In the past twenty years, few changes, innovations, and interoperability initiatives have entered the first responder and emergency response markets. Specifically, the interoperability of communications for the public safety market strikes at the center of what appears to be a common sense must have – the ability for every public safety agency to communicate with each other, or interoperability. However, for several decades interoperability was a word said to be rumored by many and practiced by few. The tragedy of September 11 brought a tremendous focus to interoperable communication and the dire need for the immediate implementation of this idea became clear. Unfortunately, the steady march forward has been encouraging at times and utterly disappointing other times. Particularly in the area of providing interoperable communication and other spectrum for public safety in both the local, community to community, and community to state level, the FCC’s allocation of frequency has seen only a few positive developments while mostly witnessing many delays in the name of money, confusion, and misinformation about the true needs of the market.

The FCC understands the need for appropriate spectrum allocation for public safety use. In 1995, the FCC and NTIA (National Telecommunications and Information Administration) established the Public Safety Wireless Advisory Committee (PSWAC) to evaluate wireless communication needs for the local, state and federal public safety agencies. PSWAC recommended utilizing portions in the 746 to 806 MHz band and estimated that 97.5 KHz of spectrum would be necessary over the next decade. The FCC adopted the PSWAC recommendation to allocate an additional 24 MHZ of spectrum in the 700 MHZ band for public safety. The newly allocated spectrum doubled the public safety frequency, adding approximately 51 percent of new spectrum. However, this seemingly large step forward became the last bastion of spectrum realignment and practical implementation methodology for several years. The FCC was slow to push public safety spectrum allocation and opted to focus on the commercial allocation of spectrum - and for good reason. The FCC can charge millions and billions for portions of spectrum. However, as the organization centered its efforts on the rich and lucrative sale of spectrum for commercial groups, a brewing disaster was about to occur that would alter the way the FCC viewed public safety spectrum.

As the aftermath of the tragedy spawned several investigations and post incident reports, the nation renewed efforts to place billions towards outfitting public safety groups with the latest equipment and technologies, as well as developing integrative and response-effective procedures and methodologies. As part of the nationwide advancement, the FCC began to address public safety interoperability and the appropriate allocation of spectrum, and freeing current public safety spectrum from rampant interference. The organization introduced the 800 MHz refarming program and allocated frequencies in the 4.9 MHz band for public safety. The 800 MHz rebanding would be a hallmark event in the halls of public safety spectrum allocation. Today, the rebanding effort creates confusion and delays among regional and federal committees seeking coordination and assurance, but remains on pace for completion in 2006. The rebanding is designed to occur at the local level, with regional planning committees responsible for allocating and planning use of the 800 MHz band for public safety groups. The decentralized structure appears on the surface to bring a logical approach to an area of usually mass confusion and bureaucracy. However, it is not so much the approach used by the FCC to allocate 800 band frequencies, but the method of the plan that draws the ire of many individuals, groups, and even several inside the federal government. The regional planning committees and overall structure to ‘refarm’ the 800 MHz band has made it difficult for the FCC, the NTIA, and others to identify and access up-to-date regional plans. Also, monitoring the regional plans has proven burdensome and system managers and system designers, who use this regional information, remain in a foggy disarray. It appears the decentralization effort may have gone beyond the scope of what is required to allocate effectively portions of the 800 MHz band.

The mere allocation of the 700 MHz band has been a positive event for the nation. However, inefficiencies such as the 800 MHz refarming effort and organizational cohabitation and processes are leading the public safety interoperability communication capabilities down an auspicious road. Extrapolating beyond today, among other potential disaster points, a foreseeable capacity constraint will likely arise from a potential large-scale crisis where multiple jurisdictions flood the public safety bands. The targeted assault on public safety frequencies will result, at best, in mild productivity. In a best case scenario, simply routing low frequency communications will be moderately effective. Taken a step further, though public safety is receiving portions of the 800MHz and 4.9 MHz bands, the focus should be on the actual limitations of the limited and interference-prone spectrum allotment. A steadfast effort to reform public safety spectrum guidelines, processes, and allocation is required from not only the FCC but also the top of the federal government - the executive branch.

Unquestionably, America needs to increase the amount of available spectrum to the public safety groups. The FCC has provided frequencies inside bands such as the 800 MHz, increasing the total public safety spectrum. This is not sufficient. The FCC should take the entire band, or near it, for public safety only. Commonly, the FCC has grown accustom to allocating what is known as guard bands adjacent to the public safety megahertz. However, the FCC has turned around and sold the guard bands to guard band managers, who in turn sell the frequency for commercial use – raising the likelihood of interference. And, though guard bands are intended to clear adjacent frequency noise, the reselling of this band and the limited amount of spectrum for public safety will continue to produce nationwide interference – long after the 800 MHz refarming is complete. From a governing body perspective, the NTIA has been the designate agency to advise the president. Together with the FCC, these two organizations are to set national policy for spectrum allocation. From this interplay, the voice of the executive branch is to lay down desired spectrum policy. The intended results from this alignment have been mediocre with no real leadership. The executive branch must take an authorative stance on public safety allocation and squash efforts to seek billions instead of citizen safety. Regardless of monetary wishes, the executive branch and the FCC could forcibly realign spectrum to clear a large portion of a band for public safety and in doing so create a more secure and expandable framework for increasing interoperability and decreasing interference. This proposed initiative, which will be termed "renaissance rebanding", would be a swap of spectrum, similar to what occurred with Nextel swapping out of the 800 MHz band. As the critical link to such efforts, the NTIA must influence the executive branch and the FCC to pursue programs that benefit commercial interests while prioritizing communications for public safety groups. Also, the guard bands must be free of all commercial interest and slated for public safety groups as a means for last resort communications. Currently, several interest groups hotly debate the idea of standards across the public safety environment. This may be more of a time consuming rotisserie. Standards will likely remain broad-based, or few, if any. However, the FCC can and should implement more technical parameters and requirements, which would assist the singular regional planning committees. They must lay out basic requirements that are workable, manageable, and not irrelevant for a community that operates off a plethora of disparate systems. Finally, the FCC and NTIA must advance the security, effectiveness, and trust of society by blending capitalistic ideas with pointed solution handling and authority, rather than implementing total decentralization, dollar centric, and hands free ideals in terms of areas such as interoperability initiatives and spectrum allocation for the public safety market. In doing so, the FCC or NTIA must setup an internal group to handle the 800 MHz refarming initiative that elevates beyond today’s scope of limited oversight and infrequent analysis. The group must be responsible for leading regional refarming efforts and requiring local and regional compliance to central guidelines, and better coordinating the nation’s total effort to enhance communications among public safety groups.

The FCC, NTIA, and the Executive Branch face a critical moment in our history. The question remains, will they continue to organize public safety spectrum through the ideas of today, or will they accord the public safety market with the spectrum requirements necessary to interoperate multiple jurisdictions, communities, and states on a daily basis as well as during a national disaster? The solution appears simple, but then at times taking that final step is less what may be the better solution and more about progress, change, and the ability to seek purposeful outcomes as opposed to cash in the bank.

For further information please contact:

Katja Feick
Corporate Communications
+44 (0) 207 915 7856
Katja.Feick@frost.com

www.medicaldevices.frost.com