Public Safety Urges Caution as FCC Considers 700 MHz Rules
The FCC went too far with the questions it asked in a Jan. 25 rulemaking notice on a common technology platform for a nationwide public safety broadband network, the Association of Public-Safety Communications Officials and the Public Safety Spectrum Trust warned in separate comments in docket 07-100. The notice delves too deeply into operation of the 700 MHz network, APCO said. “The Commission should limit its rules to that which is necessary now to ensure nationwide interoperability across the network.” Operability requirements “should not be incorporated into the rules,” APCO said. It said the agency must avoid adopting prematurely “rules covering operational and technical issues that have yet to be fully explored in real world environments."
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"Many of the items discussed in the FNPRM are prematurely presented, as there is considerable additional work to perform before specific solutions can be suggested, discussed, selected, or regulated,” the public safety trust said. “Moreover, some issues raised in the FNPRM are outside of the scope of ensuring interoperability.” Public safety, not the FCC, is “best suited to determine where and how to build out a local, regional, or statewide part of nationwide network, and detailed, prescriptive regulations in this area may be counterproductive,” the trust said. Andrew Seybold, vice chairman of APCO’s Broadband Committee, raised similar concerns (CD April 12 p12).
Northrop Grumman said the network’s success depends on the development of a national “Security and Identity Management” strategy, a “Common Network Applications” platform and a national “Certification, Validation, and Verification” strategy. Security is paramount, the company said. “While security is important for any communications network, it acquires a new meaning in the context of mission-critical public safety communication networks."
The Enterprise Wireless Alliance called control of the network a key issue. Public safety should decide who has access to the spectrum, the alliance said. “Clearly Congress intended to ensure that public safety retained control over its 700 MHz spectrum so that the protection of the personal safety and property of the public would always remain the highest priority use."
Nokia Siemens, meanwhile, filed an ex parte letter on a multivendor meeting held at the FCC March 17 to discuss a national public safety network. Nokia emphasized the importance of working closely with the 3rd Generation Partnership Project (3GPP) and other standard groups. “3GPP ecosystem global reach and efficiency should be leveraged not compromised,” the vendor said. “We need to consider how and where to leverage existing testing bodies and methods to help develop interoperable public safety systems."
The commission should “minimize its role in the detailed development of operational rules,” Maryland said. “Conversely Maryland believes that the Public Safety Spectrum Trust” or “some other collective body representing public safety practitioners should have the authority to adopt the nationwide standards for network operation.” LightSquared said interoperability rules developed by the commission should “facilitate the widespread deployment and use of dual-mode satellite-terrestrial devices throughout the public safety network.” The agency should adopt minimum coverage standards for public safety networks when construction is finished, but should also give agencies flexibility to build and use the networks even when funding for full deployment isn’t immediately available, the company said. “A liberal build-out and hardening waiver policy for agencies that deploy satellite-enabled dual-mode devices would yield major benefits for the public safety network."
The FCC is correctly concerned about compatibility among LTE versions, TIA said. But “backward compatibility is built into every 3GPP release” and has “been addressed in these standards,” the group said. “Further, with regard to IPv4 and IPv6 compatibility, transition mechanisms exist that can be used amongst network occupants to streamline interoperable communications.” The FCC is right to urge an open standard, TIA said. “The establishment of baseline standards that must be met for interoperability are critical, and will allow for network occupants to, if they choose to do so based on unique needs, exceed these baselines,” the group said.