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Is LMR Old and Out of Date?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

 

 

 

O’Rielly Criticizes Puerto Rico 911 Fund Diversion

FCC Commissioner Mike O’Rielly today criticized Puerto Rico’s diversion of 911 funds and suggested he would oppose approving additional universal service funds to the island if it doesn’t end the diversion practice.

Mr. O’Rielly wrote a letter dated today to Puerto Rico Gov. Ricardo Rossello Nevares responding to a March 7 letter the governor wrote him that responded to a Feb. 20 letter that Mr. O’Rielly sent to the governors of Puerto Rico, New York, Oklahoma, Missouri, Montana, Northern Mariana, and Guam asking why they did not submit requested information to the FCC for its latest annual report on 911 fund diversions (TR Daily, Feb. 20).

In his letter to Mr. O’Rielly, Gov. Nevares said that Puerto Rico collected the requested information but did not send it “due to a clerical error. We have taken measures to ensure that this situation does not happen again and we include herein the forms for the requested year.” Continue reading

Entities Seek Extension of 911 NOI Reply Comment Deadline

Public safety and industry entities have asked the FCC to extend by one week the reply comment deadline for a notice of inquiry adopted last month looking at ways to ensure that 911 calls placed from mobile phones reach the correct public safety answering point (PSAP) (TR Daily, March 22). Comments are due May 7 and replies June 21 in PS docket 18-64. In a joint motion for an extension filed yesterday seeking an extension of the reply comment deadline to June 28, the entities cited the timing of the National Emergency Number Association’s annual conference in Nashville June 16-21.

“Granting a one-week extension of time will allow these critical stakeholders time to review, analyze, and comment on all of the comments in the record, without direct time constraint conflicts between preparing NOI reply comments regarding location-based routing for wireless 9-1-1 calls and other 9-1-1 efforts associated with the NENA Conference.,” the filing argued. The filing was submitted by NENA, the National Association of State 9-1-1 Administrators, the Texas 9-1-1 Entities, West Safety Services, Inc., Comtech Communications, Inc., and CTIA.

Courtesy TRDailly

Coalition Emphasizes Homeland Security Importance of 3.5 GHz Band

Members of the Industrial Internet of Things Coalition have asked the FCC to consider the impact on “national and homeland security” of the rules it adopts for priority access licenses (PALs) in the 3.5 gigahertz band Citizens Broadband Radio Service.

In an ex parte filing yesterday in GN docket 17-258, the entities emphasized the importance of the FCC’s licensing the spectrum in small enough geographic areas for them to be useful to industrial and critical-infrastructure entities.

“Thus, as the Commission considers different CBRS licensing approaches in this proceeding, the IIoT Coalition urges it to weigh the effects of its policy choices on U.S. national and homeland security,” the filing said. “If industrial and critical-infrastructure companies are able to compete in auctions for census-tract licenses and gain meaningful access to licensed CBRS spectrum, these companies can realize the full benefits of the IIoT revolution, including improved safety, security, and system resilience at America’s critical-infrastructure facilities. With a full understanding of the complexity of their own operations, industrial and critical-infrastructure entities will be able to employ essential IIoT security, device, and network control features to further safeguard their core-mission operations from foreign and domestic hacking efforts and cyber intrusions, to the great benefit of the American public.” Continue reading

Andy Seybold’s Public Safety Advocate, April 19, 2018

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FCC Official Stresses Importance of 4.9 GHz Band Utilization

The chief of the FCC’s Public Safety and Homeland Security Bureau today stressed the importance of the 4.9 gigahertz band being widely utilized, which she stressed that it hasn’t so far. Last month, Republican FCC Commissioners emphasized the potential benefit of repurposing the band for commercial purposes, or at least opening it up to additional usage, citing the fact that the spectrum has not been heavily used since the Commission made it available for public safety agencies in 2002 (TR Daily, March 22).

Their comments came as Commissioners unanimously adopted a sixth further notice of proposed rulemaking in WP docket 07-100 seeking views on ways to promote more intensive use of the 4940-4990 megahertz band.

During luncheon remarks this afternoon at the annual meeting of the Land Mobile Communications Council, Lisa Fowlkes said that “public safety’s use of the 4.9 GHz band has fallen short of its potential. The further notice seeks ways to reverse this trend.”

Among the options the FCC is seeking comments on are extending use of the band to utilities are repurposing it for commercial use, she noted. “But let me be clear: all options for this band are on the table, except … for the option of allowing underutilization of the band to continue,” she said. “It is important that we hear from the LMCC and its members on the proposals and options.” Continue reading

FCC Urges Providers to Follow Best Practices

The FCC’s Public Safety and Homeland Security Bureau released a public notice today to detail “lessons learned from major network outages” and remind providers “to review industry best practices to ensure network reliability.”

“Based on its recent analysis of several major network outages that affected subscribers, including those calling 911 for emergency assistance, Bureau staff determined that the outages could likely have been prevented or mitigated if the provider had followed certain network reliability best practices,” the public notice said. “Therefore, the Bureau encourages communications service providers to implement the following industry best practices, as previously recommended by the Commission’s Communications Security, Reliability and Interoperability Council: 1. Minimize Impact of Maintenance Windows. Network operators and service providers should be aware of the dynamic nature of peak traffic periods and should consider scheduling potentially service-affecting procedures (e.g., maintenance, high-risk procedures, growth activities) to minimize the impact on end-user services. 2. Monitor 911 Network Components. Network operators, service providers, and public safety entities should actively monitor and manage the 911 network components using network management controls, where available, to quickly restore 911 service and provide priority repair during network failure events. When multiple interconnecting providers and vendors are involved, they will need to cooperate to provide end-to-end analysis of complex call-handling problems. 3. Ensure Real-World Testing Conditions. Service providers and network operators should consider validating upgrades, new procedures and commands in a lab or other test environment that simulates the target network and load prior to the first application in the field.” Continue reading