Protecting the safety of our first responders and the security of our nation in the 21st Century requires 21st Century tools. The very plan intended to deliver these tools threatens to take them away.
Endangering first responders and citizens with insufficient communications
Lack of capacity for day-to-day operations, incident management and catastrophic incidents puts America at risk.
- The need to ensure interference protection between the two blocks of spectrum will require isolation or a guard band between the D Block and the public safety spectrum
- The institution of such a guard band can only be accomplished by reducing the amount of useable spectrum within the D Block spectrum which in turn will reduce the auction value and capacity for commercial services
- Public safety requires multi-agency coordination, recognizing that alongside police, fire and EMS, priority may be needed to shut down gas, electric or to clean a dangerous spill
- 10 MHz alone cannot provide the necessary bandwidth to share across the response teams to support such tactical, multi-agency operations
- Catastrophic incidents cannot be described, they must be seen; video is increasingly recognized as an essential component of mission critical operations
- Even with advancements anticipated in the next decade, 10MHz alone will not support basic video applications offering the lowest acceptable quality from real-time situational awareness
Accountability without control threatens lives
Current FCC plan places control and priority with commercial entities rather than public safety
- Large scale incidents requiring public safety to utilize commercial spectrum have proven commercial networks to be the least available
- There are numerous examples of carrier networks struggling even during the most routine public events like a football game
- Commercial LTE prioritization cannot support public safety requirements; standard LTE is not built to consider the individual and the nature of the situation to determine priority
- A user that detaches from the public safety block attempting to get more bandwidth from a commercial carrier may discover sites are down or overloaded and drop service.
- No mandate for carriers to grant “immediate priority” or pre-emption; technical mechanisms to enable this in standard LTE commercial systems are yet unproven
A dropped call or missed message for public safety can mean live or death
D Block interference will result in coverage holes for public safety
- Even with interference mitigation between the D Block and the public safety spectrum, first responders near a D Block base site may have their communications terminated
- Technical analysis demonstrates that advance RF techniques including forced guard band, filtering, and power trimming cannot resolve the severity of the interference.
- The location and nature of the coverage holes will change dynamically based on any changes in either the D Block of public safety systems
- A similar issue resulted in massive re-banding effort between Nextel, FCC and public safety networks to ensure interference-free communications within the 800 MHz spectrum
Freedom of choice is removed; D Block auction winner would become sole-source partner for life
Technical realities resulting from FCC plan eliminate free market play by forcing exclusive site coordination with D Block auction winner
- The FCC plan inadvertently penalizes Verizon Wireless and AT & T keeping them from effectively competing on a level playing field to win public safety LTE business and reducing equipment and service cost
- Technical realities resulting from the FCC plan offer only one option: The PSST and D Block site deployments must be collocated and coordinated
- Technical analysis demonstrates that advanced RF techniques including guard band and filtering between the D Block and public safety systems cannot resolve the severity of the interference
- If sites are left uncoordinated, interference surrounding the D Block base sites will result in coverage holes with no service for public safety users
- As public safety agencies are forced to coordinate sites with D Block winners, it leaves no option to public safety except to work exclusively with the successful D Block winner, which will result in increased costs and a potential monopoly of the public safety broadband market