Andy Seybold’s Public Safety Advocate, February 21, 2019

Joining FirstNet. For the last year I have been receiving enquiries from readers and others about what is required to join FirstNet (Built with AT&T) and why an agency should join this network when it already has a contract with another broadband network. This is a fair question, especially when another network claims to be as good as FirstNet.

Let’s look at the reasons to join FirstNet. At the top of the list is the purpose for which the network was envisioned and then became the law of the land: to provide a nationwide broadband network dedicated solely to public safety agencies and personnel. From its inception, FirstNet was not intended to replace Land Mobile Radio (LMR) systems now or well into the future. It was designed to provide interoperability between agencies with different LMR systems and resolve the issues encountered when coordinating with other agencies on different portions of the LMR spectrum. Think of FirstNet as the common network that augments all existing LMR networks used for Push-To-Talk (PTT) voice with the inclusion of data and video.

Next, unlike commercial networks, FirstNet was designed from day one to be the most secure wireless network possible. It was mandatory that it meet all the stringent requirements for the medical community as well as law enforcement and the federal government rules when it comes to obtaining or sharing data. It also needed to be as secure as possible to prevent hacking or the introduction of malware or other viruses. This security was to be designed in and built in prior to the network’s launch and those charged with building and running the network had to agree on both having a separate and private core or central heart of the network and monitoring and updating the network on a full-time basis.
Read the Entire Post Here.

Here are the articles I have selected with the help of Discovery Patterns artificial intelligence
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Entities Disagree on Unlicensed Use of 6 GHz Band

A myriad of stakeholders have offered the FCC advice on a notice of proposed rulemaking adopted in October that proposed to free up as much of 1,200 megahertz of spectrum for unlicensed use in the 6 gigahertz band (5.925-7.125 GHz band), with commercial, public safety, critical infrastructure, and scientific incumbents and prospective new entrants disagreeing on whether unlicensed operations can be permitted in the band without causing harmful interference to incumbents.

Incumbents say that if the FCC decides to permit unlicensed use of the band, it should adopt more stringent rules than those supported by unlicensed advocates. There is also disagreement about whether the Commission should permit any licensed use of the 6 GHz band.

“The proposed rules are designed to allow unlicensed devices to operate in the 6 GHz band without interfering with the operation of the licensed services that will continue to use this spectrum. In those portions of the 6 GHz band that are heavily used by point-to-point microwave links [5.925-6.425 GHz and 6.525-6.875 GHz], the Commission proposes to allow unlicensed devices to operate where permitted by an automated frequency coordination system and invites comment as to whether this is necessary for devices operated only indoors,” the agency said in a news release on the item, which was adopted in ET docket 18-295 and GN docket 17-183 (TR Daily, Oct. 23, 2018). “In the other portions of the band [6.425-6.525 GHz and 6.875-7.125 GHz] where licensed mobile services, such as the Broadcast Auxiliary Service and Cable Television Relay Service, operate, the unlicensed devices would be restricted to indoor operations at lower power. These proposed rules will allow a valuable spectrum resource to be more intensively used to benefit consumers while allowing the existing licensed uses of the 6 GHz band to continue uninterrupted.”

In 2017, the Commission adopted a notice of inquiry in its mid-band proceeding that included spectrum in the 3.7-4.2 GHz and 6 GHz bands (TR Daily, Aug. 3, 2017). A number of incumbents expressed concern in response to the NOI that use of the 6 GHz band by unlicensed devices would cause interference to their operations. Some reiterated those concerns in comments on the NPRM, while potential new entrants said the interference concerns were overblown.

In joint comments, Apple, Inc., Broadcom, Inc., Cisco Systems, Inc., Facebook, Inc., Google LLC, Hewlett Packard Enterprise, Intel Corp., Marvell Semiconductor, Inc., Microsoft Corp., Qualcomm, Inc., and Ruckus Networks said, “The Commission’s proposal to open the entire 6 GHz band for unlicensed technologies will expand access to broadband, promote innovation, and spur economic growth — while protecting existing users. The NPRM is a crucial step in making more unlicensed spectrum available to address exploding consumer demand for wireless technologies. The Commission has wisely proposed to make spectrum available under a regulatory structure based on the successful and time-tested Unlicensed National Information Infrastructure (U-NII) rules, while adding an additional set of conservative restrictions that will protect incumbent operations. These proposed rules accomplish this goal by creating different categories of unlicensed devices in four unlicensed 6 GHz sub-bands: 5.925-6.425GHz (U-NII-5); 6.425-6.525 GHz (U-NII-6); 6.525-6.875 GHz (U-NII-7); and 6.875-7.125 GHz (U-NII-8). In these comments, we explain how the Commission can adopt final rules for the band that promote efficient spectrum use, facilitate rapid deployment, and protect incumbent services from interference. Because access to this spectrum is so critical, both to meet growing consumer demand for Wi-Fi and to support other 5G investments, we ask that the Commission move quickly to resolve this proceeding and adopt rules that allow for rapid product deployment to maximize the value of the 6 GHz band for the country.”

The tech companies said that the FCC should “[i]mprove efficiency and intensity of use by permitting unlicensed operations to share the entire 5975-7125 MHz frequency range with incumbents — and reject introducing a new licensed mobile service in any portion of the band, which would displace incumbents.”

The Commission also should “[p]ermit standard-power AFC-controlled devices and LPI [low-power indoor] devices without AFC — while (1) allowing LPI devices to operate in all four sub-bands, (2) adding a 14-dBm very-low-power device class that can operate indoors or outdoors in U-NII-5, U-NII-7, and the bottom 100 megahertz of U-NII-8, (3) authorizing standard-power operations in U-NII-8 on a limited basis, and (4) revising proposed client-device power levels to permit symmetric operation,” according to the filing.

They also called on the FCC to “[a]dopt rigorous but flexible AFC rules that require careful protection of incumbents, while rejecting calls to over-regulate or dictate specific elements of AFC implementation, by permitting (1) portable and in-vehicle operation, (2) flexible geolocation strategies, (3) interference protection calculations that take FS and RLAN device height into account, and (4) operation without professional installation, device registration, ID transmission, or tracking of consumer devices or APs.”

The agency should also “[a]dopt technical rules based on the successful U-NII band, while also (1) adjusting power spectral density and client-device power levels to permit manufacturers to bring the latest wireless innovations to American consumers and (2) supporting WISPs’ efforts in rural communities by permitting greater directional gain for AFC-controlled devices and facilitating P2P and P2MP operations,” the companies added.

The Wi-Fi Alliance agreed “with the Commission’s proposal to divide the 6 GHz band into the U-NII-5 (5.925-6.425 GHz), U-NII-6 (6.425-6.525 GHz), U-NII-7 (6.525-6.875 GHz) and U-NII-8 (6.875-7.125 GHz) sub-bands, based on the characteristics of incumbent services.” It expressed support for regulating “unlicensed use in the 6 GHz band based on a ‘two-class approach,’ which differentiates between low-power, indoor-only (LPI) AP and standard-power AP devices.”

The alliance asked the agency to consider these “adjustments and clarifications” to the proposed rules: (1) “[a]llow LPI AP operations across the entire 6 GHz band, including the U-NII-5 and U-NII-7 bands, without an unnecessary automatic frequency coordination (‘AFC’) requirement for those bands”; (2) “[a]llow standard-power AP operations in U-NII-8 band using AFC technology to avoid transmissions in areas where TV pickup operations are licensed”; (3) “[a]llow client devices that operate under the control of an AP to operate at the same power level as the AP (whether standard-power or LPI)”; (4) “allow operation of fixed point-to-point operations with higher-gain antennas”; and (5) “allow mobile and transportable U-NII operations based on regulatory conditions comparable to LPI U-NII devices (i.e., applying very low power transmit power levels) or by using AFC technology.”

The Dynamic Spectrum Alliance said it “appreciates the Commission’s forward-thinking 6 GHz-band proposal and is eager to work with the Commission to ensure that dynamic spectrum access is a success in the band. The AFC approach the Commission proposes is only the most recent example of use of effective spectrum-sharing technologies to increase access to spectrum, and it is the result of hard work by Commission staff and a wide array of companies dedicated to making the most of the United States’ spectrum resources. DSA encourages the Commission to adopt its proposed framework, and to enact simple, flexible rules to support investment and innovation in the 6 GHz band.”

“The Commission should carefully craft technical rules to facilitate both incumbent and new unlicensed uses of the 6 GHz sub-bands. Protecting incumbents should remain the primary focus, but any new rules should, where possible, be harmonized with technical rules applicable to Unlicensed National Information Infrastructure (U-NII) devices that already operate in the 5 GHz band,” NCTA said.

NCTA said that the FCC should (1) “[p]ermit standard-power access points (APs) in the 5.925-6.425 GHz (U-NII-5) and 6.525-6.875 GHz (U-NII-7) sub-bands to use power levels permitted for unlicensed use in the U-NII-1 and U-NII-3 bands to operate on frequencies determined by an Automated Frequency Coordination (AFC) system;” and (2) “[p]ermit indoor, low-power AP operation in the 6.425-6.525 GHz (U-NII-6) and 6.875-7.125 GHz (U-NII-8) sub-bands using lower, more restricted power levels applicable to operations in the U-NII-2 band, so long as those operations do not cause harmful interference to incumbent users.”

NCTA also called on the Commission to (1) “[a]dopt higher permissible power limits for all client devices across the 6 GHz band;” and (2) “[p]ermit AP operations in the U-NII-5 and U-NII-7 bands under the same conditions as proposed for the U-NII-6 and U-NII-8 bands; i.e., low-power, indoor-only use without the need for authorization from an AFC system.” NCTA added that “[t]echnical analysis on the record suggests that these proposals can likely be adopted while still protecting incumbent operations. However, if additional technical analysis in the record suggests that incumbents would not in fact be protected from harmful interference, in either the near or long term, NCTA would no longer support the adoption of such rules.”

Starry, Inc., said that it “strongly supports the Commission’s quick action to make the 6 GHz band available for unlicensed operation, and largely supports the proposals in the 6 GHz NPRM. We believe that by allowing higher gain antennas and higher power client devices, along with deployment flexibility at any elevation, the Commission can ensure that this band will become part of the critical unlicensed backbone powering the U.S. wireless ecosystem, including for fixed wireless broadband.”

“The Commission should be commended for initiating this proceeding seeking comment on ways that 1200 megahertz of the 6 GHz band can be shared for unlicensed use.  In particular, the Commission should make the U-NII-5 and U-NII-7 bands available at higher power to facilitate outdoor use under the control of the AFC and with the technical requirements described above,” said the Wireless Internet Service Providers Association. “With such rules in place, WISPs can take great strides to helping extend broadband access to more rural and unserved areas with less threat of harmful interference, and without causing interference  to licensed links. The Commission also should adopt rules enabling lower-power indoor operations across the entire 6 GHz band.”

“As long as valuable incumbent uses are protected, unlicensed use in 6 GHz spectrum holds substantial promise to develop new services and enhance existing ones,” Verizon Communications, Inc., said. “Unlicensed versions of LTE (e.g., LAA, LTE-U, or newer versions) and WiFi will help expand capacity, relieve congestion on licensed wireless networks, and offer new broadband access points. To preserve a dynamic unlicensed ecosystem, any rules governing unlicensed operation in the band must maintain a technology-neutral approach that ensures permission-less innovation subject to compliance with all technical rules. The key to promoting unlicensed use in the 6 GHz band is a sharing model that protects incumbents through a cloud-based, IP-connected Automated Frequency Coordination (‘AFC’) manager. Unlike traditional unlicensed approaches that involve free-standing unmanaged devices, the AFC should use a ‘closed loop’ network framework that positively controls unlicensed radio access to the band and thereby protects incumbent operations. Active AFC management of unlicensed access points will enable greater security and protection and, in turn, allow for higher powered unlicensed use.”

“In principle we support the Commission’s approach to merge licensed and unlicensed services. If this can be successfully implemented, it will usher in a new, highly efficient, approach to frequency management. As expected, however, the devil is lurking in the details,” said the National Spectrum Management Association. “Given this new approach is unproven, we should proceed cautiously. A key component of the process will be the AFC function. The authorized agencies must meet the needs of all parties but be limited in number to avoid difficulty in determining the responsible agency for problem resolution. Another key component is a technical organization with extensive technical oversight and authority. An independent industry organization which is responsive to the needs of all interested parties should be used to develop the myriad of details needed to successfully implement these proposals. Among these would be the development of an appropriate path attenuation model adequate to protect licensed users. The organization’s responsibility should extend several years into the implementation phase. This organization should be allowed to develop technical details acceptable to operators and service providers and periodically report progress to the Commission.”

NSMA said that it “is one of a few organizations qualified to participate in this function. Field trials, monitored by all interested parties, should precede large scale implementation. The field trials should be based upon substantial agreement among all users. Large scale deployment should not begin until the field trials have been successfully completed to the substantial satisfaction of all parties.”

The 5G Automotive Association said it “supports the Commission’s efforts in these proceedings to identify new opportunities for unlicensed use in the 6 GHz band, and believes that the 6 GHz band – and not the 5.9 GHz band – represents the best opportunity for providing for more spectrum for unlicensed uses. However, without proper safeguards in place, out-of-band emissions (‘OOBE’) from secondary 6 GHz unlicensed operations will degrade primary licensed vehicle safety communications operations in the 5.9 GHz band. To prevent such an outcome, the Commission should adopt the protection criteria proposed by 5GAA herein.”

Motorola Solutions, Inc., said it “believes that the 6 GHz band has the potential to support a wide range of new and innovative applications. Therefore, MSI generally supports the Commission’s pursuit of a carefully crafted spectrum sharing approach that will accomplish the goal of expanded use of the 6 GHz band by secondary devices while providing sufficient protection for existing and future incumbent operations. As a critical component of this approach, MSI supports employing cloud-based AFC mechanisms that will allow rapid and uniform updates to incumbent protection information. MSI strongly believes that a carefully selected interference-to-noise (I/N) protection ratio is essential and recommends that the ratio for protecting critical incumbent links be set no higher than -12 dB I/N levels. Finally, the Commission should take several steps to enable the efficient and safe use of this band including by requiring AFC functions to record the operational frequencies and identifiers of authorized unlicensed devices operating in the band, and providing a mechanism for timely remediation of interference events.”

The Boeing Co. said it “supports the identification of additional spectrum resources in the 6 GHz band for [use] by unlicensed systems and devices. To ensure that this unlicensed spectrum is used for the greatest benefit, the Commission should refrain from imposing operating restrictions that are unnecessary to prevent harmful interference. Specifically, the Commission should permit all 6 GHz unlicensed devices to be used indoors without AFC control. The Commission should treat the inside of aircraft as indoor spaces for purposes of these rules and the Commission should permit the use of 6 GHz unlicensed spectrum for transmissions involving aircraft parked at airport facilities. Each of these measures will expand the use of unlicensed spectrum in the 6 GHz band without resulting in harmful interference to incumbent services. At the same time, the Commission should strive to ensure that the proposed additional unlicensed uses of the 6 GHz band do not prevent the continued operation of UWB devices that are also authorized in this spectrum.” Continue reading

PSCR Newsletter Online Now

PSCR Insider: UI Researchers Create VR Environments Based on Physical Modeling, Plus More Articles Here

Awards Coming Soon: iAxis, MCVQoE PSCR will announce two awards as part of its Public Safety Innovation Accelerator Program: the Mission Critical Voice Quality of Experience (MCV QoE) funding opportunity and i-Axis. We expect to announce these awards in just a few days. Bookmark the pages to stay updated about the winners.

Calling All First Responders: NIST Needs Your Feedback. NIST recently launched a nationwide usability survey on public safety communication technology and needs input from first responders. The 15-minute survey asks questions about the communication technology first responders currently use, need, and want in the future. If you’re a first responder, please help improve PSCR’s research by taking this survey.

Andy Seybold’s Public Safety Advocate, February 14, 2019

Spreading the Word.  It’s Valentine’s Day! I hope it is a good one for all of you. Last week’s Advocate drew many good comments about the lack of press coverage of FirstNet. It appears as though this lack of news stories in local media has been noticed by others and that this will be changing sooner rather than later. So, I thought perhaps I would take a crack at writing an article for local news outlets including newspapers and perhaps even as a story of interest for local TV news shows.

To write an article in a newspaper that people want to read, it must start off with a catchy headline and the first paragraph must be a real grabber to hook people so they will want to read the entire article. Then, of course, is the old adage of tell them what you are going to tell them, tell them, and then tell them what you told them. I learned the angles of newsprint journalism over the years of writing a newsletter for Forbes on Wireless Communications where I was coached by the best in the industry, and during thirty years of publishing variously titled thirty-six-page newsletters every month. However, writing for a news outlet where readers are not experienced in anything wireless besides their own cell phones and writing for an audience that is wireless-literate are completely different things. With that said, I will now take a crack at an article for a news outlet.

Public Safety Has New Partner to Fight Crime, Save Lives

We all use cell phones. We talk, text, and send pictures and videos to others with them, check the news, and stream movies. Cell phones are a way of life, delivering three or more means for conveying information to others. Meanwhile, the public safety community, using “Land Mobile Radio,” has had only voice to communicate with those in the field. Yes, they can and do use their own or agency-supplied cell phones when needed. However, during large events and major incidents, public safety had not been guaranteed access to networks congested with citizen’s calls. Read the Entire Post Here Continue reading

DHS Releases P25 CAB for 30-Day Comment Period

Project 25 Compliance Assessment Program seeks feedback on Compliance Assessment Bulletin for new program testing requirements.

WASHINGTON – The U.S. Department of Homeland Security (DHS) Science and Technology Directorate (S&T) announced the release of a Project 25 Compliance Assessment Program (P25 CAP) draft Compliance Assessment Bulletin (CAB) for review and comment. This draft CAB is available for public comment through March 14, 2019 and addresses P25 Baseline Inter-Radio Frequency Sub-System Interface (ISSI) and Console Sub-System Interface (CSSI) Conformance Testing Requirements.

This bulletin expands the P25 CAP’s testing scope to allow a more diverse set of equipment to become a part of the program.

Project 25 (P25) is a suite of standards that enables interoperability among digital two-way land mobile radio (LMR) and standardizes interfaces between the various components of the LMR systems that first responders use. P25 CAP is a voluntary program that allows communication equipment manufacturers to publicly attest to their products’ compliance through testing at DHS-recognized laboratories. All approved equipment is eligible to be purchased using federal grant funding.

After the comment period, DHS S&T will review comments, incorporate feedback, and finalize the CAB. The final CAB and adjudicated comments will be posted to the P25 CAP website. For more information, visit https://www.dhs.gov/science-and-technology/p25-cap.       

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Entities Suggest FCC Seek More Info for 911 Fee Diversion Reports

Parties have suggested that the FCC seek additional information from states for annual reports to Congress on 911 fee diversion. Several entities weighed in on 911 fee diversions in the wake of a report released by the FCC’s Public Safety and Homeland Security Bureau in December that said nearly 10% of the total 911 fees collected by all 50 states, five territories, and the District of Columbia in 2017 were diverted to other purposes (TR Daily, Dec. 19, 2018).

Diversions occurred in Montana, Nevada, New Jersey, New York, Rhode Island, West Virginia, and the U.S. Virgin Islands, according to the report. “The total amount of 911/E911 funds diverted by all reporting jurisdictions in calendar year 2017 was $284.9 million, or approximately 9.70% of total 911/E911 fees collected,” it added. The annual report is mandated by the New and Emerging Technologies 911 Improvement Act of 2008 (NET 911 Act).

“The annual reports are helpful for providing insight into the nation’s 9-1-1 ecosystem and combatting fee diversion, but as APCO has previously commented, the Commission could make the reports more useful,” the Association of Public-Safety Officials-International said in its filing in PS docket 09-14. “For the eleventh and subsequent annual reports on 9-1-1 fee collection and expenditure, the Commission should revise the information collection questionnaire consistent with APCO’s suggestions.”

“Ending fee diversion, while essential, will not ensure ECCs [emergency communications centers] have the resources they need,” APCO also stressed. “Significant federal funding is necessary to modernize the nation’s 9-1-1 systems and could provide the additional benefit of serving as a compelling deterrent to fee diversion.”

“States need clear notice about what constitutes fee diversion in order to appropriately document and combat the practice,” APCO added. “For example, the Commission has ‘generally determined that funds used to support public safety radio systems … are not 911-related,’ but that expenditures to integrate radio systems with 9-1-1 could be 9-1-1-related where sufficient documentation is provided. While APCO agrees with this particular guidance, it may be helpful for the Commission to provide specific examples of what constitutes fee diversion in advance of future information collections, for example, by including a record of its previous determinations and descriptions of how states have demonstrated that an expenditure is ‘911-related.’”

APCO also noted that the FCC’s “annual questionnaire asks several questions related to NG9-1-1 services and expenditures. The report’s information on NG9-1-1 could be made more useful by providing a comprehensive understanding of what constitutes NG9-1-1, how states are ensuring interoperability, and the approaches being taken to achieve NG9-1-1 capabilities.”

The FCC also “should collect and report more detailed information on the ‘other’ service types for 9-1-1 calls, meaning not identified as wireline, wireless, or VoIP calls,” APCO said. “As technology evolves and provides new methods for contacting 9-1-1, these ‘other’ types of calls could have implications for public safety telecommunicators’ and callers’ experience during an emergency. For example, an upward trend in real-time text 9-1-1 calls will likely warrant technology and training changes for ECCs.”

The Colorado Public Utilities Commission said it “has no knowledge of any 911 fee diversion in Colorado. All 911 funding is local, and we are unaware of any local 911 fee diversion. However, we believe that it is important to remember that there is a division of responsibility for oversight of 911 services at the federal, state and local government levels, with overlap in some areas. For example, both the FCC and the states both have roles in overseeing network reliability, outage reporting, and outage mitigation.

“Regarding the actual handling of 911 calls by public safety telecommunicators, and how state-authorized 911 surcharge funds are spent, this is an area that is solely the responsibility of state and local governments,” the COPUC added. “Although some states have chosen to use 911 surcharge funds in a manner that, from the FCC’s perspective and role, is not consistent with their intended uses, the COPUC does not believe that this is a problem for the FCC to solve. How state governments or local governments expend 911 surcharge funds is a matter that they must resolve.

“To the extent that federal funds are to be made available for use at the state and local level, it is appropriate to only make those funds available to state and local governments that spend their funds in a manner that is consistent with the statutorily allowed use of those funds,” the COPUC added.

It also recommended that the FCC “encourage states in undertaking auditing authority of providers regarding remittance of 911 surcharges” and “[c]onsider adding the topics of state MLTS [multi-line telephone system] legislation and non-surcharge-based 911 funding to future editions of the FCC’s annual report to Congress.”

The Boulder (Colo.) Regional Emergency Telephone Service Authority (BRETSA) renewed its request for the FCC “to adopt regulations and/or develop information which will (i) make auditing of 9-1-1 fee remittances feasible for local and state authorities, (ii) identify whether there is under-remittance of 9-1-1 fees on prepaid service, and (iii) address application of 9-1-1 fee requirements to evolving technologies and markets.” Continue reading