Andy Seybold’s Public Safety Advocate, August 10, 2017

Why Public Safety Devices Need a New SIM Card This week’s PSA is based on a question I hear nearly every day. It started when AT&T won the FirstNet contract and offered up its own LTE networks in addition to what it will build out on FirstNet Band 14 spectrum. AT&T is offering early opt-in state and territories (at least 11 so far) the use of its AT&T network on a priority access basis with full pre-emption on the entire AT&T LTE network by the start of 2018.

AT&T says it is easy to start using the AT&T network for public safety. Once a state has opted in, each public safety entity will decide if it wants to join the FirstNet system and become users on the AT&T broadband network. If the answer is yes and the pricing is acceptable to the agency, all that is needed, according to AT&T, is to install a new SIM (Subscriber Identity Module) into the mobile device to be instantly considered a public safety user on the AT&T network and on Band 14 as it is built over time.

The question about why you need to install a new SIM in your device is based on a number of factors. The most important of these is that the new SIM identifies the device (and the user) as a member of the public safety community. The network is then notified that when this device is on the network, in addition to normal AT&T capabilities, the user will have access to all additional capabilities and information being made available only to the FirstNet public safety community. The AT&T network and soon FirstNet Band 14 recognizes a user as a public safety user by the SIM in the device and the information it contains. Read the Entire Blog Here  Continue reading

Problems with ECFS Fixed

Problems with the FCC’s electronic comment filing system were fixed today, and ECFS appeared back to normal this afternoon. Yesterday and earlier today, searches for standard filings posted yesterday turned up more than 2,600 items, most of which had no attachments. Although ECFS said the documents were posted yesterday, most appeared old, including filings by companies no longer in business, such as Cyren Call Communications Corp. and M2Z Networks, Inc. “During an update to the ECFS system, some files from the old system that were lacking dates were temporarily appearing as new files,” an FCC spokesman told TR Daily this afternoon. “The issue has been resolved.”

Courtesy TRDaily

911 Reliability System Open

The FCC’s Public Safety and Homeland Security Bureau announced today that the agency’s 911 Reliability Certification System is open for filing of annual reliability certifications. They are due Oct. 15.

Courtesy TRDaily

RWA Takes Issue with T-Mobile on Report for 700 MHz Band Licenses

The Rural Wireless Association is taking issue with a construction progress report that T-Mobile US, Inc., recently filed for three 700 megahertz band licenses covering areas in Montana and Wyoming. Last December, the Mobility Division of the FCC’s Wireless Telecommunications Bureau granted T-Mobile a conditional waiver of rules that mandate the acceleration by two years of the final build-out deadline (TRDaily, Dec. 21, 2106).

In an Aug. 4 ex parte filing in WT docket 16-319, RWA said that “the report does not provide any information from which T-Mobile’s current coverage area, much less the roll back area, can be determined. The report speaks in very aspirational terms in defining T-Mobile’s goals and planning but is lacking in any specifics that would show the level of coverage and service availability T-Mobile has accomplished to date. With respect to WQJQ805 and WQJQ806, T-Mobile has filed no buildout showings whatsoever. With respect to WQJQ807, T-Mobile has submitted a buildout showing current as of February 17, 2017. With respect to the former two stations, T-Mobile must be required to demonstrate actual coverage and service availability as it existed on June 13, 2017 or stipulate to the fact that no coverage or service availability existed for those two licenses as of that date. With respect to WQJQ807, T-Mobile last filed coverage and service availability information on February 17, 2017.

“If in fact there has been no expansion of coverage or service area since T-Mobile’s last construction notice showing coverage as of February 17, 2017, then at a minimum T-Mobile should stipulate to this fact,” RWA added. “If coverage and service areas were increased between December 13, 2016 and June 13, 2017 then it is incumbent upon T-Mobile to demonstrate this fact through the submission of an appropriate construction showing.

“Without the filing of system maps and shapefile data reflecting coverage as of June 13, 2017, there will be no way for potential competitors to determine the boundaries of T-Mobile’s license area in the event that it fails to meet all of the conditions imposed by the waiver letter,” RWA argued. “This point was specifically acknowledged by the Bureau in its recent decision granting a conditional waiver of section 27.14 of the rules to Alaska Wireless Network (‘AWN’) for one of its 700 MHz licenses [TR Daily, June 6]. In that case, the Bureau specifically required AWN to file ‘a showing demonstrating its geographic coverage area within 15 days of June 13, 2017’ so that the June 13, 2017 coverage area could be readily ascertained. These same concerns apply with equal force in the present case and the Bureau should rectify its potential oversight by requiring T-Mobile either to submit a construction notification for each of its licenses subject to the waiver immediately, or to include that data in its upcoming construction progress report.” —Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily

FCC Amends Applicant Form

The FCC’s Wireless Telecommunications Bureau announced today that its “Form 605, Quick-Form Application for Authorization in the Ship, Aircraft, Amateur, Restricted and Commercial Operator, and General Mobile Radio Services, has been revised in both paper and electronic form to ask whether the applicant has ever been convicted of a felony, a revision consistent with application forms for other Commission services.  The previous edition of FCC Form 605 will become obsolete and the new edition of the form must be used upon deployment on Sept. 7, 2017.”

Courtesy TRDaily

Comment Sought on Request for Extra Time to Build Out 700 MHz Band Licenses

The FCC’s Wireless Telecommunications Bureau sought comment today on a request for an extension of time or a waiver to give 700 megahertz band guard band A-block licensees additional time to make their “substantial service” construction showing.  Comments are due Sept. 6 and replies Sept. 21 in WT docket 17-201.  The request was filed by FELHC, Inc., BPC Spectrum LLC, Dominion 700 Inc., and Access 700 LLC.  “The license terms in this case expire on June 13, 2019.

The parties explain that the licenses will be deployed as a private, internal radio system to support utility operations and the reliable monitoring and control of electrical equipment at thousands of locations across several states,” a public notice observed.  “The parties seek an extension of time or waiver until Dec. 31, 2022, to transition from legacy copper communications facilities to the planned 700 MHz Guard Band A Block-based wireless system.  In addition, the parties seek clarification regarding the construction metric that will be used to demonstrate compliance with the substantial service performance requirement.”

Courtesy TRDaily

Parties Support Waiver to Permit 800 MHz Band System

Parties have filed comments that generally support a waiver request filed by the Arizona Public Service Company (APSC), an electric utility, to allow it to deploy a new 800 megahertz band Project 25 system.

APSC has filed 54 applications for 800 MHz channels at 53 locations for a statewide trunked radio system, which it said will improve coverage over its current network. “The requested operations are in National Public Safety Planning Advisory Committee (NPSPAC) regions along the border with Mexico. These areas currently are subject to a freeze on 800 MHz non-rebanding applications, in order to preserve vacant channels for licensees retuning their systems according to the Public Safety and Homeland Security Bureau’s updated band plan for licensees operating along the border with Mexico,” the FCC’s Wireless Telecommunications Bureau noted in a public notice released in June seeking comments on APSC’s waiver request. “APSC states that it selected frequencies that will neither cause interference to incumbent licensees nor disrupt the rebanding process. Consequently, it requests a waiver of the licensing freeze.” Continue reading

Seybold Suggests Push to Delay T-Band Reallocation

Andy Seybold, a wireless industry consultant and public safety advocate, suggests in his latest weekly commentary that the public safety community lobby Congress to delay by five years the reallocation of the T-band. The Middle Class Tax Relief and Job Creation Act of 2012, which created the First Responder Network Authority (FirstNet), requires the FCC to reallocate and auction public safety spectrum in the T-band by 2021 and relocate incumbents by 2023. Proceeds from the auction can be used to cover the relocation costs of public safety licensees. But the law didn’t say anything about relocating non-public safety licensees.

The cost of relocating public safety T-band operations to other spectrum would be more than $5.9 billion, according to a report released in 2013 by the National Public Safety Telecommunications Council (TR Daily, March 15, 2013).

“Recently I have been considering an approach that might, in fact, be agreeable to Congress. What if the public safety community were to request an extension of the time before the move is required as opposed to repealing the law? I think a five-year extension would provide enough time to figure out if FirstNet will be capable of handling the traffic in these 11 heavily congested metro areas, or if the FCC can find additional spectrum (and funds) for relocation elsewhere,” Mr. Seybold said in his commentary. Continue reading

Parties Disagree on Some Details of FCC’s NPRM to Implement Blue Alerts

Parties have generally expressed support for an FCC proposal to amend its Emergency Alert System (EAS) rules to add the event code “BLU” for Blue Alerts, but they disagree on some details, including the timeframe for deploying the new code and whether it should be voluntary. The new alert would enable the dissemination of information when law enforcement officers have been killed or seriously injured, are in imminent danger, or are missing.

In comments filed in PS docket 15-94 in response to a notice of proposed rulemaking adopted in June (TR Daily, June 22), the National Association of Broadcasters said it “supports the Commission’s commitment to public safety, and in particular, its effort to facilitate the apprehension of suspects who pose an imminent threat to law enforcement officers by notifying the public of an actionable threat to law enforcement officers. NAB recommends certain measures designed to enhance the effectiveness of Blue Alerts. Specifically, we submit that the highly successful AMBER Alert program provides a useful model for implementation of Blue Alerts. For example, like the AMBER program, a uniform approach to Blue Alerts will facilitate nationwide implementation, uniform message formulation and the consistent dissemination of Blue Alerts by EAS Participants. Also similar to AMBER Alerts, the Commission should require a comprehensive training and technical assistance program for message originators to ensure efficient message origination. Finally, we agree with the Commission’s proposed implementation period of six months, so long as a reasonable waiver process is available to broadcasters that face unexpected delays in introducing the new code.”

NAB proposed “that, as in the AMBER Alert program, Blue Alert stakeholders should agree that law enforcement officials will issue alerts only when established criteria have been met. Law enforcement officials should also help EAS Participants provide accurate information, and provide a method for handling tips and inquiries once the alert has been activated. Also, like AMBER Alerts, news organizations may use information in a Blue Alert for news purposes, and supplement that information with legitimate reporting to better inform the public. These and other criteria will help to ensure that Blue Alerts are accurate, timely and issued in an efficient manner.”

NCTA said its “member companies support the Commission’s proposal, unveiled at a recent DOJ event, to add Blue Alerts to EAS to assist in the protection and safety of police and other law enforcement officers in dire emergency situations in the line of duty. And as with other non-Presidential emergency alerts, including weather alerts and other state and local alerts, the transmission of Blue Alerts by EAS participants will be voluntary. This is consistent with the voluntary nature of the Blue Alert program and appropriate for incorporating the new code into the EAS rules.”

But NCTA noted that the NPRM “proposes to have EAS equipment manufacturers integrate the Blue Alert event code into equipment yet to be manufactured or sold, and to make necessary software upgrades available to EAS Participants within six months from the effective date of the rules. We urge the Commission to work with EAS equipment manufacturers to determine the adequacy of this timeframe. Under the proposed rules, EAS Participants may upgrade their equipment through either new equipment programmed with the new code or by installing the software upgrade from the manufacturer into existing equipment on a voluntary basis until their equipment is replaced. This is a sensible and effective approach for adopting a new code by EAS Participants based on past experience with other new EAS event codes.” Continue reading

Andy Seybold’s Public Safety Advocate August 3, 2017

A T-Band Call to Action Public Safety Advocate: A T-Band Call to Action Many people, even some of those involved in public safety, have no idea what the T-band is and why it is of vital importance to 11 metro areas with a combined population of more than 90 million. When Congress passed Title VI of the 2012 Middle Class Tax Relief Bill creating FirstNet, and giving an additional 10 MHz of broadband spectrum to public safety, there was a “spectrum give-back” required. It turns out this “give-back” in the bill Congress passed also stated that the major cities and their suburbs using the T-Band for public safety services (But the law did not mention the business and industrial LMR users also on this protion of the spectrum) would have to suspend operations on the T-Band, “no later than 9 years after the date of engagement of this title.”

The title was enacted in February of 2012 and if you add 9 years to that it lands in 2021. Further, the law states, “Relocation shall be completed no later than 2 years after the date on which the system of competitive bidding described in subsection (a)(2) is completed.” The T-Band give-back date is drawing closer. In spite of the wonderful reports the National Public Safety Telecommunications Council (NPSTC) wrote and submitted to Congress and the FCC, and the hours and hours of lobbying by the cities and agencies affected by this portion of the bill, Congress has shown no interest in removing this requirement from the law. Without action from Congress, and soon, the requirement to move off of the T-band will begin to present some really serious problems for both public safety agencies in these areas and the citizens they protect. The time to rally together to push out the give-back deadline is now. Read the Entire Blog Here. Continue reading