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PSA Reacts to Continued Inaccuracies & Misrepresentations in Second House Subcommittee Hearing



Correcting the Record as Myths Perpetuate

PSA Reacts to Continued Inaccuracies & Misrepresentations in Second House Subcommittee Hearing

June 2, 2011 Alexandria, VA – As another hearing is undertaken, and in the aftermath of a second hearing on spectrum policy held last week by the House Energy and Commerce Subcommittee on Communications, the Public Safety Alliance today responded to statements, reports and assertions made by those who continue to question public safety’s need for spectrum and funding to achieve nationwide mission-critical broadband capabilities. This deep-seated challenge stems from a fundamental misunderstanding of public safety:

(1) ASSERTION: $13 billion has been provided by the federal government and spent by state and local governments to attempt to achieve interoperability without success since 9/11: FALSE.

The TRUTH is that the CRS Report from March 18, 2011 by Linda Moore is inaccurate and is based on a on a misinterpretation of a series of NEMA reports. The reports were mischaracterized as estimates of actual government expenditures, when they were actually surveys of state EMA’s on how much they estimated it would cost to achieve statewide interoperability. The CRS Report asserts, “…it seems difficult to prepare an accurate accounting of what has been spent and how, and CRS was unable to locate such an accounting. It is likely however that federal grants to improve emergency communications have exceeded $13 billion over the period 2001-2010, using the $11 billion for 2001-2006 reported by NEMA as the baseline. (See NEMA letter to CRS as attached.)

(2) ASSERTION: 24 MHz of spectrum was provided to public safety in response to the 9/11 Commission Recommendation: FALSE.

The TRUTH is that 24 MHz was sought, identified and secured to relieve the dangerous congestion and interference on existing Land Mobile Radio (LMR) voice and data communications in 1996 with the help of the Big Seven state and local associations in the wake of the interoperability problems experienced by first responders at the site of the Oklahoma City, OK bombing by domestic terrorists in 1995. Then-Senate Commerce Committee Chairman John McCain led the fight to secure the 24 MHz, but only obtained a “soft” date for broadcasters to clear those channels as part of the digital TV transition.

In 2007, Congress finally set a “hard” date for clearing this spectrum, and by that time, broadband was a new technology requiring large swaths of contiguous spectrum that achieved greater efficiency. Therefore, the FCC, with support from public safety, issued and Order to repurpose 10 of the 24 MHz for broadband. The FCC then sought to establish a public-private partnership with the D Block auction winner to build out a 20 MHz system that would meet public safety’s needs.

(3) ASSERTION: Public safety, with a subscriber base of roughly 2 million, has almost 100 MHz of spectrum in its possession, which is as much or more spectrum than most commercial carriers possess, who have anywhere from 10-20 million users: FALSE.

The TRUTH is, like land ownership, some spectrum is worth more than other spectrum, so it is inaccurate to compare amounts without comparing use and quality of the spectrum held. While public safety has almost 100 MHz of spectrum, 50 MHz lies in the 4.9 GHz band, and is of little-to-no value in achieving in-building penetration or longer distance communications. In fact, its sole value with existing technology is for the creation of mobile hot-spots, not for the build-out of a nationwide broadband network.

Remember that in-building penetration was a major communications flaw that costs hundreds of firefighters and police officers their lives on 9/11, as well as untold amounts thousands of civilians who were relying on those first responders for direction, when they were unable to communicate with their colleagues on the ground outside the World Trade Center to get accurate information and updates on the deteriorating situation. None of the existing spectrum in public safety’s possession is currently for data and video, other than the 10 MHz repurposed for this, and that with the expectation of coupling it with D Block. The 50 MHz in the 4.9 GHz band provided for public safety has limitations that are operationally and financially insurmountable for wide area mobile coverage. It is also the truth that Commercial carriers possess or have been allocated more than 500 MHz of spectrum.

(4) ASSERTION: Public safety has not achieved nationwide voice interoperability, despite a major focus by the federal government and significant federal resources since 9/11: TRUE.

The TRUTH is public safety has greatly enhanced interoperability, yet we have not achieved nationwide, cross-border, and ubiquitous mission-critical interoperable voice communications. Several factors have contributed to this problem. The primary, reason is that much of the spectrum allocated to public safety over the past 70 years has been allocated in small splices across five different spectral bands. Much of the spectrum is heavily interwoven with other licensees that include broadcasters, business-industrial licensees and federal government users, which contribute to the interoperability issues surrounding public safety communications. Allocating the D block and pairing it with the existing 10 MHz that was repurposed for public safety broadband would provide public safety with a big enough swath of contiguous spectrum to achieve mission-critical broadband, finally well-equipped to protect our nation.

The 700 MHz band is uniquely suited for public safety, as the spectrum has excellent propagation characteristics, which reduces the cost of building out the network, while providing significant in-building penetration. Public safety would like nothing more than to realize the National Broadband Plan’s (NBP) vision of creating a national public safety architecture to migrate all forms of communication to the 700 and 800 bands while achieving converged networks of mission-critical voice, video and data. This would allow public safety to replace antiquated, disparate, proprietary and voice-only systems with mission-critical public safety broadband systems for nationwide interoperability.

Additionally, Senate bill language would allow secondary users on the public safety broadband network, which would expand the subscriber base and achieve economies of scale with device and application development. Public safety subscribers should be classified as “super-users,” meaning each public safety user is capable of using twice the amount of the network’s capacity compared to “normal or average users,” especially during emergencies that are centered around one or two cell sectors.

In order to extend the economies of scale beyond the US and North America, the APCO Global Alliance recently adopted LTE Broadband as the worldwide standard for public safety, meaning the US market will benefit from the larger world market with increased competition in devices, applications and infrastructure.

(5) ASSERTION: The National Broadband Plan recommends auctioning the D block to a commercial provider to allow for public-private partnerships: FALSE.

The TRUTH is, in recommending the commercial auction of the D block, the National Broadband Plan specifically removed public-private partnership requirements, which would have forced the successful D Block bidder to provide ruthless preemption on the spectrum in the event of an emergency. This, along with other mandatory public safety requirements formed the underpinning of the failed 2008 commercial auction.

The Public Safety Alliance and public safety’s “D block allocation with funding” approach is the only method that allows for public-private partnerships. However, public safety will only be able to utilize this option by uniting the D block and the 10 MHz of spectrum already allocated to public safety. If public safety fails to secure the D Block, our community will not be able to leverage the resources, efficiencies or shared infrastructure of the wide array of commercial interests and potential partners including utilities, power, water, sewer and other critical infrastructure. Without the 20 MHz and the public-public and public-private partnership opportunities that result from leveraging excess capacity, costs associated with the network build-out will be driven up, and it will force public safety to roam onto commercial networks during large-scale emergencies when both public safety and commercial networks are clogged and are most vulnerable. This will be a problem particularly when citizens, as consumers, are trying to dial 9-1-1 in order to receive public emergency services for help or to reach family members during crisis situations.

(6) ASSERTION: Current narrowband channels in 700 and 800 MHz bands could immediately and/or easily be switched over to broadband if and when mission-critical voice capabilities are proven in an LTE environment: FALSE.

The TRUTH is that $100s of millions have already been set aside and/or expended by state and local governments to plan, deploy and operate 700 and 800 MHz radio systems with the expectation that public safety will utilize these systems for 15 to 20 years from now. Therefore, even if public safety broadband systems can be widely achieved throughout the United States within the next three to five years and mission-critical voice can be operationally proven in the field in that same time span, some state and local governments may still need to operate their LMR systems for some time in the future for purposes of redundancy and/or justification of the investments already made to their constituencies and state and local leaders.

(7) ASSERTION: Mission-critical voice capabilities will be achieved, commercially available and operationally wide spread within LTE Broadband, making traditional Land Mobile Radio (LMR) systems unnecessary while freeing up spectrum for “give back” in one to five years, (FALSE), or in five to 10 years? POSSIBLY.

The TRUTH is that, the first generation of LTE Broadband deployment on commercial networks does not provide voice communications. Verizon, AT&T, and other carriers rolling out LTE Broadband are offering 4G services for data and video only. The commercial rollout of LTE by Verizon and others does not even contemplate commercial voice (let alone the significantly higher demands of mission-critical voice) until iteration 10, which is targeted for release in 2012. The commercial rollout is in iteration 8 of LTE deployment today. In fact, nobody in the industry is contemplating mission-critical voice over broadband in the near-term, and there seems to be increasing consensus, as testified by several of the witnesses at the hearing, that it may be achieved in five to 10 years. In the longer term, public safety is eagerly looking to be able to establish converged systems that provide voice, video and data all on the same network to achieve greater efficiency, effectiveness and nationwide interoperability. The creation of a mobile broadband network of networks is crucial to improving the communications tools available to America’s first responders by increasing their capabilities to rapidly share videos, photos and large data sets during emergencies every day.

“The PSA leadership urges Members of Congress and staff alike to carefully scrutinize, listen and consider the facts. The recent CRS report is just one example of how dangerous it can be to mischaracterize or otherwise misrepresent information. This is a complex issue that the leaders within public safety, state and local government and the industry know very well. We have neither motive, nor reason to mislead Congress or acquire this spectrum and funding beyond doing our job of protecting the public as efficiently and effectively as possible. We will continue to actively meet with Members of Congress and their staff - in DC and at home in their districts - to educate them on the issue and answer their questions. We call on all Members of Congress to listen, to accurately understand and appreciate the past and how we got here, question the accuracy of their assumptions and sources, and join us in leaning and looking forward. Time is of the essence.

To perpetuate the myths - or worse, try to rewrite history - is counterproductive and these continued delays will result in the same mistakes of the past that have gotten us here in the first place. There are legislative proposals in the U.S. Senate that have garnered bi-partisan support for allocation of the D Block to public safety with federal funding derived from proceeds of other spectrum auctions, including AWS and incentive-based auctions. We applaud the subcommittee for holding another hearing on spectrum auction options available to help finance the Public Safety Broadband Network, create jobs, increase spectrum efficiency and effectiveness, help realize future cost savings at every level of government through spectrum and technology policy and to help reduce the deficit.

The public needs and deserves a nationwide public safety interoperable communications solution. Congress can achieve this through legislation that allocates D block spectrum and provides budget-neutral funding through other spectrum auction proceeds. That legislation should be on the President’s desk by 9/11/11.”

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