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Rethinking 700 MHz for Public Safety

Though municipal CIOs and public safety leaders have applauded the fundamental idea of setting aside a band for interoperable communications, many large cities and counties now feel that the current plan is fatally flawed.

Emergency Response
Photo: Shaun Ward of the Asheville Police Department showing off Emergency Response Team communications gear. By Jason Sandford. CC Attribution 2.0 Generic


 

Emergency communications save lives.

The unfortunate corollary to this maxim: Communication failures kill. Increasingly attention is being focused on how to increase communication, not only within an emergency response organization, but also across first responders from different agencies. To remain fully connected, key communications officers have often adopted a "bat belt" approach with several communications devices - sometimes a half dozen or more - strapped to their waist. It's a necessity for communicating among the many different federal, state and local agencies' wireless networks during an incident.

Today's IT is increasingly sophisticated, and emergency response agencies and hardware platforms are proliferating, which makes the importance of interoperable communications ever more urgent. Disasters, whether natural or man-made, require close interaction of numerous organizations, but the sad reality is that too many communications systems aren't interoperable; this can lead to on-the-ground snafus, inefficiencies in service provision, and tragedies - as was exemplified in the disaster response after Hurricane Katrina. Within these contexts, the Federal Communications Commission (FCC) is working to open up new radio frequencies to meet first responders' increasing interoperability needs.

Current FCC proceedings focus on creating a nationwide public-safety band for wireless communications among first responders. Ryan Hallahan and Jon Peha sum up the opportunities this rulemaking holds in their 2008 paper, Quantifying the Costs of a Nationwide Broadband Public Safety Wireless Network: "The problems facing the public safety wireless communication systems in the U.S. could be significantly reduced or eliminated through the deployment of a single nationwide network that serves all public safety personnel." On Sept. 25, 2008, the FCC released a Third Further Notice of Proposed Rulemaking after the auction for the proposed public safety band failed to achieve its reserve price. The third notice strives to achieve "the goal of a nationwide interoperable broadband wireless network for public safety entities."

While municipal CIOs and public safety leaders have applauded the fundamental idea of setting aside a band for interoperable public safety communications, details have proven hard to nail down. With the proceeding dragging into its third year, public safety representatives - frustrated with the lack of significant progress and faced with the daily difficulties associated with manynoninterconnected systems - have begun to organize and weigh in. Many of them believe the 700 MHz band is potentially a paradigm-shifter that would let them upgrade their existing infrastructures - adding services, applications, speed and interoperability in one swoop. For municipalities seeking to transition from analog systems to digital networks, the 700 MHz band provides a once-in-a-generation opportunity for an across-the-board upgrade.

Existing Emergency Response Networks Challenges
Today's emergency responders use several communications devices, which are often tailored to the constituencies they serve. Thus, fire responder radios are built to ensure that their equipment doesn't generate electronic sparks, which makes them safe to use during gas leaks. While this is necessary for obvious reasons, problems arise, for example, when fire responder and police radios, operating on different systems, can't communicate effectively with each other. Michelle Geddes, interoperability program manager of San Francisco's Department of Emergency Management, makes the succinct assessment that two major challenges exist today: voice interoperability and data operability. To facilitate this, Project 25 was established to develop interoperable, digital communications standards for emergency responders. "In terms of voice communications, the Project 25 standards are just being ratified, and [a] standards-based product is slowly coming to market," Geddes said. "The cost for the P25 technology is still extremely high, most likely due to the small market for these systems, making it financially difficult for municipalities to afford these networks."

But once affordable hardware is available, there's still the problem of accessing public airwaves. According to Geddes, the 700 MHz public safety proceedings are supposed to solve the problem that "municipalities don't have a viable spectrum option to deploy ubiquitous wireless broadband systems within their jurisdictions." Currently municipalities tend to get by with the creation of systems kludged together from less-optimal spectrum bands - usually 2.4 and 5 GHz (i.e., Wi-Fi) and 4.9 GHz public safety bands. The quick rule of thumb is that the higher the frequency, the worse the propagation characteristics. Therefore, the 700 MHz band offers superior connectivity over distances and through barriers that Wi-Fi could never reach. Experts familiar with the technology say that 700 MHz networks may need only 25 percent of the base stations that are needed for ubiquitous coverage at higher frequencies.

The 700 MHz bands that the FCC attempted to auction (758-763 MHz and 788-793 MHz) were used for over-the-air TV channels 62 and 67. With the digital TV transition - all TV over-the-air broadcasts will switch to digital broadcasting on Feb. 17, 2009 - these channels were vacated. The FCC decided to sell licenses to use these frequencies in an auction with the caveat that the winner of this so-called "D Block" would be mandated to partner with public safety constituencies to make use of the adjacent public safety broadband spectrum (conveniently located at 763-768 MHz and 793-798 MHz). Through a network sharing agreement, the FCC's goal was to create a unified, commercial/public safety network.

In theory, this sounds like a good plan, but the on-the-ground reality proves difficult to overcome. Because there's confusion about the requirements of interoperability and network sharing, the original reserve price was never met, thereby sending the idea back to the drawing board. For public safety constituencies, the notion that a private entity would control the entire infrastructure - and consequently could charge monopolistic rents - has been a major concern. For example, Paul J. Cosgrave, commissioner of the New York City Department of Information Technology and Telecommunications, raised the concern that potential providers have floated the idea of a $49 per month charge per device on the network. Cosgrave said the New York City Police Department has 30,000 to 40,000 people, so for a single year's service the city would have to pay $17.6 million to $23.5 million just for the police department - a base price that almost certainly excludes add-on services and taxes, which could add another $15 million to $25 million to the price tag. These costs make such networks prohibitively expensive for most communities.

Without an alternative, public safety officials are forced to swallow a bitter pill. As Geddes lamented, for communities that lack access to adequate spectrum, "The only other option is for local government to pay monthly service charges for subscription-based wireless broadband service through a carrier-based service like AT&T or Verizon - these services are vulnerable in emergency situations and are typically overwhelmed and unreliable in the event of a major incident."

Cosgrave leads his city's effort to develop a proof-of-concept implementation. According to a letter from the New York City Department of Information and Telecommunications to the FCC, the "project was proposed to serve as a national model for next-generation public safety radio systems." Cosgrave pointed out that the needs of responders often vary by geographic area. As such, a single, nationwide network may be a suboptimal solution for many locations. "An FCC-mandated, one-size-fits-all solution fails to take into account some fundamental facts," Cosgrave said. "In NYC the tall buildings are quite different than, for example, out West with its wide-open areas; a national standard isn't going to work [for everyone]."

Effects of the 700 MHz Auction
While many experts have noted that the 700 MHz auction is a flawed process for maximizing the benefits to public safety, the auction was mandated by a 2005 telecommunications bill sponsored by Arizona Sen. John McCain. This means that the FCC's hands

are somewhat tied - they are required to auction spectrums to the highest bidder, all but guaranteeing that a private entity will manage the network's deployment and ongoing operations. Municipal leaders fear that the build-out timeline of 15 years is so long that it's likely any technology deployed immediately would be obsolete by the time many portions of the network are actually built, which would create the potential for future interoperability headaches down the road. In addition, second- and third-tier communities could be waiting until 2020 or beyond before the network is deployed in their areas.

Ideally the 700 MHz spectrum provides many opportunities for local communities to deploy state-of-the-art wireless networks. Geddes said this spectrum "offers the opportunity for local governments to run more efficiently and effectively, as well as gives first responders enhanced tools to respond to emergencies." According to Barry Fraser, telecommunications policy analyst for the San Francisco Department of Technology, "We would want to be able to use it on a daily basis for general public safety: policy, fire, EMS [emergency medical services]."

Municipalities envision public safety applications that facilitate everything from helping police by sending videos of crimes or events to an incident command center, to aiding building inspectors and fire responders with real-time updates of mapping information and the ability to download building blueprints, to helping paramedics and doctors with remote medical diagnoses and treatments.

However, the network envisioned by the FCC is single-purpose, whereas public safety officials have been interested in mixed-use networks that supply different services and applications to various users, with a focus on local needs. For many municipal, public safety officials, local network control facilitates local decision-making vis-à-vis who has access and what applications are deployed. In Geddes' opinion is at odds with the single-use, public safety network mandated by the FCC: "A whole host of other government services, like automatic meter reading, transportation enhancements for automatic fare collection and passenger counting, wireless bill pay and wireless permitting could be deployed over the network at little incremental cost to the municipalities. The network could improve the effectiveness of local government operations, not just public safety, if it were left in the hands of municipalities."

Telling it to the FCC
While private interests demanded a 15-year build-out schedule, local municipal leaders are ready to begin deploying networks immediately. "I would be deploying my wireless network on 700 MHz if it were available tomorrow - it will enable us to do things we've never been able to do - that's the bottom-line," said Donald Denning Jr., public safety CIO of Boston.

City officials are deeply concerned about the way the 700 MHz public safety band has been handled thus far. Cosgrave declared the auction process "flawed" because of its focus on a single, national license. While the regional licensure is seen as a step in the right direction, William Oates, CIO of Boston, provided a succinct analysis of the main concerns officials have raised: "Our biggest issue is to have access to this spectrum so that, from a city and regional level, we can solve the information-sharing issues in front of us. If we have to wait for the service provider, we're not sure if this will be a viable option."

Todd Sander, director of Government Technology's Digital Communities program, organized an event in Miami in June 2008 that brought together representatives from major metropolitan areas. This meeting revealed that emergency responders countrywide were concerned about the same issues. Fundamentally there was tension between the profit-driven focus of commercial enterprises and the public safety goals of emergency responders. "We had little confidence that something useful would come out of that for the city - a commercial-quality network likely would not be good enough in an emergency," Sander said.

Subsequently, public safety officials and CIOs from many of the largest cities and counties

in the US banded together through the Digital Communities 700Mhz working group to protest the FCC's new proposed rules for the 700MHz D-Block auction. In a letter to FCC Chairman Kevin J. Martin, they argued that the FCC plan to pair the public safety spectrum with the commercially auctioned "D-Block" of spectrum "will fall far short of satisfying a once in a life time opportunity to fix the weaknesses in the core structure of public safety spectrum." And they added, "We do not believe that the current plans to auction the D-Block will in any way be a solution to the public safety wireless broadband needs in our communities."

Efficiencies are a main reason why local decision-makers are so interested in the 700 MHz band. "Convergence and interoperability are the future of municipal IT," Geddes wrote. "It is the ability for every city agency ... to access the information they need, wherever they are. It is the ability for any municipal worker to take advantage of existing assets or new technology resources to perform their functions effectively."

Oates said, "Optimizing resources is a high priority, as are speed of deployment and ease of maintenance." He concluded, "We have a need to deliver data to public safety equipment in ambulances, fire apparatus and cruisers - we need a broadband solution for the mobile world." He said the city examined Wi-Fi and 4.9 GHz radios, but they aren't adequate for next-generation networking. The failure of the first D Block auction was problematic because it slowed down a process that many feel has been dragging. "We have a sense of urgency," Oates said.

Denning concurred that Boston is ready to deploy these next-generation communications networks immediately. "We have a fairly good idea for the propagation characteristics because of our 800 MHz network [and want a 700 MHz network] within the next 24 months." In the meantime, as Oates said, "We'll do this with 2.4 or 4.9 [GHz] if we can't get 700 MHz, [but] height and penetration into buildings would be greatly improved with 700 MHz."

While municipal authorities are ready to begin building next-generation networks immediately, in the end, it may come down to a question of political expediency rather than public safety. Between the recent financial meltdown that has undermined attempts to auction spectrum licenses and the political transitions happening in Washington, D.C., it's unclear how quickly the FCC will move to create this interoperable public safety band.

Municipal representatives suggest that the FCC should set some basic interoperability standards and then let local governments build out immediately the networks they need. While the FCC faces a mandate to auction some of the spectrum, many municipal IT professionals feel that the FCC should provide early access to the spectrum for those communities that are ready to deploy now.

In New York, Boston, San Francisco and elsewhere, officials are eager to deploy public safety networks. By setting basic requirements, the FCC could ensure that these systems would interoperate across municipal boundaries without further slowing the speed of implementation. "We already operate an 800 MHz wireless network - we have the towers and backhaul infrastructure in place. It would just be a matter of buying the radios, installing them and connecting them to our backhaul," Fraser said. "The locations we already have selected would equate very closely to the layout you would need for a 700 MHz system."

Cosgrave sums up the concerns of many public safety officials: "We're very uncomfortable about [the auction process]; it's set up for carriers and doesn't really meet the basic standards for public safety networks."

After Hurricane Katrina, many of the lessons learned during disaster recovery efforts were reported back to the FCC. Despite those proposed recommendations, local municipalities have been forced to implement suboptimal emergency wireless solutions while they wait for the FCC to move forward with the 700 MHz public safety band proceedings. In the end, many of our emergency response wireless networks remain noninteroperable - worrying officials who are all too aware of the consequences of noncommunication.

Sascha Meinrath is a research director at the New America Foundation and a regular contributor to Digital Communities magazine. He worked with the Yale University Fire Marshal's Office for three-and-a-half years (where he carried his own telecommunications bat belt) and coordinated the Hurricane Katrina Community Wireless Emergency Response Initiative.