Lawmakers Introduce Non-Emergency Mobile Number Bill

Reps. Susan W. Brooks (R., Ind.) and Anna G. Eshoo (D., Calif.) today introduced the National Non-Emergency Mobile Number Act (HR 5700), which would direct the FCC to take steps to facilitate the creation of a unified wireless short code for critical, but non-emergency, situations on highways.

“This commonsense, bipartisan bill ensures our 911 telecommunicators can focus on responding quickly and efficiently to phone calls reporting time-sensitive and urgent emergency matters,” said Rep. Brooks. “When people are traveling from state to state, the short non-emergency number people call to report an instance deserving of attention but may not classify as an emergency varies across state lines. Designating a code for this specific use promotes a more cohesive and effective public safety response. This bill will make it easier for travelers to contact public safety officials when reporting non-emergency situations and enables our 911 telecommunicators to focus on helping people who are dealing with an emergency.”

“In an interconnected nation, it is essential that we have a streamlined communication system across all states,” said Rep. Eshoo. “The National Non-Emergency Mobile Number Act simplifies travelers’ access to assistance in non-dire times, regardless of what state they’re in and eases unnecessary call traffic to 911. I’m proud to partner with Rep. Brooks on this straightforward legislation that will allow emergency call centers to focus on urgent matters and save the lives of those in danger.”

“Currently, there are at least eighteen different wireless short codes in operation across 29 states throughout the country,” according to a news release on the bill. “Mobile wireless non-emergency numbers primarily used on highways allow individuals, especially the traveling public, to quickly and easily contact public safety officials (typically state highway patrols) in critical times of need that do not exactly rise to the emergency level, such as car malfunctions. These numbers shift unnecessary calls away from 911 systems to help with congestion and allow emergency call centers, or public safety answering points (PSAPs), to focus on more significant matters.” It added that the bill “would help consolidate the multiple numbers existing today, thereby reducing traveler confusion and hastening response times.”

“I applaud Representatives Brooks and Eshoo for introducing the National Non-Emergency Mobile Number Act,” said FCC Commissioner Mike O’Rielly. “This is a commonsense bill that will bring uniformity to wireless short codes used today by states to redirect non-emergency calls on the highway away from 9-1-1 call centers and to state highway patrols. Just as we have one, unified number to call in times of need, it is logical to have one unified short code to call when travelers see car malfunctions or suspected drunk drivers along the highway. This bill is an important first step in eliminating traveler confusion and potentially to saving lives.”- Paul Kirby, paul.kirby@wolterskluwer.com

Firm to Pay $61,000 Fine for LED Signs

The FCC’s Enforcement Bureau today released a consent decree resolving an investigation into whether a company violated the FCC’s rules in the marketing of LED signs. “To settle this matter, Liantronics admits that it marketed LED signs without the required equipment authorization, labeling, and user manual disclosures, will implement a compliance plan, and will pay a $61,000 civil penalty,” the bureau said in an order in file no. EB-SED-17-00024694. – Courtesy TR Daily

Parties Weigh in on Ways to Address Misrouted 911 Calls

Public safety and industry entities have weighed in at the FCC with suggestions on ways to ensure that 911 calls place from cellphones reach the correct public safety answering points (PSAPs), even though some say hard data on the scope of the problem is elusive. Parties offered diverse opinions on whether technologies currently exist to address the problem and if they should be deployed, or whether it would make more sense to focus resources on the deployment of next-generation 911 technology.

The comments were filed in PS docket 18-64 in response to a notice of inquiry adopted in March seeking input into ways to address situations where 911 calls from cellphones are misrouted to the wrong PSAP because the location of the cell tower being used by phone is not in the same PSAP jurisdiction as the caller (TR Daily, March 22).

The NOI seeks input on ways call-routing could be improved, and on ways the FCC could facilitate and encourage such improvements. It notes that recent technological improvements could enable routing based on the caller’s actual location.

The item also seeks comments on recommendations regarding location-based routing made by the FCC’s Communications Security, Reliability, and Interoperability Council (CSRIC) in 2016 and asks about the costs and benefits of adopting location-based routing.

In its comments, the Association of Public-Safety Communications Officials-International said that the lack of interoperability among PSAPs can exacerbate the impact of misrouted 911 calls.

“There are still instances where PSAPs have to manually call each other to convey the information about an emergency. This holds true both for misroutes and for other incidents that would benefit from seamless voice and data sharing between PSAPs, such as calls for mutual aid,” APCO said.

“Unfortunately, early-adopter deployments of NG9-1-1 components such as ESInets have shown that the introduction of IP-based technology alone is not solving the interoperability problem,” the filing said.  “Policymakers, industry partners, and 9-1-1 authorities must recognize and work to resolve this problem.”

APCO also said that it “would welcome additional data but anticipates that precisely quantifying the scope of the problem will be difficult. PSAPs may have different policies and capabilities for transferring as well as tracking misrouted calls. Additionally, the dynamic nature of wireless networks can mean that even two 9-1-1 calls made from the same location could route to different PSAPs because one call might route based off of the nearest tower while the other call might connect through a different tower or cell sector that has been set up to route to a different PSAP based on pre-established boundaries. The frequency of misroutes likely varies greatly across PSAPs.”

“The Commission seeks comment on the CSRIC Report’s recommendations about several location-based routing solutions. APCO generally supports the Report’s recommendations. In particular, APCO agrees with the recommendations that the Commission should take steps to ensure that any location estimates considered for routing 9-1-1 calls are accurate, and support the independent testing and analysis of new location technologies that promise significantly increased accuracy and speed. PSAPs are all too often approached by companies promising solutions, without feasible methods to verify the claims or hold the providers accountable,” APCO said.

APCO noted that “the Commission asks whether the NEAD [National Emergency Address Database] will be capable of being leveraged to obtain a caller’s location for the purpose of routing a 9-1-1 call. APCO would urge caution on prematurely considering the use of the NEAD for routing purposes. While the NEAD holds great promise for achieving a dispatchable location solution for wireless 9-1-1 calls, particularly inside buildings, it remains in development. At this point, efforts concerning the NEAD should therefore remain focused on its intended purpose.”

“Finally, the Commission asks what role, if any, it should play in the creation or implementation of standards or practices for location-based routing. Standards are best handled by industry standards bodies. As a general matter, the introduction of new technology and architectural approaches will make it increasingly difficult for 9-1-1 authorities and service providers to be clear on their respective responsibilities for allocating costs,” APCO said. “Accordingly, the Commission can provide much-needed support by continuing to offer clarification and ensuring that PSAPs do not bear costs that the Commission’s rules would otherwise allocate to service providers.”

“Until the IP-native routing features of NG9-1-1 arrive, NENA supports the development and implementation of proven interim processes and technologies for location-based routing. However, NENA respectfully requests caution by the Commission that interim solutions neither cause harm to existing routing mechanisms or delay the implementation of NG9-1-1 native location-based routing,” said the National Emergency Number Association.

“The Notice requests comment on the viability and effectiveness of provisioned or registered civic addresses. Location based routing using civic address can be successful, assuming addresses are accurate. Registered or provisioned addresses have proven to be problematic if provided by customers, because the large percentage of these that are nomadic VoIP are not kept updated by their users,” NENA said. “Automatic location definition without customer action would be highly preferable to support effective 9-1-1 service. Further, wireless carriers do not currently support processes that can help 9-1-1 validate user addresses, or provide them for use by the NG9-1-1 systems for routing control.”

“The Notice also seeks information on ‘how quickly 911 calls can potentially be routed when using device-based hybrid location solutions.’ NENA notes that current trends — especially in the marketplace for third-party solutions — gravitate toward warm-start GPS processes. Assuming the data provided by these processes is properly handled and utilized, initial routing control could be accomplished within 2–3 seconds of call start for calls where the supplemental location data is determined to be dependable and adequate. However, the proprietary nature of these location services, the unknown nature of the databases that underpin them, and their management and maintenance causes questions about how well those services can be safely applied. The concepts noted in the NOI — including the NEAD — are all capable of improving call routing and timing, but not if they are applied only within the traditional routing processing timeframe of CMRS wireless 9-1-1 within the carrier networks. Many of the newer methods for location can provide data well within 5 seconds, but if it is not utilized in a timely way, little progress will be enabled.”

The Texas 911 entities, which include the Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communication Districts Association, provided some data on the frequency of 911 calls that are misrouted, saying that “recent data for a reasonably large sample of approximately 13,000 cell sectors in Texas shows that the percentage and number of misroutes varies considerably between sectors and between Public Safety Answering Point (‘PSAP’) serving areas. For example, that data appears to show approximately 70% of the cell sectors indicated no misroutes, while approximately 10% of the sectors have greater than 50% misroutes, with certain enclave areas or cities surrounded by another city often being materially impacted by misroutes. Because the data varies considerably between sectors and between PSAP serving areas, utilizing only a general aggregate average for many sectors can completely obscure a considerable number of misroutes, and obscure the potential benefits of improvements in individual sectors.

“In the absence of sufficient public disclosure of information and informed discussions between various 9-1-1 stakeholders (e.g., wireless service providers, handset manufacturers, third-party vendors, 9-1-1 authorities, etc.), the nature of the competitive market and the sheer number of stakeholders can present some challenges to making informed decisions and strategic transition planning regarding device-based handset initiated location technology solutions,” the entities added. “Given the current frequency of misroutes, in the absence of documentation of material costs to wireless service providers being submitted into the record in this proceeding, at the present time it appears that Commission action would withstand ‘the test of feasibility and functionality relative to costs.’ The manner in which device-based handset initiated location technology solutions and NG9-1-1 transition may sync up together, including interoperability and timing considerations, and how much cost responsibility is placed on wireless service providers as compared to the NG9-1-1 systems, are appropriate issues to clarify in this proceeding.”

The filing continued, “Delaying the delivery of 9-1-1 calls more than fractionally beyond 6 seconds to achieve LBR [location-based routing] should generally be avoided. This is especially the case when other alternatives appear to be available to achieve improvements towards LBR. Finally, with regard to mobile VoIP, continuing to provide only a registered and provisioned civic address from a smartphone or tablet for mobile VoIP 9-1-1 calls is quite concerning. Accordingly, the Texas 9-1-1 Entities urge the Commission, at a minimum and as recommended in the NENA Non-Mobile Technical Information Document, to consider the issue of a location sanity check when a customer with mobile VoIP changes locations and has not reregistered a caller civic location.”

“There are a number of measures which can and should be taken to remedy Phase I Misroutes of wireless calls,” said the Boulder (Colo.) Regional Emergency Telephone Service Authority. “The first two are for wireless providers to consider jurisdictional boundaries in siting and cell sectorization decisions, and for providers to evaluate available data to determine which existing cell sites produce a high percentage of Phase I Misroutes. For sites identified to have a high percentage of misroutes, remedies are available and should be considered in consultation with PSAPs from (i) flagging for dispatchers calls from cell sites or sectors with high percentages of Phase I Misroutes, and low percentages of misroutes, (ii) modifying orientation of cell sectors, to implementing Phase II Routing or ‘Phase III Routing:’ routing calls based on a location technology which is more granular than Phase I Routing and can provide a TTFF [time-to-first-fix] of five-seconds or less.”

The filing continued, “The 9-1-1 system and services must accommodate a variety of location technologies which are suitable to different environments, or may be developed in the future. A 9-1-1 location technology should be secure, reliable and provide data in a format consistent with other location technologies. BRETSA raises the prospect of terrestrial GPS signals embedded in high power broadcast signals capable of penetrating buildings, or special purpose beacons. These terrestrial GPS signals would allow WiFi, Bluetooth or BLE access points or beacons to determine their coordinates and signal timing requirements, and in turn provide GPS signals to devices located in indoor locations. This would require Commission requirements or authorizations of the terrestrial GPS transmitters, as well as of devices which would utilize these signals to become GPS transmitters themselves.”

“Given the potential synergy between the various efforts the FCC has already enabled and the vast technologies at hand the FCC should simply replace the cell site based requirement with a device based routing requirement on a short time-line for implementation,” said Robert Oenning, former enhanced 911 administrator for Washington state. “The question is not if device location based routing can be done but rather how those in the industry who have already demonstrated an ability to collaborate on improving 911 services can be enabled to make it happen.   The action the FCC takes to move forward location based routing should be tempered to assure that the industry does not again get trapped again into retaining 911 methodologies well past the point where it is practicable to move toward improved systems.”

“As the wireless industry continues to deploy technologies that enhance location information about wireless 9-1-1 calls, the Commission is right to ask whether new technologies can also reduce the number of 9-1-1 calls delivered to PSAPs in neighboring jurisdictions,” CTIA said. “The Commission should use the record developed here to carefully weigh the costs and benefits of different policy approaches to improvements in wireless 9-1-1 call routing. For example, the Commission should assess the tradeoffs associated with different 9-1-1 call routing mechanisms, such as the potential for a general delay to routing all 9-1-1 calls. The Commission also should consider whether location-based routing solutions would be better suited for, and more easily implemented in, the next generation 9-1-1 (NG911) environment. Finally, the Commission should consider alternative methods that can prevent misroutes and/or help to mitigate the impact of misrouted 9-1-1 calls, such as encouraging additional coordination among PSAPs and by PSAPs with wireless providers.”

“Such alternative techniques can be implemented far more efficiently and effectively than wholesale, standalone changes to current routing mechanisms,” CTIA added. “Therefore, as part of this proceeding, the Commission should examine and draw attention to successful techniques that can reduce misrouted 9-1-1 calls, as well as those that can mitigate the impact of calls that are misrouted.”

T-Mobile US, Inc., said it “supports improving 911 call routing, utilizing emerging location technologies, and the transition to NG911 systems. The technological improvements capable of producing high-accuracy/low-latency locations that are becoming available for use in 911 solutions have been aggressively sought-after and are welcomed by all stakeholders. But today, the single most important contribution that public safety and the Commission can make in this regard is to encourage PSAPs to expeditiously make the transition to NG911, so that public safety and consumers can benefit from these technological advancements.”

T-Mobile added “that focusing limited resources in an attempt to add location-based 911 call routing to legacy 911 systems would offer a poor return for a very significant level of effort. T-Mobile instead proposes that the concerted effort to improve 911 call routing be directly associated with the transition to NG911 systems. T-Mobile is already taking steps to help encourage this transition and subsequent testing and refinement of such improved call routing methods. In this effort, T-Mobile believes all parties would benefit from a better understanding of the real-world trade-offs between minimizing the delay of 911 call placement, and the ability to more precisely route the call to the desired PSAP. Which of these parameters is the highest priority? How long is too long to delay a 911 call to improve the precision of call routing? With better insight into these types of system design trade-offs, and a concerted effort from all relevant stakeholders, there is a strong potential for improvement.”

“Based on trial experience, Verizon agrees that location-based routing is technically feasible and can mitigate (although not eliminate) the number of instances in which 911 calls are routed to PSAPs outside the caller’s jurisdiction,” Verizon Communications, Inc., said. “The Commission is thus right to seek input on the measures that wireless, Next Generation 911 (‘NG911’) providers, and PSAPs will need to undertake to ensure that consumers benefit from location-based routing of 911 calls.”

“Stakeholders will need to carefully allocate the roles and responsibilities of wireless service providers and state/local governments in deploying and maintaining LBR capabilities to ensure that LBR is deployed efficiently and effectively,” Verizon added. “Most important for consumers’ public safety needs, LBR should be implemented in manner that does not undermine the reliability of wireless 911 call routing. That, as a practical matter, will require the continued availability of cell sector-based routing for the foreseeable future. Finally, in the interim period, the Commission should support the use of existing best practices to improve and maintain the reliability of cell sector-based routing.”

The Voice on the Net Coalition said the CSRIC report “does not address the specific challenges faced by interconnected VoIP providers (and their third party 911 vendors) who may not have the same access to location information as CMRS providers. Notwithstanding the challenges, it’s likely that location-based technologies will provide more accurate and timely routing information for mobile VoIP 911 calls than the required registered location. By moving to a routing paradigm based on acquisition of a real-time location calculation, the FCC and industry standards bodies have the opportunity to significantly improve emergency calling services by routing mobile VoIP calls to a more appropriate PSAP. To the extent that location information can be used in a manner that rapidly and efficiently routes a 911 call to the most appropriate PSAP, VON believes there is great promise in leveraging these available technologies. There is much work to be done to effectuate a new emergency call routing paradigm, but the foundation is evident in the location capabilities available in the marketplace today.”

VON also asked “that the FCC take a broader view than simply the US market. While we recognize that the FCC’s authority does not extend beyond the US, the FCC can be a leader by encouraging the use of available technologies through consistent technical standards developed across the globe.”

“The location accuracy problems inherent with the routing of wireless 9-1-1 calls can be addressed by migrating to device-based hybrid location solutions, which combine data from various sensors on the user’s mobile device and provide the best information about the user’s actual location based on context and environment. Numerous test results confirm the viability of these device-based hybrid location solutions, which can provide more accurate location information on a more timely basis as compared to the legacy 9-1-1 routing architecture,” Motorola Solutions, Inc., said.

“The Commission should use this proceeding to explore the creation of incentives for deploying location based routing technologies. Such incentives should include sufficient and sustained levels of funding for Next Generation 9-1-1 (‘NG9-1-1’) deployments, of which device-based hybrid location solutions should be an integral part,” Motorola added. “Specifically, the Commission should explore the creation of incentives for: (1) ongoing testing and pilot activity validating improvement/benefits derived from location based routing technology; (2) PSAPs to use location based routing technology; and (3) the migration to NG9-1-1 and the use of location based routing technology at the state and local levels.”

“As the Commission recognizes, the path forward to achieve successful 9LBR [911 LBR] requires striking a balance between the industry’s concerns over disruption to existing processes and that of providing more accurate information more quickly to aid in essential lifesaving services,” Comtech Telecommunications Corp. said. “Indispensable elements along this path include, identifying and measuring the problem, consistent use of technical terms and operational processes, application of appropriate (existing or new) industry standards, specifically addressing the ‘delay of call’ issue, safeguarding the sources and destinations of location data, and promoting consistent and systematic testing of call and location data. Also, new entrants need to understand and accept that public safety operates differently than other business arenas. Public safety isn’t a game or a greenfield for the latest consumer product fad, it’s a highly regulated industry devoted to the public good. Serious vendors are encouraged, respected, and protected; less dedicated vendors may not be.”

Comtech continued, “While technological advancement brings new ways of solving difficult problems, much of today’s well-meaning progress is being promoted in a vendor-specific, proof-of-concept approach that competes with the time-tested and more inclusive public safety coordinated, and standardized approach. While Comtech shares in the desire for innovation, some of the current side effects experienced in the fray to overturn the ‘status quo’ of what is today’s emergency location processes include[:] lack of common goals, the inability to verify results, unanswered questions around whether there is statistical significance, and unknowns as to whether these experiments are replicable.

“Wireless 9-1-1 location based routing is not a panacea for all of 9-1-1’s ills, and the quest for 9LBR cannot impede the goal of maintaining reliable wireless 9-1-1 calling. It is imperative that for 9-1-1, we achieve consistent, reliable methods and solutions, avoiding at all costs, experiments that potentially jeopardize ‘live’ 9-1-1 calls without carrier and FCC notification,” Comtech concluded.

West Safety Services, Inc., said it “has experienced encouraging test results for handset-initiated location technologies that utilize device-based hybrid location information. Unlike network-initiated technologies, calls to 9-1-1 over these handset-initiated technologies do not have to traverse complex carrier networks or wait to reach the carrier’s routing element before initiating the process for location determination. West Safety believes these handset-initiated location technologies offer promise for significantly reducing the PSAP transfer rate. West Safety cautions the Commission, however, that carriers should maintain control over any implementations of device-based hybrid location solutions. Permitting third-party applications to deliver locations directly to PSAPs without interconnecting to the carrier’s routing element should be avoided. Carriers are in the exclusive position to ensure location uniformity, security, reliability and validation under centralized Commission oversight and clear jurisdiction.”

NextNav LLC said that the FCC “should ensure that any location-based routing solution that is employed for E911 calls incorporates adequate backup protection in scenarios where a technology might be used by a wireless carrier for location compliance, but fails to timely achieve an accurate fix in all instances. For example, in those cases in which a carrier employs A-GPS, other location technologies should be available to support the routing of calls originating from indoor locations where A-GPS may not produce a location fix. In addition, if a DBH [device-based hybrid] approach is used, consideration must be given to whether the resulting location information is sufficiently reliable to support call routing, particularly in communities and neighborhoods where broadband penetration is low (such as in low income areas), where Wi-Fi devices may be subject to frequent relocation (such as college dorms or apartment complexes), or in cases in which individuals may have turned off the location functions on their wireless handsets due to privacy concerns.”

NextNav also said that its location technology could be deployed to quickly ensure that 911 calls are accurately routed to the correct PSAP.

LaaSer Critical Communications said it “has created patented technology that pinpoints a 911 caller’s location using any mobile device, efficiently routes them to the appropriate Public Safety Answering Point (PSAP), and provides the emergency operator and responders with precise location information.” It said “that the answer to the question ‘what is the best way to avoid delays’ caused by ‘misroutes’ is inclusion of DBH location within the existing wireless carrier routing systems. Such a deployment leverages the best of what DBH has to offer, ensures that routing improvements are only ever additive with existing systems providing a consistent and reliable base level of performance, allows for ubiquitous PSAP availability, and is available in current-state environments, NG911 environments, and transitional environments.”

Precision Broadband LLC described its prototype fixed broadband 911 location and routing system and said that “[b]y utilizing fixed broadband for 911, state governments would be justified, and legally empowered, to assess 911 fees on home broadband service (as is done today on landline and mobile phone service). When applied to the 106 million US broadband households, an additional $1 billion annually could be collected for 911 services. These fees, along with revenues from new entrants in the 911 market, could be used to implement the solutions being developed by Precision Broadband and other market participants as well as expediting the deployment of NG911 technologies.”

Onvoy LLC (d/b/a Inteliquent) said it “appreciates and supports the Commission’s efforts to solve the very real problem of wireless 9-1-1 call misroutes due to the outdated cell-tower-based call routing system. Inteliquent’s experience counsels that device-based solutions are the way forward to delivering fast and accurate location information to the correct PSAP at the outset. Inteliquent is already working with its partners on developing such a solution, and looks forward to real-world testing of the solution later this year. Any steps taken by the Commission should facilitate and encourage device-based location routing for 9-1-1 calls, and avoid solutions that rely on centralized databases that are costly to update and maintain at the level necessary for use in emergency services.”

Mission Critical Partners LLC encouraged the FCC “to promote the uniform adoption of location-based routing technologies, especially with universal transition to Next Generation 911 (NG911). Particularly, the Commission should encourage the implementation of Advanced Mobile Location (AML) or the vendor-specific variations, e.g., Emergency Location Service (ELS), a proven life-saving technology. MCP believes the Commission can support the implementation of location-based routing by removing liability barriers that could be raised by the Commercial Mobile Radio Service (CMRS) providers and NG911 solution providers for using third-party location.”

Charity Feb of Camas, Wash., whose 911 call about her husband, who had a fatal heart attack in 2012, was routed in Portland, Ore., thanked the FCC for launching its proceeding. – Paul Kirby, paul.kirby@wolterskluwer.com

Pai Tells ACS It May Not Decline Service to Rural Healthcare Providers

FCC Chairman Ajit Pai has reminded Alaska Communications Systems Group, Inc., (ACS) that it has an obligation under the Communications Act and FCC rules to comply with a “bona fide request” for telecom services “which are necessary for the provision of health care services in a State,” and that it must not charge rural healthcare providers more than the urban rate for such services.

In a letter dated today, Chairman Pai told ACS President and Chief Executive Officer Anand Vadapalli that he was “disheartened to hear this past week that Alaska Communications, because of questions about its compliance with Commission rules, is reconsidering its participation in the [Universal Service] Fund’s Telecommunications Program, a program that is key to providing remote Alaskan villages with telecommunications services.”

Under the Act and FCC rules, Chairman Pai said, “Alaska Communications may not deny or cut off service to any of its existing rural healthcare provider customers.”  It also “may not deny or cut off service to any of its existing rural healthcare provider customers for lack of payment of any charge higher than the urban rate,” Chairman Pai said.

“I would also remind you that, as a telecommunications carrier offering telecommunications services to rural healthcare providers, Alaska Communications is prohibited from engaging in unjust and unreasonable practices or from discontinuing service to a community without prior Commission approval.” — Lynn Stanton, lynn.stanton@wolterksluwer.com – Courtesy TR Daily

FCC Reaches Settlements Over LED Signs

The FCC’s Enforcement Bureau has reached consent decrees with two companies to resolve investigations into whether they marketed LED signs used in digital billboards and other commercial and industrial applications without the required FCC equipment authorization, labeling, and disclosures in violation of agency rules. In a consent decree in file no. EB-SED-17-00024598, Optec Displays, Inc., agreed to pay $54,000, while in a consent decree in file no. EB-SED-17-00024600, Tradenet Enterprise Inc. (d/b/a Vantage LED) agreed to pay $15,000. Courtesy – TRDaily

Andy Seybold’s Public Safety Advocate, May 3, 2018

Is LMR Old and Out of Date? LTE the Future? For the past few weeks I have been talking with folks in D.C., states, and locally about FirstNet and if and when it will replace Land Mobile Radio (LMR) systems. I have found that among those not directly involved with public safety and do not have much, if any, technical background, there is a great deal of confusion surrounding LMR, FirstNet, and the limited amount of spectrum available to us.

These issues include but are not limited to the perception that LTE and 5G represents the only wireless future and land mobile radio is an antiquated technology that is no longer needed. Further, they believe all spectrum regardless of where it is located in the radio spectrum continuum is worth a fortune and therefore should be converted to broadband spectrum as soon as possible so it can be auctioned. It is interesting that these are the same issues the Public Safety Spectrum Trust (PSST) and Public Safety Alliance (PSA) faced when they were first engaging with those in the federal government to convince elected officials that public safety needed more broadband spectrum but needed to keep its LMR spectrum as well.

It took a while but public safety gained the support of the governors’ and mayors’ associations. However, when FirstNet was passed, Congress required a give-back of the T-Band spectrum. Part of the reason for this was the belief that the spectrum in these eleven major markets, once vacated by public safety (Congress forgot about business users also authorized in the T-Band), would be worth $billions of dollars and that funding could be used to relocate the T-Band public safety users and pay off a portion of the U.S. debt. However, it has not turned out that way. Now there is a bill in Congress to forgive the T-Band give-back but so far it has not progressed as quickly as we would have liked.

All of the above has convinced me that many of the staffers and those who served in Congress during the years preceding the law that created FirstNet in 2012 have left Congress or are not in the same committees they were. The new guard, as it were, grew up with cell phones. That is all they know, I don’t think any of them have been exposed to handheld radios with push-to-talk-only capabilities, even Family Service Radios (FSRs) that can be purchased for less than $20 in most stores. Nor do I think many, if any, have asked for a ride-along with police or sheriff personnel. Instead, they believe their smartphone can do anything and everything needed by public safety. And when they have a dropped call or cannot access the network it is an inconvenience and they complain, but they don’t seem to realize that it is not the same as a police officer being shot at and needing back-up. In that case, not being able to access the network or not being able to communicate with others can become a whole lot more than an inconvenience.

Even those in charge at FirstNet will tell you that both FirstNet and LMR networks are vital tools for public safety. Most recently, the head of AT&T’s FirstNet efforts was featured and quoted in an article in Urgent Communications and reposted on allthingsfirstnet.com saying the following:

“Push-to-talk over cellular (PoC) already is being used to replace LMR in non-mission-critical scenarios, but learning from those experiences eventually will impact acceptance of MCPTT-standard offerings, according to Chris Sambar, AT&T’s senior vice president for FirstNet.

It will start with extended primary [users] in public safety, and it will move to first responders, in time,” Sambar said last month during an event sponsored by Sonim Technologies. “I don’t know how long that will take. I think there will always be a place for LMR, because it’s a great tool. I think [LMR] will start slowly moving to a backup technology, though. But it will take time.””

Even AT&T understands that both FirstNet and LMR are needed today and into the future to ensure the safety of our first responders. As Mr. Sambar stated, it is possible today to move some administrative and other non-front-line public safety personnel off their LMR systems onto push-to-talk over FirstNet but it will take some time, if ever, for FirstNet to become the only communications platform for public safety.

Looking at the Other Concerns

Is LMR an antiquated technology or a proven technology? LMR was developed and deployed starting in the 1930s and push-to-talk communications were used by the military during World War II and in every conflict since. Some of today’s systems are based on digital technology (P-25) but there are still analog FM LMR systems in use, particularly in smaller agencies. LMR has evolved and now P25 PTT includes group PTT, one-to-one PTT, and the ability to be cross-connected with PTT on FirstNet.

One of the most significant advantages of LMR today is that many LMR systems are much closer to meeting the public safety-grade criteria than FirstNet. However, it is FirstNet’s (AT&T’s) goal to move FirstNet, over time, as close to a public safety-grade network as possible. While some new standards have been developed or are being developed to add even more redundancy to FirstNet, the results of these new standards remain untested.

LMR, on the other hand, has the real advantage of multiple modes of operation. If an LMR system is up and running using multiple sites in one of several modes that make that possible, and one or more sites fail, these sites, if still operational locally, switch to local access. If the site fails completely, units in the area can still communicate with each other using direct mode or off-network communications. This type of fallback is vital to the robustness of LMR. Further, if a site is in standalone operations mode, any unit in range will be able to communicate through the site. In the cellular world today, even if a site remains up but disconnected from the rest of the network, it is not clear whether devices will still be able to use the site because the device IDs and access rights are normally validated in the network core.

The most significant disadvantage FirstNet and all LTE networks have today when it comes to push-to-talk are that off-network PTT is not possible today with LTE. If two units or a group of units want to have a PTT conversation they must be in range of the network and the network must be operational. With LMR, neither of these is required. Off-network PTT can occur within the coverage of a network when one device is in network coverage and one is out of coverage, and if all units are out of coverage. This is a vital function of LMR that must be provided for FirstNet devices if FirstNet is ever to replace LMR PTT functions as well as network-related functions.

What Is Spectrum Worth?

This is an issue for which there are many answers. My answers are based on the following criteria:

  • In what portion of the RF spectrum is the subject spectrum?
  • How much of it is available?
  • What other services will need to be relocated out of this spectrum?
    1. To where will they move?
    2. Who will pay for the relocation?
  • Is the spectrum in a portion designed to cover LTE or 5G?
  • Is it possible to make this spectrum available nationwide?
  • Is the spectrum usable in mobile devices? (antenna size, battery life, device size)
  • Who are potential customers and is there more than one type of customer that might be interested enough in the spectrum to make it more valuable at auction?
  • What other factors might impact the cost of the spectrum?

Let’s start with LTE frequency allocations. According to Radio-Electronics.com, the issue with spectrum allocations for LTE using Frequency Division Duplex (FDD) where the cell site transmits on one part of the spectrum and the device transmits on another (what we are accustomed to), is that there must be sufficient separation between the two portions of spectrum to prevent the receiver from being blocked by the proximity of the transmitter. The FDD chart includes band 31 sets of spectrum at 452.5–457.5-MHz and 462.5–467.5-MHz, both of which are located in highly congested LTE public safety, business, paging, and other LMR systems in the United States. But this band is limited to 5 MHz of bandwidth, which means the value of this spectrum for broadband is very much diminished.

There are also LTE spectrum allocations for Time Division Duplex (TDD) (see some of Sprint’s 2-GHz spectrum holdings). In this case, the cell site and the device transmit on the same radio channel but in time slices so as not to interfere with each other. In TDD, the lowest spectrum supported is band 44, which is 100 MHz of spectrum in the 703–803-MHz range. Since Verizon and FirstNet broadband and LMR 700 are already in this spectrum in the United States, it is not practical to try to make use of it.

The T-Band 470–512-MHz is not included in any of the FDD or TDD LTE spectrum allocations. It does not offer enough spectrum in any given city (12 MHz total) for a reasonable FDD LTE transmit and receive split and the chances of it being used for TDD LTE in my estimation are slim to none. Add to this that this spectrum is only available in eleven major markets and the rest of the country is using this spectrum for its original purpose, which was to provide channels for TV stations, and there is yet another reason to limit the value of the T-Band spectrum.

The questions then boil down to who would want spectrum only in eleven major metro areas, who would then pay the estimated $billions in relocation fees for public safety (not including business users), and to where would these public safety systems be relocated? At one point the FCC was talking about using the T-Band for low-powered TV stations and translators but companies that do that are not inclined to pay much for spectrum. If the FCC were to offer the spectrum to them for nothing we would have more of a problem because there would be nowhere to move T-Band users to and no money with which to move them.

The value of spectrum varies widely based on the answers to my above questions. If you remember back to the AWS-3 auction (which funded the $7billion starter fund for FirstNet with the bulk of the $Billions coming from AT&T), it generated $44 billion in auction revenue. The price paid for this spectrum was more than had ever been paid for spectrum per-MHz in the United States. If you fast forward to the 600-MHz auction it was not nearly as successful for several reasons. First, carriers had all decided that 5G small cells were the be-all, end-all for capacity and speed increases in metro markets. The 600-MHz spectrum is great for more of the same LTE systems already on 700-MHz and other portions of the spectrum, but only spectrum above 2.5-GHz is really suitable for small cell. Many TV channels went unsold, and the price paid for the spectrum that was auctioned was much lower than expected. Verzion did not win a single piece of the spectrum even though it was registered to bid, and it stated beforehand that it really wanted 5G spectrum, not 600-MHz spectrum. As it turned out, Verizon did not bid on FirstNet either saying it simply did not need the spectrum. Not all of the spectrum was bid on and won and the bidding totaled $19.8billion, well below AWS-3 receipts.

Those who believe spectrum, regardless of where it is located in the RF spectrum, is worth a lot of money do not understand the issues. To raise money at an auction it needs to have nationwide availability and be in part of the spectrum where LTE or 5G spectrum is in demand. To try to convert 150–170-MHz from Land Mobile Radio to broadband mobile would end up with no one at the bidders’ table. Perhaps there are better future uses for this spectrum but not today and not with it encumbered with many different classes of license holders. The same goes for the 450–470-MHz and 800-MHz public safety bands.

The law that created FirstNet included a provision that the 12 MHz of 700-MHz spectrum used for LMR public safety communications could, at some future time, be converted to more broadband spectrum but only for public safety. That would not generate any revenue and would cause even more problems with LMR systems in the 700-MHz band that are deployed coast to coast including entire states such as Michigan. It appears as though those who are elected and can change the wireless landscape with their votes lose interest in converting a lot of spectrum to broadband when they come to understand that the highest and best use for spectrum in some portions of the RF spectrum is not for mobile broadband.

The AM broadcast band (525 KHz to 1705 KHz) is good for AM radio but at night local stations sometimes have to compete with interference from stations in other cities. As we move up the band into the MHz-region, we find long-distance ship-to-shore, country-to-country, amateur radio, and other forms of communications in spectrum that is not at all suited for broadband services. Then we reach VHF, UHF, and higher and some of this spectrum is great for broadband but some, such as 600-MHz and 700-MHz spectrum is better for larger cells with more coverage—the higher the spectrum the less range. 5G is based on the premise that there will be many small cells that are part of the network and users will move from one to another seamlessly as with cellular. However, since they are small cells with a lot of bandwidth, they will be able to deliver more capacity and data speeds.

Some people could have become very rich if they had realized four or five years ago that the real value for spectrum would shift to 2 GHz and above. However, until only a few years ago, the concept of cellular was the same: more towers closer together, and over time adding microcells. While 5G is a logical move forward, it was not widely considered viable until recently and now every carrier, cable tv company, and others want to play in this space.

The value of spectrum to the federal government depends on how many companies want access to the spectrum and for what purpose. 5G and the Internet of Things (IoT) seem to be the big drivers today, which leaves spectrum such as the T-Band and, thankfully, the rest of the public safety spectrum as spectrum having value to be sure, but not enough for elected officials to see visions of national debt dollars floating before their eyes.

The Last Word

The UK has come to understand that in order to move its public safety community over to LTE in the next two years or so it will have to use Tetra for off-network PTT since LTE won’t be anywhere close to providing this capability.

Sonim has announced it will be providing off-network PTT using licensed P-25 channels and Harris’s XP-200p has four bands of LMR and FirstNet, too (once approved by AT&T). There will be more products coming, and a larger variety of options. At some point, the technology will enable a single device with lots of LMR capability and FirstNet with long battery life. Until then, public safety needs to be able to use LMR and FirstNet through different devices: FirstNet for information, visual prompts, video of the scene, and more; LMR for normal day-to-day voice communications that have for years worked and saved lives.

When we were all working with Congress and I was presenting at APCO broadband summits, I had a set of PowerPoints that compared and contrasted LMR and LTE. Perhaps it is time to dust them off, update them, and hold a few Wireless Universities again!

Andrew M. Seybold
©2018 Andrew Seybold, Inc.

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FCC Extends Reply Comment Deadline for 911 NOI

The FCC’s Public Safety and Homeland Security Bureau today granted a request to extend by one week the reply comment deadline for a notice of inquiry adopted in March looking at ways to ensure that 911 calls placed from mobile phones reach the correct public safety answering point (PSAP) (TR Daily, March 22). Replies had been due June 21 in PS docket 18-64, but they will now be due June 28. In a joint motion for an extension filed last month (TR Daily, April 20), the National Emergency Number Association, the National Association of State 9-1-1 Administrators, the Texas 9-1-1 Entities, West Safety Services, Inc., Comtech Communications, Inc., and CTIA cited the timing of the National Emergency Number Association’s annual conference in Nashville June 16-21. – Courtesy, Paul Kirby