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FCC White Paper Counters Public Safety Push for D-Block

An FCC white paper released Tuesday builds a case against giving public safety direct access to the 10 MHz D-block, which the National Broadband Plan proposes be sold in an upcoming auction. Public safety groups have waged a ferocious battle against the NBP’s recommendations.

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"Our goal is to bring true interoperable mobile broadband communications to America’s first responders,” said Jamie Barnett, chief of the FCC Public Safety Bureau. “The FCC study shows how we can maximize capacity, performance, reliability and resiliency of public safety broadband communications even in the most extraordinary emergencies when life-saving response efforts are underway and communications demands are at their peak.” Jon Peha, FCC chief technologist, is the lead author of the report.

Public safety already has 24 MHz of 700 MHz spectrum, the paper notes. “This 24 MHz allocation makes public safety among the largest holders of spectrum in the 700 MHz band,” the paper said. The FCC designated 10 megahertz for broadband use. “Even if one only considers this 10 megahertz of spectrum allocated for broadband use, public safety would have 200,000 users per megahertz,” it said. “This is considerably fewer users than the estimated number of users that commercial broadband providers will support in an equivalent amount of similar spectrum. Accordingly, 10 megahertz of spectrum is a relatively large allocation for public safety’s routine communications traffic. Furthermore, our analysis demonstrates that 10 megahertz of spectrum will provide significant capacity for the public safety broadband network on a day to day and emergency basis."

The paper examines several scenarios, including a “dirty bomb” attack at Manhattan’s Penn Station, a bridge collapse in Minneapolis, and a hurricane in Houston. “This analysis determines that a system deployed in 10 megahertz of spectrum with the number of sites proposed in the FCC Cost Model would have sufficient capacity for estimated broadband communications in each of these scenarios,” the paper said. Overall, public safety already has 97 MHz allocated for its use across the spectrum including 60 MHz that can be used for broadband, the paper said: “Using 2010 data, the allocation of spectrum per user for public safety is now 25 times that of commercial providers.”

But, the paper argues, giving public safety the D-block “would not guarantee public safety sufficient capacity for the worst emergencies. Priority access and roaming onto commercial bands can provide public safety with far more capacity during periods of greatest need.” At times, even an additional 30 MHz of spectrum would not be enough to guarantee public safety has all the spectrum it needs, the paper contends. “In these cases, it is critical that public safety have access to additional broadband wireless networks, such as those operated by commercial network operators,” the paper said. “Guaranteeing access to these networks will enable the public safety community to have access to substantially more capacity than a dedicated network can provide without vastly more dedicated spectrum than is under consideration.” The model proposed in the NBP would make at least 50 or 60 MHz of additional spectrum immediately available to public safety, the paper said.

The 700 MHz network proposed in the NBP calls for the deployment of 44,000 sites nationwide, the paper said. “This would give the public safety network at 700 MHz a site density comparable to commercial providers, and a total site count greater than all but two of these providers,” the FCC said.

David Farber, former FCC chief technologist, said the FCC deserves credit for a plan that offers a solution beyond throwing more spectrum at a problem. “They looked at the demand, looked at what was available and I thought came up with a very intelligent approach,” Farber said. Some public safety groups are “rooted in the old way of thinking,” he added. “There will always be protests against anything you do.”