NATIONAL
PUBLIC SAFTEY TELECOMMUNICATIONS
COUNCIL
NPSTC
Urges FCC To Follow Public Safety Guidelines for
Potential 700 MHz Broadband Network (Littleton,
Colorado, July 6, 2007)
-Recognizing that the
Federal Communications Commission soon will
complete its deliberations in the 700 MHz
proceedings, decisions that will shape critical
wireless telecommunications capabilities for
decades to come, the National Public Safety
Telecommunications Council (NPSTC), a federation
of national organizations representing the
communications leadership of the public safety
community, wishes to clarify for members of
Congress and the FCC certain matters relating to
issues affecting public safety.
The current discussion centers primarily on a
proposal developed by Frontline Wireless. That
proposal recommends that the FCC designate 10 MHz
of spectrum to be auctioned, to be called the E
Block, which would contain certain restrictions to
the auction winner to enter into a private/public
partnership with public safety to build a
nationwide public safety/commercial broadband
network. NPSTC and its representatives have spent
considerable time discussing the issues with
Frontline Wireless and others concerning the
policies and principles we believe should guide
the FCC in its deliberations:
- The
700 MHz rules should facilitate deployment of a
nationwide, broadband, interoperable, open
standard 4G network built to public safety
specifications.
- The
FCC should designate 10 MHz of the 700 MHz
public safety spectrum allocation for broadband
use and should assign that spectrum to a
national public safety licensee (NPSL), an
entity broadly representative of public safety
interests, in a single nationwide
authorization.
- The
NPSL broadband spectrum should be combined with
10 MHz of auctioned spectrum (referred to as the
"E Block") to form a single, shared, nationwide,
broadband, interoperable network that provides
public safety with priority access through the
NPSL.
- Because
public safety does not have access to funds even
to build, much less to operate, maintain or
refresh such a network, network deployment must
be funded pursuant to a public safety-commercial
partnership between the NPSL and the E Block
auction winner as codified in the FCC rules and
in the Network Sharing Agreement (NSA) to be
negotiated between the NPSL and the E Block
auction winner.
- The
goal of nationwide public safety
interoperability, as well as public safety
access to a public safety grade network, would
be greatly complicated and likely placed at
serious risk if the E Block is auctioned in
geographic sub-units rather than as a single
nationwide license.
- The
FCC rules should define in reasonable
specificity certain aspects of the shared
network requirements, including, but not limited
to, the E Block licensee's coverage build
obligations, both in terms of geographic scope
and service levels consistent with public safety
on street and in-building needs, to ensure
responsible bidding in that auction and the
NPSL's reasonable right to select network
technology at initial deployment and throughout
the life of the network. The FCC should also
mandate protections against potential business
failure of the E Block licensee
- NPSTC
is advocating the following coverage and
benchmarks for the combined network:
4
years...........75.0% population/13% CONUS
landmass
7
years...........95.0% population/45% CONUS
landmass
10
years.........99.3% population/75% CONUS
landmass
NPSTC
would also support additional requirements to
ensure coverage for isolated population centers,
and anticipates the use of satellite technologies
to provide coverage to remote areas.
- The
FCC rules also should identify required elements
of the NSA and should provide for FCC oversight
of the NSA negotiation process.
- The
FCC should encourage the NPSL to develop a
Statement of Requirements well in advance of the
commencement of the auction to further clarify
for potential participants the totality of
public safety requirements and should host a
bidders conference to better disseminate this
information to those bidders.
- The
FCC rules should provide for issuance of the E
Block license after the successful negotiation
of the NSA. If no NSA has been agreed to between
the NPSL and the E Block auction winner within a
specified time established by the FCC, the FCC
would resolve any differences between the
parties. If the NPSL accepts the FCC's
resolution, the E Block licensee would be bound
by it as well, and an NSA reflecting the
parties' agreement (and, to the extent relevant,
the FCC's decision) would be entered into by the
NPSL and the E Block licensee. If the NPSL
rejects the FCC's decision, the E Block would be
re-auctioned.
- NPSTC
does not believe that "open access" should be a
requirement for the E Block, partly due to the
absence of a commonly agreed upon definition of
what open access means. NPSTC would like the
NPSL to be able to negotiate with the E Block
auction winner regarding issues related to open
access, some of which we may agree to and some
of which we may not.
Although
the public safety community recognizes that the
type of public/private partnership contemplated
herein presents certain novel regulatory issues,
encumbering a portion of the commercial 700 MHz
spectrum with obligations to provide public safety
with needed critical broadband communications
capabilities, and permitting public safety and a
commercial network operator to combine certain
portions of their licensed spectrum holdings in a
shared network, represents the only currently
realistic potential alternative to deliver a
viable, affordable, self-sustaining route to meet
the 21st century communications of public safety.
NPSTC
is a federation of organizations whose mission is
to improve public safety communications and
interoperability through collaborative
leadership. |
