Industry Already Rejected FM Chips in Cellphones, CTIA Tells FCC

“More than two years after the completion of the CMSAAC efforts, broadcasters are raising an eleventh hour argument that FM chipsets should be placed into commercial wireless devices to receive emergency alerts,” CTIA said. “However, the technological issues surrounding such a suggestion are formidable and the broadcasters have not addressed how commercial wireless devices would be adversely affected by this proposal.”

Because FM radio frequencies “are considerably lower in frequency than CMRS bands, FM chipsets present significant antenna/reception issues for the mobile devices,” CTIA said. “Moreover, constant monitoring for an FM emergency alert signal would rapidly diminish the battery life of a mobile device.” CTIA said the broadcaster proposal was “considered at length” by the CMSAAC and “ultimately dismissed.”

CTIA also cautioned that raiding of E911 funds by local and state governments is slowing progress to next-generation E911 systems in many parts of the country. “In some cases, the slow adoption rate of Phase II by [public safety answering points] can be attributed to raiding of E911 funds by cash-strapped state legislatures,” CTIA said. “Some state legislatures and city governments have sought to increase E911 fees as a means of raising revenue for purposes unrelated to E911 deployment. In addition to slowing current E911 deployment, these activities endanger future funding for technical support and deployment of both E911 and NG911 systems.”

CTIA said the trend has continued in 2009. Among recent examples cited by the group, in Wisconsin a law passed this year shifted $20 million in E911 funds to general revenue, even though four counties there haven’t completed implementation of Phase I E911. In Hawaii, a law diverted $16 million in E911 money to the general fund. In Delaware, a law authorized the transfer of $4 million from the E911 fund into the general fund. “The diversion of $4 million from the E911 Fund to the General Fund has placed in jeopardy plans for much needed improvements to Delaware’s E911 system,” CTIA said. “NG911 deployment is certain to be challenging, and public safety will surely suffer if misappropriation of 911 funding is not stopped.”

Verizon and Verizon Wireless, filing jointly, said the FCC should encourage Congress to approve legislation so that local agencies can take control of 700 MHz D-block spectrum and begin to build systems in the band. “Many of public safety’s current emergency communications needs can be met with existing commercial broadband networks like Verizon Wireless’ advanced 3G network,” the companies said. “However, some state and local officials have concluded that dedicated public safety networks may be required in some areas to ensure that public safety’s critical needs are met. As a result, we expect future emergency communications needs to be met through a combination of commercial and dedicated broadband mobile networks.”

The FCC should formally encourage Congress to reallocate the D Block for a nationwide public safety network and “establish rules that facilitate the deployment of dedicated and/or shared regional networks that will enable state and local public safety,” Verizon and Verizon Wireless said. To guarantee interoperability, the commission should adopt a national technical framework with national technical standards, the companies said. Finally, the agency should allow public safety entities to partner with the commercial provider or providers of their choice, they said. “Local or regional partnerships that are tailored specifically to meet the needs of individual public safety agencies across the country are more likely to succeed than attempting to establish a single national partnership through an auction, which would require public safety entities to commit to a single model that may not satisfy local agencies’ needs.”

AT&T said “Congress should repurpose the 10 MHz of 700 MHz D-Block commercial spectrum (758-763/788-793 MHz) for public safety broadband use. … Coupled with the 10 MHz of 700 MHz broadband spectrum licensed to the Public Safety Spectrum Trust (763-768/793-798 MHz), the D-Block spectrum would give public safety entities a full 20 MHz of broadband spectrum, the amount of spectrum necessary to support advanced applications at fourth generation data rates for multiple users.” The company said nationwide interoperability ultimately would be achieved “by linking the 700 MHz local and regional networks and establishing reciprocal roaming agreements and credentialing procedures between all public safety entities.”

But Sprint Nextel, filing with Clearwire, and T-Mobile urged the regulator to auction the D-block a second time. “Any possible benefits of Verizon and AT&T’s proposal are outweighed by two fundamental flaws,” Sprint and Clearwire said. “First, the proposal would effectively prevent a third nationwide commercial operator from ever emerging in the 700 MHz band by precluding commercial ownership of the D-Block. Second, the proposal would confine all public safety broadband communications to a single technology in a single band. Verizon and AT&T’s plan would use regulatory fiat to restrict the supply of competitive service and prevent public safety demand from finding competitive alternatives.”

NENA said the FCC should not miss the opportunity to send a clear message in the National Broadband Plan. “It is essential that the … Plan’s recommendations include concrete proposals and suggestions designed to facilitate the transition of our nation’s 911 and emergency communications systems to broadband-enabled, IP-based platforms,” NENA said. “The Plan should clearly articulate that it is the policy of the United States to foster the migration from analog, voice- centric 911 and emergency communications systems into a broadband-enabled 21st century, IP-based emergency services model.”

The FCC also asked for more specific guidance on the spectrum needs of public safety and how public safety agencies will use wireless broadband. At an August broadband workshop, public safety officials disagreed on how first responders would use newfound broadband connectivity if a national network is launched (CD Aug 26 p1).

APCO’s filing said that broadband communications are expected to become “fundamental” to public safety communications on both a daily and emergency basis. “Robust daily usage applications will include [computer-aided dispatch], [radio over IP], traditional voice, text and data, mobile office and many others,” APCO said. “During localized events, such as fires, police surveillance, and EMS responses, broadband requirements will expand with video and other multimedia applications being engaged for inter-agency and intra-agency communications.” The group submitted a chart “for discussion purposes only” describing likely throughput needs. It estimated that video will take 100 kbps-1 Mbps, per video stream, with four to 10 needed during a major incident.

The Public Safety Spectrum Trust said many of the questions posed by the FCC “are not currently answerable.” But the PSST offered 19 uses for mobile data applications, such as giving officers in the field access to criminal databases and motor vehicle records and computer assisted dispatch. NENA submitted results of a recent survey of public safety broadband use. “Overall, survey results indicate that broadband, where available, plays an important role in everyday PSAP and emergency services operations and will continue to do so in the future as broadband-enabled applications and services are deployed,” NENA said.