proposed in the initial FCC planning. Public safety leaders argue that they need the entire 20 MHz allocation including the D Block, in order to assure they have the dedicated spectrum needed to fully take advantage of LTE s capabilities, and because of the uncertainties that commercial carriers will fully support the specific needs and priorities of public safety. The FCC sees its plan as an opportunity for commercial carriers to share their infrastructures with public safety to help lower the cost of building the network. In a technical paper released in April 2010, the FCC states: The National Broadband Plan s vision is to create a communications system that allows public safety agencies to take full advantage of cutting-edge broadband technologies. It is therefore essential that public safety agencies have access to commercial technologies, ruggedized for public safety use. This leveraging of commercial technologies will enable public safety agencies to achieve greater communications capabilities, but at much lower costs. The FCC envisions the national public safety wireless broadband network founded on a four-tier infrastructure. The foundation would be a hardened dedicated public safety network providing reliable service across most of the country. This public safety network would be supplemented by commercial wireless networks on which public safety can roam for a reasonable fee and gain both capacity and resiliency. Localized coverage will be improved through another tier composed of fixed microcells and distributed antenna systems, such as those that provide indoor wireless coverage in office buildings. The final tier consists of equipment caches
Page 7 The FCC sees the national public safety wireless broadband network founded on a hardened network providing reliable service across a wide area. that enable fire trucks, police cars and ambulances to become mobile picocells after a disaster. The FCC anticipates that this national network will be built on a county and regional basis. Each jurisdiction would apply for a portion of the funding available, agree to FCC requirements, bid the system locally and put in place agreements for roaming and access. Everyone would use the same core technology, which is being defined by a new Emergency Response Interoperability Center (ERIC) within the FCC. Latest Happenings On May 11, 2010 the FCC acted on a total of 21 waivers which had been submitted - the original 17 plus 4 others -states, counties and cities, requesting permission to proceed to build out their own broadband systems on spectrum currently licensed to PSST. The FCC s grant included several requirements that these entities must meet: Obtain a lease agreement from PSST to use the spectrum using the FCC-provided lease document. Pay lease fee to PSST to cover cost of administration of the leases and spectrum Federal Government users are permitted FCC Emergency Response Interoperability Center (ERIC) to establish the technical criteria. Users must employ Long Term Evolution (LTE) technology All networks be interoperable Present concrete and viable plans to ERIC Inter-system frequency coordination is routed through ERIC Roaming must be available between systems Governance of systems at a state level for coordination and intraoperability planning in concert with ERIC Deployment is at the agencies own risk Report to ERIC within 30 days of approval and quarterly thereafter the status of planning, funding, and deployment activities for the proposed system Future waiver requests will be accepted and follow the waiver process that was used for these applicants The waiver applicants have significant milestones to be met prior to granting of the waivers. More detail may be found in FCC Order 10-79 dated May 11, 2010. On May 13, NTIA announces an opening of an application window to accept applications for funding of these 17 Public Safety systems under the Broadband Technology Opportunities Program (BTOP) funding. This is a 30 day window from June 1 to July 1, 2010. ARCHITECTURE ENGINEERING COMMUNICATIONS TECHNOLOGY AVIATION CIVIL CONSTRUCTION SERVICES DATA SYSTEMS ENVIRONMENTAL FACILITIES ENGINEERING GEOSPATIAL NETWORKS PUBLIC SAFETY TRANSPORTATION
Page 8 L.R. Kimball believes that once regulatory and funding commitments are in place, we will see a widespread movement forward in procuring equipment. The L.R. Kimball View The final decision on the disposition of the D Block remains up in the air. Without congressional action, the FCC remains obligated to auction this spectrum to commercial use. Recently, a bipartisan group in the U.S. House Homeland Security Committee introduced legislation requiring the FCC to reallocate the D block to public safety, but the measure s future is uncertain. This legislation has been endorsed or supported by most major Public Safety organizations including APCO. The National Emergency Number Association (NENA) supports similar legislation but opposes this bill because it fails to address the necessary funding. L.R. Kimball believes that the United States is moving inexorably toward some type of national wireless public safety network. Already 21 cities, regions and states have been granted waiver approval for local or regional early-build networks that will use the spectrum licensed to the PSST. Many of these jurisdictions are likely to be ready to roll out applications that require wireless broadband and a 4G network. In other instances, the implications for communities will be somewhat more long term. L.R. Kimball believes that there is clearly a pent up demand for wireless broadband capable of supporting public safety applications and information sharing. As the regulatory and funding roadblocks continue to be addressed over the next several years we will see a widespread movement forward in procuring equipment and beginning to implement systems and technology for these networks. L.R. Kimball believes that the adoption by public safety of LTE the same 4G high speed technology as commercial carriers are rolling out will bring huge benefits, including lower costs and economies of scale as well as potential roaming and sharing of resources. At the same time, this technology and the potential for shared resources with commercial providers is uncharted territory for most jurisdictions. From a technology standpoint, planning and design of these networks can be substantially different than traditional land mobile radio systems. The huge capacity potential and likelihood of regional level networks that integrate with commercial systems will also require partnerships and governance plans and agreements that have not often been addressed in legacy system planning. For more information and updates on plans for a national public safety broadband wireless network, information on LTE, or help with developing any aspect of your plans for wireless broadband please visit L.R. Kimball at www.lrkimball.com or contact L.R. Kimball Senior Public Safety Consultant Kevin McGeary at 814.867.4566. ARCHITECTURE ENGINEERING COMMUNICATIONS TECHNOLOGY AVIATION CIVIL CONSTRUCTION SERVICES DATA SYSTEMS ENVIRONMENTAL FACILITIES ENGINEERING GEOSPATIAL NETWORKS PUBLIC SAFETY TRANSPORTATION L.R. Kimball (SM) is a service mark of CDI -Infrastructure, LLC. CT.T74.2010-05.WP008