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APCO, Motorola Disagree on Level of Competition in Public Safety Communications

The Association of Public-Safety Communications Officials (APCO) and Motorola, long the top provider of public safety radios, disagreed on the state of industry competition, in filings on an Aug. 19 FCC Public Safety Bureau public notice. Motorola also took issue with the notice’s characterization of the market as one where “first responders rely on communications systems supplied by a small number of equipment providers to support mission-critical communications.” Questions about competition in the public safety equipment market were raised by leaders of the House Commerce Committee in a June 30 letter to FCC Chairman Julius Genachowski.

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"Instead of addressing the real obstacles to interoperability, the Public Notice focuses on public safety equipment competition,” Motorola said. “Unfortunately, the Public Notice fails to acknowledge that vibrant competition already exists in this sector: competition driven by the Project 25 suite of interoperability standards.” The P25 standards “have created a competitive environment in which approximately thirty manufacturers and providers offer a wide array of equipment and services to public safety customers."

The Public Safety Bureau is “misguided” in its attempts to draw a comparison between the commercial market and the smaller public safety market, Motorola said. “There are considerably more customers with relatively straightforward communications needs in the commercial market, which explains why some vendors may choose to instead serve that sector rather than the smaller public safety marketplace that has more exacting technical and operational demands.”

But APCO said the FCC should promote competition in the sector. “Historically, the public safety radio equipment marketplace has consisted of one vendor with a majority of the market, one or two strong competitors, and several companies with smaller shares of the market,” APCO said. “Even when considered part of the larger private land mobile radio market, the number of users and potential purchasers has simply been too small to attract companies willing to commit substantial resources for research, development and marketing of equipment that has few if any applications in other markets.”

Competition on its own could make public safety communications less interoperable, APCO warned. “Competition must go hand-in-hand with appropriate and widely-accepted equipment standards to ensure interoperability across competing manufacturers and product lines,” the group said. The FCC should also take steps to make sure users buy equipment meeting these interoperability standards, APCO said. But standards shouldn’t be “overly intrusive” and “only that which is absolutely necessary for interoperability should be standardized,” APCO said.

"As the FCC examines requirements for a national broadband market, it should learn from the past,” said Alcatel-Lucent. “Public safety in the United States embraced the use of P25, while most countries throughout the rest of the world embraced the use of Terrestrial Trunked Radio (TETRA) -- a choice which significantly reduced the total addressable U.S. market,” the equipment maker said. “As a result, the choice did not provide the ability to advantage the market in the U.S. with ‘economies of scale’ and diversity of supply chain.”

The National Emergency Number Association said the FCC should assure that devices designed to operate on the 700 MHz D-block are fully interoperable and work outside of the 700 MHz LTE coverage area. “At a minimum, they must be backward compatible with 3G commercial networks,” NENA said. “For many years, commercial 3G deployments will cover a much larger geographic area than 700 MHz LTE deployments.” NENA also asked the FCC to “keep in mind” the need public safety answering points have for “innovative, accessible, reliable and affordable equipment” to receive and forward emergency calls.

Cellular South said the notice speaks to the need for rules that require that wireless devices in general will operate across 700 MHz spectrum. “Public safety personnel will benefit from network redundancy, lower costs and better technology where many equipment manufacturers and service providers are competing to provide the best services at the lowest cost,” the carrier said. “But to achieve this end, the Commission must put in place a regulatory scheme that requires interoperability of equipment and devices operating on compatible technologies -- including LTE technologies on the verge of deployment in the 700 MHz spectrum."