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Public Safety Rewrites 700 MHz Network Requirements Document

Public safety has gone back to the drawing board to revise its requirements for the nationwide broadband wireless to be built by private industry, according to several people involved in the process. The first draft released late last month was too restrictive and could have possibly resulted in there being few bidders for the 10 MHz nationwide license, they said. Under FCC rules, the D-block winner must enter into a network sharing agreement with public safety. The NSA calls for private industry to build public safety’s interoperable broadband network and will give public safety access to the commercial spectrum during times of emergencies.

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Late last month, the National Public Safety Telecommunications Council released the first public safety requirements document. While NPSTC won’t be the entity that private industry will work with, the document was widely seen as reflecting public safety’s desires and was cited by the Public Safety Spectrum Trust as something it was considering as it develops the actual requirements document. PSST is expected to be the public safety licensee and it hopes to release its requirements document next week (CD Nov 6 p7).

The fact that NPSTC is revising its first document isn’t a surprise since both industry and public safety officials think the first document was never supposed to be seen as a final version. Unlike a request for information or request for proposal where the contracting party sets out its requirements and vendors fill it, this time it has been a transparent process, they said. In an RFP no one gets involved in the “sausage factory” of deciding what should be involved, but this time it was done in a transparent way, said one expert.

The FCC didn’t give either side guidance in its rules except to say that both public safety and the eventual D- block winner would need to negotiate an NSA, and if disputes arose, commission staff would arbitrate. Since the negotiations will begin after the auction, many on both sides believe that public safety needs to proactively say what it expects. Potential bidders need to know before the auction what public safety expects from the 700 MHz network especially since there is a 10 percent default penalty if negotiations fail, many said. Ten percent of the billions expected to be bid on the spectrum is a lot of money, said one industry insider. To further help private industry, PSST is planning a bidders conference Nov. 28. Auction short forms are due Dec. 3.

The Oct. 26 “Public Safety Requirements” document should be a “what” document not a “how” document, said one source. Another agreed. Parties differ as to whether NPSTC achieved this objective. For example, the document shouldn’t have been seen as leading toward a specific technology or air interface since at this stage public safety doesn’t know who will win the license. Unlike in other parts of the world where the commercial industry uses one air interface, in the U.S. different carriers use different technologies. For public safety, however, the opposite is true. Public safety generally uses the same technology. This dichotomy is one of the issues that NPSTC is working through as it revises its document, said sources.

While 54 pages of details seem like a long wish list, a lot of the items fall into a few categories: coverage, hardening, redundancy, reliability and availability. These are areas that many in public safety have had complaints about over the years in connection with using commercial networks. According to several observers, private network providers want to know what public safety wants to see accomplished, not how it expects them to accomplish it.

Another issue being discussed is whether it would be better for public safety if an incumbent or non-incumbent won the D-block. Those favoring incumbents point out that these carriers have built and operated networks. Those favoring new entrants say they're not tied to old ideas. In this debate, public safety will have little say and that scares some public safety advocates.