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.
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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

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

FCC Announces 700 MHz Band Relicensing Process

The FCC’s Wireless Telecommunications Bureau released a public notice today announcing the process for relicensing 700 megahertz band spectrum in unserved areas. “We implement the Commission’s long-standing auto-termination process here, in combination with the additional filing procedures established below to address the failure of a licensee to make required filings,” the bureau said in the public notice in WT docket 06-150. “If a licensee does not file either a request for extension of time before the construction deadline or the required construction notification within 15 days after the construction deadline (as required by Section 1.946 of the Commission’s rules), we presume that the license has not been constructed or the coverage requirement has not been met.”

It also said that licensees “will be required to file an electronic coverage map that demarcates the geographic portion of the licensed area that the licensee will retain and the geographic area that will be returned to the Commission for reassignment” under the agency’s keep what you service rules. “Pursuant to the Commission’s rules, relicensing of unserved areas will occur through a two-phase application process, beginning with a 30-day Phase 1 filing window, followed by a Phase 2 rolling window for applications,” according to the public notice. “Applications for available unserved areas must be filed via ULS, and applicants must submit a shapefile describing the areas for which they seek a license.”

Courtesy TRDaily

 

Andy Seybold’s Public Safety Advocate, February 7, 2019

Sometimes it can be a real challenge to come up with a subject I think would be of interest to my readers. This week seems particularly difficult. FirstNet is humming along ahead of its required build-out for Band 14 while Verizon continues to run expensive commercials in an effort to prove to public safety that it is the best network. We all remember how Verizon throttled fire personnel and equipment during wildland fires in California but it continues its attempts to divide the public safety community between it and FirstNet. Even so, FirstNet growth in terms of new agencies added in only the last three months, it is clear that most departments understand FirstNet is the “Interoperable Public Safety Network” dedicated to first responders while other commercial carriers are simply that: commercial broadband carriers.

The FirstNet network was not thrust upon the public safety community by network operators though some were certainly supportive of the process. Rather, it was the public safety community itself that came together to walk the Halls of Congress, battle with those in the Federal Communications Commission (FCC) who did not believe public safety needed the additional spectrum known as the D Block, fight off both T-Mobile and Sprint, which at one point went as far as to put up a website to try to convince others that the spectrum should be auctioned as open to commercial networks. The public safety community, with assistance from then Vice President Joe Biden who was/is a staunch believer in public safety, fought for FirstNet from day one and it became THE public safety network.

this is not to say there are no detractors today, some of which have not become part of FirstNet and may not for a while. Several departments have balked at FirstNet (Built with AT&T) having a monthly data limit specified in its contract even though FirstNet has stated publicly that it will never throttle a public safety agency. It appears corporate AT&T requires the limit but FirstNet understands that under no circumstance can public safety be throttled, especially during an incident. This is one area that needs to be clarified so it does not keep more agencies from joining.  Read the Entire Post Here. Continue reading

Sprint Reports 800 MHz Rebanding Progress

In its latest report to the FCC on 800 megahertz rebanding progress, Sprint Corp. said that last month all retuning in NPSPAC spectrum was completed in the Southern California and San Antonio, Texas, regions. Sprint said that “all NPSPAC licensees across the entire United States, including all Border Areas[,] and territories have now retuned.” 

“Additionally during the month of January, the County of San Bernardino California completed its 800 MHz retune. San Bernardino County is the largest county in the United States by area, and the County system was one of the largest retunes Sprint and public safety worked to complete during the length of this initiative. As a result of the County completing its retune, Sprint can finally report that all 800 MHz rebanding is complete in the Nevada NPSPAC Region – the forty-sixth NPSPAC Region to be completed,” the carrier said in its filing in WT docket 02-55.

 Sprint added, “Currently only 9 of the 55 NPSPAC Regions remain incomplete, with only a handful of public safety licensees left located in only three of these remaining nine NPSPAC Regions (Southern California, El Paso – Texas and San Antonio – Texas). Overall, there are 18 total licensees remaining and only six of those eighteen remaining are public safety. One non-public safety licensee remains in the New Mexico, Oklahoma, Arkansas, Dallas, Austin and Lubbock NPSPAC Regions. All public safety retuning is complete in these six non-Border area NPSPAC Regions,” Sprint added.- Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily

 

Andy Seybold’s Public Safety Advocate, January 31, 2019

FirstNet Integration. During the formation of FirstNet and then working with FirstNet to establish the goals of the network, it was always about fostering data and video services for public safety and to create a single, nationwide broadband network accessible to all public safety agencies including state and federal government agencies. After FirstNet became a reality and AT&T was awarded the contract to build and operate FirstNet for twenty-five years, forms of integration other than those included in the original FirstNet goals began being introduced and promoted.

The first deviation comes from those who have tested and approved more than thirty different vendors for providing Push-To-Talk (PTT) over public safety networks. As I have expressed before, my take is that this is too large a number of disparate vendors and applications. If they are all permitted access to the public safety broadband network, we will be reverting to the LMR non-interoperability days. Even with 3GPP standards in place and even if all thirty meet the standards, we all know that moving forward, each vendor will tweak its PTT product to gain an advantage. Regardless of the standard, this will result in chaos.

The second form of integration being discussed is from a broadband network operator that did not bid on the FirstNet RFP but feels it should now play a part so FirstNet will be interoperable across different broadband networks. This would mean sharing the FirstNet core, which is SOLELY for first responders and not part of a shared core as with the other network. Further, a second network would also bring about confusion in the pubic safety space and most likely create more interoperability issues than it would solve. I believe this because while 3GPP has standards and releases to update the standards, each network operator is still free to choose which upgrades to use within its network. Thus, it is very possible that over time there would develop yet another lack of interoperability.

The final type of integration is push-to-talk interoperability between Land Mobile Radio (LMR) networks and FirstNet (Built with AT&T). I have been asking for this for some time and now there is a committee tasked with developing a solution. I deem this as vitally important to the public safety community because if we can achieve this level of integration, anytime an outside agency is called in to assist at an incident, which happens often, the responding units can use PTT over FirstNet and the local LMR system will be able to hear them and respond to them with what is needed where. During the incident itself, there will be coordinated communications across the entire scene.

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