dailywireless.org » Frontline Files 700MHz Plan with FCC

Frontline Files 700MHz Plan with FCC

Frontline filed their Public Safety Broadband Deployment Plan with the FCC today (pdf) which would share 10 MHz of commercial spectrum in the 700 MHz band with public safety users.

In the FCC’s Ninth Notice of Proposed Rulemaking (pdf), the FCC proposed that 12 MHz of public-safety spectrum currently would be licensed to a national public-safety broadband licensee, which could then lease the airwaves to commercial operators to build a broadband network.

Frontline’s plan calls for a nation-wide, “free” infrastructure build out for first responders. Frontline says it would enable the FCC to simultaneously advance public safety goals and speed broadband wireless access for all Americans – especially those living in rural areas.

Under the Frontline proposal, the winning commercial bidder would enter “good faith” negotiations with a national public-safety licensee on a network sharing agreement. It would provide the commercial operator with secondary access to the public-safety spectrum and public safety preemption rights to the commercial spectrum in cases of emergency.

Frontline also proposed service rules (pdf) calling for an open access network that will promote freedom of equipment choice, interoperability, innovation, and flexibility for both public safety and commercial communications.

Frontline says their FCC plan provides (pdf):

More spectrum for first responders and the ability to use commercial airwaves on a priority basis when needed
Free buildout of a hardened, robust 4G network
Maximum equipment choice with the use of open network standards
Local control for local agency networks
Nationwide interoperability among all networks. The plan would not require statutory changes or cause delays to the 700 MHz auction

Frontline adds 10 MHz for first responders (on their “E” block) by changing the “D” Block from a 10 MHz pair to a 5 MHz pair of frequencies.

According to Frontline, the 10MHz of nationwide “E” Block, combined with the 12 MHz of broadband public safety spectrum proposed by the FCC’s Ninth NPRM, ensures a minimum of 22 MHz for public safety’s broadband network – all without disturbing or otherwise interfering with the existing 12 MHz allocation for narrowband voice communications.

Consistent with the proposal in the Ninth NPRM, a single public safety licensee (“National Public Safety Licensee”) would hold the nationwide license for the public safety broadband block.
The National Public Safety Licensee would be representative of the public safety community, and would work with the E Block licensee to ensure the network is designed to meet public safety needs. The National Public Safety Licensee would be authorized to charge public safety agencies a fee for use of the broadband network.
The E Block licensee would be required to operate as a wholesale “network utility” for commercial purposes, thereby ensuring its singular focus on providing robust, reliable broadband wireless access.
The E Block licensee would be required to provide priority access to affected public
safety broadband operations during times of emergency. The E Block licensee would be required to provide roaming on its nationwide commercial license to other commercial service providers, including rural wireless operators.

The open access architecture “ensures that public safety agencies can use any equipment they choose subject to a minimum, “do-no-harm” requirement”. Public safety can take advantage of state-of-the-art technology from a variety of vendors and use it on this IP network.

Frontline’s founding team is comprised of veteran wireless industry and public policy leaders, including Reed Hundt, former Chairman of the FCC. Frontline is based in Greensboro, NC.

Critics, like Cyren Call, say Frontline wouldn’t have enough spectrum to make the service commercially viable.

Another proposal, by Cyren Call Communications, urged the FCC to establish a Public Safety Broadband Trust to hold the license for an additional 30 MHz of spectrum in the 700 MHz band in a filing to the FCC.

Whereas Frontline wants the FCC to allocate 10 MHz of commercial frequencies, Cyren wants the FCC to allocate a 30 MHz block in the 700 MHz band. Both companies would then share the spectrum between public safety and commercial usage. Cyren Call says their proposal would enable a workable, self-sustaining business model for public safety communications.

In Cyren Call’s proposal, the FCC would establish a Public Safety Broadband Trust (PSBT) to hold the license for the 30 MHz block, placing public safety needs first and making commercial usage secondary.

Cyren Call would raise roughly $5 billion from private investors for the spectrum. Critics say the spectrum is worth billions more than what Cyren Call plans to pay and they would leave rural areas with little coverage.

Cellular companys like Verizon prefer not to expand public safety frequencies in the 700MHz band. They would prefer to competitively bid on the commercial frequencies and utilize them (or not) as they see fit. Sprint and Verizon are also part of the giant $30B Integrated Wireless Network using interoperable, push-to-talk Project 25 radios. Broadband on IWN may be accomplished with a 700MHz EVDO technology developed by Alcatel-Lucent.

Some observers believe there is simply not enough spectrum available in the commercial 700 MHz band for real head-to-head competition. They worry that deep pocketed cellular operators will outbid everyone else for the valuable spectrum, then create a “closed garden”, reducing value and innovation for end users.

Why Not OFDMA in 700MHz?

Why the NTIA advised the FCC to chop up the 700MHz band into duplex frequencies — when most high school kids understand that simplex operation (like Wi-Fi) can be more cost/effective — is not entirely clear.

Credit the NTIA for “finding” 90 MHz to create the AWS band. But by the time the duplex frequencies were finally auctioned last year, Cingular had already merged with AT&T, so it mostly benefited German-based T-Mobile. Treasury got cash - but subscription revenue goes overseas.

Your tax dollars at work? Perhaps everyone would benefit if the NTIA and the FCC explained their spectrum actions more clearly in the future.

In its ninth notice of proposed rulemaking (NPRM), the FCC proposed that 12 MHz of public-safety spectrum could be leased to commercial operators to build a broadband network. The Broadband Optimization Plan consolidates narrowband spectrum further away from commercial broadband operations and establishes 5.5 MHz blocks of contiguous spectrum adjacent to commercial spectrum for broadband wireless. CTIA — the largest trade association for cellular carriers — worries the public-safety trust would dictate coverage requirements. They are correct, of course.

The federal government has spent $195 million on IWN, the Integrated Wireless Network, reports the Washington Post. But the 700 MHz public service radio network, designed to deliver interoperability for the nation’s law enforcement agencies, is at “high risk of failure,” according to the Justice Department’s inspector general report this month (pdf).